Attachment_8_-_Asbestos_Survey.pdf

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Renovate Arnold Hall Federal contract opportunity
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FA301019Renovate_Arnold_Hall
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Department of the Air Force Air Education and Training Command

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Attachment 8 - Asbestos Survey

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REPORT OF

HAZARDOUS AND REGULATED MATERIAL SURVEY

KEESLER HOSPITAL MODERNIZATION

BUILDINGS: 468, 824, AND 5901

KEESLER AIR FORCE BASE, MISSISSIPPI

CONTRACT # W91275-13-D-6001; DO-CL0001

- Prepared By -

AMEC ENVIRONMENT & INFRASTRUCTURE, INC.

9211 North Davis Highway Pensacola, Florida 32514

J.E. DUNN PROJECT NO. 13076900

AMEC PROJECT NO. 6376-13-0046.01

28 April 2014

11 April 2014

Mr. Kevin Rogers, LEED AP Phone: 816-474-8600 J.E. Dunn Construction Company Email: kevin.rogers@jedunn.com 1001 Locust Street Kansas City, MO 64106

Subject: Report of Hazardous and Regulated Materials Survey

Keesler Hospital Modernization Buildings 468, 824, and 5901 Keesler Air Force Base, Mississippi

Contract # W91275-13-D-6001; DO-CL0001 J.E. Dunn Project No. 13076900 AMEC Project No. 6376-13-0046.01

Mr. Rogers:

AMEC Environment & Infrastructure, Inc. (AMEC) is pleased to present to J.E. Dunn Construction Company this report of consulting services to be used to plan the renovation and demolition activities for the Keesler Hospital Modernization at Keesler Air Force Base, in Biloxi, Mississippi. This report includes background information, findings of our survey, recommendations and supporting documentation.

We appreciate the opportunity to provide our consulting services on this project. If you have any questions or require additional information or services, please contact us.

Respectfully, AMEC ENVIRONMENT & INFRASTRUCTURE, INC.

Richard J. Brown Russell E. Stauffer, P.E.

Project Manager Project Principal For R.E. Stauffer with Permission

Attachments: As Referenced

28 April 2014 Report of Hazardous and Regulated Materials Survey Keesler Hospital Modernization AMEC Project No. 6376-13-0046.01

TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................................................................................. i

1.0 PROJECT INFORMATION

1.1 PURPOSE AND SCOPE

2.0 ASBESTOS SURVEY

2.1 PURPOSE AND SCOPE

2.2 SURVEY TASKS

2.3 ASBESTOS BULK SAMPLING AND ANALYSIS

2.4 CONCLUSIONS AND RECOMMENDATIONS

2.4.1 GENERAL RECOMMENDATIONS

2.4.2 SPECIFIC ASBESTOS RECOMMENDATIONS

2.4.3 STATE OF FLORIDA ASBESTOS REGULATIONS

2.4.4 INTERIM MEASURES

2.4.5 LEGAL AND MEDICAL CONSIDERATIONS

3.0 PAINT CONTAINING LEAD (PCL) SURVEY

3.1 PURPOSE AND SCOPE

3.2 LEAD XRF TESTING PROCEDURES

3.3 TESTING CRITERIA AND RESULTS

3.4 CONCLUSIONS AND RECOMMENDATIONS

4.0 HAZARDOUS AND / OR REGULATED MATERIALS SURVEY

4.1 PURPOSE AND SCOPE

4.2 FINDINGS ............................................................................. Error! Bookmark not defined.

4.3 CONCLUSIONS AND RECOMMENDATIONS

5.0 OBSERVATIONS FOR SUSPECT MOLD

5.1 PURPOSE AND SCOPE

5.2 FINDINGS ............................................................................. Error! Bookmark not defined.

5.3 CONCLUSIONS AND RECOMMENDATIONS

APPENDICES

APPENDIX A: FIGURES

Figure 1: Building Location Plan Figures 1A Through 1E: HRM Survey Location Areas Drawings 001 through 014 Asbestos Location Plans

APPENDIX B: TABLES

Table 1: Summary of Bulk Sample Positive Results for Asbestos- Containing Materials

Table 2: Summary of PCL Laboratory Test Locations and Results Table 3: PCL Field Test Locations and Results

APPENDIX C: PROTOCOLS

C.1 Asbestos Bulk Sampling and Laboratory Analysis Protocol C.2 Paint Containing Lead Sampling and Analysis Protocol C.3 Hazardous and Regulated Material Survey Protocol C.4 Mold Observations Protocol C.5 Qualifications of Report

APPENDIX D: ASBESTOS BULK SAMPLE LABORATORY ANALYSIS REPORTS

APPENDIX E: XRF AND PCL CALIBRATION CHECKS & PCL LABORATORY

ANALYSIS REPORTS

i 28 April 2014

AMEC Project No. 6376-14-0046.01

EXECUTIVE SUMMARY

Under a contract agreement between J.E. Dunn Construction Company (J.E. Dunn) and AMEC, AMEC was contracted to perform a Hazardous and Regulated Material Survey for the planned renovation and demolition associated with the Keesler Hospital Modernization at Keesler Air

Force Base, Biloxi, Mississippi. The project involves renovation and demolition of the following:

Renovation Areas

Building 468 (Keesler Hospital): Select areas of the Ground Floor, 1st, 2nd, 3rd, 4th, and 5th

Floors (Approximately 163,000 feet of renovation area).

Building 5901 (Arnold Mental Health Center): Renovation for temporary office space.

Demolition

Building 824 (Dental Clinic).

This report presents information obtained during the Hazardous and Regulated Material Survey and includes the following:

• NESHAP Asbestos Survey;

• Paint Containing Lead (PCL) Survey;

• Visual Survey for Hazardous and Regulated Materials;

• Visual Observation for Mold Suspect.

Field activities for the above referenced tasks were initiated on October 28, 2013 and completed on October 31, 2013. The following is a summary of findings:

ii 28 April 2014

ASBESTOS-CONTAING MATERIALS:

The following materials were found to contain asbestos:

Building 468 (Keesler Hospital)

First Floor:

9” x 9” Vinyl Floor Tile Black floor tile mastic Black and White Duct Mastic

Second Floor:

Black, beige and white duct/mastic 12” x 12” Vinyl Floor tile Black floor tile mastic Thermal System Insulation

Third Floor:

12” x 12” Vinyl floor tile White and black duct mastic Thermal System Insulation

Fourth Floor:

12” x 12” Vinyl floor tile Black floor tile mastic Black and white duct mastic Duct seam wrap Spray-applied texture Black Sink Undercoating

Fifth Floor:

12” x 12” Vinyl floor tile White and black duct mastic Black floor tile mastic

Building 824 (Dental Clinic)

Black Duct Mastic Exterior Window Caulking Exterior Window Sealant

Building 5901 (Arnold Mental Health Center)

None iii 28 April 2014

The friable ACMs and non-friable ACMs that may become friable during disturbance typically require removal by a State of Mississippi Licensed Asbestos Abatement Contractor prior to any renovation or demolition activities that may disturb the materials.

Paint Containing Lead (PCL) Survey

Paint-Containing Lead (PCL), detectable levels, was identified on various building components. If any of the items coated with PCL are planned to be impacted during the planned renovations we recommend proper removal and handling. Any renovation/demolition actions that impact these components should utilize proper engineering controls and work procedures to comply with the

OSHA Construction Standard for Lead (29 CFR 1926.62). If these PCL coated components are not going to be removed as part of the project they can be managed in place using an Operations and Maintenance Program (OMP).

Hazardous / Regulated Materials Survey:

The following hazardous / regulated materials were identified:

Building 468 (Hospital)

Mercury-containing fluorescent lamps Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment Chlorofluorocarbons (CFCs) in water fountains, refrigerators, and HVAC equipment Fire extinguishers Batteries in exit signs, emergency lighting, clocks, and smoke detectors Lead lining in X-ray rooms Medical Air in operating areas Pharmaceuticals High intensity discharge lamps Petroleum Products in compressors and escalator equipment

Mercury-containing fluorescent lamps Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment Batteries in exit signs, emergency lights, clocks, and smoke detectors Chlorofluorocarbons (CFCs) in water fountains, refrigerators and HVAC equipment High intensity discharge lamps Fire extinguishers Pad-mounted transformer Petroleum Products in compressors and escalator equipment Lead lining in X-ray rooms iv 28 April 2014

Mercury-containing fluorescent lamps Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment Batteries in exit signs, emergency lights, clocks, and smoke detectors Chlorofluorocarbons (CFCs) in water fountains

These materials will require special handling and disposal or recycling in accordance with USEPA and Mississippi Department of Environmental Quality (MDEQ) requirements prior to demolition.

Visual Observations for the Suspect Mold

Suspect mold growth was observed in Building 486 in the following areas: thermal system insulation, and duct insulation on HVAC Units located in mechanical rooms, and thermal system insulation and above ceiling tiles on in the vicinity of Room 1F232.

1 28 April 2014

1.0 PROJECT INFORMATION

The Keesler Hospital (Building 468) which houses the 81st Medical Group was originally constructed in the 1950s with multiple major additions and renovations over the years. We understand that J.E. Dunn has been awarded the Design/Build contract for the Keesler Hospital

Modernization by the Little Rock District of the U.S. Army Corps of Engineers. J.E. Dunn’s design partner is Hoefer Wysocki Architects, LLC (HWA). Under a contract agreement between J.E.

Dunn Construction Company (J.E. Dunn) and AMEC, AMEC was contracted to perform a

Hazardous and Regulated Material Survey for the planned renovation and demolition associated with the Keesler Hospital Modernization at Keesler Air Force Base, Biloxi, Mississippi. The project involves renovation and demolition of the following:

Renovation Areas

Bldg 468 (Keesler Hospital): Select areas of Ground Floor,1st, 2nd, 3rd, 4th, and 5th Floors

(Approximately 163,000 feet of renovation area).

Building 5901 (Arnold Mental Health Center): Renovation for temporary office space.

Demolition

Bldg 824 (Dental Clinic).

Figure 1: Building Location Plan presented in Appendix A identifies the location of the subject buildings.

1.1 PURPOSE AND SCOPE

The purpose of the Hazardous and Regulated Material survey is to provide an indication of the presence and extent of potentially hazardous or regulated building materials, equipment, and fixtures (i.e. components) within the structures that will be directly or indirectly affected by the planned project. Specifically, our survey included the areas of Building 468 identified in Figures

1A through 1f: HRM Survey Location Areas (Building 468). The Survey area also included the interior and exterior of Building 824 (excluding roofing), and the interior of Building 5901. AMEC’s services for the project included the following:

• NESHAP Survey for Asbestos Containing Materials (ACMs) that involved the collection of representative samples of suspect ACMs for laboratory analysis of asbestos content by Polarized Light Microscopy.

• Paint Containing Lead (PCL) Survey to identify PCL using a portable X-Ray Fluorescent (XRF) analyzer and confirmatory laboratory analysis of paint chips.

2 28 April 2014

• Visual survey for Hazardous and Regulated Materials to attempt to identify potentially hazardous materials in the buildings and/or suspect building components which could be regulated by governmental agencies.

• Visual observations for mold to attempt to identify the presence of obvious mold growth.

• Provide recommendations for asbestos abatement and safe handling and disposal of PCL and other hazardous and / or regulated materials identified in the survey.

AMEC performed the field survey between October 28 and 30, 2013 and March 12 and 13, 2014.

The PCL survey was performed by Mr. James Marsh of AMEC, a State of Mississippi Lead Paint

Risk Assessor. The Asbestos and HRM Survey team was led by Mr. Michael Cobb of AMEC, a

State of Mississippi Asbestos Building Inspector.

3 28 April 2014

2.0 ASBESTOS SURVEY

AMEC performed a National Emissions Standards for Hazardous Air Pollutants (NESHAP) [40

CFR Part 61 Subpart M] compliant asbestos survey on select areas of the ground floor through

5th floor of Building 468, select areas of Arnold Hall in Building 5901 and Building 824 in its entirety. In Appendix C, we present the following:

• Asbestos Lead Coating, HRM and Mold Protocol; and

• Qualifications of the Report.

2.1 PURPOSE AND SCOPE

The EPA and MDEQ regulate the handling and disposal of asbestos-containing materials (ACM).

OSHA regulates the protection of workers whose work may expose them to asbestos. The EPA’s rules concerning asbestos were issued under the National Emissions Standards for Hazardous

Air Pollutants (NESHAP) [40 CFR Part 61, Subpart M]. The NESHAP specifically requires that regulated asbestos-containing materials (RACM) be removed from any regulated facility prior to renovation or demolition. The NESHAP also requires that buildings to be renovated or demolished be surveyed for ACM.

The purpose of the NESHAP ACM survey is to identify the regulated ACM in the structures scheduled for renovation or demolition. In Building 468 our services were limited to select renovation areas as identified on the AMEC HRM Survey Location Plan presented in the

Appendix. Our services were limited to the interior of Building 5901. Building 824 is scheduled for demolition and all accessible areas were sampled with the exception of the roof. These findings will be used to assist in renovation design and demolition activities.

The scope of the asbestos survey included the observation of accessible interior and exterior

(where applicable) building components for suspected ACM. The suspect materials observed were categorized by type, homogeneous area, general condition, and friability. A homogeneous area contains material that is uniform in texture and appearance, was installed at one time. The

EPA has defined as "friable" those materials that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Samplings of homogeneous areas of suspect materials were collected in general accordance with current EPA Asbestos Hazard Emergency Response Act (AHERA) bulk sampling guidelines.

4 28 April 2014

This protocol has been found to reduce the likelihood of "false negative" analyses. The samples were analyzed in accordance with AHERA "first positive analysis" protocol recommended by the

EPA. Additional details of the sampling protocols are presented in Appendix C.

2.2 SURVEY TASKS

The following tasks were performed as part of this asbestos survey:

1. A visual survey was performed to identify homogeneous areas of suspect ACM and to assess potential for damage/disturbance during demolition/renovation operations and their potential to expose demolition/renovation workers to asbestos fibers.

2. Samples of accessible suspect materials were collected and analyzed by AMEC’s subcontracted laboratory following EPA-recommended procedures. The locations and extents of identified and assumed ACMs were estimated.

3. Report our findings and present recommendations for further actions to accommodate demolition/renovation.

2.3 ASBESTOS BULK SAMPLING AND ANALYSIS

AMEC representatives Mr. Angel Vizcarrondo and Mr. Michael Cobb performed the survey on

October 28, 2013 through October 31, 2013 and on March 12 and 13, 2014. AMEC utilized accredited asbestos inspectors in accordance with the EPA Model Accreditation Program (MAP) and State of Mississippi requirements. Bulk sample analyses were performed by AMEC’s subcontract laboratory, Cates Laboratories located in Dallas, Texas. The laboratory is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP No. 200569-0) to analyze samples of suspect asbestos-containing material using polarized light microscopy (PLM). The bulk sample analysis was performed in accordance with EPA Method 600/R-93/116. Point counting was not included in our scope of work.

A total of 540 bulk samples were collected: 421 samples in Building 468, 58 samples in Building

824, and 61 samples in Building 5901. Copies of laboratory analyses reports and bulk sample

Chain of Custodies are included in Appendix D.

The following suspect materials (materials thought to possibly contain asbestos) were sampled during the survey.

5 28 April 2014

• 12”x12” floor tile with mastic

• 9” x 9” floor tile with mastic

• Cove base with mastic

• Drywall with joint compound

• 2 ’x 2’ ceiling tile

• 2’ x 4’ ceiling tile

• Wall Surfacing Material

• Putty (Fire stop)

• Caulking

• Duct mastics and wraps

• Vinyl sheet flooring

• Thermal System Insulation (TSI)

• Mortar

• Spray applied fire proofing

• Sink undercoating

• Vibration damper

• Expansion joint material

• Stair tread mastic

Building 824 (Dental Building)

• Cove base with mastic

• Drywall with joint compound

• Vinyl sheet flooring

• 2’x2’ ceiling tile

• Duct mastics/tapes

• Pipe and elbow insulation

• 12”x12” floor tiles with mastic

• Carpet with mastic

• Mortar

• Caulking

• Window sealant

• Surfacing material

• 2’x2’ ceiling tile

• Drywall with joint compound

• Cove base with mastic

• Carpet with mastic

• Mortar

• 12”x12” floor tile with mastic

• Duct mastic

• Pipe wrap

• Sink insulation

6 28 April 2014

2.4 CONCLUSIONS AND RECOMMENDATIONS (ASBESTOS)

The following materials were found to contain asbestos:

Building 468 (Keesler Hospital)

First Floor:

9” x 9” Vinyl Floor Tile Black floor tile mastic Black and White Duct Mastic

Third Floor:

12” x 12” Vinyl floor tile White and black duct mastic Thermal System Insulation (Custodial Closet)

Fifth Floor:

12” x 12” Vinyl floor tile White and black duct mastic Black floor tile mastic

Second Floor:

Black, beige and white duct/mastic 12” x 12” Vinyl Floor tile Black floor tile mastic Thermal System Insulation

Fourth Floor:

12” x 12” Vinyl floor tile Black floor tile mastic Black and white duct mastic Duct seam wrap Spray-applied texture Black sink undercoating

Black Duct Mastic Exterior Window Caulking Exterior Window Sealant

Refer to Appendix B, Table 1: Summary of Bulk Sample Positive Results for Asbestos-Containing

Materials for detailed information regarding sample location, ACM location, quantity, condition, and other information. It should be noted that the quantities provided in Table 1 are estimates only and should not be relied upon for cost estimation without verification. See Drawings 001 through 014 for Asbestos Location Plans.

2.4.1 GENERAL RECOMMENDATIONS

There are four recognized response actions to manage ACMs in buildings and abate potential hazards to human health and the environment:

• Removal

• Enclosure

• Encapsulation

7 28 April 2014

• Repair of damaged materials in conjunction with special Operations and Maintenance (O&M) and re-observation programs.

The selection of a particular response action should be based upon intended usage of the building, actual exposure rates and cost. The EPA has Federal regulations regarding asbestos removal associated with renovation and demolition projects conducted in “facilities” as defined in the regulations. The EPA NESHAP rule includes several important definitions. The definitions that greatly affect abatement alternatives are the categories of ACM. These categories are as follows:

• Friable ACM means any material that can be reduced to powder by hand pressure when dry.

• Category I Non-Friable ACM means packing, gaskets, resilient floor coverings and roofing products that contain more than one- percent asbestos.

• Category II Non-Friable ACM means any material, excluding Category I Non-Friable ACM that contains more than one- percent asbestos, and is not friable.

• Regulated ACM (RACM) includes all friable ACM; Category I Non-Friable ACM that will be or has been subject to sanding, grinding, cutting or abrading; Category I Non-Friable ACM that has become friable; and Category II Non-Friable ACM that has a high probability of becoming, or has become crumbled, pulverized, or reduced to a powder by forces expected to act on the material in the course of demolition or renovation operations.

OSHA also has rules which govern maintenance, renovation, or demolition work which impacts

ACM, including removal, in public and commercial buildings. The OSHA construction rules for asbestos establish four distinct classes of work. Each class of asbestos work requires specialized training and engineering controls. The OSHA classes of asbestos work are:

• Class I Asbestos Work means activities involving the removal of ACM insulation on mechanical systems (i.e. pipes, boilers, ducts, etc.) and applied to surfaces (i.e. fireproofing, acoustical treatments, and plaster).

• Class II Asbestos Work means activities involving the removal of materials which are not on mechanical systems or applied to surfaces (i.e. floor coverings, gypsum wallboard, mastics, roofing, etc.).

• Class III Asbestos Work means activities involving the disturbance, for maintenance purposes only, small amounts of ACM up to that amount which will fit in one waste bag.

• Class IV Asbestos Work means clean up of ACM dust and debris on construction projects.

2.4.2 SPECIFIC ASBESTOS RECOMMENDATIONS

Duct Mastics (Building 468 and Building 824)

The EPA NESHAP classifies these materials as Non-Friable Category I ACM. While these materials are non-friable, disturbance of the materials may render them friable. Removal as

RACM is required by NESHAP prior to any activities that subject this material to cutting, sanding, 8 28 April 2014 grinding, abrading, or otherwise rendering them friable during demolition activities. The OSHA

Construction Standard classifies disturbance, removal, or demolition of structures with this material as Class II asbestos work, which requires specialized training and engineering controls, etc. 11 Mississippi Administrative Code Part 2 Chapter 10 generally requires that a state licensed asbestos abatement contractor perform the removal, repair, or encapsulation of this type material.

Floor Coverings and Adhesive Mastics (Building 468)

The EPA NESHAP classifies these materials as Category I, non-friable ACM. Removal as RACM is required by NESHAP prior to any activities that subject this material to cutting, sanding, grinding, abrading, or otherwise rendering them friable during demolition activities. The OSHA

Construction Standard classifies disturbance, removal, or demolition of structures with this material as Class II asbestos work, which requires specialized training and engineering controls, Spray Applied Texture (Building 468)

The EPA NESHAP classifies these materials as Friable ACM. Removal as RACM is required by

NESHAP prior to any activities that disturb the material during demolition activities. The OSHA

Construction Standard classifies disturbance, removal, or demolition of structures with this material as Class I asbestos work, which requires specialized training and engineering controls, etc. 11 Mississippi Administrative Code Part 2 Chapter 10 generally requires that a state licensed asbestos abatement contractor perform the removal, repair, or encapsulation of this type of material.

Window Sealant and Window Caulking (Building 824)

The EPA NESHAP classifies these materials as Category I, non-friable ACM. Removal as RACM is required by NESHAP prior to any activities that subject this material to cutting, sanding, grinding, abrading, or otherwise rendering them friable during demolition activities. The OSHA

Construction Standard classifies disturbance, removal, or demolition of structures with this material as Class II asbestos work, which requires specialized training and engineering controls, 9 28 April 2014

2.4.3 STATE OF MISSISSIPPI ASBESTOS REGULATIONS

11 Mississippi Administrative Code Part 2 Chapter 10 generally requires that a state licensed asbestos abatement contractor perform the removal, repair, or encapsulation of the types of ACM identified in this report.

Notification Requirements

The State of Mississippi requires that prior to any demolition, renovation or asbestos abatement activities a ten working day written notification be completed. A State of Mississippi

Demolition/Renovation Notification Form must be completed and submitted to the MDEQ office in

Jackson, Mississippi.

2.4.4 INTERIM MEASURES

We recommend occupants of Building 468 and Building`824 be made aware of the presence of the ACM and also instructed to minimize disturbance of the material until removal. If removal is not cost effective at this time, we recommend that control measures be established for any other personnel who may enter the structure to minimize their exposure to asbestos. Also, periodic reassessment of the condition of the asbestos-containing materials should be undertaken and precautions and procedures should be in writing and be thoroughly documented. These features, in addition to others such as training, etc., can be implemented by the adoption of an Operations and Maintenance (O&M) Program.

2.4.5 LEGAL AND MEDICAL CONSIDERATIONS

Due to the health hazards and legal ramifications involved in asbestos exposure in public buildings, an interdisciplinary approach between the engineering, medical and legal communities should be involved when determining an asbestos control program. There is presently a tremendous amount of litigation in the courts concerning present and past asbestos exposure in public and private facilities, as well as in the workplace environment. One basis for much of the litigation stems from the lack of adequate notification by the building owner to building occupants/employees following the identification of asbestos in buildings. As a minimum, building owners should notify building employees, occupants, vendors, and others as required in the

OSHA Asbestos Standards (29 CFR 1910.1001 and 29 CFR 1926.1101). We recommend that you involve appropriate legal counsel in your asbestos control program to address these very important issues.

10 28 April 2014

If, during renovation activities, additional suspect ACMs are revealed, bulk samples should be obtained to determine asbestos content.

11 28 April 2014

3.0 PAINT CONTAINING LEAD (PCL) SURVEY

3.1 PURPOSE AND SCOPE

The EPA and MDEQ regulate the disposal of lead which, over a certain leachable threshold, is defined as a hazardous waste. OSHA regulates the protection of workers whose work may expose them to lead that may be inhaled or ingested. The purpose of the PCL testing was to identify the lead containing paint located in the renovation areas. Paint coatings visually representative (area/color) were evaluated during this testing.

3.2 LEAD TESTING PROCEDURES

Mr. James Marsh of AMEC performed the PCL survey between October 28 and 29, 2013. Mr.

Marsh is a State of Mississippi Lead Risk Assessor. The PCL testing was performed using the

Lead Paint Analyzer (LPA-1), manufactured by the Radiation Monitoring Devices (RMD). The

LPA-1 is a portable, in-situ test and measurement instrument that operates on the principal of X-

Ray Fluorescence.

During the testing of walls, the test equipment was placed on the wall at varying vertical heights

(high, middle, low). During the testing of the floors, the test equipment was placed near a corner of the floor surface. During the testing of ceilings, the equipment was placed near the center of the room/area being tested. The areas tested were chosen by Mr. Marsh based on accessibility.

The specific test locations are identified in Table 3: PCL Field Test Locations and Results in

Appendix B attached to this report.

We also obtained 10 paint chip samples for laboratory analysis. The purpose of the paint chip sample collection and analysis was to compare to the XRF readings as an accuracy check.

Appendix B, Table 2: PCL Laboratory Test Results summarizes the paint chip sample analysis.

Additional details of protocols utilized for the PCL survey are provided in Appendix C.

12 28 April 2014

3.3 TESTING CRITERIA AND RESULTS

During the testing 582 XRF tests were performed at the project site, 444 in the Hospital, 92 in the

Dental Clinic and 46 in the Arnold Mental Health Center. Table 3 in Appendix B identifies test locations and results of the testing.

We obtained 10 paint chips (six from Hospital and four from Dental Clinic) during the XRF testing for laboratory analysis for lead to quality control the XRF field test results. The result of that analysis is provided in Table 2: PCL Laboratory Test Results presented in Appendix B. Based on the results of the XRF testing (detectable concentrations) and analysis of the 10 paint chip samples, the following is a summary of testing results:

• 41 XRF tests showed detectable concentrations of lead (0.1 mg/cm2 and above) on tested coatings.

• Two of the six paint chips showed lead concentrations above the 2009 Consumer Product

Safety Commission (CPSC) definition of 90 parts per million (ppm) for lead-based paint.

• Thirteen XRF tests showed detectable concentrations of lead (0.1 mg/cm2 and above) on tested coatings.

• Two of the four paint chips showed lead concentrations above the 2009 Consumer

Product Safety Commission (CPSC) definition of 90 parts per million (ppm) for lead-based paint.

Two XRF tests showed detectable concentrations of lead (0.1 mg/cm2 and above) on tested coatings.

13 28 April 2014

3.4 CONCLUSIONS AND RECOMMENDATIONS

As a result of the field XRF testing and paint chip sample analysis it appears that lead containing coatings include the following:

Building 468 (Hospital)

Ground Floor:

• Hall at 027 West Drywall Wall

• Pediatrics N.W. Stair Handrail

• Pediatrics N.W. Stairwell Handrail Support

• Stairs GF-1 West Concrete Wall

• Stairs GF-1 Handrail

• Stairs GB-2 Handrail

• Escalator Ground Floor West Drywall Chase

First Floor:

• Stairs 1F-1 Metal Door

• Stairs 1F-1 South Concrete Wall

• Mechanical 1F400 West Concrete Wall

• Exam Room 1F-126 Wood Door

• Classroom 1F-118 East Drywall Wall

• Exam Room 1G-435 South Drywall Wall

• Hall @ 1G-410 West Drywall Wall

• Stairs 1B-1 Handrail

• 1B-408 (Men’s RR) Wall Tile

• 1B-407 (Ladies RR) Wall Tile

• 1A-126 Lobby Drywall Light Chase

Second Floor:

• South Elev Lobby North Wall Corner Guard

• Elev 1-4 Lobby East & West Concrete Walls

• Freight Elev Lobby East Concrete Wall

• Room 2B-131 Wood Door

• OR #3 Door Frame

• OR Hall @2C-135 North Wall

• OR Hall @2C-135 South Wall

• OR Hall @ OR #6 North Wall

Third Floor:

• Room 3C-125 East Plaster Wall

• Stairs 3B-2 West Concrete Wall

• Room 3B-140 South Drywall Wall

• Room 3B-140 East Plaster Wall

• Room 3B-123 North Plaster Wall

14 28 April 2014

Fourth Floor:

• Room 4A-176 East Drywall Wall

• Room 4A-167 South Drywall Wall

• Room 4A-139 West Drywall Wall

• Room 4A-139 Bath Drywall Ceiling

Fifth Floor:

• Room 5A-174 Wood Door

• Mech 5A-106 Wood Door

• Mech 5A-106 North Concrete Wall

• Mech 3C Metal Door

• Mech 6 Metal Door Frame

• Mech 6 Metal Door

• Mech 6 East Concrete Wall

• Mech 6 Roof Access Door Frame

• Elevator Loft Ladder Stringer

• Elevator Loft Ladder Handrail

• Elevator Loft Ladder Step

• H-79 Plaster Ceiling

• F-46 West Plaster Wall

• B-30 Metal Door Frame

• B-27 Metal Door Frame

• A-116 East Plaster Wall

• Dental Lab Waiting West Plaster Wall

• Room 129 South Plaster Wall

• Hall @ Room 14 South Plaster Wall

• South Entry Lobby East Brick Wall

• South Entry Lobby South Brick Wall

Building 5901 (Arnold Mental Health Center)

• Room B-01 Wood Door

• Occupational Therapy Lobby North Drywall Column

• Occupational Therapy East Drywall Wall

Within Building 468, we recommend all components coated with orange paint and ceramic wall tiles be assumed to be coated with PCL. The high lead concentrations on the OR hall walls appears to be related to leaded shielding rather than wall coatings based on the paint chip sample analysis results.

15 28 April 2014

Components with detectable lead concentrations may be impacted during renovations. Should renovations necessitate the removal of paint with detectable lead concentrations on components, the coatings or component would need to be removed by a contractor with lead experience and training. If the PCL coated components are to remain, the PCL can be managed in place using an Operations and Maintenance Program (OMP).

The OSHA regulations require that exposures to construction workers and general industry personnel be controlled by proper work procedures, proper worker training, respiratory training, etc. Any renovation/demolition actions should utilize the proper engineering controls and comply with the OSHA Construction Standards for Lead (29 CFR 1926.62).

Regarding PCL disposal, removed coatings and components should be segregated from the renovation/demolition waste stream and coatings tested for leachate lead in accordance with

Toxicity Characteristics Leachate Procedure (TCLP). If testing indicates the PCL waste is within acceptable levels the waste may be disposed as typical construction and demolition waste. If not, the waste may require disposal as a hazardous waste.

Metal building components removed intact can be exempt from TCLP testing, if removed and sent for recycling.

Any chips, dusts, contaminated soils and sludges containing lead based paint debris generated by renovation or demolition would have to be characterized and managed in accordance with the

RCRA hazardous waste rules.

Torch cutting metals coated with lead concentrations of concern should be avoided. Areas that must be torch cut to facilitate component removal should have the torch cut area coatings remove by a lead removal contractor prior to the torch cutting in compliance with the requirements of the

OSHA Lead Construction Standard.

16 28 April 2014

4.0 HAZARDOUS AND / OR REGULATED MATERIALS SURVEY

4.1 PURPOSE AND SCOPE

AMEC’s scope of services included performance of visual observations for other hazardous and regulated materials including mercury found in lighting components and switches, polychlorinated biphenyls (PCB) found in electrical insulating oils, and hydrocarbon fluids in mechanical equipment. The purpose of the observations is to provide an indication of the presence and extent of potentially hazardous or regulated building materials, equipment and fixtures (i.e.

components) within the three buildings planned for renovation or demolition.

4.2 FINDINGS

The following hazardous or regulated materials were identified on the site:

Building 468 (Hospital)

• Mercury-containing fluorescent lamps

• Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment

• Chlorofluorocarbons (CFCs) in water fountains, refrigerators, and HVAC equipment

• Fire extinguishers

• Batteries in exit signs, emergency lighting, clocks, and smoke detectors

• Lead lining in X-ray rooms

• Medical Air in operating areas

• Pharmaceuticals

• High intensity discharge lamps

• Petroleum Products in compressors and escalator equipment

Building 824 (Dental Clinic)

• Mercury-containing fluorescent lamps

• Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment

• Batteries in exit signs, emergency lights, clocks, and smoke detectors

• Chlorofluorocarbons (CFCs) in water fountains, refrigerators and HVAC equipment

• High intensity discharge lamps

• Fire extinguishers

• Pad-mounted transformer

• Petroleum Products in compressors and escalator equipment

• Mercury-containing fluorescent lamps

• Potential PCB containing electrical insulating fluids in lighting ballasts and electrical equipment

• Batteries in exit signs, emergency lights, clocks, and smoke detectors

• Chlorofluorocarbons (CFCs) in water fountains

17 28 April 2014

4.3 CONCLUSIONS AND RECOMMENDATIONS

The identified hazardous and regulated materials should be properly removed and handled before renovation and demolition activities begin in the buildings. A removal plan should be developed that includes worker training and protection, identification and removal procedures, storage, transport and disposal procedures. The following sections generally provide appropriate disposal options for the indentified materials.

Fluorescent Light Tubes

The suspect mercury-containing fluorescent lamps should be disposed of or recycled in accordance with 40 CFR Part 273, the Standards for Universal Waste Treatment, unless they are determined not to contain mercury by analysis or manufacturer’s documentation. If present, reliance on the green markings on light tubes designating lamps as “low mercury, non-hazardous” may be appropriate. Generally, these materials may be disposed of in a lined, sanitary (Class I) landfill. These materials cannot be disposed of as Construction and Demolition (C&D) waste in a

C&D (Class III) unlined landfill. Also, no mercury (of any concentration) lamps can be incinerated, therefore, in areas where waste is incinerated, disposal in said waste is not allowed. The responsible disposal option for fluorescent bulbs is recycling and arrangements should be made with an appropriate recycler.

High Intensity Discharge Lamps

High intensity discharge (HID) bulbs may contain mercury vapor, high pressure sodium, and metal halide lamps. The regulations governing the devices as a waste are the same as those documented above for fluorescent light tubes. HID lamp bulbs can be recycled and arrangements should be made with an appropriate recycler.

Lighting Ballasts, Electrical Equipment, Transformers

The suspect PCB-containing materials should also be disposed of or recycled in accordance with the Standards for Universal Waste Treatment and Toxic Substances Control Act (TSCA), 40 CFR

Part 261, unless they can be determined not to contain regulated concentrations of PCBs. The recommended disposal option is to collect all materials potentially containing electrical insulating fluids and recycle through an appropriate recycler.

18 28 April 2014

Batteries

Batteries may contain lead, nickel, and cadmium and their disposal is regulated by RCRA and the

MDEQ. Batteries may not be disposed of in a landfill or municipal waste incinerator.

Arrangements should be made for recycling with an appropriate waste recycler.

Lead Lining

X-ray rooms are suspected to be lined with rolled lead sheathing walls, ceilings, and floors.

Disposal of these materials is regulated by RCRA and the MDEQ. These materials should be recycled by an appropriate recycler.

Petroleum Products

Petroleum products including hydraulic fluids should be properly drained from equipment prior to dismantling. Petroleum product disposal is regulated by the MDEQ. Petroleum products should be recycled by an appropriate recycler.

Household Chemicals, Paints, and Solvents

Household chemicals, paints, and solvents are regulated by RCRA and the MDEQ. These materials may be disposed as special wastes at the local MDEQ permitted landfill, but must be segregated from the overall project waste stream.

Pharmaceuticals

Pharmaceuticals should be disposed in accordance with the proper manufacturer’s instructions and all applicable Federal, State and local regulations.

Chlorofluorocarbons (CFCs)

Refrigerants are regulated under Section 608 of the Clean Air Act. The State of Mississippi abides by Section 608 of the Clean Air Act and does not have state specific laws regarding CFCs.

During removal and disposal, refrigerants may not be knowingly vented to the atmosphere.

Instead, refrigerants should be recovered. Refrigerants should be reclaimed and recycled by a qualified CFC reclamation contractor prior to disturbance. Recycling of refrigerants should be performed in accordance with Section 40 CFR 82, Subpart F, Protection of Stratospheric Ozone

Recycling and Emission Radiation.

19 28 April 2014

Fire Extinguishers

The contents of fire extinguishers may be considered hazardous and the contents are often under pressure. Fire extinguishers should be collected from the renovation area and recycled.

20 28 April 2014

5.0 OBSERVATIONS FOR SUSPECT MOLD

5.1 PURPOSE AND SCOPE

AMEC’s scope of services included performance of visual observations for the presence of obvious suspect mold growth. No testing for the presence of mold was performed. Our observations were performed in readily accessible locations that coincided with our asbestos and

HRM survey. The purpose of the services was to document locations where suspect mold growth is present within the work areas.

5.2 FINDINGS

Suspect mold growth was observed in the survey areas as further described below:

Building 468 (Hospital)

Suspect mold growth was observed in Building 486 in the following areas: thermal system insulation, and duct insulation on HVAC Units located in mechanical rooms, and thermal system insulation above the drop ceiling in the vicinity of Room 1F232.

Building 824 (Dental Clinic)

None

5.3 CONCLUSIONS AND RECOMMENDATIONS

We recommend that additional investigation of the areas containing mold growth is performed to evaluate conditions that contribute to the mold growth. Remedying conditions that contribute to mold growth should be performed.

If the project impacts the areas of components containing mold growth, a remediation plan for the proper removal and/or cleaning of the materials should be developed and implemented.

APPENDIX A

FIGURES

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AMEC ENVIRONMENT & INFRASTRUCTURE, INC.

9211 NORTH DAVIS HIGHWAY

PENSACOLA, FLORIDA 32514

PH: (850) 478-8100 FX: (850) 478-0990

PROJECT NO: 6376-13-0046.02

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HOEFER WYSOCKI

ARCHITECTS

H oefer W ysocki A rchitects, L L

C

JE

D

U N

N + H

W A

12/10/2013 9:14:19 AMC:\Users\craneke\Documents\34111_A13_MATOC_Keesler_1st_Floor_craneke.rvt

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HOEFER WYSOCKI

ARCHITECTS

H oefer W ysocki A rchitects, L L

C

JE

D

U N

N + H

W A

12/10/2013 9:14:28…

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