Attachment 4 - NEXGEN Travis Bldg B31- Room 64 Asbestos and Lead Survey Report.pdf

554 Morning Glory Drive, Benicia, CA 94510· (707) 745-1137· http://www.acs-ltd.us

AMERICAN COMPLIANCE SERVICES, LTD

LIMITED ASBESTOS & LEAD PAINT SURVEY

TRAVIS AIR FORCE BASE

BUILDING 31 – ROOM 64

TRAVIS, CALIFORNIA

24A-7031

PREPARED FOR:

Ms. Valentina Langill

CA 9453560 CES/CEOES

241 V Street, Bldg. 878 Travis AFB, CA 94535

PREPARED BY:

American Compliance Services, LTD 554 Morning Glory Drive

Benicia, CA 94510

DATE PREPARED:

March 7, 2024 http://www.acs-ltd.us/

Table of Contents

SECTION I EXECUTIVE SUMMARY

SECTION II SCOPE OF WORK

SECTION III DEFINITIONS

ASBESTOS

LEAD

SECTION IV ASBESTOS INSPECTION RESULTS & FINDINGS

Table 1 - Asbestos Sample Results - Room 303

SECTION V LEAD INSPECTION RESULTS & FINDINGS

Table 2 Lead Sample Results – Room 303

SECTION VI METHODS

SECTION VII LIMITATION AND EXCLUSIONS

SECTION VIII TECHNICAL STAFF SIGNATURES - CERTIFICATE OF REPORT

Attachments Sample Location Map(s) Laboratory Results Consultants’ Certification(s)

Limited Asbestos and Lead Survey Travis Air Force Base – PO 24A7031 Building 31, Room 64 Travis, California Page 1 of 6

SECTION I EXECUTIVE SUMMARY

On March 1, 2024, American Compliance Services, LTD (ACS) conducted a limited asbestos and lead survey at Travis Air Force Base, in Building 31, Room 64, in Travis, California. David Kummer, a Certified Site Surveillance Technician (CSST) and CDPH Lead Sampling Technician, conducted the survey.

SECTION II SCOPE OF WORK

The scope of work for Building 31 consists of testing the drywall and base cove in Room 64 prior to remodeling. Should the final construction plans change and require penetration into materials not included in this report, additional sampling and analysis will be required at this site.

SECTION III DEFINITIONS

ASBESTOS

A material is considered by the EPA and the State of California to be an Asbestos Containing Material (ACM) if at least one sample collected from the homogeneous area shows asbestos present in an amount greater than one percent (>1%) https://www.dir.ca.gov/title8/ch3_2sb2a2_5.html. California Code of Regulations (CCR) 1529 defines Asbestos Containing Construction Material (ACCM) as materials containing greater than one-tenth of one-percent (0.1) asbestos by weight. Under 1529 CCR, materials containing between 0.1 % and 1 % asbestos are still regulated as “other” operations by this standard. The ACCM designation is applicable only to reporting (user registration, temporary worksite notification, and incident reporting). https://www.dir.ca.gov/title8/1529.html

The removal or disturbance of 100 square feet or more of ACM or ACCM must be performed by a contractor certified by the California Contractor's State License Board to conduct asbestos-related work and/or an employer/contractor registered with the California Division of Occupational Safety and Health (DOSH) to perform asbestos-related work.

OSHA CLASSIFICATIONS

"Class I asbestos work" means activities involving the removal of TSI and surfacing ACM and

PACM.

"Class II asbestos work" means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

"Class III asbestos work" means repair and maintenance operations, where "ACM", including TSI and surfacing ACM and PACM, is likely to be disturbed.

“Class IV asbestos work” means maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.

http://www.acs-ltd.us/ https://www.dir.ca.gov/title8/ch3_2sb2a2_5.html https://www.dir.ca.gov/title8/1529.html

Travis, California Page 2 of 6

“Disturbance” means activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM. Disturbance includes cutting away small amounts of ACM and PACM, no greater than the amount which can be contained in one standard sized glove bag or waste bag in order to access a building component. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width.

NESHAP CATEGORIES

Friable Materials (RACM) NESHAP defines a friable ACM as any material containing more than one percent asbestos that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable NESHAP defines a Category I non-friable ACM as packing, gaskets, resilient floor covering (except sheet flooring products which are considered friable), and asphalt roofing products which contain more than one percent asbestos.

Category II Non-friable NESHAP defines a Category II non-friable ACM as any material, except for a Category I non-friable ACM, which contains more than one- percent asbestos and cannot be reduced to a powder by hand pressure when dry.

LEAD

The CDPH, Title 17, California Code of Regulations, Division 1, Chapter 8, Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards, defines lead based paint as any coating containing lead at or above 1.0 Milligram/Centimeter Squared (mg/cm²) and/or 5,000 parts per million (ppm) of lead or 0.5 % lead by weight or greater. A 24-hour notification is required to OSHA before disturbing lead-based paint.

Disturbing lead-based paint without containment is considered a lead hazard by the EPA and CDPH, and impact to these painted surfaces must be done in accordance with the established regulations and procedures.

Lead contaminated dust means dust levels on interior floors in excess of 10 micrograms per square foot (10 µg/sq. Ft.), 100 µg/sq. Ft. for interior horizontal surfaces, and 400 µg/sq. Ft. for exterior horizontal surfaces.

Lead-contaminated soil means bare soil that contains an amount of lead equal to, or in excess of, 400 parts per million (ppm) in children’s play areas and 1,000 ppm in all other areas.

The Cal/OSHA Lead in Construction Standard 1532.1 regulations take effect when employees disturb lead coatings or materials that contain any detectable levels of lead. California OSHA regulations assume exposures above the Permissible Exposure Level (PEL) where lead coatings or paint with lead at any level is present when “trigger” tasks are performed until an exposure assessment is conducted. The contractor must comply with this regulation when disturbing lead containing paint or materials.

NESHAP 40 CFR, Part 61 M, and the EPA rule “Lead: Renovation, Repair and Painting Activities that Disturb Lead-Based Paint”, EPA 40 CFR 745.227 Title 40 - Protection of Environment for conducting lead-based paint activities and 40 CFR 745.85 for conducting renovations.

https://www.law.cornell.edu/cfr/text/40/745.85 https://govt.westlaw.com/calregs/Document/I20F6E4A0D60711DE88AEDDE29ED1DC0A?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default) https://govt.westlaw.com/calregs/Document/I20F6E4A0D60711DE88AEDDE29ED1DC0A?viewType=FullText&originationContext=documenttoc&transitionType=CategoryPageItem&contextData=(sc.Default) https://www.dir.ca.gov/title8/1532_1.html https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved=2ahUKEwik6M3Uw4fqAhXJup4KHZFBBwAQFjACegQIBBAB&url=https%3A%2F%2Fwww.govinfo.gov%2Fapp%2Fdetails%2FCFR-2011-title40-vol31%2FCFR-2011-title40-vol31-sec745-227&usg=AOvVaw2TpXmI4CSD6ZxsKsRpZaJP https://www.law.cornell.edu/cfr/text/40/745.85

Travis, California Page 3 of 6

SECTION IV ASBESTOS INSPECTION RESULTS & FINDINGS

ACS collected five (5) samples from Room 64 for asbestos laboratory analysis. EPA guidelines were used to determine the sampling protocol. Asbestos was not detected in the material sampled. The results are summarized in the table below:

Table 1 - Asbestos Sample Results - Room 303

SAMPLE

NUMBER

MATERIAL

DESCRIPTION

SAMPLE

LOCATION/

HOMOGENEOUS

AREA

NESHAP /

OSHA

CATEGORIES

% ASBESTOS

ESTIMATED

QUANTITY

64-01-1 64-01-2 64-01-3 64-02-4

Textured Drywall System

Throughout NA Drywall: ND Texture; ND

Tape / Paint: ND

NA

64-03-5 4” Grey Base

Cove Throughout NA

Base Cove: ND Mastic: ND

NA

NA: Asbestos classification and estimated quantities are not applicable for non-asbestos containing material; ND: Non-Detect.

SECTION V LEAD INSPECTION RESULTS & FINDINGS

Three (3) lead samples were collected during the survey. The material sampled is representative of the coating sampled. The paint is determined not to be lead-based, and lead was not detected at, or above, the laboratory’s detection limit. The laboratory results are presented in the table below.

Table 2 Lead Sample Results – Room 303

Sample # Description and Location Results ppm

EPA/CDPH

LBP Limit

64-P1 Purple Paint on Textured Drywall <79 5,000 ppm

64-P2 White Paint on Textured Drywall <81 5,000 ppm

64-P3 Black Paint on Drywall <120 5,000 ppm ppm: parts per million; EPA: Environmental Protection Agency; CDPH: CA Department of Public Health; LBP: Lead-Based Paint; <: Less than the laboratory’s detection limit, none detected.

SECTION VI METHODS

ASBESTOS

Asbestos Inspection and sampling procedures were performed in general accordance with the guidelines published by the Environmental Protection Agency (EPA) in 40 CFR Part 763 Subpart E, October 30, 1987. https://www.law.cornell.edu/cfr/text/40/part-763/subpart-E The survey consisted of three major activities: visual inspection and physical assessment, sampling, and quantification of building materials.

ASBESTOS BULK SAMPLE ANALYSIS

Micro Analytical Laboratory in Emeryville, California performed the Asbestos analysis. A chain-of-custody form submitted with the bulk samples, documented the possession of the samples from the time they were collected until they were analyzed. The original chain-of-custody accompanied the samples at all times. Custody documentation began at the time the sample was https://www.law.cornell.edu/cfr/text/40/part-763/subpart-E

Travis, California Page 4 of 6 collected and a copy of the chain-of-custody record was retained by each transferor. The laboratory performed the asbestos analysis using the bulk sample for visual observation and slide preparation(s) for microscopic examination and identification. They mounted samples on slides and then analyzed the samples for asbestos (chrysotile, amosite, crocidolite, anthophyllite, and actinolite/tremolite), fibrous non-asbestos constituents (mineral wool, paper, etc.) and non-fibrous constituents. Asbestos was identified by refractive indices, morphology, color, pleochroism, birefringence, extinction characteristics, and signs of elongation. The same characteristics were used to identify the non-asbestos constituents. The microscopist visually estimated relative amounts of each constituent using a stereoscope to determine the volume of each constituent in proportion to the total volume of the sample.

All bulk samples were analyzed by Polarized Light Microscopy (PLM) with dispersion staining as described by the method of the determination of asbestos in bulk insulation, EPA/600/R-93/116, July 1993. This is a standard method of analysis in optical mineralogy and the currently accepted method for the determination of asbestos in bulk samples. A suspect material is immersed in a solution of known refractive index and subjected to illumination by polarized light. The characteristic color displayed enables mineral identification. It should be noted that some ACM might not be accurately identified and/or quantified by PLM. As an example, the original fabrication of vinyl floor tiles routinely involved milling of asbestos fibers to extremely small sizes.

As a result, these fibers may go undetected under the standard polarized light microscopy method. Transmission Electron Microscopy (TEM) is required for a more definitive analysis of these materials.

QUANTIFICATION

Quantities are not applicable for non-asbestos containing material.

ASBESTOS BULK SAMPLE ANALYSIS

Micro Analytical Laboratory in Emeryville, California performed the Asbestos analysis. A chain-of-custody form submitted with the bulk samples, documented the possession of the samples from the time they were collected until they were analyzed. The original chain-of-custody accompanied the samples at all times. Custody documentation began at the time the sample was collected and a copy of the chain-of-custody record was retained by each transferor. The laboratory performed the asbestos analysis using the bulk sample for visual observation and slide preparation(s) for microscopic examination and identification. They mounted samples on slides and then analyzed the samples for asbestos (chrysotile, amosite, crocidolite, anthophyllite, and actinolite/tremolite), fibrous non-asbestos constituents (mineral wool, paper, etc.) and non-fibrous constituents. Asbestos was identified by refractive indices, morphology, color, pleochroism, birefringence, extinction characteristics, and signs of elongation. The same characteristics were used to identify the non-asbestos constituents. The microscopist visually estimated relative amounts of each constituent using a stereoscope to determine the volume of each constituent in proportion to the total volume of the sample.

All bulk samples were analyzed by Polarized Light Microscopy (PLM) with dispersion staining as described by the method of the determination of asbestos in bulk insulation, EPA/600/R-93/116, July 1993. This is a standard method of analysis in optical mineralogy and the currently accepted method for the determination of asbestos in bulk samples. A suspect material is immersed in a solution of known refractive index and subjected to illumination by polarized light. The characteristic color displayed enables mineral identification. It should be noted that some ACM might not be accurately identified and/or quantified by PLM. As an example, the original fabrication of vinyl floor tiles routinely involved milling of asbestos fibers to extremely small sizes.

As a result, these fibers may go undetected under the standard polarized light microscopy

Travis, California Page 5 of 6 method. Transmission Electron Microscopy (TEM) is required for a more definitive analysis of these materials.

LEAD

The Lead inspection was performed in general accordance with EPA and CDPH guidelines and procedures. The paint chip samples taken were approximately 2” x 2“, representing all potential paint layers. Testing locations were recorded on a diagram, as provided in the appendix.

Sampling locations were chosen to be representative of the homogeneous material.

LEAD ANALYTICAL METHODS

Lead analysis was performed by Micro Analytics Incorporated, a NLLAP-accredited laboratory using a Flame Atomic Absorption Spectrophotometer (FLAA) (Method 7420). The FLAA was calibrated using a known lead standard. After the FLAA calibration procedure was completed, the lead-chip samples were analyzed by the FLAA.

SECTION VII LIMITATION AND EXCLUSIONS

American Compliance Services, LTD (ACS), warrants that the findings contained herein have been prepared with the level of care and skill exercised by experienced and knowledgeable environmental consultants who are appropriately licensed or otherwise trained to perform asbestos / lead assessments pursuant to OSHA, as well as state and local agencies, as applicable. Our responsibility is limited to correcting any error or omission. No other liability is included or implied. We did not inspect or sample inaccessible areas such as behind walls or within ductwork and did not dismantle any part of the structure to survey inaccessible areas.

Inaccessible is defined as areas of the building that could not be tested (sampled) without destruction of the structure or a portion of the structure.

Information and opinions presented herein apply to the existing and reasonable foreseeable site conditions at the time of our investigation. They cannot necessarily apply to site changes of which this office is unaware and has not had the opportunity to review. Changes in applicable standards may occur because of new legislation or from the broadening of knowledge. Accordingly, findings of this report may be invalidated wholly, or in part, by changes beyond our control.

ACS trusts that the information presented herein provides the data you require. Should you have any questions or comments, please contact ACS. This report, and all available supporting documents and drawings used to prepare the report, have been reviewed by the undersigned, the personnel responsible for this project. The signatory affirms that the Asbestos Investigation documented herein was conducted in substantial conformance with applicable procedures documented in 40 CFR Part 763 – Asbestos, Subpart E – Asbestos Containing Materials in Schools [AHERA, June 24, 1992], and the EPA Guidance Manual “Asbestos Containing Materials in Buildings” (EPA 560/5-85-030a, October, 1985). The investigation by American Compliance Services, LTD, consisted solely of the activities described in this report and is subject to the Exceptions of Assessment, Limitations, and Service Constraints described herein.

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SECTION VIII TECHNICAL STAFF SIGNATURES - CERTIFICATE OF REPORT

The following personnel were responsible for this survey. We (I) certify that information contained herein was collected on the dates recorded and the site described in this report.

Wendy Plank Davis, CAC # 01-2904 Certified Asbestos Consultant, Expires 4/4/2024 CDPH Lead Inspector/Assessor, PM, S, LRC 8107, 8, 6, Expires 5/18/2024

David Kummer, CSST # 08-4363 Certified Site Surveillance Technician Expires 6/19/2024 Lead Sampling Technician CDPH Lead Certification # LRC 7343 Expiration Date: 10/27/2024

SAMPLE LOCATION MAP(S)

31-01-1

BUILDING 31, ROOM 64, TRAVIS AFB

SAMPLE LOCATION MAP

ASBESTOS SAMPLE

31-01-2

31-01-3

31-03-531-02-4

31-P1

31-P2

LEAD SAMPLE

LABORATORY RESULTS

ASBESTOS

LEAD

CONSULTANTS’ CERTIFICATIONS