Attachment 6 B-5725 Report 1.pdf

LIMITED ASBESTOS & LEAD

INSPECTIONS

Building 5725 Lackland AFB, Texas

For

Mr. Manuel Hernandez

502 CES/CENMLQ

1555 Gott St., Bldg. 5595 JBSA Lackland AFB, Texas 78236 by AEHS, Inc.

4402 Center Gate San Antonio, Texas 78217

(210) 656-9300 www.aehs-sa.com

Asbestos and Lead Inspections AEHS, Inc.

JBSA-LAFB Building 5725, San Antonio, Texas Environmental, Health, and Safety Consulting April 2018

LIMITED ASBESTOS AND LEAD INSPECTIONS

JBSA-LAFB AFB, Texas

This report is divided into two sections corresponding to the consulting performed. The on-site inspections were performed by Matthew Louderback under the overall direction of Ronald M. Bishop. Matt is a Texas Department of State Health Services (TDSHS) licensed Asbestos Inspector (No. 60-2816) and Lead Risk Assessor (No. 2070871). Ron Bishop is a TDSHS licensed Asbestos Consultant, Lead Risk Assessor, Lead Project Designer, and Mold Consultant as well as a Certified Industrial Hygienist, Certified Safety Executive, Registered Sanitarian, Diplomate in Environmental Health, and Registered Environmental Professional, Registered Environmental Manager and Green Consultant.

A. ASBESTOS INSPECTION

1.0. GENERAL.

1.1. Construction materials containing asbestos have been used extensively in buildings because it possesses excellent properties for fire-proofing, insulation, and condensation control. Asbestos may be found in: (1) cement products; (2) spray applied or trowel applied materials on ceiling, walls, and other surfaces; (3) insulation on pipes, boilers, tanks, ducts, and other equipment; (4) vinyl floor tiles; (5) roofing; (6) flooring coatings; and (7) other miscellaneous products.

1.2. Friable materials are those materials that when dry can be crumbled, pulverized, or reduced to powder by hand pressure. Material that contains more than one percent asbestos by weight is considered to be asbestos containing material. Some of these asbestos-containing building materials are not considered friable now, but could become friable if not properly managed and maintained under an asbestos management program.

1.3. The concern about exposure to asbestos in buildings is based on evidence linking various respiratory diseases with occupational exposure in the shipbuilding, mining, milling, and fabricating industries. The presence of asbestos in a building does not mean that there is a significant health risk to building occupants. As long as asbestos-containing materials remain in good condition and are not disturbed, exposure is unlikely. Through proper control of building operations and maintenance activities, disturbance or damage to asbestos-containing materials is minimized, thus limiting the building occupant's exposure to airborne asbestos fibers.

1.4. Building alterations and/or demolition require knowledge of what materials contain asbestos and if they will be removed or disturbed during the project. Under the Clean Air Act, EPA has issued a National Emission Standard for Asbestos (40 CFR 61.140 - 61.156). This Standard regulates reporting requirements, work practices, waste disposal, and emissions from facility modification and/or demolition operations. The Standard applies only to materials containing more than one percent asbestos. The State of Texas has adopted a set of regulations (25 TAC 295.31 - 295.70) known as "Texas Asbestos Health Protection Rules" which govern asbestos removal, encapsulation, or enclosure, including licensing and regulation, in all buildings of public occupancy or access. Any disturbance or removal of ACBM in the building or facilities are subject to this Texas Statute.

2.0. BACKGROUND.

2.1. AEHS, Inc. was contacted by Manuel Hernandez to perform limited asbestos and lead inspections on JBSA-LAFB Building 5725, San Antonio, Texas.

2.2. The building houses hallways, offices, and restrooms.

3.0. SCOPE OF WORK.

3.1. The asbestos inspection was performed on 5 April 2018 and consisted of visual assessments to determine the presence of suspect ACBM in the area of concern. Bulk samples of suspect ACBM (materials which possibly contain asbestos, as determined by an accredited EPA AHERA Building Inspector/Consultant) were collected. The visual inspection, bulk sampling, and inspection documentation was performed by Matthew Louderback [Asbestos Inspector (No. 60-2816)].

3.2. AEHS, Inc. is a TDSHS Licensed Asbestos Constant Agency (No.10-0335), PCM Laboratory (No. 30-0295), and Training Provider (No. 00-0068).

3.3. The specific objectives of the survey were to:

• Perform a visual inspection and physical assessment following the Asbestos

Hazard Emergency Response Act (AHERA) protocol as a guideline to identify, quantify, and assess accessible friable and non-friable ACBM;

• Collect and analyze bulk samples of suspect material for asbestos content and identification by an American Industrial Hygiene Association Accredited Laboratory that is also licensed by the Texas Department of State Health Services;

• Ensure the technical quality of all work by using the AHERA protocol and a TDSHS licensed consultant and inspector for the inspection.

• Ιssue a final report that includes findings, bulk sample locations, and confirmed asbestos-containing building materials.

4.0. DESCRIPTION.

4.1. The inspection was of specific roof areas in Building 5725 as indicated in the email and by the performance work statement.

4.2. It consists of a concrete fascia that will be replaced that will disturb the roof parapet wall as well.

5.0. INVESTIGATIVE METHODS.

5.1. Visual Inspection.

5.1.1. Building materials were inspected and assessed using the methods presented in the federal AHERA regulations (40 CFR, Part 763) as a guideline. The procedures mandated are considered the industry standard and are applied to all surveys performed by

5.1.2. The suspect ACBM within the space consisted of asphalt shingles and roof mastic.

5.1.3. The other materials observed but were not suspect upon close examination included concrete and aluminum fascia.

5.2. Bulk Sampling.

5.2.1. Bulk samples of all homogeneous materials from identified functional spaces containing suspect ACBM were collected. A homogeneous material is defined as a surfacing material, thermal system insulation, or miscellaneous material that is uniform in use, color and texture. Examples of homogeneous materials include:

• Pipe insulation produced by the same manufacturer and installed during the same time period;

• Floor or ceiling tile of identical size, color and/or pattern;

• Sprayed-on acoustical ceiling materials located in contiguous areas; and

• Trowelled on plaster of same texture and location.

5.2.2. A functional space is defined as any spatially distinct unit within a building that contains identifiable populations of current or previous building occupants. Examples of functional spaces include:

• Office areas;

• Storage (warehousing) areas; and

• Living quarters.

The functional space concept is helpful in determining the use and occupancy of building areas containing confirmed ACBM. Knowing the types of occupants and their use of an area also may influence the selection of an asbestos management option and/or corrective action. If multiple corrective actions are necessary, the occupancy and use of individual areas may also become important factors when establishing the priority, or ranking, of each corrective action.

5.2.3. Prior to obtaining the samples, all friable

suspect material are sprayed with amended (surfactant added) water to minimize fiber release. Small pieces of the suspect material were sampled by cutting off a sufficient quantity of the wetted suspect material in an inconspicuous location and securing the sample in a plastic bag. Samples were extracted from the center of the wetted area. The tool used to collect the suspect sample was then cleaned to ensure no cross-contamination occurred between samples. A plastic bag was used to contain the samples of the suspect material and quickly sealed to prevent the escape of the material or the introduction of ACBM contamination from outside sources.

5.3. Bulk Sample Analysis.

5.3.1. All bulk samples collected during this survey were analyzed by Environmental

Hazards Services, Inc.’s Laboratory in Richmond, Virginia. Environmental Hazards Services laboratory is accredited under the National Institute of Standards and Technology’s National Voluntary Laboratory Accreditation Program (NVLAP) and the American Industrial Hygiene Association. Additionally, the laboratory is a TDSHS licensed (No. 30-0188) Asbestos Laboratory (Polarized Light Microscopy). Their address, telephone number, and quality assurance review are depicted on their laboratory reports.

5.3.2. All asbestos samples were analyzed using Polarized Light Microscopy/Dispersion Staining (PLM/DS) techniques in accordance with methodology approved by the U.S.

Environmental Protection Agency (EPA), method number 600/R-93/116. The percentage of asbestos present in the samples was determined on the basis of a visual area estimation as set forth in 40 CFR Part 763, Appendix A, Subpart F, Section 1.2 and 1.7.2.4. The lower limit of reliable detection for asbestos using the PLM/DS method is approximately 1% by volume.

5.3.2.1. The Environmental Protection Agency considers materials with greater than one percent (>1%) asbestos content to be asbestos containing. Therefore, when asbestos containing building material (ACBM) appear in this report, it should be interpreted as meaning the sample(s) taken contained greater than (>1%) asbestos and is considered a regulated material. However, material that contains equal to or less than one percent is not considered to be asbestos containing material. If the results of sampling indicate that the asbestos containing material is a trace or up to 10% asbestos, the results must be verified by polarized light microscopy point counting or presumed to be asbestos. For this survey, AEHS personnel used their experience with similar materials.

5.3.2.2. When “No Asbestos Detected” (NAD) appears in this report, it should be interpreted as meaning no asbestos was observed in the sample material above the reliable limit of detection for the PLM/DS method.

5.3.2.3. The Texas Department of State Health Services requires a minimum of three samples to be collected from each homogeneous area. In order for a material to be considered negative, all samples must be negative. On the other hand, if one of the three samples is positive, then the material is considered positive.

6.0. RESULTS OF INSPECTION.

6.1. Analytical Results. The analytical results from the inspection and chain of custody are at Appendix A. A total of six (6) samples were collected which resulted in six (6) analyses.

6.2. Summary Positive Asbestos Containing Building Materials. None. The laboratory results indicated “NAD – No Asbestos Detected” in all samples.

6.3. Photographs. Photographs are located at Appendix B.

6.4. Site Map. Asbestos sample location diagram is located at Appendix D.

7.0. ASSESSMENT.

7.1. Friable Asbestos Material. None.

7.2. Non-Friable Materials. None.

8.0. RECOMMENDATION. Maintain a copy of this report with the project files.

B. LEAD BASE PAINT

1.0. GENERAL.

1.1. Background.

1.1.1. Inspections and risk assessments for lead base paint (LBP) hazards emerged in response to an insurance problem in the nation’s public housing programs after children in housing units throughout the nation were found to contain elevated blood lead levels.

When investigations pursued, the houses were found to contain LBP where deterioration was extensive and the children were ingesting the paint directly (chewing on the sills, etc.)

or indirectly by placing contaminated items into their mouths.

1.1.2. At the present time, many of the standards used in lead hazard assessments are not health-based standards. A limit that will not produce adverse health affects has not been established for lead content of paint, dust or in soil. This is due in part to differences in individual behavior, particularly with respect to hand-to-mouth activity. However, the limits that are established in the various standards will significantly reduce the health impacts. Also, these limits dictate requirements for action, if exceeded.

1.1.3. The reason lead base paint inspections are conducted for commercial facilities is to determine potential worker exposure and environmental insult during demolition and disposal of the wastes based on the lead content.

1.2. Standards. As indicated in the Table 1 below, there are various standards that currently define lead base paint. The applicable standards to this project include the OSHA requirements, for worker protection performing the renovation, and the environmental requirements for disposal of materials painted with lead base paint.

Table 1

Lead Standards

Standard/Regulation Level Remarks

Consumer Product Safety Commission 600 ppm 0.06% parts per million % by weight

HUD – 24 CFR Part 35 0.5% by weight

1.0 mg/cm

NLLAP Accredited Lab

2 XRF

TELLR - Texas Environmental Lead Reduction Rules

0.5% by weight

1.0 mg/cm

NLLAP Accredited Lab

2 XRF

OSHA - 29 CFR 1926.62 - Lead in Construction; Interim Final Rule Any amount Worker Protection

EPA - 40 CFR 261 - Identification and Listing of Hazardous Wastes 5 ppm TCLP TCLP - Toxicity Characteristic

Leaching Procedure

1.3. Lead Risk Assessment.

1.3.1. A Lead Risk Assessment is to determine, and then report on the existence, nature, severity, and location of lead base paint hazards in residential dwellings through on-site investigations. Normally, risk assessments determine the immediately available sources of lead in a dwelling and provides advice on long-term and/or short-term responses to any hazards found. In general, inspections measure lead base paint concentrations while risk assessments measure lead base paint hazards.

1.3.2. The specific differences between an Inspection and a Risk Assessment depicted in Table 2, below:

Table 2

Inspections/Risk Assessments

Inspections Risk Assessments Measure the concentration of lead in the paint on a surface-by-surface basis

Measure the level of lead in dust and soil and deteriorated paint

Identify the presence of lead base paint on all components

Identity the location and nature of all lead base paint hazards (primary prevention)

Allow the owner to avoid treating paint that is not lead base paint

Consider information about past maintenance and management practices

Allow the owner to treat all lead hazards present

Limited Risk Assessment/Inspection A combination of the Inspection and Risk Assessment tailored to the specific renovations to be performed under the specifications.

2.0. APPROACH.

2.1. Limited Inspection. A limited lead base paint inspection was conducted on 5 April 2018 at the location as described in paragraph 4 of the Asbestos Section.

2.2. Credentials.

2.2.1. The Limited Inspection was performed by Matthew Louderback. Matt is a TDSHS certified Lead Risk Assessor (No. 2070871).

2.2.2. AEHS, Inc. is a TDSHS certified/licensed Lead Firm (No. 21100283) and Lead Training Provider (No. 20439).

2.3. Methodology. XRF measurements were taken at representative locations on interior painted surfaces in the area of concern as requested by the escort. Heuresis Pb200i (Serial No.

1531; Resource Date: May 10, 2017) was used in the testing for lead base paint. Calibrations were performed prior to and after testing each building in accordance with Performance Characteristics Sheets (PCS). See Appendix C for a table of the results.

3.0. DISCUSSION/CONCLUSIONS.

3.1. The HUD/EPA guidance for target housing is 1 mg/cm2

while the Toxic Characteristic Leaching Procedure (TCLP) limit for lead is 5 parts per million (ppm).

3.2. The OSHA requirements, as promulgated in 29 CFR 1926.62 (Lead Standard for the Construction Industry), considers any amount of lead as lead containing paint; however, any measured surface below 0.1 mg/cm2 should be considered negative for lead base paint.

4.0. RESULTS.

4.1. Seventeen (17) measurements were made with the XRF for lead content.

4.2. Based on the XRF measurements, AEHS, Inc. has determined that the following should considered positive for lead base paint:

• None

5.0. RECOMMENDATIONS. Maintain a copy of this report with the project files.

DISCLAIMER

This report, which contains inspections/measurements for hazardous material is given for the sole benefit of the aforementioned client(s). The client expressly confirms their understanding that the conclusions/ recommendations stated in this report are limited to and based solely upon the scope of the assignment, and samples and field measurements taken. In addition, the client understands that any field observations contained herein reflect the conditions present on the date and time of inspection. No representations or warranties are made or may be implied as to the validity of their applicability to any other days or times.

Ronald M. Bishop, MPH, CIH Asbestos Consultant (10-5492) Lead Risk Assessor (2070124) Lead Project Designer (2090015) 12 April 2018

Appendix A

Asbestos Lab Results

Asbestos Bulk Analysis Report

Client:

Report Number:

Project/Test Address:

Client Number:

Reported Date:

Received Date:

Analyzed Date:

AEHS 04/06/2018

45-5371

04/11/2018

18-04-00862

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Building 5725; Lackland AFB; San Antonio, TX

Laboratory Results Fax Number:

210-656-8499

4402 Center Gate San Antonio, TX 78217

04/10/2018

Layer Type AsbestosClient Sample Number

Other Materials

Lab Gross DescriptionLab Sample Number

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-001 AS-A1 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-002 AS-A2 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-003 AS-A3 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-004 RM-A4 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-005 RM-A5 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

1 of 2Page

Gray Aggregate; Black Tar-Like; Inhomogeneous

18-04-00862-006 RM-A6 5% Cellulose 15% Fibrous Glass 80% Non-Fibrous

NAD

Missy Kanode

1% Asbestos

Analyst:

Reporting Limit:

Method:

QC Blank:

QC Sample:

Angel McDaniel

EPA Method 600/R-93/116, EPA Method 600/M4-82-020

QA/QC Clerk

Reviewed By Authorized Signatory:

26-M22010-1

SRM 1866 Fiberglass

NAD = no asbestos detectedLEGEND:

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. Each distinct component in an inhomogeneous sample was analyzed separately and reported as a composite. Results represent the analysis of samples submitted by the client. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the Environmental Hazards Service, L.L.C. California Certification #2319 NY ELAP #11714 NVLAP #101882-0 VELAP 460172. All information concerning sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection.

Environmental Hazards Services, L.L.C. recommends reanalysis by point count (for more accurate quantification) or Transmission Electron Microscopy (TEM), (for enhanced detection capabilities) for materials regulated by EPA NESHAP (National Emission Standards for Hazardous Air Pollutants) and found to contain less than ten percent (<10%) asbestos by polarized light microscopy (PLM). Both services are available for an additional fee.

400 Point Count Analysis, where noted, performed per EPA Method 600/R-93/116 with a Reporting Limit of 0.25%.

* All California samples analyzed by Polarized Light Microscopy, EPA Method 600/M4-82-020, Dec. 1982.

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:45-5371 18-04-00862

Building 5725; Lackland AFB; San Antonio, TX

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

2 of 2Page

Appendix B

Photographs

JBSA-LAFB AFB, Texas

1. Non-suspect concrete wall to be replaced 2. Roof Mastic - No Asbestos Detected(NAD)

3. Metal Roof Fascia - No Lead Detected 4. Asphalt Shingle - No Asbestos Detected(NAD)

5. Metal Yellow and Brown Pipe - No 6. Roof Parapet where concrete fascia will be Lead Detected removed

Appendix C

XRF Measurements

XRF Lead Measurements

Building 5725 Roof

JBSA-Lackland AFB, San Antonio, TX

No. Date Bldg. Room Component Feature Substrate Cond Color Results PbC

1 4/5/18 13:44 1.8

2 4/5/18 14:02 Calibration Negative 0.9

3 4/5/18 14:03 Calibration Negative 0.9

4 4/5/18 14:03 Calibration Negative 0.9

5 4/5/18 14:05 5725 Exterior Roof Rail Cap Aluminum Intact Brown Negative 0

6 4/5/18 14:05 5725 Exterior Roof Fascia Aluminum Intact Brown Negative 0

7 4/5/18 14:06 5725 Exterior Roof Pipe Metal Intact Brown Negative 0

8 4/5/18 14:06 5725 Exterior Roof Pipe Metal Intact Yellow Negative 0

9 4/5/18 14:08 5725 Exterior Wall EFS Det Beige Negative 0.05

10 4/5/18 14:09 5725 Exterior Wall EFS Det Beige Negative 0

11 4/5/18 14:10 5725 Exterior Wall EFS Det Beige Negative 0

12 4/5/18 14:11 5725 Exterior Wall EFS Det Beige Negative 0

13 4/5/18 14:14 5725 Exterior Wall Concrete Det Natural Negative 0.01

14 4/5/18 14:14 5725 Exterior Wall Brick Det White Negative 0

15 4/5/18 14:15 5725 Exterior Wall Brick Det Beige Negative 0.01

16 4/5/18 14:16 5725 Exterior Roof Asphalt Det Beige Negative 0

17 4/5/18 14:17 5725 Exterior Roof Rail Cap Aluminum Det Brown Negative 0

18 4/5/18 14:18 5725 Exterior Wall Rebar Metal Det Natural Negative 0

19 4/5/18 14:19 5725 Exterior Wall Concrete Det Natural Negative 0.02

20 4/5/18 14:20 5725 Exterior Wall Concrete Det Natural Negative 0

21 4/5/18 14:21 5725 Exterior Wall Rail Cap Aluminum Det Brown Negative 0

22 4/5/18 14:27 Calibration Positive 1

23 4/5/18 14:28 Calibration Positive 1

24 4/5/18 14:29 Calibration Negative 0.9

Appendix D

Site Map

Sides A-D are located clockwise with Side A as the address or street side of dwelling.

4402 Centergate

San Antonio, TX 78217

(210) 656-9300 www.aehs-sa.comCreated with OpenOffice 4.0.1

Not to scale

Project No. 18-059 Date: April 12, 2018 Site Map for

Building 5725 JBSA-Lackland AFB, Texas

AS-A1

AS-A2 AS-A3

RM-A4

RM-A5

RM-A6

Limited Risk Assessment/Inspection