B08_Attch_4_HAZMAT_Rpt_1-10-23.pdf

Pre-Demolition Regulated Building Material Inspection

Little Bighorn Battlefield National Monument Visitor Center Facility Replacement

Battlefield Tour Road

Crow Agency, Montana

December 22, 2022, Revised January 10, 2023

Terracon Project No. 26227062

Prepared for:

AJC Architects, PC Salt Lake City, Utah

Prepared by:

Terracon Consultants, Inc.

Billings, Montana

Pre-Demolition RBM Inspection LIBI Visitor Center Replacement Crow Agency, Montana December 22, 2022, Revised January 10, 2023 Terracon Project No. 26227062

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

1.1 Project Objective

1.2 Asbestos Inspection

1.3 Lead Paint Inspection

1.4 Hazardous Building Materials Inventory

BUILDING INFORMATION

ASBESTOS

3.1 Inspection

Visual Assessment Physical Assessment Sample Collection Sample Analysis

3.2 Regulatory Overview

3.3 Findings and Recommendations

LEAD PAINT INSPECTION

4.1 Visual Assessment

4.2 Lead Paint Sampling and Laboratory Analysis

4.3 Lead Regulatory Overview

4.4 Lead Findings and Recommendations

HAZARDOUS BUILDING MATERIALS INVENTORY

5.1 HBM Regulatory Overview

5.2 HBM Findings and Recommendations

Batteries Mercury Stored Paints, Solvents, Chemicals, Pesticides, and Herbicides PCB-Containing Equipment Chlorofluorocarbons (CFCs) Tritium Exit Signs Smoke Detectors Compressed Gases

LIMITATIONS/GENERAL COMMENTS

APPENDIX A ASESTOS INSPECTION SAMPLE SUMMARY

APPENDIX B LEAD INSPECTION SAMPLE SUMMARY

APPENDIX C ANALYTICAL LABORATORY DATA AND CHAIN-OF-CUSTODY

APPENDIX D DRAWINGS

APPENDIX E PHOTO LOG

APPENDIX F ACCREDITATIONS

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EXECUTIVE SUMMARY

This Pre-Demolition Regulated Building Materials (RBM) inspection was conducted in accordance with Terracon Proposal No. P26227062 and included an asbestos inspection, lead paint inspection, and hazardous building materials (HBM) inventory. The asbestos inspection was conducted in accordance with USEPA 40 CFR Part 61 NESHAP, Subpart M and State of Montana ARM

17.74.354. The lead paint inspection was conducted to provide information for compliance with OSHA 29 CFR 1926.62 Lead. The HBM inventory was conducted to provide information for compliance with USEPA RCRA and TSCA regulations. The survey was conducted on October 11, 2022, by Mr. Ethan J. Perro, Ms. Kristina S. Miller, and Mr. Kyle A. Groves, and on December 6, 2022, by Ms. Kristina S. Miller, Montana-accredited asbestos inspectors. The inspection included the interior and exterior of the building.

Conclusions

Asbestos Terracon collected 77 bulk samples from 25 homogeneous areas of suspect asbestos containing materials (ACM). The following materials were found to be ACM by laboratory analysis or were assumed to be ACM:

Off-White Joint Compound (Drywall System) Grey/Beige Pipe Insulation Brown 9x9 Floor Tile Cream 12x12 Floor Tile (blue streaks) and mastic

Cream 12x12 Floor Tile (yellow and red streaks) and mastic Off-White Joint Compound (behind brown cove base)

The following material containing 1% asbestos or less was identified in the project area of the subject buildings as a result of laboratory analysis:

Tan Mastic associated w/ Grey Cove Base

Lead Paint Terracon collected eight bulk paint samples from four homogeneous areas. Detectable quantities of lead were identified in the following painted building components as a result of laboratory analysis:

Yellow Paint, Building Exterior Bronze Paint, Exterior Window Frame (Stucco) Bronze Paint, Exterior Window Frame (Stucco)

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Hazardous Building Materials Per the proposal Scope of Services, no sampling of HBMs was performed. The following suspect hazardous building materials were observed and inventoried:

Batteries Mercury-containing light tubes PCB light ballasts CFC-containing equipment

A/C unit Mercury-containing lamps Thermostat Fire extinguisher

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Recommendations

Friable ACM and nonfriable ACM that will become friable during renovation or demolition must be removed prior to renovation or demolition activities by a qualified asbestos abatement contractor in accordance with applicable federal and state regulations. Materials containing 1% asbestos or less are not regulated by NESHAP or MDEQ however OSHA regulates any detectable asbestos and disturbance must comply with OSHA 29 CFR 1926.1101 Asbestos.

Compliance with OSHA 29 CFR 1926.62 Lead is required for employees that may be occupationally exposed to lead and waste determination for disposal of lead waste must comply with USEPA RCRA.

Universal wastes should be recycled or properly disposed of under USEPA RCRA and certain HBMs must be properly disposed of under USEPA TSCA. Other waste concerns identified in the inventory (e.g., fire extinguishers) should be recycled or properly disposed of as prescribed by law or industry standard.

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PRE-DEMOLITION REGULATED BUILDING MATERIALS INSPECTION

Little Bighorn Battlefield National Monument

Visitor Center Facility Replacement Crow Agency, Montana Terracon Project No. 26227062

December 22, 2022, Revised January 10, 2023

INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a pre-demolition regulated building materials (RBM) inspection of the Little Bighorn Battlefield National Monument (LIBI) Visitor Center Facility located on Battlefield Tour Road, Crow Agency, Montana, which included the pre-demolition asbestos inspection, a lead paint inspection, and an inventory of HBM. The inspection was conducted on October 11, 2022, and December 6, 2022, by State of Montana-certified asbestos inspectors in general accordance with Terracon Proposal No. P26227062

1.1 Project Objective

Terracon understands the asbestos inspection, lead paint inspection, and HBM inventory were requested by AJC Architects, PC to meet informational needs prior to the planned demolition of the existing LIBI Visitor Center.

1.2 Asbestos Inspection

The pre-demolition asbestos inspection was conducted in accordance with standards of the United States Environmental Protection Agency (USEPA) including 40 Code of Federal Regulations (CFR) Part 763-Asbestos, Subpart E-Asbestos-Containing Materials in Schools [40 CFR 763; known as the Asbestos Hazard Emergency Response Act (AHERA) and USEPA 40 CFR Part 61-National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M- Asbestos; Montana Department of Environmental Quality (MDEQ) Administrative Rules of Montana (ARM) Title 17 Chapter 74, Sub-chapter 3, Rule 17.74.354, Inspection Requirements for Demolition and Renovation Activities; the United States Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1101 Asbestos standard for construction; and other applicable industry standards.

The pre-demolition asbestos inspection included the exterior and interior of the building, including the basement and roof.

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1.3 Lead Paint Inspection

The lead paint (LP) inspection was performed to satisfy the requirements of OSHA’s construction standard for lead (29 CFR 1926.62), which defines lead-containing paint as paint containing any detectable lead. The sampling conducted for this project was not intended to meet the requirements of the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP) Hazards in Housing or the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination.

1.4 Hazardous Building Materials Inventory

The hazardous building materials (HBM) inventory included universal wastes and other hazardous building materials, such as polychlorinated biphenyls (PCB) in light ballasts and transformers; chlorofluorocarbons (CFCs); smoke/heat detectors containing radioactive material;

paints, solvents, chemicals, herbicides, and compressed gas. HBMs in the building are required to be properly disposed of or recycled prior to demolition in accordance with USEPA Resource Conservation and Recovery Act (RCRA) and USEPA Toxic Substances Control Act (TSCA).

BUILDING INFORMATION

The LIBI Visitor Center on Battlefield Tour Road, Crow Agency, Montana was built in 1952 and is an approximately 7,600-square-foot (SF) single-story structure with a basement.

The building consisted of a concrete foundation with concrete masonry unit (CMU) block walls and a tar and gravel roof supported by steel columns, beams, and trusses. The exterior façade was finished with brick veneer and stucco. The interior floors were bare concrete or finished with carpeting or ceramic tiles. The interior walls were bare CMU block or finished with drywall. The interior ceilings were bare steel deck or finished with lay-in suspended ceiling panels, adhered-on ceiling tiles, and/or drywall. Heating, ventilating, and air conditioning (HVAC) was provided by roof-mounted, forced-air, air conditioning units and distributed by ductwork and vents.

ASBESTOS

3.1 Inspection

The asbestos inspection was conducted on October 11, 2022, by Mr. Ethan J. Perro, Ms. Kristina S. Miller, and Mr. Kyle A. Groves, and December 6, 2022, by Ms. Kristina S. Miller, State of Montana-certified asbestos building inspectors. Copies of the asbestos inspectors’ accreditations are attached in Appendix F. The inspection was conducted in general accordance with the sample collection protocols established in USEPA regulation 40 CFR 763.

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A material is considered to be ACM if the asbestos content is greater than 1%. USEPA and Montana Department of Environmental Quality (MDEQ) define friable materials as those materials that can be crumbled or reduced to powder by hand pressure, whereas nonfriable materials cannot. Friable materials are more likely to release asbestos fibers into the air, especially during renovation and demolition of the building, and are therefore more stringently regulated.

The scope of the asbestos inspection was to identify ACMs and included the following steps:

Inspect building to identify areas of suspect homogeneous and non-homogeneous

ACM

Determine friability by touching suspect ACM Develop a sampling plan for each material based on the homogeneous area, material type, friability, accessibility and material locations Collect samples and submit for laboratory analysis by polarized light microscopy

(PLM).

Record sampling information on sample log and photograph suspect ACM Document sample locations on drawings

Drawings identifying sample locations are presented in Appendix D and the photos of suspect ACM are presented in Appendix E.

A summary of inspection activities is provided below.

Visual Assessment

Inspection activities began with visual observation of the interior and exterior of the building to identify homogeneous areas of suspect ACM. A homogeneous area consists of a building material that appears similar throughout in terms of color, texture and date of application. Interior assessment was conducted throughout visually accessible areas of the building. The exterior inspection included an assessment of the exterior walls and roof.

The following building systems were inspected to identify suspected homogeneous materials:

Structural systems Flooring systems Wall/partition systems Ceiling systems

Thermal/mechanical systems Electrical systems Miscellaneous systems

Materials that were inspected, but not suspected to contain asbestos, are not included in this report. Such materials include concrete, stone, ceramic tiles, carpet, fiberglass, mineral/rock wool, plastic, glass, rubber, and wood products.

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Each material was classified into one of three types of material.

Surfacing material refers to a wide range of troweled-on or spray-applied materials typically used for acoustical or fire-retardant purposes. Examples include spray-applied fire retardants and acoustical texture ceilings.

Thermal system insulation (TSI) refers to insulation that is applied to heating or mechanical system components. Examples include pipe, tank, and boiler insulation.

Miscellaneous material refers to other materials that do not fall into one of the above categories. Examples include floor tile, adhesives, and ceiling tiles.

Terracon identified 25 homogeneous areas of suspect ACM within the building.

Physical Assessment

Once the material classification was determined, the inspector determined the friability of the material. The USEPA distinguishes between friable and nonfriable forms of ACMs. Friable materials can be crumbled or reduced to powder by hand pressure, whereas nonfriable materials cannot. Friable materials are more likely to release fibers into the air, especially during renovation and demolition activities. Therefore, the distinction between friable and nonfriable materials is important.

The following bulk sampling protocol for friable and Category I and II nonfriable materials was used to determine the number of samples to be collected for friable and nonfriable materials deemed potential regulated ACM (RACM) (nonfriable materials with potential to be rendered friable during normal demolition).

Table #1 - Bulk Sampling Strategy

Material Homogeneous Area

(SF)

Units Minimum

Number of Samples

Friable surfacing Less than 1,000 1,000 to 5,000

More than 5,000

SF

Nonfriable surfacing Not applicable SF 3

Friable and nonfriable thermal system insulation Not applicable LF / SF / EA 3

Friable and nonfriable miscellaneous materials Not applicable LF / SF / EA 3

Sample Collection

As part of the inspection, bulk samples of each suspect material were collected by accredited asbestos inspectors in a random and representative manner as determined by each inspector.

Samples were collected by taking a core sample that included all layers within the suspect

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Each type of suspect building material was assigned a unique identification code. Each sample was identified by project number, homogenous area (HA) number, and the sample number. For example, if drywall system is sampled, the sample nomenclature starts with the project number indicator 062, then the HA number 01 (the first type of material sampled), followed by the sample number 1 (the first sample collected). The completed nomenclature appears as 062-01-1 (followed by subsequent samples, 062-01-2, 062-01-3, etc.).

Terracon collected 77 bulk samples from 25 homogeneous areas of suspect ACM in the building.

Sample Analysis

The inspectors shipped the samples along with a completed chain-of-custody to the laboratory.

The laboratory then arranged the samples in numerical order. If a discrepancy between the samples exists, this is noted and initialed on the log sheet. The laboratory signed a copy of the chain-of-custody to acknowledge receipt. The inspector retained the signed copy for evidentiary purposes. Further, the laboratory assigned a laboratory number to each sample received. The laboratory labeled both the analytical report and the sample container with this laboratory number for cross-reference purposes.

The bulk samples were submitted under chain of custody (COC) to International Asbestos Testing Laboratories (iATL) of Mount Laurel, New Jersey for analysis by polarized light microscopy (PLM) with dispersion staining techniques in accordance with USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93/116). The asbestos content, if present, was determined by microscopic visual estimation. iATL is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP), Accreditation No. 101165-0. The laboratory analytical report and COC are provided in Appendix C. A sample location diagram is provided in Appendix D. Photographic documentation is provided in Appendix E.

Analysis of the bulk samples was performed using PLM using procedures developed by McCrone Research Institute and in compliance with the guidelines established by the USEPA (EPA- 600/R93/116, July 1993 and M4-82-020, Dec. 1982) to determine asbestos type and content. The PLM samples are reported as percent asbestos by area. Percent asbestos for separate layers and total for the sample are delineated in the laboratory report. Unused portions of samples are archived for six months unless the client requests special handling.

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As of November 20, 1990, the USEPA NESHAP requires that samples of friable material with less than 10 percent asbestos be analyzed by the point-count procedure or must be assumed positive for asbestos.

Laboratory analytical reports and chain-of-custodies are presented in Appendix C.

3.2 Regulatory Overview

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Friable ACMs are considered regulated asbestos-containing material (RACM).

The asbestos NESHAP regulation classifies ACM as RACM, Category I nonfriable ACM or Category II nonfriable ACM. RACM includes all friable ACMs, along with Category I and Category II nonfriable ACMs that have become friable; will be or have been subjected to sanding, grinding, cutting or abrading; or have a high probability of becoming or have become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I nonfriable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II nonfriable ACM are all other nonfriable materials other than Category I nonfriable ACM that contain more than 1% asbestos. Category II nonfriable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

The MDEQ incorporates the asbestos NESHAP by reference in ARM Title 17, Chapter 74. The owner or operator must provide MDEQ with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than to 160 square feet, 260 linear feet or a 35 cubic feet of volume. The owner or operator must provide MDEQ with written notification at least 5 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts involving more than 10 square feet but less than 160 square feet, more than 3 linear feet but less than 260 linear feet linear feet or more than 3 cubic feet but less than 35 cubic feet of volume.

The OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below the permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) or 1.0 f/cc as a 30-minute excursion limit. The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when

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3.3 Findings and Recommendations

The following materials were identified as ACM as a result of laboratory analysis:

HA No. Material Description Homogenous Area Location % and Type Asbestos

Off-White Joint Compound associated with Drywall Wall Curator’s Office, southeast wall

2.6% Chrysotile

Off-White Joint Compound behind

Brown Cove Base 1.2% Chrysotile

05 Grey Pipe Insulation Archive southeast 10% Chrysotile Trace Amosite

13 Brown 9x9 Floor Tile WNPA southwest corner

1.7% Chrysotile

1.8% Chrysotile

2.1% Chrysotile

Cream 12x12 Floor Tile (yellow and red streaks) w/ Mastic

West of stairs 2.4% Chrysotile

Center of stairs 2.6% Chrysotile

East side of stairs 3.0% Chrysotile

Cream 12x12 Floor Tile (blue streaks) w/ Mastic

NE corner of bathroom 3.1% Chrysotile

SE corner of bathroom 2.6% Chrysotile

NW corner of bathroom 2.8% Chrysotile

Drywall Taping Mud associated with Drywall Wall East center Museum 1.3% Chrysotile

The following material was identified as containing 1% asbestos or less as the result of laboratory analysis:

HA No. Material Description Homogenous Area Location % and Type Asbestos

18 Grey Cove Base SE Corner of Bathroom 0.75% Chrysotile

Materials that contain 1% or less asbestos through point count analysis are not considered RACM and are not subject to MDEQ or NESHAP regulations. However, OSHA regulates any detectable amount of asbestos and compliance with all applicable OSHA regulations regarding occupational exposure during renovation or demolition activities is mandatory. OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities be protected from asbestos fibers in excess of the PEL of 0.1 f/cc of air. Contractors must comply with applicable provisions of OSHA 29 CFR 1926.1101 during renovation or demolition activities.

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It should be noted that the inspectors were not able to access the room labeled “Living History” during the initial mobilization during which they collected the LBP samples and summarized the hazardous materials, or during the remobilization to collect the asbestos samples. However, based on the location of this room, the visual observations made of the surrounding rooms, and the samples collected, the materials within his room would likely not be any different than those in the surrounding rooms. Building materials discovered in rooms not accessed or elsewhere that have not been sampled and analyzed, must be assumed to contain asbestos and treated as such unless, prior to disturbance, sampling by an AHERA-accredited and State of Montana-certified asbestos inspector and analysis by an NVLAP-accredited laboratory, in accordance with local, state, and federal regulations, determines otherwise

A summary of the classification, condition and approximate quantity of identified ACM is presented in Appendix A. Laboratory analytical reports are included in Appendix C.

LEAD PAINT INSPECTION

The lead paint inspection was conducted on October 11, 2022, by Mr. Ethan J. Perro, Ms. Kristina S. Miller, and Mr. Kyle A. Groves. The LP inspection sampling was performed in general accordance with the procedures prescribed in the USEPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The sampling conducted for this project was not intended to meet the requirements of the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP) Hazards in Housing and the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination.

4.1 Visual Assessment

Sampling activities began with visual observation of areas the building to identify unique combinations of paint most prevalent in or on the building. A unique combination of paint consists of paint that is applied to a building material and has similar color, substrate and component. The observation was conducted throughout the visually accessible interior and exterior areas of the building. Additional paint combinations may be in concealed areas or other spaces not accessed.

A physical assessment of each unique combination of paint was conducted to assess the condition of the paint. Paint was visually assessed and assigned a condition of intact, top layer failure, multi-layer failure and substrate failure.

4.2 Lead Paint Sampling and Laboratory Analysis

Based on Terracon’s visual observations, chip samples were collected from painted interior drywall walls, exterior CMU block walls, and exterior window trim. Paint chip samples included all layers of paint with care taken to minimize collection of substrate. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. This number (along

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The inspector shipped the samples along with a completed chain-of-custody document to the laboratory. The laboratory then arranged the samples in numerical order. If a discrepancy between the samples exists, this is noted and initialed on the log sheet. The laboratory signed a copy of the chain-of-custody to acknowledge receipt. The inspector retained the signed copy for evidentiary purposes. Further, the laboratory assigned a laboratory number to each sample received. The laboratory labeled both the analytical report and the sample container with this laboratory number for cross-reference purposes.

Samples of suspect LP were delivered under proper chain-of-custody to International Asbestos Testing Laboratories (iATL), Inc. (EMSL) of Mount Laurel, New Jersey for analysis using Atomic Absorption Spectrophotometry (AAS)/Atomic Emission Spectroscopy-Inductively Coupled Plasma (AES-ICP) USEPA Method SW846 3050B/7000B. iATL is accredited under the American Industrial Hygiene Association (AIHA) Environmental Lead Laboratory Accreditation Program (ELLAP) program (Lab ID 100188). Copies of the analytical report and chain-of-custody form are provided in Appendix C.

4.3 Lead Regulatory Overview

The OSHA lead standard for construction (29 CFR 1926.62) regulates workplace exposure to lead. OSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Personnel performing renovation or demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure.

Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than the PEL of 50 micrograms per cubic meter ( g/m3) averaged over an eight-hour period without adequate protection. The OSHA standard also establishes an action level of 30 g/m3, which if exceeded, triggers requirements for recurrent exposure monitoring, medical surveillance program, and training about lead. OSHA does not define the amount of lead in paint that constitutes lead containing paint. An exposure assessment per trigger task should be conducted to determine if actual airborne levels are below the required OSHA action and permissible levels.

The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials. Specific

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4.4 Lead Findings and Recommendations

Detectable quantities of lead were identified as a result of laboratory analysis:

SAMPLE

NUMBER

LOCATION COMPONENT SUBSTRATE COLOR CONDITION

RESULT

(% by wt.)

062-LP-6

Exterior, west-southwest side of building

Wall Paint Yellow Intact 0.0058

062-LP-7

Exterior window frame (stucco), north side of building, west side of entrance

Wall Paint Bronze Intact 0.0090

062-LP-8

Exterior window frame (stucco), west-southwest side of building

Wall Paint Bronze Intact 0.0063

Paints containing any detectable lead concentrations are regulated by OSHA. Disposal of lead-contaminated waste is regulated by USEPA.

A summary of the lead paint sample locations and analysis is presented in Appendix B. Laboratory analytical reports are included in Appendix C.

HAZARDOUS BUILDING MATERIALS INVENTORY

The hazardous building materials (HBM) inventory was conducted on October 11, 2022, by Mr.

Ethan J. Perro, Ms. Kristina S. Miller, and Mr. Kyle A. Groves. The HBM inventory was performed to provide information for hazardous materials covered under the USEPA Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA).

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5.1 HBM Regulatory Overview

Universal Waste

USEPA’s universal waste regulations are found in 40 CFR 273 Universal Wastes. The State of Montana has adopted 40 CFR 273 and does not recognize universal wastes other than those set forth by the USEPA. The universal waste regulation streamlines the hazardous waste management standards for certain categories of hazardous waste that are commonly generated by a wide variety of establishments. The universal waste regulations apply to four types of universal waste:

Batteries (40 CFR 273.2) Pesticides (40 CFR 273.3) Mercury-containing equipment (40 CFR 273.4) Mercury lamps (40 CFR 273.5)

The standard helps the promote the collection and recycling of universal waste, ease the regulatory burden on retail stores and other generators that wish to collect these wastes, ease the regulatory burden on transporters of these wastes, and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

Four types of regulated participants are defined in the universal waste system: small quantity handlers, large quantity handlers, universal waste transporters, and universal waste destination facilities.

In general, materials managed as universal waste can be stored for a year and are not required to be shipped with a manifest. In addition, universal waste does not need to be counted for the purpose of determining whether the generator is conditionally exempt small quantity, small quantity, or large quantity. The universal waste regulations do require that the materials be managed in a way to prevent releases to the environment and tailors those requirements to each type of universal waste (for small quantity handlers and for large quantity handlers). Finally, the standards also include labeling, a requirement to respond to releases, and transport to a facility that is permitted or otherwise designated for receiving hazardous waste, like a recycler.

Polychlorinated Biphenyls

USEPA regulation 40 CFR 761, Subpart R regulates disposal of PCB bulk product waste under section 761.62. Small ballasts containing less than 50 parts per million (ppm) PCBs may be disposed of at a solid waste landfill. However, the effort to determine the PCB content in ballasts is burdensome, and the USEPA recommends that all PCB ballasts be disposed of at a TSCA-approved incinerator facility. It should be noted that ballasts manufactured after 1978 do not typically contain

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PCBs and “No PCBs” will be stated on labels affixed to these ballasts. If no indication is made on the ballast label, the ballast should be assumed to contain PCBs.

The PCB inspection consisted of locating suspect PCB-containing equipment, such as electrical transformers, large electrical capacitors and electrical light ballasts.

Chlorofluorocarbons (CFC)

USEPA regulations 40 CFR 82, Subpart F under Section 608 of the Clean Air Act include requirements for the safe disposal of refrigeration and air-conditioning equipment. These requirements are designed to minimize refrigerant emissions when these appliances are disposed. CFCs are not considered a hazardous waste if reclaimed.

Air conditioning units and other refrigeration devices will not be accepted at a solid waste landfill unless regulated refrigerants have been properly evacuated and recovered from the equipment.

Smoke/Heat Detectors

Smoke/heat detectors can be one of two kinds: photoelectric or ionizing. The ionizing variety contains a small amount of radioactive material (americium-241).

Specific requirements do not exist for the disposal of smoke/heat detection devices. USEPA’s Household Hazardous Waste program encourages waste reduction and minimization, but does not exert any special disposal requirements. Many manufacturers encourage return of the devices to their facilities for salvage and recycling of components. The battery or batteries should be removed from the unit(s) prior to disposal.

Tritium Exit Signs

Exit signs that glow in the dark (without need of an external energy source such as electricity) often contain a radioactive gas called tritium. Tritium exit signs pose little or no threat to public health and safety and do not constitute a security risk. Tritium is regulated by the United States Nuclear Regulatory Commission (USNRC) 10 CFR 31.5.

USNRC requires proper accounting and disposal of all radioactive materials. Proper handling and accounting are important, because a damaged or broken sign could cause mild radioactive contamination of the immediate vicinity, requiring a potentially expensive clean up.

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5.2 HBM Findings and Recommendations

Hazardous building materials observed during inventory included the following:

Universal Waste

Batteries

Emergency Lamps

Batteries

Other

Liquid Mercury- Containing Equipment

Mercury-Vapor Containing

Lamps/Tubes Pesticides

3 12 None Observed 166 0

Hazardous Building Materials

PCB-containing Light Ballasts

PCB-containing Transformers

Chemicals, Herbicides, Solvents

77 None Observed None Observed

Other Concerns

Compressed Gasses

(Fire Extinguishers and Suppression

System(s))

Smoke/Heat Detectors

CFC-Containing Equipment Stored Paint Tritium Signs

5 14 7 None Observed None Observed

The HBM inventory was limited to visual observations of readily accessible areas and providing an inventory of recognizable and identified hazardous materials documenting the presence, location, and condition of suspect PCB-containing equipment, mercury liquid-containing equipment, mercury vapor-containing equipment, and CFC-containing equipment. The stored materials inventory included identifying the presence, location, and quantity of paints, solvents, chemicals, pesticides, herbicides, and compressed gasses. Sampling of HBMs was not performed.

Batteries

The following equipment was observed to be battery-backed:

3 Exit signs

Terracon recommends that batteries be managed in compliance with the 40 CFR 273.2 of the universal waste regulation.

December 22, 2022, Revised January 10, 2023 Terracon Project No. 26227062

Responsive Resourceful Reliable 12

Mercury

Mercury is a toxic heavy metal and in its vapor form or liquid metal form, may be located in switches and light bulbs. When a mercury device breaks, it releases mercury into the air, which is toxic to the human nervous system and can poison wildlife.

Mercury Liquid-Containing Equipment

Mercury liquid-containing equipment was not observed.

Mercury Vapor-Containing Lamps

A cursory inspection was conducted and the following lighting equipment was assumed to contain mercury:

166 fluorescent light tubes

Terracon recommends that mercury vapor-containing light tubes or lamps be managed in compliance with the 40 CFR 273.5 of the universal waste regulation.

Stored Paints, Solvents, Chemicals, Pesticides, and Herbicides

Stored paints, solvents, chemicals, pesticides or herbicides were not observed.

PCB-Containing Equipment

Polychlorinated biphenyls, or PCBs, are a class of synthetic chemicals, once widely used by industry. Their physical properties made them ideal as insulating and cooling fluids in electrical equipment such as transformers, light ballasts, and capacitors and were added to window caulking for protection from ultraviolet (UV) light degradation. PCBs are known carcinogens and the manufacturing of PCBs was banned in 1977.

PCB-Containing Light Ballasts

A cursory inspection was conducted and PCBs were observed or assumed present in the following equipment:

Approximately 77 light ballasts observed did not have “No PCBs” printed on the label and are assumed to be PCB-containing.

Terracon recommends checking all light ballast labeling and properly disposing PCB ballast in compliance with TSCA 40 CFR 671.

December 22, 2022, Revised January 10, 2023 Terracon Project No. 26227062

Responsive Resourceful Reliable 13

PCB-Containing Equipment

The following equipment was observed or assumed to contain PCBs.

1 transformer

Chlorofluorocarbons (CFCs)

The following equipment was observed or assumed to contain CFCs.

7 roof-mounted air conditioning units

Terracon recommends CFCs be recycled in compliance with 40 CFR 82.

Tritium Exit Signs

There were no tritium exit signs observed.

Smoke Detectors

The following equipment was observed or assumed to be photoelectric or ionizing variety smoke detectors.

14 smoke detectors

Compressed Gases

The following items were observed.

5 fire extinguishers

Terracon recommends recycling fire extinguishers.

LIMITATIONS/GENERAL COMMENTS

Terracon made reasonable efforts to access and sample suspect materials within known areas of restricted access which required demolition or destructive activities such as opening walls, dismantling of equipment and removal of protective coverings. Those entities and persons involved with the inspection and generation of this report do not imply or guarantee that all

December 22, 2022, Revised January 10, 2023 Terracon Project No. 26227062

Responsive Resourceful Reliable 14 potential asbestos-containing materials on or in the building have been identified or sampled.

Areas which posed a health or safety risk to Terracon personnel were not sampled.

The asbestos inspection, lead inspection, and hazardous building materials inventory were conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our inspection of the building. The information contained in this report is relevant to the dates on which this inspection was performed and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by AJC Architects, PC for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

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2-

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2-

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