B-2 Amistad Power Plant Asbestos and Lead Survey Report.pdf

Asbestos & LeadPaint Survey Report

USIBWC Amistad Power Plant and Warehouse Del Rio, Texas

Request for Proposal (RFP) #12‐05

IDIQ Fixed Price Proposal Contract IBM09D0010

Prepared for:

U.S. International Boundary and Water Commission

4171 N. Mesa St., Suite C‐100 El Paso, Texas 79902‐1441

Submitted by:

505 East Huntland Drive, Suite 250

Austin, Texas 78752 Telephone: (512) 329-6080 Facsimile: (512) 343-1083

May 31, 2012

Asbestos and Lead-Based Paint Survey Report Page 1 IBWC Amistad Power Plant and Warehouse, Del Rio, TX May 31, 2012

Table of Contents

Executive Summary………………………………………………………………………………2

1.0 Introduction……………………………………………………………………………….4

2.0 Building Descriptions…………………………………………………………………..4

3.0 Background…………………………………………………………………………………5

4.0 Asbestos Findings…………………………………………………………………………6

4.1Asbestos Containing Materials

4.2 Negative Materials

4.3 Asbestos Recommendations

5.0 Lead-Based Paint Inspection………………………………………………………….9

5.1 Summary of Lead-Based Paint Testing Results

5.2 Lead-Based Paint Conclusions

5.3 Lead-Based Paint Recommendations

5.4 Lead-Based Paint General Recommendations

5.5 Waste Characterization Recommendations

6.0 Disclaimer……………………………………………………………………………………15

7.0 Signatory……………………………………………………………………………………..16

Appendices

Appendix A-Bulk Asbestos Sample laboratory Report

Appendix B-Lead-Based Paint XRF Field Data sheets

Appendix C-Sample Location Drawings

Appendix D-Photographs of Positive Materials

Appendix E-Inspector Certifications

Asbestos and Lead-Based Paint Survey Report Page 2

EXECUTIVE SUMMARY

TRC Environmental Corporation (TRC) was contracted by the United States International Boundary and Water Commission (IBWC) to conduct an asbestos and a lead-based paint survey at the Amistad Power Plant and Warehouse Building located at 670 Texas Spur 349, Del Rio, Texas. The asbestos survey comprised of surveying the accessible interior and exterior building materials at the Power Plant and the Warehouse buildings. The survey consisted of identification of suspect building materials, collection of bulk samples of suspect asbestos containing materials, material condition assessments, and laboratory analysis of samples collected. The lead-based paint survey comprised of the assessment and testing of painted surfaces using a X-ray Fluorescence (XRF) Lead spectrum analyzer for the detection of lead based paint. The survey was performed on April 10- 11, 2012 by Mr. Sam Seneviratne, and assisted by Mr.

Hector Gonzalez.

Asbestos Findings Results of the asbestos survey indicated the presence of detectable asbestos in the following materials:

Power Plant

Vinyl Sheet Flooring Blue, Green and White Square Pattern-Office Areas on the 4th Floor and Employee Lunch room, Locker room, and Toilets on the 3rd Floor- 90% Chrysotile

Roof Parapet Wall Metal Flashing Caulking- Upper and Lower Roofs-5% Chrysotile

Flange Gasket-1st Floor Chemical Storage Tank Side Flange-90% Chrysotile Gasket Materials-3rd Floor Mezzanine Parts Storage Area-80% Chrysotile Sink Countertop-4th, Floor Battery Room- Assumed to Contain Asbestos Gray-Metal Slider Door Core-1st Floor Chemical Storage- Assumed to Contain

Asbestos

Warehouse Building No asbestos materials found.

Lead-Based Paint Findings The results of the lead-based paint investigation indicates that some of the painted components and fixtures tested in the Power Plant structure were found to contain lead at concentrations above the Federal lead-based paint level of 1.0 milligram per square centimeter (mg/cm²), as identified by XRF analyzer.

Power Plant

Black-Metal Gantry Crane Frame and Platform-Exterior Southwest Beige-Metal Elevator Door Frame on floors 1 thru 4 White-Glazed Metal Sink-Custodian Closet 4th and 3rd, floors Orange-Metal Powerhouse Crane Frame, 20 and 125 Ton Hooks-Erection Floor Cream-Metal Cable Tray and Support-Exterior North side Yellow-Metal Flammable Storage Cabinet- Exterior North side Yellow-Metal 2 ton Crane Boom- 3rd Floor Machine Shop

Asbestos and Lead-Based Paint Survey Report Page 3

Black-Metal-Handrail-3rd, Floor Parts Storage Area Yellow-Concrete Floor stripping-3rd Floor Elevator lobby Black-Metal Elevator Gate 1st, thru 4th, floors Red-Metal Hitachi Tool Rack-Generator Bay Blue-Metal Step and Riser-Stairs to Turbine Pit from Generator Bay Blue-Metal Wall-Inside Turbine Pit Blue-Metal Servo Linkage- Inside Turbine Pit Gray-Metal Shim-Upper Roof Parapet wall flashing fastener Gray-Metal Slider Door-1st Floor Chemical Storage area Gray-Metal Clean Oil Storage Tank 1st Floor Chemical Storage area Gray-Metal Dirty Oil Storage Tank 1st Floor Chemical Storage area Gray-Metal Spiral Case and Access Hatch 1st Floor Piping Gallery Black-Metal Handrail-Stairs to Penstock Gallery Green-Metal Piping-Penstock Drain/Fill #2 Gray-Metal Draft Tube and Access Hatch-Penstock Gallery

No lead-based paint found

Asbestos and Lead-Based Paint Survey Report Page 4

1.0 Introduction

TRC Environmental Corporation (TRC) was contracted by the United States International Boundary and Water Commission (IBWC) to conduct an asbestos and a lead based paint survey at the Amistad Power Plant and Warehouse Building located at 670 Texas Spur 349, Del Rio, Texas. The survey was performed on April 10-11, 2012, by Mr. Sam Seneviratne, and Mr. Hector Gonzalez, both EPA Accredited AHERA Asbestos Building inspectors and EPA Lead Inspectors employed by TRC. The survey included the inspection and assessment of accessible interior and exterior construction materials associated with the building structures on site.

The asbestos and lead-based paint survey findings will be used to effectively manage asbestos-containing materials (ACM) and Lead-Based Paint (LBP) in the scope areas of the Power Plant and Warehouse building structures (the “Site”). The accumulated assessment information may be used in operations and maintenance plans for the facility designed to prevent accidental disturbance to ACM and LBP.

2.0 Building Descriptions

The following provides a summary of the Power Plant Building and Warehouse Building areas defined as the scope of work areas under Contract # IBM09D0010. Both of the building structures are located on federal land, were considered non-public buildings, are secured by fencing/locked gates, and have industrial processes. A description of the building structures are as follows:

Power Plant Structure: This is a 27,786 Square foot of building, built of concrete with steel framed roof. This building has four levels. The top level (Elevation 930 or 4th Floor) has offices, switchgear rooms, and an HVAC fan room. The 4th floor is actually at ground level as you enter the building from the roadway. The 3rd level (Elevation 910, down one level from the 4th floor) houses the maintenance shops, parts room, lunch room and restrooms. The 2nd level (elevation 891) houses the control panels, the Turbine room, and pump area. The 1st level (elevation 876) houses the oil room, compressors, and piping galleries.

Warehouse: The warehouse building is located just east of the dam up-gradient from the power plant. The building is of metal frame construction built slab on grade with metal panel siding and metal panel roof. The main storage area of the warehouse is unfinished with concrete floors and the metal siding/roofing. The southern portion of the building has a meeting/conference room a kitchen, two offices, restrooms, and a small closet/storage area. The warehouse comprises approximately 10,200 square feet of area and is single-story with a high ceiling/roof.

Asbestos and Lead-Based Paint Survey Report Page 5

3.0 Background

Asbestos Containing Materials

The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) define an asbestos-containing material (ACM) as any material containing more than one percent (>1.0%) asbestos by weight. In addition, ACM are designated by the EPA into one of three characteristic categories as follows:

• Friable asbestos - material which can be crumbled, pulverized or reduced to powder by hand pressure, a.k.a. Regulated Asbestos Containing Materials

(RACM)

• Category I Non-friable - includes resilient floor coverings, asphalt roofing products, gaskets and packing. These materials may become friable if degraded or damaged to the point where the material can be crumbled, pulverized or reduced to powder by hand pressure.

• Category II Non-friable - any non-friable ACM that is not in Category I (i.e.

Asbestos-cement (Transite®) siding or roofing mastics).

Asbestos Sampling and Analytical Procedures

Representative bulk samples of suspect asbestos-containing building materials were randomly collected from the identified homogenous building material applications.

Homogenous material determination was based on the following criteria:

• Similar physical characteristics (same appearance, age, color and texture, etc.),

• Application (e.g. sprayed or trowel-on, assembly into a system, etc.),

• Material function (e.g. thermal insulation, floor tile, wallboard system, etc.).

Laboratory services were provided by TRC’s laboratory located in Windsor, Connecticut.

TRC’s analytical laboratory is a National Voluntary Laboratory Accreditation Program (NVLAP) certified laboratory (NVLAP code # 101424-0).

Bulk samples were analyzed by polarized light microscopy (PLM) utilizing the EPA’s Test Methods: Methods for the Determination of Asbestos in Bulk Building Materials (EPA 600/R-93/116, July 1993) and the McCrone Research Institute’s The Asbestos Particle Atlas as method references.

Analysis by PLM was performed by visual observation of the bulk sample and by microscopic analysis using dispersion staining PLM methodology. The samples were analyzed for asbestiform minerals (Chrysotile, Amosite, Crocidolite, Anthophyllite, Actinolite, and Tremolite), fibrous non-asbestos constituents (mineral wool, cellulose, etc.) and non-fibrous constituents. Using a stereoscope, the microscopist visually estimates the relative amounts of each constituent by determining the estimated area of the asbestos compared with the area estimate of the total sample.

Asbestos and Lead-Based Paint Survey Report Page 6

4.0 Asbestos Findings

Suspect Asbestos-Containing Materials (ACM), including building materials/finishes, insulated wire, and equipment/machinery components, e.g., gaskets, packing, dampening materials and insulation were inspected, sampled and analyzed for asbestos.

Typical suspect building materials include finishes (e.g. drywall systems, suspended ceiling panels, glued ceiling tiles, floor tiles, vinyl sheet flooring, floor finish adhesives, cove base, cove base adhesive, textured coatings, roofing materials, caulks, sealants, and plasters. Non-suspect asbestos materials are items purely composed of glass, metal, concrete, rubber, brick, ceramic, grouts, fiberglass, foam, Styrofoam, and paper.

According to federal regulations, regulated ACM are ACMs containing greater than 1% asbestos by weight.

4.1 Asbestos Containing Materials (>1%)

Asbestos was either detected in concentrations exceeding one percent in the following materials sampled during the asbestos survey or the listed component/materials was presumed to have asbestos, based on limitations of sampling feasibility. Results of the asbestos survey indicated the presence of detectable asbestos in the following materials:

Power Plant

Material Location Percentage/

Type Approx

Quantity*

NESHAP

Category

Condition

Vinyl Sheet Flooring (Blue, Green and White Square Pattern)

Power Plant-4th Floor Office Areas and 3rd Floor Employee Lunch room, Locker room and Toilets

90% Chrysotile

1,400 SF RACM Poor

Roof Parapet Wall Metal Flashing Caulking White

Power Plant – Upper and Lower

Roofs

5% Chrysotile

850 SF CAT II Poor

Flange Gasket

Power Plant 1st Floor Chemical

Storage Tank Side Flange

90% Chrysotile

40 Linear Feet

CAT I Good

Gasket Materials Power Plant 3rd

Floor Mezzanine Parts Storage Area

80% Chrysotile

200 SF CAT I Good

Various Flange and Valve Gasket

On Piping and Equipment on

Floors 1-4 Power Plant

Presumed to Contain Asbestos

1,000 LF CAT I Good

Sink Countertop Power Plant 4th, Floor Battery Room

Presumed to Contain Asbestos

25 SF CAT II Good

Gray Metal Slider Door core

1st Floor Chemical Storage Area

Presumed to Contain Asbestos

200 SF CAT II Good

Asbestos and Lead-Based Paint Survey Report Page 7

*Estimated quantities of ACMs listed are provided as a guide to the building owner. The material quantities listed in the table are approximations and TRC is not responsible for the accuracy of the quantities and measurements provided.

Material Location Percentage/Ty pe Approx

Quantity

NESHAP

Category

Asbestos was not detected in any of the sampled materials

4.2 Negative Materials

Samples of the following suspect materials were collected in the locations noted below and were reported with no detectable asbestos, as indicated by laboratory PLM analysis:

Negative Materials

Material Sample Locations

2’ x 2’ Drop Ceiling Panels Maintenance/Tool Storage, Supervisor & Records Office, Hallways and Electrical Room

Duct Sealant Caulk (White) Maintenance/Tool Storage, Supervisor & records Office, Hallways, Electrical Room and

HVAC room 4" Cove Base (Black) & Associated Mastic

(Brown) Maintenance/Tool Storage, Supervisor &

Records Office, Hallways, Electrical Room and 3rd Floor Employee Lunch room, Wall board & Joint Compound Maintenance/Tool Storage, Supervisor & records Office, Hallways, Electrical Room and 3rd Floor Employee Lunch room, Locker room and Toilets Vinyl Sheet Floor Mastic (Brown) 4th Floor Office Areas and 3rd Floor Employee

Lunch room, Locker room and Toilets Ceramic Tile (Green) and Grout (Gray) 4th, and 3rd Floor Restrooms

Textured Paint Walls of the Erection Floor Wall Texture Coat Walls of the Erection Floor

Concrete Panel and Block Wall Caulk Interior and exterior walls and roof Pipe Insulation Glue/ Mastic Pipe Insulation on exterior north side and interior floors 1-4 Duct Insulation Paper And Glue 4th Floor HVAC room

Roof Mastic Sealant (Black & with Silver Paint)

Upper and lower roofs, Parapet walls

Poured in place Concrete walls Roof parapets and exterior walls Mastic at Roof Penetrations Lower roof penetrations

Fiberglass Pipe Insulation end cap caulk 4th floor, HVAC room, 3rd Floor Maintenance Shop & 2nd Floor Turbine room

Electric Wire Insulation-various colors 3rd Floor Mezzanine storage area 9" OD Gaskets 2nd Floor Turbine room

Asbestos and Lead-Based Paint Survey Report Page 8

Negative Materials

Material Sample Locations

Interior Panel Insulation Metal roof and walls 12" Floor Tile (Tan with white and gray specks) and Mastic (Yellow) Conference room floor

4" Cove Base (Black) & Associated Mastic (Dark Brown)

Conference room walls

Wall board & Joint Compound Conference room and offices Floor leveling /filler compound (Brown) Storage room under floor tile

2’ x 2’ Drop Ceiling Panels Conference room and offices Roof Sealant on metal seams Warehouse roof

4.3 Asbestos Recommendations

Results of bulk sample analysis confirmed that asbestos was identified in regulated concentrations within some of the building materials sampled. The ACM was found to be in fair to good condition at the time of the inspection. If damaged ACM is encountered, it should be repaired, encapsulated, or removed as soon as feasible.

Access to the damaged ACM by building occupants should be restricted in the areas of damage until abatement response actions can be completed. Such abatement methods should be performed by a qualified/licensed asbestos abatement contractor, and ACM should be handled, stored, and disposed of according to all local, state, and federal regulations.

Persons performing construction or maintenance work in the Site should be aware of the types and locations of ACM and that additional materials (not identified in this report), which are either inaccessible or hidden, may exist at the Site. Care should be used when performing work that disturbs building materials. Any suspect asbestos containing materials uncovered during maintenance, renovation, or demolition activities that are not addressed in this inspection report, or presumed asbestos containing materials (e.g. fire doors with asbestos laden cores), must be sampled by an accredited asbestos inspector prior to disturbance, or they must otherwise be assumed and treated as asbestos containing.

Asbestos and Lead-Based Paint Survey Report Page 9

5.0 Lead-Based Paint Inspection

TRC conducted a lead-based paint (LBP) inspection for the determination of LBP and/or lead-based components at the Power Plant and Warehouse building structures (the “Site”). The LBP inspection was conducted in accordance with the United States Housing and Urban Development (HUD) guidance document, entitled “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing,” 1997 Revision.

The general purpose of this investigation was to document the general condition of interior and exterior painted building surfaces and to characterize the composition of painted surfaces with regard to lead content. Information derived from this investigation may be used to further refine the scope of LBP abatement activities in support of future procurement activities and to establish baseline conditions for other portions of the property with regard to LBP. The scope of work associated with this investigation included the following elements:

• Visual inspection of interior and exterior building painted surfaces and components and

• Field testing of painted surfaces and components using an X-Ray Fluorescence (XRF) analyzer

The lead based paint testing was conducted by Sam Seneviratne, an EPA; Department of Housing and Urban Development (HUD) certified Lead-Based Paint Building Inspector/Assessor, Project Monitor. The inspection was conducted on April 10 and 11, 2012. Assistance was provided by Hector Gonzalez, an EPA/HUD Lead-Based Paint Sampling Technician.

Definition of Lead-Based Paint

The United States Department of Housing and Urban Development (HUD), and United States Environmental Protection Agency define lead-based paint as a paint or other surface coatings that contain an amount of lead equal to, or in excess of:

• One milligram per square centimeter (1.0 mg/cm2); or

• One-half of one percent (0.5%) by weight.

Sampling and Analytical Procedures

All lead-based paint testing was performed using a RMD Model LPA-1B, X-ray Fluorescence (XRF) spectrum analyzer, serial #1124. Assessment activities and XRF testing were performed in accordance with the United States HUD guidance document, entitled “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing,” 1997 Revision.

The RMD Model LPA-1B XRF uses a 12 milicurie Cobalt 57 sealed radioactive source which has a half life of 18 months. The XRF measures the L & K electron shell energy released by the excited atoms of the test material such as the painted and/or coated surface location to calculate the concentrations of a specific metal on the surface coating

Asbestos and Lead-Based Paint Survey Report Page 10 down to the substrate. The RMD Model LPA-1B XRF does not have an inconclusive range such as the older generation XRF machines.

At the beginning and end of each work day and at various times during the day, the XRF was calibrated in order to ensure that the instrument was functioning properly. A series of three calibrated readings were obtained using a 1.9 mg/cm2 NIST Paint Film Standard in accordance with the instrument manufacturer’s protocol. In all cases, the instrument was functioning within the standard deviation as defined by the manufacturer and the Performance Characteristic Sheets. All validation readings were recorded in a logbook, which accompanies the instrument. A total of fifteen calibration tests were performed during the course of this investigation.

During this investigation, a total of one-hundred and seventy six (176) painted or coated substrate measurements were obtained using the XRF. The XRF field test data sheets with the results of the paint test measurements are presented in Appendix B-Lead- Based Paint XRF Field Data sheets.

5.1 Summary of Lead-Based Paint Testing Results

The XRF test results indicate that select painted surfaces and building components were found to be containing lead above the United States Department of Housing and Urban Development, and United States Environmental Protection Agency definition of lead-based paint. A summary of paints/coatings determined to be LBP by XRF analysis is provided below:

Component(s) Color Location(s) Lead XRF

Result (mg/cm²)

Approximate Quantity

Paint Condition

Metal Gantry Crane Frame and Platform

Black Exterior Southwest 3.0 to 2.4 400 SF Poor

Metal Elevator Door Frame

Beige Floors 1 thru 4 4.0-7.5 4 Doors x 20 SF each

Intact

Glazed Metal Custodian sink

White Custodian Closets 4th and 3rd, floors

>9.9 2 sinks Intact

Metal Powerhouse Crane Frame, and 20 &

125 Ton Hook Orange Erection Floor 4.2

1,500 SF

(Crane)

50 SF (Hooks) Intact

Metal Cable Tray Support

Cream Exterior North side >9.9 6,000 SF Fair

Metal Flammable Storage Cabinet

Yellow Exterior North side 1.2 50 SF Poor

Metal 2 ton Crane Boom

Yellow Machine Shop >9.9 20 SF Intact

Metal-Handrail Black 3rd, Floor Parts

Storage

2.1 100 SF Poor

Concrete Floor stripping

Yellow 3rd Floor Elevator lobby

2.9 16 SF Poor

Metal Elevator Gate Black 1st,-4th Floors- Elevator Door

1.0 200 SF Intact

Metal Tool Rack Red Generator Bay Hitachi Tool Rack

9.8 60 SF Intact

Asbestos and Lead-Based Paint Survey Report Page 11

Result (mg/cm²)

Approximate Quantity

Paint Condition

Metal Step and Riser Blue Stairs to Turbine Pit from Generator Bay >9.9 160 SF Intact

Metal Wall Blue Inside Turbine Pit >9.9 600 SF Intact

Metal Servo Linkage Blue Inside Turbine Pit >9.9 1,000 SF Intact

Metal Shim Gray Upper Roof Parapet

Wall Flashing fastener

>9.9 40 SF Poor

Metal Slider Door Gray 1st Floor Chemical

Storage >9.9 200 SF Intact

Metal Clean Oil Storage Tank

Gray 1st Floor Chemical

Storage >9.9 300.SF Intact

Metal Dirty Oil Storage Tank

Gray 1st Floor Chemical

Storage

9.2 300 SF Intact

Metal Spiral Case and Access

Gray Floor Piping Gallery >9.9-7.1 12,000 SF Intact

Metal Handrail Black Stairs to Penstock Gallery

2.1 60 LF Intact

Metal Piping Green Penstock Drain/Fill #2

2.3 150 SF Intact

Metal Draft Tube Gray Penstock Gallery >9.9 10.000 Sf Poor

Metal Access Hatch to Draft Tube- Gray Penstock Gallery 3.2 16 SF Poor

Result (mg/cm²)

Approx.

Quantity

Condition

Lead-based paint components were not found in the Warehouse building.

5.2 Lead-Based Paint Conclusions

Visual assessment of the lead-based paint identified in the Power Plant building identified painted surfaces in conditions other than “intact” in multiple areas of the interior and/or exterior of the buildings. The lead paint in poor condition (i.e., less than intact) must be stabilized or abated prior to demolition or repainting activities to prevent environmental contamination and worker exposure from lead paint.

Asbestos and Lead-Based Paint Survey Report Page 12

5.3 Lead-Based Paint Recommendations

Disturbance of lead based paint should be performed by a contractor who has experience and expertise in LBP, abatement, handling and disposal and who can protect the employees of IBWC Amistad Power Plant, and the environment from lead exposure hazards. For construction work where an employee may be occupationally exposed to lead in any amount, the workers and contractor must comply with Federal Occupational Safety and Health (OSHA) worker lead exposure regulations 29 CFR 1910.1025 and

1926.62 (lead in construction). Additionally, lead containing waste must be characterized and profiled for proper disposal according to applicable federal State and local regulations.

TRC recommends that interior and exterior painted surfaces containing lead at concentrations greater than or equal to 1.0. Mg/cm2 and that are in poor condition be abated and/or stabilized. Based on the results of this assessment, the following materials meet the criteria for abatement and/or stabilization:

Result (mg/cm²)

Approximate Quantity

Condition

Metal Gantry Crane Frame and Platform

Black Exterior Southwest 3.0 to 2.4 400 SF Poor

Metal Flammable

Storage Cabinet Yellow Exterior North side 1.2 50 SF Poor

Metal-Handrail Black 3rd, Floor Parts Storage 2.1 100 SF Poor

Concrete Floor stripping

Yellow 3rd Floor Elevator lobby 2.9 16 SF Poor

Metal Shim Gray Upper Roof Parapet Wall

Flashing fastener >9.9 40 SF Poor

Metal Draft Tube

Gray Penstock Gallery >9.9 10,000 SF Poor

Metal Access Hatch to Draft

Tube- Gray Penstock Gallery 3.2 16 SF Poor

5.4 Lead-Based Paint General Recommendations

Lead is a hazardous substance and its condition, handling and disposal are regulated by Federal, State and local agencies. Lead-containing materials, Lead-based paint, and Lead-Containing Paint generally do not pose a health risk unless the material is disturbed or sufficiently deteriorated to produce dust, which may become airborne and inhaled or ingested. Future site maintenance activities, including surface preparation and painting, may involve practices that could disturb lead-containing materials. The following paragraphs provide a general overview of applicable regulatory standards that relate to the management and/or disposal of lead-based paint:

Asbestos and Lead-Based Paint Survey Report Page 13

• The Federal Occupational Safety and Health (OSHA) 29 CFR 1910.1025 and

1926.62 (lead in construction) do not provide a definition for “lead-based paint”.

Rather, the Lead Construction Standard provides a Permissible Exposure Limit (PEL) for worker exposure to airborne lead particles of 50 micrograms per cubic meter of air (50 µg/m3 for an 8-hour time-weighted average). All employees (workers) and supervisors, who are engaged in lead-related construction activities and shown to be exposed to lead at or above the Permissible Exposure Limit, shall be trained by state-accredited training providers and certified by the Environmental Protection Agency. The OSHA Lead in Construction Standard states that “negative” readings i.e. those below the HUD/EPA definition of what constitutes LBP (1.0 mg/cm2), “DO NOT” relieve contractors from performing exposure assessments (personal exposure monitoring) on their employees per the OSHA Lead Standard, and should not be interpreted as lead is not present.

Although a reading may indicate “negative” result or lead concentration, concentrations of airborne lead may still exceed the OSHA Action Level or the OSHA Permissible Exposure Limit (PEL) depending on the work activity.

• Future site maintenance activities, including repair, surface preparation and painting, sand/shot blasting, and sanding, in areas where lead-based paint has been identified may result in the liberation of lead at concentrations in excess of the OSHA PEL. TRC recommends the removal and/or stabilization of building materials during planned renovation. Lead-based painted materials should only be removed, handled or stabilized by lead trained personnel in accordance with all applicable federal, state, and local regulations. These requirements include, but are not limited to, the following: Exposure Assessments; Methods of Compliance including work practices, administrative, and engineering controls;

Respiratory Protection; Protective Clothing and Equipment; Housekeeping;

Hygiene Facilities; Medical Surveillance; and Employee Information and Training. The waste materials generated must be segregated accordingly and must be subjected to waste characterization testing and disposed of according to applicable regulations.

• Lead containing waste must be disposed of in accordance with all applicable federal, state, county or local regulations and guidelines. It is the sole responsibility of the Contractor to assure compliance with all laws and regulations relating to the disposal. The abatement contractor should comply with the requirements of the Resource Conservation and Recovery Act (RCRA).

Waste materials shall be segregated into separate waste streams (i.e. paint chips, personal protective equipment, plastic, etc.) and placed into labeled, leak-tight containers. Wastewater from the washing facilities should be captured, filtered, and sampled for lead content prior to disposal into the sanitary sewer system.

Additional details regarding waste characterization sampling and analysis are provided in the following section.

5.5 Waste Characterization Recommendations

Wastes that are generated during demolition and/or building maintenance activities may contain concentrations of lead that would render the waste material as a hazardous waste. In order to determine whether the wastes are to be classified as non-hazardous

Asbestos and Lead-Based Paint Survey Report Page 14 solid or hazardous waste as defined by the RCRA, a Toxic Characterization Leaching Procedure (TCLP) test must be performed. If any of the waste characterization test samples are at or above the 5.0 mg/liter threshold criteria, the Contractor shall dispose of the waste material as hazardous waste.

The contractor should check in advance with the intended landfill to inquire about the testing requirements of that landfill. Testing for other hazards may be required.

Segregation of waste materials and representative characterization analysis for the disposal of wastes as provided herein shall be the responsibility and be required of the Contractor.

Asbestos and Lead-Based Paint Survey Report Page 15

6.0 DISCLAIMER

The content presented in this report is based on data collected during the site inspection and survey, review of pertinent regulations, requirements, guidelines and commonly followed industry standards, and information provided (if any) by the property owner, their clients, agents, and representatives.

The work has been conducted in an objective and unbiased manner and in accordance with generally accepted professional practice for this type of work. TRC believes the data and analysis to be accurate and relevant, but cannot accept responsibility for the accuracy or completeness of available documentation or possible withholding of information of other parties. Structures or components thereof surveyed may contain hidden surfaces or materials requiring destructive access to inspect and/or sample. It is possible that additional materials could be discovered during destructive or demolition activities. In the event additional materials (not identified herein) are discovered during such activities, additional investigation and sampling may be necessary.

This asbestos survey and lead-based paint inspection report is designed to aid the property owner, architect, construction manager, general contractor, and asbestos or LBP abatement contractor in locating ACM and/or LBP . This report is not intended for, and may not be utilized as, a bidding document or as an abatement project specification document.

Asbestos and Lead-Based Paint Survey Report Page 16

7.0 SIGNATORY

This asbestos and lead-based paint survey activities and report of the findings were provided by TRC, was conducted by a licensed professional, experienced in the inspection and survey for asbestos containing materials and lead-based paint in building structures and associated components thereof. If there are any questions concerning information contained in this report, you may contact one of the undersigned in our Irvine, California office, phone # 949.727.9336.

Sincerely, TRC Environmental Corporation

Sam Seneviratne, CAC, REA Douglas W. Coburn, CAC, REA Project Manager Senior Project Manager AHERA Building Inspector Certification # 211-206-BIR Exp: December 8, 2012

Appendix A

Bulk Asbestos Sample Laboratory Analytical Report

And Chain of Custody

40714 USIBWC (2).doc

TRC LABORATORY ASBESTOS ANALYTICAL ACCREDITATIONS

NVLAP Lab Code 101424-0 AIHA #100122 CT #PH-0426 ME LA-0075, LB-0071 MA #AA000052 NY #10980 WV# LT000356 RI #AAL-007C3 TX #300354 VT #AL014538 VA #3333 000283 AZ #A20944 HI #L-09-004 NJ #CT004 CA #10275CA

Industrial Hygiene Laboratory

21 Griffin Road North Windsor, CT 06095

(860) 298-6308

BULK ASBESTOS ANALYSIS REPORT

CLIENT: U.S. International Boundary & Water Company

Site: Amistad Power Plant, 670 Texas Spur 349, Del Rio, TX Lab Log #: 40714 Project #: 192271.0000.0000 Date Received: 05/03/12 Date Analyzed: 05/03/12

RESULTS

Sample No. Color Homogeneous Multi- Layered

Layer No. Other Matrix Mat’ls Asbestos

% Asbestos Type

74 White Yes No -- 90% synthetic ND None

75 Black Yes No -- -- 90% Chrysotile

Reporting limit- asbestos present at 1% ND - asbestos was not detected Trace- asbestos was observed at level of less than 1%

Note: Polarized-light microscopy is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials.

In those cases, negative results must be confirmed by quantitative transmission electron microscopy.

The Laboratory at TRC follows the EPA's Interim Method for the Determination of Asbestos in Bulk Insulation (1982), and the EPA recommended Method for the Determination of Asbestos in Bulk Building Materials (EPA/600/R-93/116), July 1993, R.L. Perkins and B.W. Harvey which utilizes polarized light microscopy (PLM). Our analysts have completed an accredited course in asbestos identification. TRC's Laboratory is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP), for Bulk Asbestos Fiber Analysis, NVLAP Code 18/A01, effective through June 30, 2012. TRC is an American Industrial Hygiene Association (AIHA) accredited lab for PLM effective through October 1, 2012. Asbestos content is determined by visual estimate unless otherwise indicated. Quality Control is performed in-house on at least 10% of samples and the QC data related to the samples is available upon written request from the client.

This report shall not be reproduced, except in full, without the written approval of TRC. This report must not be used by the client to claim product endorsement by NVLAP or any agency of the U.S. Government. This report relates only to the items tested.

Analyzed by __________________________________ Kathleen Williamson, Laboratory Manager

Reviewed by __________________________________ Kathleen Williamson, Laboratory Manager or other approved signatory

Date Issued: ____________________

Appendix B

Lead-Based Paint XRF Field Data Sheets

Appendix C

Sample Location Drawings

IBWCIBWCIBWC - AmistadAmistadAmistad PowerPowerPower PlantPlantPlant Floor 1

Asbestos Sample Location Diagram

IBWC - Amistad Power Plant Floor 2

Asbestos Sample Location Diagram

72 82 83

Floor 3

Asbestos Sample Location Diagram

21, 27, 73, 74, 75, 76, 77, 78, 79, 80, 81

- ACM Vinyl Sheet Flooring

IBWCIBWCIBWC - A i dA i t dAmistad PPPower PlPl tPlant Floor 4

Asbestos Sample Location Diagram

7, 666666

8, 9,999999

13, 1616161616161611141414414, 15, 18188181818

19,,,, 20, 25, 26, 31, 32, 333333333333 ,, 363666663

400040404 , 4141414141,, 4444422222222,,, 4444555

- ACM Vinyl Sheet Flooring

Roof

Asbestos Sample Location Diagram

4644 , 474747444 , 4844444 , 49, 50555 , 515 52

55, 5656, 5777, 60006000

63 64 65

6666666666

KSwindle Rectangle

KSwindle Text Box IBWC - Amistad Power Plant Warehouse Asbestos Sample Location Diagram

KSwindle Line

KSwindle Text Box North

KSwindle Callout

KSwindle Callout

KSwindle Callout

KSwindle Callout 89, 92

KSwindle Callout 90, 93

KSwindle Callout 91, 94

KSwindle Callout 97, 100

KSwindle Callout 95, 98

KSwindle Callout 96, 99

KSwindle Callout 101, 104

KSwindle Callout 102, 105

KSwindle Callout 103, 106

KSwindle Callout 107, 108, 109

KSwindle Callout

KSwindle Callout

KSwindle Callout

KSwindle Text Box Mezzanine Storage

IBWCIBWCIBWC --- AmistadAmistadAmistad PowerPowerPower PlantPlantPlant Floor 1

Lead Sample Location Diagram

137137 138138 139139 140140

1444146

147148149

155156 157158

160161162 163164

165 166

Floor 2

Lead Sample Location Diagram

115116

117118

119120 121122

124 125 126

127128

Floor 3

Lead Sample Location Diagram

88 89

97777 98 99

1010101010111 0 101 102

103103

105 106

107 108109 110 111

IBWCIBWCIBWC - A i t dA i t dAmistad PPPower Pl tPl tPlant Floor 4

Lead Sample Location Diagram

7 89 5

13 14 15 16, 17 18 19 20

2222222222

26272222288

300031 33322222 33333

33333334444444444444444

3553333

38888888

399999939393333340

45454444444

466664

50050555

515151115151

535455555555555555656577 55555555558

4040404444444444040

5999959999

777777776666666

79 80818283 84

Roof

Lead Sample Location Diagram

Generator Bay Transverse Section Plan

Lead Sample Location Diagram

Crane

66, 68, 70, IBBWCW - Amistad

Warehouse

Lead Sample Location Diagram

North

Mezzanine Storage

173 174 175

177, 179, Appendix D

Photographs of Positive Materials

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

1. ACM-Vinyl Sheet Flooring Blue, Green and White Square Pattern 2. ACM-Roof Parapet Wall Metal Flashing Caulking

3. ACM-Flange Gasket-1st Floor Chemical Storage Tank Side Flange 4. ACM-Gasket Materials-3rd Floor Mezzanine Parts Storage Area

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

5. Assumed ACM-Sink Countertop-4th, Floor Battery Room 6. LBP- Gantry Crane Frame and Platform-Exterior Southwest

7. LBP Elevator Door frame 8. LBP-Powerhouse Crane Frame, 20 and 125 Ton Hooks

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

9. LBP-Cable Tray and Support 10. LBP-Flammable Storage Cabinet

11. LBP-2 ton Crane Boom- 12. LBP-Glazed Metal Custodian Sink

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

13. LBP-Handrail-3rd, Floor Parts Storage 14. LBP-Concrete Floor stripping

15. LBP-Elevator Gate 1st, thru 4th, floors 16. LBP-Hitachi Tool Rack-Generator Bay

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

17. LBP-Step and Riser-Stairs to Turbine Pit 18. LBP-Wall-Inside Turbine Pit

19. LBP-Servo Linkage- Inside Turbine Pit 20. LBP-Metal Shim-Upper Roof Parapet wall flashing fastener

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

21. Assumed ACM & LBP-Slider Door-1st Floor Chemical Storage area

22. LBP-Clean and Dirty Oil Storage Tanks Chemical Storage area

23. LBP-Spiral Case Access 1st Floor Piping Gallery 24. LBP-Stair Handrail to Penstock Gallery

US IBWC-Amistad Power Plant, Del Rio, TX TRC Project Number 192271 Site Visit Date April 10 & 11, 2012

25. LBP-Piping-Penstock Drain/Fill #2 26. LBP-Draft Tube And Access Hatch-Penstock Gallery

Appendix E

Inspector Certifications

Lead-Related Constructbn

Certif'rcate

Ccrtific*e Tvp

Exfiiration Date state of carifsin*r Dcpntment of Public FteaFh t'//'-

State of California Division of Occupational Safety and Health

Certified Site Surveillance Technician

Hector E Gonzalez Name

Certification No. 064072

Expires on 09120112

This certification was issued by the Division of

Occupational Safety and Health as authorized by

Sections 7180 et seq. of the Business and

Professions Code, sjgffiTffiffifran ffix

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