Atch 6 - Blackstart Hazmat Survey Report.pdf

SUSTAINABLE ENVIRONMENT, ENERGY,

HEALTH & SAFETY PROFESSIONAL SERVICES

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NORTECH, Inc.

Accounting Office:

2400 College Rd

Fairbanks, AK 99709 907.452.5688

907.452.5694 Fax

3105 Lakeshore Drive Suite A106

Anchorage, AK 99517 907.222.2445

907.222.0915 Fax

5438 Shaune Drive Suite B

Juneau, AK 99801 907.586.6813

907.586.6819 Fax

www.nortechengr.com

January 23, 2019 Sent via email to:

Electric Power Systems, Inc. jrowland@espinc.com 3305 Arctic Boulevard, Suite 200 Anchorage, AK 99503

Attn: Jason Rowland, PE

RE: Hazardous Materials Investigation and Design Repair Black Start Generator, Building 6203, EAFB CHPP / FTQW 12-1012

Jason:

NORTECH Sustainable Environment, Energy, Health & Safety Professional Services is pleased to provide Electric Power Systems (EPS) with this Limited Hazardous Materials Investigation Report for the Eielson Air Force Base (EAFB) Combined Heat and Power Plant (CHPP) Design Repair Black Start Generator Project. The following is a brief synopsis of the background, scope of work, methodology, field activities, and sampling results with discussion, including conclusions and recommendations where appropriate.

Background and Scope of Work EAFB selected the EPS team to perform the investigation and design of upgrades to the CHPP Black Start Generator. The specific goals of the project are to replace the existing Black Start Generator, repairing heating and ventilation in the Black Start room.

The 2.5 MW diesel-powered Black Start Generator is housed on the lower level, inside the CHPP on EAFB. This unit provides a “black start” capability for restoring electrical power without relying on the external electric power transmission network in the event of a total power outage. The current Black Start generator was manufactured by Electro-Motive Division (EMD) of the General Motors Corporation and was installed in 1987 as part of a major plant upgrade.

Due to excessive emissions, Eielson’s Air Permit includes operational limits for the unit. The Black Start generator is not allowed to consume more than 157,000 gallons of fuel in any rolling 12-month period and the peak output is limited to 1,800 kW. The current Black Start Generator was used for peak load shaving, but due to the fuel and output limits, the practice is no longer possible.

NORTECH’s scope of work is to provide limited hazardous material investigation services. This included sampling suspect asbestos containing building material, analyzing paint for lead content, and sampling settled dust for asbestos, and lead contamination within project areas of this phase of the project.

Methodology Project efforts were completed in accordance with NORTECH Hazardous Material Standardized Methodologies (v17). Project work was performed by an experienced Health and Safety Professional with current EPA AHERA inspector certification

Hazardous Materials Investigation and Design Repair Black Start Generator EAFB CHPP/ FTQW 12-1012

Page 2Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Blackstartgenerator-Hazmatreport-Final.Docx utilizing industrial hygiene inspection practices dedicated to the anticipation, recognition, evaluation and control of those materials within workplaces. Work was reviewed and signed off by a registered Professional Engineer.

All samples were sent to EMSL Analytical, Inc. (EMSL), a laboratory certified through the National Voluntary Laboratory Accreditation Program (NVLAP). The suspected asbestos samples were analyzed by Phase Light Microscopy (PLM) using the EPA Method 600 or ASTM 6480. Lead dust samples were analyzed by Flame AAS (SW 846 3050B/7000B). This method measures lead loading, the amount of lead dust on a specific surface area.

Field Activities On October 19, 2018, Hilary Clifton and Jeanette Daniel of NORTECH completed the hazardous materials investigation for the CHPP Black Start Generator. The main scope of work for the project is to replace the existing Black Start Generator and repair the heating and ventilation system in the existing generator room. The following summarizes field activities by category of hazardous material.

Asbestos Containing Material (ACM) Sampling Building materials suspected of containing asbestos included joint compound, gypsum wallboard, generator caulking, floor covering and mastic, roof caulking, insulation, pipe wrap thermal system insulation (TSI) and pipe caulking. A total of 8 samples were collected from both interior and exterior locations and submitted for laboratory analysis to determine the percent content of asbestos by the polarized light microscopic (PLM) method. Sample locations are shown on Figure 3.

Lead Based Paint (LBP) A handheld NITON XLP-303A X-Ray fluorescence spectrometer (XRF) was used to analyze 21 various paint locations for lead in paint. This included the generator scheduled for replacement along with interior supporting structures such as I-beams and walls, and exterior components that will be affected. The specific locations, materials, and colors are shown in Figure 3.

Dust Sampling Visible accumulations of dust were observed on horizontal surfaces, including the floor inside of the Black Start generator room. Lead in settled dust was suspected due the facility burning coal and asbestos contamination was suspect due to the historical use of thermal systems insulation (TSI) and other ACM materials throughout the facility.

To quantify the amount of dust present, the inspector used a scale from 1 to 5 with the following descriptions:

1 – low to no visual dust or debris present 2 – low dust, substrate is visible 3 – moderate dust, substrate is partially obstructed 4 – heavy dust, substrate is no longer visible 5 – extensive dust, non-uniform distribution, accumulations of ≥ 0.25” of dust and debris

A visual assessment determined that a low to moderate amount of settled dust (rated 2-3) is present on top of horizontal surfaces throughout the facility scope of work area. A representative dust sample for lead was collected from the top of blue/green tank and the Black Start generator. A representative dust sample for asbestos was collected from the top of the blue metal compressor and from the Black Start Generator. Sample locations are shown on Figure 3.

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Universal Waste and Other Materials Requiring Special Handling Lighting in the Black Start room will require removal as part of this project. The lights could not be accessed for the inspection, however, based on lighting observed elsewhere in the CHPP, mercury fluorescent bulbs, high pressure sodium (HPS) lamps, HID, or LED fixtures may be present. Fluorescent tubes and HPS lamps contain mercury and light fixtures with magnetic ballasts can contain PCBs.

Environmental Concerns Soil and groundwater samples were not collected as part of this investigation. Information regarding previous investigations in the vicinity of the project area was provided by EAFB for review. Additional information available on the Alaska Department of Environmental Conservation (ADEC) Contaminated Sites online database was also reviewed. This information is summarized in the Sample Results and Discussion section below.

Sample Results with Discussion Sample locations and summary tables are depicted on the attached project figures. A copy of all laboratory results is attached. The following is a discussion of sample results with analysis by hazardous material type.

Asbestos No ACM was identified in the CHPP Black Start Generator scope of work area. No materials had an asbestos content in excess of 1%, the regulatory threshold of a building material to be considered ACM. ACM samples, descriptions, locations and results are presented in Figure 3.

Since no ACM is present, no abatement of ACM is necessary prior to construction and demolition (C&D). The waste stream will be considered non-ACM.

Demolition will be required to meet the general demolition NESHAP of no visible dust emissions during demolition.

Lead Based Paint XRF sample results above the EPA Housing and Urban Development (HUD) limit of 1.0 mg/cm2 were not observed. Sample results ranged from 0.0 to 0.11 mg/cm2. Due to the minimal amount of lead in paint observed, the debris waste stream is considered non-hazardous for leachable lead.

Painted surfaces and finishes that contain lead at any concentration also represent a potential hazard for workers who are performing lead trigger tasks such as burning, sanding or grinding.

Demolition design documents should provide contractor notification of the lead content of the lead containing materials as a potential work hazard. The approved demolition work plan should document lead hazard reduction practices, proper PPE used, lead awareness training for onsite workers, and other safety measures to be implemented during building demolition.

Settled Dust The dust samples collected within the Black Start Generator room are a non-detect for asbestos fibers. Precleaning of the Black Start Generator scope of work area can be completed without concern for asbestos exposure and cleaning material can be disposed of as non-asbestos containing.

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The current federal lead dust hazard and clearance standards (see below) were incorporated into regulations by the U.S. EPA Housing and Urban Development (HUD). The HUD lead hazard standard for floors is ≥ 40 µg/ft2. There are not currently lead standards for commercial and industrial buildings.

The surface dust samples collected from horizontal surfaces within the Black Start room indicate deposits of lead ranging from 21 µg/ft2 to 110 µg/ft2. The tabulated results and sample locations are shown in Figure 3.

In summary, dust on and around the Black Start Generator are non-detect for asbestos fibers but do contain low concentrations of lead. Additionally, previous sampling events throughout the CHPP building have confirmed the presence of RCRA-8 metals in dust as well.

In addition, OSHA regulations are set to protect worker inhalation exposure, and are not correlated to surface dust concentrations. The worker inhalation permissible exposure level for airborne lead is 50 µg/m3.

Electrical panels, transformers, conduit, the Black Start Generator and other horizontal surfaces with settled dust that will be disturbed during project efforts should be precleaned before demolition begins. Precleaning efforts should be performed by qualified workers who at a minimum have taken lead awareness training and avoid lead trigger tasks.

All dust, PPE, and other materials generated during the dust cleaning activities may be lead hazardous. A lead toxicity characteristic leaching procedure (TCLP) sample is recommended to characterize project PPE and cleaning materials following dust cleaning to determine appropriate handling and disposal requirements.

Universal Waste Universal waste was found to be consistent with items typically found in commercial and industrial buildings. Lighting in the building was observed to consist of fixtures that mercury containing fluorescent light bulbs and HPS lamps. These items should be removed from the project area as necessary and properly disposed of before renovation or demolition. All light ballasts and transformers should be inspected before disposal to ensure they say “no-PCB” or other markings indicating there is no PCB fluid in the ballast.

Environmental Concerns Project work will require the excavation of soil in the vicinity of the Black Start Generator for the installation of supplementary equipment for the new engine. Information provided by EAFB suggests that previous sampling events have identified contaminants in soil in areas likely to be impacted by the project work. The following is a summary of known conditions near the project area:

Based on drawings provided by EAFB dated October 2018, Source Area ST048 (ADEC File # 107.38.070) encompasses the exterior areas adjacent to the Black Start Generator room.

Contaminants of concern have been identified as fuel-related and include benzene, toluene, ethylbenzene, and xylenes (BTEX). Gasoline range organics (GRO) and diesel range organics (DRO) were also identified in groundwater in the area. The source of the contamination is former buried fuel pipelines that are no longer in use and were abandoned in place.

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Prohibitions and restrictions within Source Area ST048 state that any activity that may result in the disturbance of soil requires approval by Installation Management (CES/CEI). Completion of Form 103 (Base Civil Engineering Work Clearance), and approval prior to commencing any work. Contaminated soil removed from the Site must be treated or disposed in accordance with state and federal regulations. Source Area ST048 has a 200-foot buffer around it until better delineation of the release can be defined. A contaminated soil specification should be included in the project design documents.

Additionally, during a sewer line excavation performed in May 2016, it was determined through sampling that PAH compound benzo(a)pyrene is present above cleanup levels in that specific project area. This project was located relatively close to the proposed Black Start project area.

Conclusions and Recommendations Based on the findings of the hazardous material assessment, the following conclusions and recommendations have been developed regarding the EAFB Black Start Generator Upgrade Project:

Asbestos Containing Material

No ACM was identified

Lead Based Paint No LBP was observed in excess of 1.0 mg/cm2 Materials containing lower concentrations of lead are also present Lead trigger tasks and appropriate controls should be identified in the Contractor’s

Demolition Work Plan

Settled Dust

Dust on horizontal surfaces is non-detect for asbestos fibers Dust on horizontal surfaces show lead contamination both above and below the EPA

HUD standard o It is recommended horizontal surfaces are cleaned and abated/decontaminated using a project specific work plan o The work plan should include lead abatement work practices, engineering controls, HEPA filtration, no visible emissions and PPE Data collected in other areas of the CHPP indicates the presence of RCRA-8 metals in dust o All dust, PPE, and other materials generated during the cleaning activities may be lead/metal hazardous o A TCLP sample should be collected from project PPE and cleaning materials following dust cleaning to determine handling and disposal requirements

Universal Waste Mercury containing fluorescent light bulbs and HPS lamps, PCB light ballasts and transformers involved in the project work scope should be removed from the building and properly disposed of before renovation or demolition

Environmental Concerns

The project area is located within Source Area ST048 with known contamination and long term monitoring

Page 6Https://Nortechinc.Sharepoint.Com/00-Jobs/2018/1026/Shared Documents/Reports/Drafts/Blackstartgenerator-Hazmatreport-Final.Docx o This area has restrictions related to the disturbance of soil and/or groundwater The appropriate forms and permissions must be approved prior to beginning work A contaminated soil specification should be included in project design documents

This hazardous building materials assessment was conducted to identify the potential hazards in preparation of the EAFB Black Start Generator Upgrade Project. All information about hazardous material associated with the building should be made available to employees, contractors and/or abatement/demolition contractors associated with the renovation or demolition of the Black Start project. Specific abatement work practices may require additional sampling by the contractor to comply with OSHA worker exposure regulatory guidelines.

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, NORTECH

Jeanette Daniel Peter Beardsley, PE Environmental Health & Safety Professional Principal

Attachments: Figures

Photo Pages Lab Results

Methodology

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AutoCAD SHX Text 2400 College Road, Fairbanks, AK. 99709, 907-452-5688

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ENVIRONMENT, ENERGY, HEALTH & SAFETY CONSULTANTS

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ENVIRONMENT, ENERGY, HEALTH & SAFETY CONSULTANTS

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²

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Lead Dust Data Table Surveyed by Nortech: October 2018

Sample ID Location Lead (μg/ft²)

L1 Square Station 110 L2 Generator 21

Lead Data Table Surveyed by Nortech: October 2018

Sample ID Color Location Substrate Lead 3242 Tan Wall Concrete 0.0 3243 Red Floor Concrete 0.0 3244 White I-Beam Steel 0.03 3245 Blue Compressor Metal 0.02 3246 Blue/Green Tank Metal 0.0 3247 Red Curb Concrete 0.0 3248 Blue Blackstart Metal 0.0 3249 Tan Bulletin Board Wood 0.0 3250 Tan Column Concrete 0.0 3251 Red Steps Concrete 0.0 3252 Tan Door Metal 0.0 3253 Tan Door Frame Metal 0.0 3255 Tan Door Frame Metal 0.0 3256 Yellow Battery Stand Metal 0.0 3257 Gray Blackstart Metal 0.01 3258 Tan Main Floor Control Metal 0.0 3259 Tan Siding Metal 0.0 3260 Tan Condenser Support Metal 0.11 3261 Tan Side of Condenser Metal 0.05 3262 Tan Bollard Concrete 0.0 3263 Red Overhang Metal 0.0

Asbestos Dust Data Table Surveyed by Nortech: October 2018

Sample ID Location Asbestos (structures/cm²)

A1 Square Station ND A2 Generator ND

Asbestos Data Table Surveyed by Nortech: October 2018

Sample ID Description Result A3 gray caulking ND A4 white floor sheet ND A5 brown/white gwb ND A6 black caulking ND R1 gray caulking ND R2 gray caulking ND R3 gray/blue caulking ND E1 gray insulation ND E2 black pipe wrap ND

AutoCAD SHX Text LEAD BASED PAINT SAMPLE NEGATIVE (< 1 mg/cm²)(HUD) 1 mg/cm²)(HUD))(HUD)

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ASBESTOS SAMPLE LOCATIONS NEGATIVE (<1% ASBESTOS)

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ENVIRONMENT, ENERGY, HEALTH & SAFETY CONSULTANTS

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NOTE: SAMPLE A5 WAS COLLECTED FROM THE MAIN FLOOR AT THE OPENING NEAR THE DAY TANK.

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Black Start Generator EAFB CHPP/ FTQW 12-1012 Report

November 19, 2018

Photo 1: Black Start Generator inside of EAFB CHPP

Photo 2: Black Start Generator Insulated Asbestos Free Labeled Ducting

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Photo 3: Blue Metal Compressor, Asbestos Wipe Sample Area

Photo 4: Blue/Green Metal Tank, Lead Wipe Sample Area

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Photo 5: Black Start Generator, Lead Wipe Sample Area

Photo 6: Black Start Generator, Asbestos Wipe Sample Area

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Photo 7: CHPP Exterior Black Start Components

Photo 8: CHPP Exterior Black Start Components

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041831811EMSL Order:

Customer ID: NORT69

Customer PO: 18-1026

Project ID:

Attention: Phone:Jeanette Daniel (907) 452-5688

Fax:Nortech Environmental & Engineer Cnslt. (907) 452-5694

Received Date:2400 College Road 10/23/2018 9:20 AM

Analysis Date:Fairbanks, AK 99709 10/31/2018

Collected Date: 10/18/2018

Project:

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

A3

041831811-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Generator - Caulking

A4-Floor Sheet

041831811-0004

None DetectedNon-fibrous (Other)90%Synthetic10%White

Fibrous

Homogeneous

Floor Sheet

A4-Mastic

041831811-0004A

None DetectedNon-fibrous (Other)100%Yellow/Green

Non-Fibrous

Homogeneous

Yellow Mastic

A5

041831811-0005

None DetectedNon-fibrous (Other)77%Cellulose

Glass

15%

8%

Brown/White

Fibrous

Homogeneous

GWB

A6

041831811-0006

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Roof-Exterior Pipe

Caulking

R1

041831811-0007

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Roof Caulking

R2

041831811-0008

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Roof Caulking

R3

041831811-0009

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

Non-Fibrous

Homogeneous

Roof Caulking

E1

041831811-0010

None DetectedNon-fibrous (Other)20%Glass80%Gray

Fibrous

Homogeneous

Exterior Insulation

(Friable)

E2

041831811-0011

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Exterior-Pipe Wrap

Analyst(s)

Amy Johnson (10) Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 "Interim

Method"), but augmented with procedures outlined in the 1993 ("final") version of the method. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . Interpretation and use of test results are the responsibility of the client. All samples received in acceptable condition unless otherwise noted. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. EMSL recommends gravimetric reduction for all non -friable organically bound materials prior to analysis. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial report from: 10/31/2018 08:37:03

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 10/31/2018 8:37 AM

200 Route 130 North Cinnaminson, NJ 08077

Phone/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

EMSL Analytical, Inc.

041831811EMSL Order:

NORT69Customer ID:

18-1026Customer PO:

Project ID:

Attention: Phone: (907) 452-5688Jeanette Daniel

Nortech Environmental & Engineer Cnslt. Fax: (907) 452-5694

2400 College Road Received Date: 10/23/2018 9:20 AM

Fairbanks, AK 99709 Analysis Date: 10/31/2018

Collected Date: 10/18/2018

Test Report: Asbestos Analysis of Dust Samples Using Method ASTM 6480

Sample ID

Area

Sampled

(cm²)

Asbestos

Type

Asbestos

Structures

Sensitivity

(str/cm²)

Concentration

(str/cm²) Comments

None

Detected

523 <1560<2.99A1 Due to excessive particulate the target analytical sensitivity of 260 str/cm² was not reached.

041831811-0001

None

Detected

250 <748<2.99A2

041831811-0002

Analyst(s):

Ted Young (2) Benjamin Ellis, Laboratory Manager or other approved signatory

EMSL maintains liability to cost of analysis . This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. Samples received in good condition unless otherwise noted.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ

Initial report from: 10/31/2018 08:53:52

ASB_TEMMV_0014 Printed 10/31/2018 8:53:53AM Page 1 of 1

Client Sample Description ConcentrationLab ID Analyzed Area Sampled Lead

Collected

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: Jeanette Daniel Nortech Environmental & Engineer Cnslt.

2400 College Road Fairbanks, AK 99709

Received: 10/23/18 10:00 AM Fax: (907) 452-5694 Phone: (907) 452-5688

10/18/2018Collected:

Test Report: Lead in Dust by Flame AAS (SW 846 3050B/7000B)*

201812361 CustomerID: NORT69 CustomerPO: 18-1026 ProjectID:

EMSL Order:

Site: Square Station 201812361-0001L1 1 110 µg/ft²ft²10/29/201810/18/2018

Site: Generator 201812361-0002L2 1 21 µg/ft²ft²10/29/201810/18/2018

Phillip Worby, Lead Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 10/30/2018 9:36:15 AM

*Analysis following Lead in Dust by EMSL SOP/ Determination of Environmental Lead by FLAA. Reporting limit is 10 µg/wipe. ug/wipe =µg/ft² x area sampled in ft². Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities (such as volume sampled) or analytical method limitations. Samples received in good condition unless otherwise noted. The lab is not responsible for data reported in µg/ft² which is dependent on the area provided by non-lab personnel. The test results contained within this report meet the requirements of NELAC unless otherwise noted. "<" (less than) results signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 10/30/2018 09:36:15 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com

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Https://Nortechinc.Sharepoint.Com/Shared Documents/Hazardous Materials/Haz Mat Methods V17.Docx

HAZARDOUS MATERIALS

STANDARDIZED METHODOLOGY

Version 17 October 2018

Objective and Management NORTECH 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 inspection 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 NORTECH provides a variety of hazardous material services as necessary to meet project specific needs cost effectively. In order to minimize costs, NORTECH 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)

• Lead Based Paint (LBP)

• Universal Wastes

• Poly Chlorinated Byphenyls (PCB)

• 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 (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.

Hazardous Materials Standardized Methodology

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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%.

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 http://www.gpo.gov/fdsys/pkg/CFR-2012-title40-vol28/xml/CFR-2012-title40-vol28-part273.xml http://www.epa.gov/osw/hazard/wastetypes/universal/batteries.htm http://www.epa.gov/osw/hazard/wastetypes/universal/pesticides.htm http://www.epa.gov/osw/hazard/wastetypes/universal/mce.htm

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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 (Millett and Hays) 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.

Sillica in Dusts Surface sampling for silica by Crystalline Analysis of Bulk Material using X-Ray Diffraction by NIOSH Method 7500 with modification for analysis of wipe samples. Method sensitivity for Quartz and Cristobalite on alcholol wipes is 10 ug/sample or 0.5% by weight of mineral dust.

Workers’ exposures would be limited to a new PEL of 50 micrograms of respirable crystalline silica per cubic meter of air (μg/m3), averaged over an 8-hour day. The new PEL is the same in all industries covered by the rule. There is currently no standard to compare silica dust concentrations against. The presence of silica contamination in dust is a worker exposure issue if the dust becomes airborne and is inhaled. OSHA regulations for crystalline silica containing dust is set to protect worker inhalation exposure, and are not correlated to surface dust concentrations.

Lead Based Paint (LBP) Quantification of lead-based paint is performed according to NIOSH 7702, using a Thermo Fisher NITON XLp-303A (XRF), x-ray fluorescent 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 contains 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.

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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.

Poly Chlorinated Byphenyls (PCB) There are currenty 4 collection methods for the Quantification of PCB. Depending on the location and materials to be sampled, one or more of the following collection methods may be used:

• Bulk solid sample

• Porous surface samples

• Non-porous samples

• Indoor air samples

Bulk solid sample collection: Bulk solid samples include such materials as caulk, soil, and sand.

Bulk solid sampling typically includes removing a small portion of the potentially contaminated material directly from the suspect area for analytical testing in sufficient quantity for laboratory testing. Care shall be taken to avoid contaminating the final sample with adjacent materials such as wood or concrete that may skew the sample analysis results. Soil or sand samples are collected with consideration of whether the PCBs are on the soil surface or suspect of being located deeper in the soil – including soil disturbances that may have caused surface debris to become buried.

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Porous surface sample collection: PCBs can readily migrate into porous surfaces such as brick, masonry, concrete or wood. Surface wipe sampling is inadequate to characterize the PCB concentration of porous surfaces. Porous surfaces will have core samples collected on a bulk basis (mg/kg) to ensure the top 0.5 to 2 cm of the porous surface is collected. Tools such as chisels, drills, and saws may be used to collect the sample with care taken to minimize dust generation. Samples are ideally collected from the top 0.5 cm to 2 cm of the surface closest to the likely source of PCB contamination.

Non-porous surface sample collection: Smooth and impervious surfaces such as unpainted metal surfaces are sampled using the wipe collection method. The standard wipe test is specified in 40 CFR 761.123, and uses a 10 cm by 10 cm (or equivalent that equals 100 cm2) template to outline the sample area and a gauze pad or glass wool that has been saturated with hexane to collect the sample. The hexane-saturated wipe is used to thoroughly swab the area inside the 100 cm2 template. Sample results will be based on the 100 cm2 sample area (μg per 100 cm2).

Indoor air sample collection: Indoor air samples are collected using EPA Methods TO-10A, TO- 4A, or equivalent. Sufficient sample volumes, as referenced in the EPA Methods will be collected to prove a minimum laboratory reporting limit of less than 0.1 μg/m3. Consultation with EPA PCB Regional Coordinator may be required to determine the number of samples to be collected and which sampling method is to be used.

Consultation with the analyzing laboratory shall be done prior to collecting samples to ensure all parameters for proper collection of samples is followed to ensure proper analysis.

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:

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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 in which LBP concentrations are assumed to be greater than EPA/HUD’s standard of <1.0% limit for what can be considered non-lead based paint. The calculations use the highest average theoretical value (1.0 or greater) for each painted surface.