Atch 9 - SXHT12-1042 B402 Add-On B561 Demo_Hazardous Materials Survey.pdf

Pb 3 Environmental Monitoring, LLC.

Asbestos, Lead Paint and Construction Air Monitoring Consulting Bulk Sampling for Laboratory Analysis

(321) 507-4748 Fax: (321) 507-4914 email: robpbo3@gmail.com or rrasmussen72@gmail.com

FL Licensed Asbestos Business Organization No. ZA527 U.S. EPA Certified Lead-Based Paint Activities Firm No. NAT-F178890-1

P. O. Box 236754 Cocoa, FL 32923 321.507.4748 Fax 321.507.4914

September 15, 2022

Project:

Asbestos Survey for Demolition

Building 561 Patrick Space Force Base, FL 32925

Client:

Sunrise Systems of Brevard, Inc.

280 N. Burnett Rd.

Cocoa, FL 32926

Unofficial without seal Peter Swarr, PE #44159FL

LAC #63

Signed electronically 9/17/22 by Peter C. Swarr, PE

FA252123B0001

Attachment 9

Asbestos Survey for Demolition Building 561 Patrick Space Force Base, FL 32925

PbO3 ENVIRONMENTAL MONITORING, LLC. 321.507.4748

ASBESTOS LICENSE # ZA527

According to your instructions PbO3 Environmental Monitoring, LLC., Inc. has completed an asbestos survey at the subject property (Project). The following pages of this report contain the results of this Inspection. This limited asbestos inspection report presents data that describes the location of asbestos-containing material (ACM) identified in the subject property. This report is to be used as a program-planning tool for the proposed demolition, renovation, construction and/or maintenance activities scheduled at this facility. This survey was conducted on site by EPA/AHERA trained professional inspector(s).

Suspect materials not previously identified in this report may be encountered during any renovation or demolition.

These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise.

This report is intended for the exclusive use of our client. The findings are relevant to the conditions observed during the physical process of performing the Inspection. These findings should not be treated as absolute nor should they be relied upon to represent conditions at significantly later dates.

PbO3 Environmental Monitoring, LLC.

Robert Rasmussen Building Inspector Asbestos License # ZA527

Patrick Space Force Base, FL 32925

PbO3 ENVIRONMENTAL MONITORING, LLC. 321.507.4748

ASBESTOS LICENSE # ZA527

1.0 INTRODUCTION

PbO3 was contracted by our client to conduct an Asbestos Survey of suspect asbestos containing materials found in the subject property.

1) Identify suspect asbestos-containing materials that would be disturbed during demolition and/or select renovations to this structure.

1.1 INSPECTION AND SAMPLING PROCEDURE

PbO3 inspection and sample collection procedures are based on the Environmental Protection Agency (EPA) protocols.

An initial facility walk through is conducted to familiarize the inspector with the facility layout. The facility is then divided into functional available spaces that can be accessed. The suspect homogeneous materials are selected for bulk sampling. Samples are collected and placed into separate, sealed plastic bags. Each sample is individually numbered and sample information is entered onto a Field Data Sheet. Sample tools are decontaminated after each sample collection. The samples are delivered to an accredited laboratory for analysis, accompanied by a completed Chain of Custody Form.

Suspect materials are divided into three categories: surfacing materials (such as plaster and surface coatings), thermal system insulation (TSI) (such as mudded TSI fittings, duct insulation, and pipe insulation), and miscellaneous material (such as floor tile, drywall, and mastic). Asbestos-containing materials are classified according to:

Friability * Friable

* Non-friable

Friable asbestos-containing material (ACM), is defined as any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM), that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. (Sec. 61.141)

Nonfriable ACM is any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Supbart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM), that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. EPA also defines two categories of nonfriable ACM, Category I and Category II nonfriable ACM, which are described later in this guidance.

"Regulated Asbestos-Containing Material" (RACM) is (a) friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

A particular suspect material may be found in several different locations within a facility. The EPA does not require that these materials be sampled in each location, provided the materials are of the same type, age, appearance, have the same date of installation, and are sampled in accordance with EPA requirements to provide statistically reliable data that can be extrapolated onto all remaining non-sampled areas.

Accredited inspectors determine the number of samples of each material to be collected, depending on the material's category and the amount of material present.

The EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations and the Florida Department of Environmental Protection (FDEP) Asbestos program regulate the removal and disposal of asbestos-containing building materials (any material containing more than 1% asbestos).

Asbestos NESHAP regulations must be followed for demolitions and/or renovations of facilities with at least 80 linear meters (260 linear feet) of regulated asbestos-containing materials (RACM) on pipes, 15 square meters (160 square feet) of regulated asbestos-containing materials on other facility components, or at least one cubic meter (35 cubic feet) of facility components where the amount of RACM previously removed from pipes and other facility components could not be measured before stripping.

1.2 METHODS OF LABORATORY ANALYSIS

Samples are analyzed in accordance with AHERA requirements using the following reference methods:

EPA Interim Method for the Detection of Asbestos in Bulk Insulation Samples (EPA 600/M4-82020, December 1982).

McCrone Research Institute's The Asbestos Particle Atlas.

All bulk samples are analyzed using PLM visual area estimate (VAE). Friable materials containing asbestos estimated at less than ten percent by PLM-VAE may be reanalyzed by PLM point counting. Additional treatment and tests may be used as required to accurately define composition (i.e., ashing, extractions, and TEM). All bulk sample laboratory reports are verified through an established quality assurance (QA) procedure.

1.3 QUALITY CONTROL PROCEEDURES

Laboratories accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) analyze all samples. These laboratories participate in the NVLAP, as well as the American Industrial Hygiene Association (AIHA) Bulk Asbestos Sample Quality Assurance Program. PbO3 verifies all sample data for accuracy by cross-referencing Field Data Sheets, Chain of Custody Forms, and field notes.

1.4 DETERMINATION OF ACM CLASSIFICATION

The positive identification of asbestos in a material or product can only be made through laboratory analysis.

Visual inspection or common knowledge is not a positive test. The asbestos content of a suspect material is determined by collecting a bulk sample and having it analyzed by PLM. The PLM technique determines the specific type of asbestos present in the bulk sample and VAE provides an estimate of the percentage of asbestos.

The EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) - National Emission Standard for Asbestos (40 CFR Part 61, subpart M) defines a non-friable asbestos-containing material as any material with an asbestos content greater than one percent as determined by PLM analysis. A friable material estimated to contain less than ten percent asbestos as determined by PLM-VAE must be analyzed by PLM point counting and determined to contain less than one-percent asbestos in order to be considered a non-regulated ACM.

A clarification memorandum issued by the EPA regarding the NESHAP regulation included the following statement:

The parties legally responsible for a building (owner or operator) may take a conservative approach to being regulated by the NESHAP. The responsible party - may choose to act as though the building material is an asbestos-containing material (greater than 1%) at any level of asbestos content (even less than 1% asbestos).

Thus, if the analyst detects asbestos in the sample and estimates the amount to be less than 10% by visual estimation, the parties legally responsible (owner or operator) of the building may elect to assume the amount to be greater than 1% and treat the material as regulated asbestos containing material or require verification of the amount by point counting.

1.5 INSPECTION LIMITS

PbO3 has performed the Client requested tasks in a thorough and professional manner consistent with commonly accepted standard industry practices, using state of the art practices and best available known technology, as of the date of the assessment. PbO3 cannot guarantee and does not warrant that this Asbestos Survey has identified all adverse environmental factors and/or conditions affecting the subject properties on the date of the Assessment.

PbO3 cannot and will not warrant that this Asbestos Survey that was requested by the client will satisfy the dictates of, or provide a legal defense in connection with, any environmental laws or regulations. It is the responsibility of the client to know and abide by all applicable laws, regulations, and standards. The results reported and conclusions reached by PbO3 are solely for the benefit of the client. The results and opinions in this report, based solely upon the conditions found on the property as of the date of the Assessment, will be valid only as of the date of the Assessment. Please note that the test results relate only to those homogeneous materials tested. If conditions, or materials, other than those addressed in this report are encountered during the planned demolition activities, PbO3 should be contacted to assess the potential impact of these materials or conditions relative to the findings or recommendations included herein. The survey was performed by observing suspect materials throughout the structure where accessible. We must emphasize that it is not possible to look within every location of a building.

The visual survey documents only general locations of suspect materials but does not determine exact boundaries.

Concealed locations of asbestos may exist at the subject property, and the levels may vary from those stated in this report. There may be variations in the composition of materials which appear similar. Materials may be hidden from view and not accessible. Hypothetical examples include floor tile hidden under carpeting, and not detected by our typical examination of the area under the carpet at a corner(s) or existing hole(s), an abandoned length of insulated pipe hidden within a finished wall, an asbestos-cement sewer vent pipe in the wall behind a toilet, asbestos paper/felt between hardwood flooring and the sub-floor or old vinyl floor tile covered over with plywood and newer flooring materials. No attempt was made to disassemble equipment or demolish structural elements and finishes as this is beyond the scope of our authorized services. Visual observations were made only at convenient locations, due to these limitations, wall voids, flooring under carpet, building cavities and mechanical equipment, and other areas may contain unreported asbestos-containing materials. Suspect materials not previously identified in this report may be encountered during any demolition activity. These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise.

All fire doors should be assumed asbestos containing material since disassembly of locks and/or other work to access the door insulation is not possible.

We generally assume that roofing material, vinyl flooring and floor mastic contains asbestos, as asbestos roofing material, asbestos vinyl flooring and asbestos floor mastic are very common unless noted as sampled. Location and sampling of underground items, such as asbestos-cement pipes, would have been outside of the scope of the survey. Cloth jacketed electrical wiring if present, should be assumed asbestos containing material. Electrical wiring is typically not sampled unless the electrical system has been verified by our client as de-energized.

Electrical wiring is typically not sampled unless the electrical system has been verified by our client as de-energized. Swimming pools are not tested unless they are accessible and drained. Swimming pools should be assumed an asbestos containing material.

EPA 6001R-93/116 is the specified method for analysis of bulk material samples for asbestos under the EPA Asbestos Hazard Emergency Response Act, there have been reports that this method may not identify asbestos when fiber sizes are extremely small or if they are bound in a resinous material. Such materials include floor tile, mastic and asphaltic roofing. Currently, reanalysis by Transmission Electron Microscopy (TEM) to verify results of <1 % or "None Detected" for these materials is recommended.

Quantities shown in this survey are estimates, actual quantities may vary. Field verification is the responsibility of the contractor. Contractors are responsible for their own verification of quantities prior to bid submittal.

Suspect materials not previously identified in this report may be encountered during any demolition, renovation and/or maintenance activities. These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise.

1.6 INSPECTION DATE AND INSPECTOR INFORMATION:

PbO3 employee Richard Anderson & Julian Spadt inspected the structure on September 8, 2022.

2.0 FACILITY CONSTRUCTION INFORMATION:

The structure is a two story CMU block structure on a concrete slab with an assumed built up asphalt roof.

*The roof was not accessible and should be assumed a non-friable Asbestos Containing Material.

2.1 FACILITY MAINTENANCE AND/OR RENOVATION HISTORY

Unknown

2.2 SUSPECT MATERIAL SUMMARY

12”x 12” Acoustic Ceiling Tile and Adhesive (Wormhole) 12”x 12” Acoustic Ceiling Tile and Adhesive (Small Pinhole) 12”x 12” Acoustic Ceiling Tile and Adhesive (Large Pinhole) 2’x 2’ Acoustic Ceiling Tile (Wormhole)

9”x 9” Vinyl Floor Tile (Green) 12”x 12” Vinyl Floor Tile (Gray) HVAC Duct Mastic (White) HVAC Vibration Damper 6” Pipe Insulation (Straight Runs) 6” Pipe Insulation (Fittings) 8” Pipe Insulation (Straight Runs) 8” Pipe Insulation (Fittings) Drywall & Joint Compound Rolled Vinyl Flooring (Yellow) Cove Base Mastic Ceiling Plaster Vinyl Staircase Flooring Carpet Adhesive CMU Block Concrete Exterior Caulking Stucco Wall Texture

2.3 RESULTS

There was a total of Ninety-Five (95) samples (including sub-samples) were analyzed by EPA Method 600/M4/82/020R-93/116. Three (3) samples of the exterior stucco wall texture were reanalyzed by the EPA Point Count Method. Based upon our visual observations, bulk sampling of suspect materials and subsequent microscopic analysis, we have determined that asbestos minerals were detected in the samples analyzed.

Sample No. Location Asbestos Component Asbestos Qty Friable

Amount

561-A-04 RM. 1 Storage 1 9”x 9” Vinyl Floor Tile (Green) 3% Chrysotile No

+/- 550 Ft2

561-A-04 RM. 1 Storage 1 Vinyl Floor Tile Mastic 6% Chrysotile No Assumed Throughout the Entire Structure

561-A-10 RM. 1 Storage 1 6” Pipe Insulation (Straight Runs) 12% Chrysotile 18% Amosite Yes

+/- 200 Lft

561-A-13 RM. 1 Storage 1 6” Pipe Insulation (Fittings) 25% Chrysotile Yes

+/- 30 Fittings

561-A-19 RM. 1 Storage 1, Entry

Rolled Vinyl Flooring (Yellow) 18% Chrysotile No

+/- 450 Ft2

561-A-22 RM. 108

12”x 12” Acoustic Ceiling Tile

(Small Pinhole) 2% Amosite Yes

+/- 60 Ft2

561-A-34 North Entry Vinyl Floor Tile Mastic 2% Chrysotile No Assumed Throughout the Entire Structure

*The roof was not accessible and should be assumed a non-friable Asbestos Containing Material.

2.4 SUMMARY AND CONCLUSIONS

PbO3 was contracted by our client to conduct an Asbestos Survey of suspect asbestos containing materials found in the subject property.

1. Regulated-Friable Asbestos Containing Material was detected in the 6” Pipe Insulation and the 12”x 12” Acoustical Ceiling Tiles.

2. Non-Friable Asbestos Containing Materials were detected in the Rolled Vinyl Flooring, 9”x 9” Vinyl Floor Tile and the associated Vinyl Floor Tile Mastic in this structure.

2.5 RECOMMENDATIONS

Suspect materials not previously identified in this report may be encountered during any demolition, renovation and/or maintenance activities. These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise.

That this survey be used to identify asbestos containing material and components prior to any planned demolition, renovation, construction and/or maintenance activities scheduled at this facility.

Controlled “Wet” demolition of all materials in place is recommended. Provided the demolition activities do not subject presumed non-friable asbestos containing material (if present) to cutting, sanding, grinding, abrading, or otherwise rendering them friable during demolition.

29 CFR 1926.1101- OSHA's Asbestos Standard for the Construction Industry does apply to the demolition of all buildings identified with Asbestos Containing Material (ACM) and/or presumed ACM. The contractor will need to comply with the specific training, duties and responsibilities outlined in this CFR.

Disturbances to the Friable Asbestos 6” Pipe Insulation and the 12”x 12” Acoustical Ceiling Tiles:

Shall be performed by a Florida Licensed Asbestos Abatement Contractor

U.S. Occupational Safety and Health Administration (OSHA) regulations apply to the disturbance of material; containing any percentage of asbestos fibers as outlined in 29 CFR 1926.1101- OSHA's Asbestos Standard for the Construction Industry. The contractor will need to comply with the specific training, duties and responsibilities outlined in this CFR.

OSHA 29 CFR 1910.1001. OSHA 29 CFR 1910.1001 requires the communication of information concerning asbestos hazards. Employees engaged in work activities with installed ACM may be exposed to asbestos fibers. The owner or operator should take the necessary steps to reduce the potential for disturbance.

Disturbances to Non-Friable Asbestos in the Rolled Vinyl Flooring, 9”x 9” Vinyl Floor Tile and the associated Vinyl Floor Tile Mastic:

Option 1

Abate all Non-Friable Asbestos Containing Material prior to any renovation that may impact the Rolled Vinyl Flooring, 9”x 9” Vinyl Floor Tile and the associated Vinyl Floor Tile Mastic. Abatement should be performed by a Florida Licensed Asbestos Abatement Contractor.

29 CFR 1926.1101- OSHA's Asbestos Standard for the Construction Industry does apply if the abatement option is chosen.

OSHA 29 CFR 1910.1001 requires the communication of information concerning asbestos hazards.

Employees engaged in work activities with installed ACM may be exposed to asbestos fibers. The owner or operator should take the necessary steps to reduce the potential for disturbance.

All Asbestos projects must in compliance with Florida Statute Title XXXII Chapter 469 Asbestos Abatement.

Option 2

Non-Friable Asbestos Containing Material was detected in the Rolled Vinyl Flooring, 9”x 9” Vinyl Floor Tile and the associated Vinyl Floor Tile Mastic. The EPA NESHAP (40 CFR Part 61, Appendix A to Subpart M) classifies this material as a Category I, non-friable ACM. Removal is not required by NESHAP provided the renovation activities do not subject this material to cutting, sanding, grinding, abrading, or otherwise rendering them friable during renovation.

29 CFR 1926.1101- OSHA's Asbestos Standard for the Construction Industry does apply to the demolition/renovation of all dwellings identified with asbestos containing material. The demolition contractor will need to comply with the specific training, duties and responsibilities outlined in this

CFR.

OSHA 29 CFR 1910.1001 requires the communication of information concerning asbestos hazards.

Employees engaged in work activities with installed ACM may be exposed to asbestos fibers. The owner or operator should take the necessary steps to reduce the potential for disturbance.

General Recommendations

The EPA’s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations and the Florida Department of Environmental Protection (DEP) Asbestos program regulate the removal and disposal of asbestos-containing building materials. The Florida Department of Environmental Protection (DEP) administers an asbestos removal program under Chapter 62-257, Florida Administrative Code. The Asbestos NESHAP has been adopted by reference in section 62-204.800, Florida Administrative Code. The program’s intent is to minimize the release of asbestos fibers during activities involving the processing, handling, and disposal of asbestos-containing material.

The regulations of these agencies require the removal of friable asbestos-containing materials prior to extensive renovation or demolition projects, and the removal of non-friable asbestos-containing materials that may be rendered friable in the course of renovation or demolition projects. Only a Florida licensed asbestos contractor using properly trained, certified, and licensed asbestos workers can perform asbestos removal projects in Florida.

Air monitoring during and after abatement activities is also recommended to document the fiber levels inside and outside the abatement work area.

The asbestos NESHAP requires that an asbestos trained person be on site i.e. 40 CFR 61.145 (c) (8) states in part “no RACM shall be stripped, removed, or otherwise handled or disturbed at a facility regulated by this section unless at least one on-site representative, such as a foreman or management level person or other authorized person, trained in the provisions of this regulation and the means of complying with them is present.”

DEP recommends that this “trained person” be on site when non-friable ACM is present so that developing problems can be caught early and corrected without delay. In addition, the regulations require the owner of the building and/or the operator to notify the applicable DEP District Office or Local Pollution Control Agency before any demolition, or before renovations of buildings that contain a certain threshold amount of asbestos or asbestos containing materials.

Florida requires the submission of a 10-Day Notification for all renovations and demolitions of facilities with at least 260 linear feet of regulated asbestos-containing materials (RACM), 160 square feet of regulated asbestos containing materials on other facility components, or at least one cubic meter (35 cubic feet) off facility components. Asbestos waste requires disposal at an approved solid waste disposal facility.

Local agencies may also have specific requirements for demolition/renovation projects involving asbestos-containing building materials.

OSHA 29 CFR 1910.1001 requires the communication of information concerning asbestos hazards. Employees engaged in work activities with installed ACM may be exposed to asbestos fibers. The owner or operator should take the necessary steps to reduce the potential for disturbance.

29 CFR 1926.1101- OSHA's Asbestos Standard for the Construction Industry does apply to the abatement, renovation and/or demolition of all buildings identified with asbestos containing material. The contractor will need to comply with the specific training, duties and responsibilities outlined in this CFR.

APPENDIX A

LABORATORY RESULTS

Asbestos Bulk Analysis Report

Client:

Report Number:

Project/Test Address:

Client Number:

Reported Date:

Received Date:

Analyzed Date:

PbO3 Environmental Monitoring, LLC 09/09/2022

201413

09/13/2022

22-09-01498

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Demolition; Bldg 561 Patrick Space Force Base, FL

Laboratory Results Fax Number:

321-507-4914

P.O. Box 236754 Cocoa, FL 32923

09/11/2022

Layer Type AsbestosClient Sample Number

Other Materials

Lab Gross DescriptionLab Sample Number

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-001A 561-A-01 5% Cellulose 65% Fibrous Glass 30% Non-Fibrous

Ceiling Tile

NAD

Brown Adhesive;

Homogeneous

22-09-01498-001B 561-A-01 100% Non-FibrousMastic NAD

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-002A 561-A-02 5% Cellulose 65% Fibrous Glass 30% Non-Fibrous

Ceiling Tile

NAD

Brown Adhesive;

Homogeneous

22-09-01498-002B 561-A-02 100% Non-FibrousMastic NAD

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-003A 561-A-03 5% Cellulose 65% Fibrous Glass 30% Non-Fibrous

Ceiling Tile

NAD

1 of 13Page

Brown Adhesive;

Homogeneous

22-09-01498-003B 561-A-03 100% Non-FibrousMastic NAD

Green Vinyl;

Homogeneous

22-09-01498-004A 561-A-04 97% Non-FibrousTile 3% Chrysotile

3%Total Asbestos:

Black Tar-Like;

Homogeneous

22-09-01498-004B 561-A-04 94% Non-FibrousMastic 6% Chrysotile

6%Total Asbestos:

22-09-01498-005 561-A-05 Did Not Analyze (Positive Stop)

22-09-01498-006 561-A-06 Did Not Analyze (Positive Stop)

Off-White Brittle; Tan Fibrous; Silver Foil;

Inhomogeneous

22-09-01498-007 561-A-07 12% Cellulose 15% Fibrous Glass 73% Non-Fibrous

NAD

Off-White Brittle; Tan Fibrous; Silver Foil;

Inhomogeneous

22-09-01498-008 561-A-08 12% Cellulose 15% Fibrous Glass 73% Non-Fibrous

NAD

Off-White Brittle; Tan Fibrous; Silver Foil;

Inhomogeneous

22-09-01498-009 561-A-09 12% Cellulose 15% Fibrous Glass 73% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

2 of 13Page

White Powder; Fibrous;

Paint-Like;

Inhomogeneous

22-09-01498-010 561-A-10 70% Non-Fibrous12% Chrysotile 18% Amosite

Chrysotile and Amosite present throughout sample.

30%Total Asbestos:

22-09-01498-011 561-A-11 Did Not Analyze (Positive Stop)

22-09-01498-012 561-A-12 Did Not Analyze (Positive Stop)

Brown Powder; Fibrous;

White Brittle;

Inhomogeneous

22-09-01498-013 561-A-13 6% Cellulose 15% Fibrous Glass 54% Non-Fibrous

25% Chrysotile

Chrysotile present throughout sample.

25%Total Asbestos:

22-09-01498-014 561-A-14 Did Not Analyze (Positive Stop)

22-09-01498-015 561-A-15 Did Not Analyze (Positive Stop)

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-016 561-A-16 20% Cellulose 80% Non-Fibrous

NAD

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-017 561-A-17 18% Cellulose 82% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

3 of 13Page

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-018 561-A-18 19% Cellulose 81% Non-Fibrous

NAD

Tan Vinyl; Beige Fibrous;

Yellow Adhesive;

Inhomogeneous

22-09-01498-019 561-A-19 12% Cellulose 70% Non-Fibrous

18% Chrysotile

Unable to cleanly separate mastic from fibrous backing. Chrysotile present in fibrous backing.

18%Total Asbestos:

22-09-01498-020 561-A-20 Did Not Analyze (Positive Stop)

22-09-01498-021 561-A-21 Did Not Analyze (Positive Stop)

Gray Fibrous; Cream Paint-Like;

Inhomogeneous

22-09-01498-022A 561-A-22 1% Cellulose 65% Fibrous Glass 32% Non-Fibrous

Ceiling Tile

2% Amosite

Amosite present throughout sample.

2%Total Asbestos:

Brown Adhesive;

Homogeneous

22-09-01498-022B 561-A-22 100% Non-FibrousMastic NAD

22-09-01498-023A 561-A-23 Ceiling Tile

Did Not Analyze (Positive Stop)

Brown Adhesive;

Homogeneous

22-09-01498-023B 561-A-23 100% Non-FibrousMastic NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

4 of 13Page

22-09-01498-024A 561-A-24 Ceiling Tile

Did Not Analyze (Positive Stop)

Brown Adhesive;

Homogeneous

22-09-01498-024B 561-A-24 100% Non-FibrousMastic NAD

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-025 561-A-25 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

NAD

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-026 561-A-26 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

NAD

Gray Fibrous; White Paint- Like; Inhomogeneous

22-09-01498-027 561-A-27 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

NAD

Blue/Gray Vinyl;

Inhomogeneous

22-09-01498-028A 561-A-28 100% Non-FibrousCove Base

NAD

Beige Adhesive;

Homogeneous

22-09-01498-028B 561-A-28 100% Non-FibrousMastic I NAD

Brown Adhesive;

Homogeneous

22-09-01498-028C 561-A-28 100% Non-FibrousMastic II NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

5 of 13Page

Blue/Gray Vinyl;

Inhomogeneous

22-09-01498-029A 561-A-29 100% Non-FibrousCove Base

NAD

Beige Adhesive;

Homogeneous

22-09-01498-029B 561-A-29 100% Non-FibrousMastic NAD

No brown mastic present.

Blue/Gray Vinyl;

Homogeneous

22-09-01498-030A 561-A-30 100% Non-FibrousCove Base

NAD

Beige Adhesive;

Homogeneous

22-09-01498-030B 561-A-30 100% Non-FibrousMastic I NAD

Brown Adhesive;

Homogeneous

22-09-01498-030C 561-A-30 100% Non-FibrousMastic II NAD

Gray Cementitious; Green Paint-Like;

Inhomogeneous

22-09-01498-031 561-A-31 100% Non-FibrousNAD

Gray Cementitious; Green Paint-Like;

Inhomogeneous

22-09-01498-032 561-A-32 100% Non-FibrousNAD

Gray Cementitious; Green Paint-Like;

Inhomogeneous

22-09-01498-033 561-A-33 100% Non-FibrousNAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

6 of 13Page

Gray Vinyl; Homogeneous22-09-01498-034A 561-A-34 100% Non-FibrousTile NAD

Black/Yellow Adhesive;

Inhomogeneous

22-09-01498-034B 561-A-34 1% Cellulose 97% Non-Fibrous

Mastic 2% Chrysotile

Unable to cleanly separate mastics.

2%Total Asbestos:

Gray Vinyl; Homogeneous22-09-01498-035A 561-A-35 100% Non-FibrousTile NAD

22-09-01498-035B 561-A-35 Mastic Did Not Analyze (Positive Stop)

Gray Vinyl; Homogeneous22-09-01498-036A 561-A-36 100% Non-FibrousTile NAD

22-09-01498-036B 561-A-36 Mastic Did Not Analyze (Positive Stop)

Burgundy Vinyl;

Homogeneous

22-09-01498-037A 561-A-37 100% Non-FibrousTread NAD

Tan Adhesive;

Homogeneous

22-09-01498-037B 561-A-37 100% Non-FibrousMastic I NAD

Brown Adhesive;

Homogeneous

22-09-01498-037C 561-A-37 100% Non-FibrousMastic II NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

7 of 13Page

Burgundy Vinyl;

22-09-01498-038A 561-A-38 100% Non-FibrousTread NAD

Tan Adhesive;

Homogeneous

22-09-01498-038B 561-A-38 100% Non-FibrousMastic I NAD

Brown Adhesive;

Homogeneous

22-09-01498-038C 561-A-38 100% Non-FibrousMastic II NAD

Burgundy Vinyl;

Homogeneous

22-09-01498-039A 561-A-39 100% Non-FibrousTread NAD

Tan Adhesive;

Homogeneous

22-09-01498-039B 561-A-39 100% Non-FibrousMastic I NAD

Brown Adhesive;

Homogeneous

22-09-01498-039C 561-A-39 100% Non-FibrousMastic II NAD

Black Rubbery; White Fibrous; Inhomogeneous

22-09-01498-040 561-A-40 35% Fibrous Glass 65% Non-Fibrous

NAD

Black Rubbery; White Fibrous; Inhomogeneous

22-09-01498-041 561-A-41 35% Fibrous Glass 65% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

8 of 13Page

Black Rubbery; White Fibrous; Inhomogeneous

22-09-01498-042 561-A-42 35% Fibrous Glass 65% Non-Fibrous

NAD

Black Brittle; White Rubbery; Fibrous; Paint- Like; Inhomogeneous

22-09-01498-043 561-A-43 14% Fibrous Glass 86% Non-Fibrous

NAD

Black Brittle; White Rubbery; Fibrous; Paint- Like; Inhomogeneous

22-09-01498-044 561-A-44 14% Fibrous Glass 86% Non-Fibrous

NAD

Black Brittle; White Rubbery; Fibrous; Paint- Like; Inhomogeneous

22-09-01498-045 561-A-45 14% Fibrous Glass 86% Non-Fibrous

NAD

Black Brittle; Gray Rubbery; White Fibrous;

Paint-Like;

Inhomogeneous

22-09-01498-046 561-A-46 15% Fibrous Glass 85% Non-Fibrous

NAD

Black Brittle; Gray Rubbery; White Fibrous;

Paint-Like;

Inhomogeneous

22-09-01498-047 561-A-47 15% Fibrous Glass 85% Non-Fibrous

NAD

Black Brittle; White Rubbery; Fibrous; Paint- Like; Inhomogeneous

22-09-01498-048 561-A-48 14% Fibrous Glass 86% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

9 of 13Page

Dark Yellow to Brown Adhesive; Homogeneous

22-09-01498-049 561-A-49 2% Synthetic 98% Non-Fibrous

NAD

Dark Yellow to Brown Adhesive; Homogeneous

22-09-01498-050 561-A-50 2% Synthetic 98% Non-Fibrous

NAD

Dark Yellow to Brown Adhesive; Homogeneous

22-09-01498-051 561-A-51 2% Synthetic 98% Non-Fibrous

NAD

Light Gray Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-052A 561-A-52 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

Ceiling Tile

NAD

Brown Adhesive; Fibrous;

Inhomogeneous

22-09-01498-052B 561-A-52 12% Cellulose 88% Non-Fibrous

Mastic NAD

Light Gray Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-053A 561-A-53 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

Ceiling Tile

NAD

Brown Adhesive;

Homogeneous

22-09-01498-053B 561-A-53 1% Cellulose 99% Non-Fibrous

Mastic NAD

Light Gray Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-054A 561-A-54 1% Cellulose 70% Fibrous Glass 29% Non-Fibrous

Ceiling Tile

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

10 of 13Page

Brown Adhesive;

22-09-01498-054B 561-A-54 1% Cellulose 99% Non-Fibrous

Mastic NAD

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-055 561-A-55 20% Cellulose 80% Non-Fibrous

NAD

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-056 561-A-56 17% Cellulose 83% Non-Fibrous

NAD

White Granular; Light Gray Powder; White/Tan Fibrous; White Paint-Like;

Inhomogeneous

22-09-01498-057 561-A-57 18% Cellulose 82% Non-Fibrous

NAD

Gray Cementitious; Beige Paint-Like;

Inhomogeneous

22-09-01498-058 561-A-58 100% Non-FibrousNAD

Gray Cementitious;

Homogeneous

22-09-01498-059 561-A-59 100% Non-FibrousNAD

Black Rubbery;

Homogeneous

22-09-01498-060 561-A-60 100% Non-FibrousNAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

11 of 13Page

Black Rubbery;

22-09-01498-061 561-A-61 100% Non-FibrousNAD

Black Rubbery;

Homogeneous

22-09-01498-062 561-A-62 100% Non-FibrousNAD

White Powder; Fibrous;

Inhomogeneous

22-09-01498-063 561-A-63 30% Cellulose 70% Non-Fibrous

NAD

White Powder; Fibrous;

Inhomogeneous

22-09-01498-064 561-A-64 30% Cellulose 70% Non-Fibrous

NAD

White Powder; Fibrous;

Inhomogeneous

22-09-01498-065 561-A-65 30% Cellulose 70% Non-Fibrous

NAD

Gray Powder; Fibrous;

Inhomogeneous

22-09-01498-066 561-A-66 3% Cellulose 30% Fibrous Glass 67% Non-Fibrous

NAD

Gray Powder; Fibrous;

Inhomogeneous

22-09-01498-067 561-A-67 3% Cellulose 30% Fibrous Glass 67% Non-Fibrous

NAD

Gray Powder; Fibrous;

Inhomogeneous

22-09-01498-068 561-A-68 3% Cellulose 30% Fibrous Glass 67% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

12 of 13Page

Beige Granular; Paint- Like; Inhomogeneous

22-09-01498-069 561-A-69 100% Non-FibrousTrace <1% Chrysotile

Chrysotile present throughout sample.

Trace <1%Total Asbestos:

Beige Granular; Paint- Like; Inhomogeneous

22-09-01498-070 561-A-70 1% Cellulose 99% Non-Fibrous

Trace <1% Chrysotile

Chrysotile present throughout sample.

Trace <1%Total Asbestos:

Beige Granular; Paint- Like; Inhomogeneous

22-09-01498-071 561-A-71 100% Non-FibrousTrace <1% Chrysotile

Chrysotile present throughout sample.

Trace <1%Total Asbestos:

Melissa Kanode

1% Asbestos

Analyst:

Reporting Limit:

Method:

QC Blank:

QC Sample:

Vickie Holmes

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

QA/QC Clerk

Reviewed By Authorized Signatory:

46-M12019-1

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:201413 22-09-01498

Demolition; Bldg 561 Patrick Space Force Base, FL

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

13 of 13Page

Asbestos 400 Point Count

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

% Asbestos

Laboratory Results

PbO3 Environmental Monitoring, LLC

Fax Number:

22-09-02225

Reported Date:

Project/Test Address:

Received Date:

Client Number:

Report Number:

201413

Demolition; Bldg 561 Patrick Space Force Base, FL ; EHS #22-09-01498

321-507-4914

Client:

09/16/2022

Lab Sample Number

Client Sample Number

Lab Gross Description

Analyzed Date: 09/14/2022P.O. Box 236754 Cocoa, FL 32923

Narrative ID

09/09/2022

0.25 Chrysotile%561-A-6922-09-02225-001 Beige Granular; Paint-Like

0.25 Chrysotile%561-A-7022-09-02225-002 Beige Granular; Paint-Like

0.25 Chrysotile%561-A-7122-09-02225-003 Beige Granular; Paint-Like

Tasha Eaddy

% Asbestos

Analyst:

Reporting Limit:

Method:

Kay Harris

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

QA/QC Clerk

Reviewed By Authorized Signatory:

0.25

LEGEND NAD = No Asbestos Detected

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. 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.

1 of 1Page

APPENDIX B

CERTIFICATIONS

Robert Rasmussen

July 23, 2022

ON-4644-7395-072322

23-Jul-2022

23-Jul-2023

Powered by TCPDF (www.tcpdf.org)

FA252123B0001

http://www.tcpdf.org

Julian Spadt

May 03, 2022

ON-4644-9815-050322

3-May-2022

03-May-2023

Powered by TCPDF (www.tcpdf.org)

FA252123B0001

Richard Anderson

January 11, 2022

ON-4644-11173-011122

11-Jan-2022

11-Jan-2023

Powered by TCPDF (www.tcpdf.org)

FA252123B0001

Julie I. Brown, SecretaryRon DeSantis, Governor

STATE OF FLORIDA

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION

ASBESTOS LICENSING UNIT

THE ASBESTOS BUSINESS ORGANIZATION HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 469, FLORIDA STATUTES

PBO3 ENVIRONMENTAL MONITORING, LLC

Do not alter this document in any form.

PETER C SWARR

LICENSE NUMBER: ZA527

EXPIRATION DATE: NOVEMBER 30, 2023

This is your license. It is unlawful for anyone other than the licensee to use this document.

1003 WOODSMERE PKWY.

ROCKLEDGE FL 32955

Always verify licenses online at MyFloridaLicense.com

FA252123B0001

https://www.myfloridalicense.com/LicenseDetail.asp?SID=&id=14d1a5fa777a572ef6583a48b6f694af

United States Department of Commerce National Institute of Standards and Technology

Certificate of Accreditation to ISO/IEC 17025:2017

NVLAP LAB CODE: 101882-0

Environmental Hazards Services, L.L.C.

North Chesterfield, VA is accredited by the National Voluntary Laboratory Accreditation Program for specific services, listed on the Scope of Accreditation, for:

Asbestos Fiber Analysis

2022-01-01 through 2022-12-31 Effective Dates For the National Voluntary Laboratory Accreditation Program

This laboratory is accredited in accordance with the recognized International Standard ISO/IEC 17025:2017.

This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer to joint ISO-ILAC-IAF Communique dated January 2009).

SCOPE OF ACCREDITATION TO ISO/IEC 17025:2017

For the National Voluntary Laboratory Accreditation Program

Effective

National Voluntary Laboratory Accreditation Program

2022-01-01 through 2022-12-31

Environmental Hazards Services, L.L.C.

7469 Whitepine Road

North Chesterfield, VA 23237-2261 Ms. Julie Dickerson

Phone: 804-275-4788 Fax: 804-275-4907 Email: jdickerson@leadlab.com http://www.leadlab.com

ASBESTOS FIBER ANALYSIS NVLAP LAB CODE 101882-0

Bulk Asbestos Analysis Code Description 18/A01 EPA -- 40 CFR Appendix E to Subpart E of Part 763, Interim Method of the Determination of

Asbestos in Bulk Insulation Samples

18/A03 EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials

P.O. Box 236754 Cocoa, FL 32923 321.507.4748 Fax 321.507.4914

September 13, 2022

Client: Sunrise Systems of Brevard, Inc.

P. O. Box 3188 Cocoa, FL. 32924

Project: RCRA-8 Paint Survey for Demolition

PSFB, FL

This report has been prepared for the exclusive use of Sunrise Systems of Brevard, Inc. for the expressed purpose of providing them with an understanding of the potential for occupational exposure to the agents listed in this report at the assessed property. We are not responsible for changes in applicable regulatory standards, practices or regulations following performance of services. Any reliance on the report by a third party is at such party’s sole risk. Any re-publication of this report shall be in full or listed as a extract of the full report.

According to your instructions PbO3 Environmental Monitoring, LLC. has completed a RCRA-8 paint survey at the subject property (Project). The following pages of this report contain the results of this inspection. This inspection report presents data that describes the location of the paint samples identified only within the project scope. This report is to be used as a program-planning tool for any proposed renovation or demolition activities scheduled at this facility. This survey was conducted on site by an EPA/AHERA trained professional inspector.

Suspect materials not previously identified in this report may be encountered during any renovation or demolition.

These materials should be assumed containing lead-based paint until sample collection and subsequent analysis prove otherwise.

This report is intended for the exclusive use of our client. The findings are relevant to the conditions observed during the physical process of performing the Inspection. These findings should not be treated as absolute nor should they be relied upon to represent conditions at significantly later dates.

PbO3 Environmental Monitoring, LLC.

Building Inspector

RCRA-8 Paint Survey for Demolition

Table of Contents

Section Page

1.0 Introduction 3

2.0 Background 4

2.1 Routes of Exposure 4

2.2 Generally Recognized Health Effects from RCRA-8 Metal Exposure 4

2.3 Expected Work Exposures 4

2.4 Occupational Regulations & Exposure Limits 4

2.5 Lead-Based Paint Surface Concentration Clearance Levels 5

2.6 RCRA-8 Waste Clearance Levels 6

3.0 Sampling Methods & Analysis 7

4.0 Sample Results 7

4.1 Paint Chip Samples 7

5.0 Discussion 12

6.0 Recommendation 13

1.0 Introduction

At the request of Sunrise Systems of Brevard, Inc., Mr. Julian Spadt1 of PbO3 Environmental Monitoring, LLC.

conducted a RCRA-8 survey of bulk paint that may be disturbed during the renovation of building 561 at Patrick Space Force Base, FL. The purpose of the survey was to assess the potential impact of Lead Based Paint and RCRA-8 metals on the building components that may be impacted or disturbed during the proposed demolition and/or renovation of the building. On September 8th, 2022, Mr. Julian Spadt conducted the survey and collected bulk samples of suspect paint chips to be analyzed for RCRA-8 metals. Following the receipt of the analyses, this report was prepared.

1 – Julian Spadt, Florida EPA Certified Lead-Based Paint Risk Assessor No.: LBP-R-I207340-2.

2.0 Background

2.1 Routes of Exposure

Routes of exposure for heavy metals are inhalation, ingestion, and skin absorption. Exposure includes occupational such as that during processing or remediating heavy metal compounds, or non-occupational exposure from bullets, ceramic glazes on fine china and cookware (especially for exported items) and other pottery, printing ink, cosmetics, toys, and drinking water. Although this report focuses on potential occupational exposure, non-occupational may significantly contribute to total exposure and thus should be considered in any assessment.

2.2 Generally Recognized Health Effects from RCRA-8 metals Exposure

The acute (short-term) effects of exposure include damage to the brain (encephalopathy), reversible kidney damage, decreased appetite, insomnia, headache, muscle and joint pain, colic, constipation, as well as anemia. Chronic effects are more deleterious and include weakness, weight loss, nausea, vomiting, blue-black dot-like pigmentation on the gums, severe headache, and abdominal cramps.

2.3 Expected Work Exposures

Exposure to RCRA-8 metals varies greatly and therefore the dose that the body receives varies greatly. The overall dose during exposure to paint containing RCRA-8 metals is affected by the duration of exposure, the route of exposure, the distance from the source, the size and form, protection measures and work habits, equipment and tools used, etc.

Some typical exposures during Lead-Based paint removal are:

Task/activity Concentration Propane Torch 4,200-10,900 ug/m3 Grinding 2,000-11,000 ug/m3 Cleanup and wet washdown 190-750 ug.m3 Ripout of baseboards and window trim 9-50 ug/m3 Sandblasting of paint 50-10,000 ug/m3 Manual scraping wetted loose paint 2-19 ug/m3 Welding < 10-19,500 ug/m3

Result from spot work (vac-blast, grinding, cutting, torching) conducted on Launch Pads, the VAB, and Hangers, etc.

over the past 22 years that we have measured have ranged from below detectable limits to 862 ug/m3 indicating highly variable control; however, no evaluation has been conducted to determine the amount of lead In paint to correlate with these results.

2.4 Occupational Regulations & Exposure Limits

OSHA construction regulations for lead are contained in 29 CFR 1962.62 were created to protect workers from adverse exposure to lead, and regulations for hazardous waste operations in 29 CFR 1926.65 that were created to protect workers from adverse exposure to RCRA-8 metals. The regulations require that a number of procedures and processes be followed where exposure (of any amount) occurs. These range from air monitoring to medical surveillance.

As indicated in the OSHA Compliance Directive2, “For all occupational exposure to Lead occurring in the course of construction work, the standard does not specify a minimum amount or concentration of that triggers a determination that the Lead is present and the potential for occupational exposure exists. However, if the employer has appropriately tested all potential sources of lead (e.g., tested all layers of paints and coatings that may be disturbed) utilizing a valid detection method for the presence of lead and found no detectable levels, the standard does not apply.” So unless the results are below detectable limits, the applicability of the regulations is determined by airborne exposure potential.

Currently, OSHA has specified an 8-Hour time-weighted-average permissible exposure limit (PEL-TWA) of;

0.5 ug/m3 for Arsenic

0.5 ug/m3 for…