Attachment 16 - NC2 IDIQ Seed Project HAZMAT Report.pdf

JBSF150049L

15 June 2015 appendix E

Hazardous Materials Report

LIMITED LEAD & ASBESTOS INSPECTIONS

Building 2792 Fort Sam Houston, Texas for Mr. Greg Belnap

CIV USAF AETC CV

AEHS, Inc.

4402 Center Gate San Antonio, Texas 78217

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

Asbestos and Lead Inspections AEHS, Inc.

Bldg 2792, Ft. Sam Houston, Texas Environmental, Health, and Safety Consulting March 2015

LIMITED ASBESTOS AND LEAD INSPECTIONS

Ft. Sam Houston, Texas

This report is divided into two sections corresponding to the consulting performed. The on-site inspections were performed by Matthew Louderback under the overall direction of Ronald M. Bishop. Matthew Louderback is a Texas Department of State Health Services (TDSHS) licensed Asbestos Inspector (No.

60-2816) and Lead Risk Assessor (No. 2070871). Ron Bishop is a TDSHS licensed Asbestos Consultant, Lead Project Designer, and Mold Consultant as well as a Certified Industrial Hygienist, Certified Safety Executive, Registered Sanitarian, Diplomate in Environmental Health, and Registered Environmental Professional, Registered Environmental Manager and Green Consultant.

A. ASBESTOS INSPECTION

1.0. GENERAL.

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

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

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

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

2.0. BACKGROUND.

2.1. AEHS, Inc. was contacted by Greg Belnap of Ft. Sam Houston concerning the need for Asbestos and Lead Inspections in Building 2792, Ft. Sam Houston, Texas.

2.2. The building houses offices, restrooms, and mechanical areas.

3.0. SCOPE OF WORK.

3.1. The asbestos inspection was performed on 26 March 2015 and consisted of visual assessments to determine the presence of suspect ACBM. Bulk samples of suspect ACBM (materials which possibly contain asbestos, as determined by an accredited EPA AHERA Building Inspector/Consultant) were collected. The visual inspection, bulk sampling, and inspection documentation was performed by Matthew Louderback [Asbestos Inspector - (No.

60-2816)]. The asbestos inspection was limited to the roof and associated materials.

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

3.3. The specific objectives of the survey were to:

• Perform a visual inspection and physical assessment following the Asbestos

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

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

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

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

4.0. DESCRIPTION.

4.1. The inspection was of the exterior roof only.

4.2. This building is scheduled for repair and renovation specifically to provide a new roof and repainting of the exterior of the building.

5.0. INVESTIGATIVE METHODS.

5.1. Visual Inspection.

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

5.1.2. The suspect ACBM consisted of: black mastic(over studs), roof parapet mastic, clay roof tile, roof felt, and built-up roof mastic/penetration mastic.

5.1.3. The roof did not contain “Pyrofill”.

5.2. Bulk Sampling.

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

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

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

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

• Trowelled on plaster of same texture and location.

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

• Office areas;

• Storage (warehousing) areas; and

• Living quarters.

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

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

5.3. Bulk Sample Analysis.

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

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

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

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

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

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

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

6.0. RESULTS OF INSPECTION.

6.1. Analytical Results. The analytical results from the inspection and chain of custody are at Appendix A. A total of fifteen (15) samples were collected which resulted in fourteen (14) analyses due to first positive stop.

6.2. Photographs. Photographs are at Appendix B.

6.3. Summary Positive Asbestos Containing Building Materials. The built-up roof mastic/penetration mastic contains 4% Chrysotile Asbestos.

7.0. ASSESSMENT.

7.1. Friable Asbestos Material. None.

7.2. Non-Friable Materials. Built-up roof mastic/penetration mastic – 3,500 square feet.

8.0. RECOMMENDATIONS.

8.1. Maintain a copy of this report with the project files.

8.2. The removal of roofing material containing asbestos falls under the purview of NESHAPS and OSHA; therefore, under NESHAPS, there can be no visible emissions during the removal.

8.3. The contractor will remove the built-up roofing/penetration mastic in accordance with OSHA’s 29 CFR 1926.1101 paragraphs (q)(8)(ii).

8.4. A TDSHS notification is required.

8.5. Specifications nor air monitoring are required.

9.0. COST ESTIMATE.

9.1. Notification - $175.00

9.2. Incremental cost differential for the removal of the ACM beyond the normal roof removal cost - $1500.00

B. LEAD BASE PAINT

1.0. GENERAL.

1.1. Background.

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

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

or indirectly by placing contaminated items into their mouths.

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

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

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

Table 1 Lead Standards

Standard/Regulation Level Remarks

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

HUD – 24 CFR Part 35 0.5% by weight

1.0 mg/cm2

NLLAP Accredited Lab

XRF

TELLR - Texas Environmental Lead Reduction Rules

0.5% by weight

1.0 mg/cm2

NLLAP Accredited Lab

XRF

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

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

Leaching Procedure

1.3. Lead Risk Assessment.

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

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

Table 2 Inspections/Risk Assessments

Inspections Risk Assessments

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

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

Identify the presence of lead base paint on all components

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

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

Consider information about past maintenance and management practices

Allow the owner to treat all lead hazards present

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

2.0. APPROACH.

2.1. Limited Inspection. A limited lead base paint inspection was conducted on 26 March 2015 of the exterior with particular concern for the exposed rafters and soffit.

2.2. Credentials.

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

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

2.3. Methodology. XRF measurements were taken at representative locations on interior painted surfaces in the area of concern. XRF Niton Model XLp 300A (Serial No. 10381) was used in the testing for lead base paint. Calibrations were performed prior to and after testing each building in accordance with Performance Characteristics Sheets (PCS). See Appendix C for a table of the results.

3.0. DISCUSSION/CONCLUSIONS.

3.1. The HUD/EPA guidance for target housing is 1 mg/cm2 while the Toxic Characteristic Leaching Procedure (TCLP) limit for lead is 5 parts per million (ppm).

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

4.0. RESULTS.

4.1. Thirty-three (33) measurements were made with the XRF for lead content.

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

o Exterior

• Exterior White Concrete Walls

• Exterior White Concrete Lower Walls

• Exterior White Metal Window Sashes

• Exterior White Concrete Window Sills

• Exterior Yellow Concrete Risers

• Exterior Yellow Concrete Stringers

• Exterior Brown Metal Pipes

• Exterior Beige Metal Window Bars

• Exterior HVAC Beige Rusted Metal Door Bars

• Exterior Brown Wood Casings

• Exterior Brown Wood Transoms

• Exterior Black Metal Hand Rails

• Exterior Black Metal Ladders

5.0. RECOMMENDATIONS.

5.1. Maintain a copy of this report with the project files.

5.2. Provide a copy of this report to the contractor and ensure they adhere to all requirements in 29 CFR 1926.62 to include training of personnel.

DISCLAIMER

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

Ronald M. Bishop, MPH, CIH ESH Consultant 31 March 2015

Appendix A

Asbestos Lab Results

Asbestos Bulk Analysis Report

Client:

Report Number:

Project/Test Address:

Client Number:

Reported Date:

Received Date:

Analyzed Date:

AEHS 03/30/2015

45-5371

03/30/2015

15-03-03590

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Ft. Sam Houston, Building 2792; San Antonio, TX

Laboratory Results Fax Number:

210-656-8499

4402 Center Gate San Antonio, TX 78217

03/30/2015

Layer Type AsbestosClient Sample Number

Other Materials

Lab Gross DescriptionLab Sample Number

Black Tar-Like;

Homogeneous

15-03-03590-001 BM-A1 100% Non-FibrousNAD

Black Tar-Like;

Homogeneous

15-03-03590-002 BM-A2 100% Non-FibrousNAD

Black Tar-Like;

Homogeneous

15-03-03590-003 BM-A3 100% Non-FibrousNAD

Black Tar-Like; Silver Paint-Like;

Inhomogeneous

15-03-03590-004 RPM-A4 2% Cellulose 98% Non-Fibrous

NAD

Black Tar-Like; Silver Paint-Like;

Inhomogeneous

15-03-03590-005 RPM-A5 2% Cellulose 98% Non-Fibrous

NAD

1 of 3Page

Black Tar-Like; Silver Paint-Like;

Inhomogeneous

15-03-03590-006 RPM-A6 2% Cellulose 98% Non-Fibrous

NAD

Red Cementitious;

Homogeneous

15-03-03590-007 CRT-A7 100% Non-FibrousNAD

Red Cementitious;

Homogeneous

15-03-03590-008 CRT-A8 100% Non-FibrousNAD

Red Cementitious;

Homogeneous

15-03-03590-009 CRT-A9 100% Non-FibrousNAD

Black Tar-Like; Fibrous;

Inhomogeneous

15-03-03590-010 RF-A10 35% Cellulose 65% Non-Fibrous

NAD

Black Tar-Like; Fibrous;

Inhomogeneous

15-03-03590-011 RF-A11 35% Cellulose 65% Non-Fibrous

NAD

Black Tar-Like; Fibrous;

Inhomogeneous

15-03-03590-012 RF-A12 35% Cellulose 65% Non-Fibrous

NAD

Black Tar-Like; Fibrous;

Inhomogeneous

15-03-03590-013 RM-A13 15% Fibrous Glass 85% Non-Fibrous

NAD

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:45-5371 15-03-03590

Ft. Sam Houston, Building 2792; San Antonio, TX

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

2 of 3Page

Black Tar-Like;

Homogeneous

15-03-03590-014 RM-A14 96% Non-Fibrous4% Chrysotile

4%Total Asbestos:

15-03-03590-015 RM-A15 Did Not Analyze (Positive Stop)

Tasha Eaddy

1% Asbestos

Analyst:

Reporting Limit:

Method:

QC Blank:

QC Sample:

Araceli Enzler

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

QA/QC Clerk

Reviewed By Authorized Signatory:

79-M22012-1

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. All information concerning sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection.

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

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

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

Environmental Hazards Services, L.L.C

Project/Test Address:

Client Number: Report Number:45-5371 15-03-03590

Ft. Sam Houston, Building 2792; San Antonio, TX

Other Materials

AsbestosLab Sample Number

Layer Type Lab Gross DescriptionClient Sample Number

3 of 3Page

Appendix B

Photographs

LIMITED LEAD & ASBESTOS INSPECTIONS

Ft. Sam Houston, Texas (Asbestos Pictures 1-6; Lead Pictures 7-11)

1. Front of Building Inspected 2. Built-up Roof Mastic –4% 3. Roof Penetration Mastic - 4% Chrysotile Asbestos Chrysotile Asbestos Select FLAT Roofing Areas Select Areas Roof Penetrations

4. Black Mastic(Over studs & 5. Roof Felt – No Asbestos 6. Ceramic Roof Tile – No Asbestos under roof tiles) – No Asbestos Detected (NAD) Detected (NAD) Detected (NAD) Various areas under tile Roof Area

7. Positive Beige Exterior 8. Positive Yellow Exterior 9. Positive Beige Exterior Concrete Walls Concrete Risers Metal Window Sashes

10. Positive Exterior HVAC 11. Positive Exterior Wood 12. Positive Exterior Metal Black Beige Rusted Metal Door Bars Brown Door Casing & Transom Hand Rail & Ladder

Appendix C

XRF Measurements

JBSA-Ft. Sam Houston B-2792

Lead Inspection Exterior Only No. Time Side Room Component Feature Substrate Cond Color Results PbC

1 3/26/2015 14:18 2.36 2 3/26/2015 15:29 Calibration Pos 1 3 3/26/2015 15:30 Calibration Pos 1 4 3/26/2015 15:33 Calibration Pos 1 5 3/26/2015 15:36 2792 Exterior Wall Concrete Det White Pos 4.6 6 3/26/2015 15:37 2792 Exterior Wall-lwr Concrete Det White Pos 11.5 7 3/26/2015 15:37 2792 Exterior Window Bars Metal Det Black Neg 0 8 3/26/2015 15:38 2792 Exterior Downspout Metal Det White Neg 0 9 3/26/2015 15:38 2792 Exterior Window Sash Metal Det White Pos 5.8

10 3/26/2015 15:39 2792 Exterior Window Sill Concrete Det White Pos 2.4 11 3/26/2015 15:39 2792 Exterior Stairs Tread Concrete Det White Neg 0 12 3/26/2015 15:40 2792 Exterior Stairs Riser Concrete Det Yellow Pos 4.7 13 3/26/2015 15:44 2792 Exterior Stairs Stringer Concrete Det Yellow Neg 0.7 14 3/26/2015 15:44 2792 Exterior Stairs Stringer Concrete Det Black Neg 0 15 3/26/2015 15:45 2792 Exterior Pipe Metal Det Yellow Neg 0.01 16 3/26/2015 15:46 2792 Exterior Pipe Metal Det Brown Neg 0.25 17 3/26/2015 15:46 2792 Exterior Hand Rail Metal Det Black Neg 0.01 18 3/26/2015 15:47 2792 Exterior Window Bars Metal Det Beige Pos 4.4 19 3/26/2015 15:49 2792 Exterior Door Metal Det Beige Neg 0.01 20 3/26/2015 15:49 2792 Exterior Door Casing Metal Det Beige Neg 0.01 21 3/26/2015 15:51 2792 Exterior Wall Concrete Det White Pos 12.4 22 3/26/2015 15:51 2792 Exterior Window Sash Metal Det Beige Neg 0.01 23 3/26/2015 15:52 2792 Exterior Door Metal Intact Beige Neg 0 24 3/26/2015 15:52 2792 Exterior Door Casing Metal Intact Beige Neg 0 25 3/26/2015 15:54 2792 Exterior Window Board Wood Intact Beige Neg -0.37 26 3/26/2015 15:54 2792 Exterior Wall CMU Intact White Neg 0.03 27 3/26/2015 15:55 2792 Exterior Door Bars Metal Intact Beige Pos 0.6 28 3/26/2015 15:56 2792 Exterior Window Bars Metal Intact White Neg 0 29 3/26/2015 15:57 2792 Exterior Door Wood Det Brown Neg 0 30 3/26/2015 15:57 2792 Exterior Door Casing Wood Det Brown Pos 1.9 31 3/26/2015 15:58 2792 Exterior Door Transom Wood Det Brown Pos 2.3 32 3/26/2015 16:00 2792 Exterior Vent Metal Det Brown Neg 0.01 33 3/26/2015 16:02 2792 Exterior Porch Ceiling Concrete Det Beige Neg 0 34 3/26/2015 16:17 2792 Exterior Hand Rail Metal Det Black Pos 2.5 35 3/26/2015 16:17 2792 Exterior Ladder Metal Det Black Pos 2.3 36 3/26/2015 16:20 2792 Exterior Rafter Wood Det Brown Neg 0.04 37 3/26/2015 16:21 2792 Exterior Soffit Wood Det Brown Neg 0 38 3/26/2015 16:27 Calibration Pos 1 39 3/26/2015 16:27 Calibration Pos 1.3 40 3/26/2015 16:28 Calibration Pos 1.1

Appendix D

Drawing

PRE-RENOVATION INSPECTION REPORT

SELECT HAZARDOUS/REGULATED MATERIALS

MEDCOM HQ BUILDING (2792) REPAIRS

FORT SAM HOUSTON

SAN ANTONIO, TEXAS

Prepared For:

ARMY CORP OF ENGINEERS

C/O

SHERLOCK, SMITH & ADAMS, INC.

P.O. BOX 11006

MONTGOMERY, ALABAMA 36111-0006

Conducted and Prepared by:

Safety Environmental Laboratories and Consulting, Inc.

3415 Lorna Lane

Birmingham, AL 35216

SELC PROJECT NUMBER 2008-972

Issued: August 2011

Inspector: Project Manager:

Elizabeth Hyde N. Glenn Ray, REM Environmental Specialist Director of Operations

Pre-Renovation Inspection Report of Select Hazardous/Regulated Materials August 2011 MEDCOM HQ Building (2792) Repairs - Ft. Sam Houston - San Antonio, TX SELC Project Number 2008-972 ii

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE OF SERVICES

2.0 PROJECT AREA DESCRIPTION

3.0 ASBESTOS INSPECTION AND SAMPLING RESULTS

3.1 FRIABLE ACM

3.2 NON FRIABLE ACM

4.0 LEAD CONTAINING PAINT INSPECTION AND SAMPLING RESULTS

4.1 LEAD PAINTS

4.2 LEAD DUST WIPES

5.0 PCB AND MERCURY INSPECTION RESULTS

6.0 OTHER HAZARDOUS / REGULATED MATERIALS

7.0 DEMOLITON WASTE STEAM CHARACTERIZATION

8.0 CONCLUSIONS AND RECOMMENDATIONS

9.0 ASSUMPTIONS AND LIMITATIONS

APPENDICES:

Appendix A Summary Table of Homogeneous Suspect Asbestos Materials

Appendix B Report of Laboratory Analysis for Asbestos

Appendix C SELC Lead Testing Data

Appendix D Previous XRF Testing Results (prepared by others) App D-1 Listing of Building Components Sorted by Location App D-2 Complete Listing of Testing Locations and Results

Appendix E Sample Location Drawings

Appendix F Lead Containing Waste Classification Guidance Documents

Appendix G Laboratory & Inspector Certification

1.0 PURPOSE AND SCOPE OF SERVICES

The purpose of this “Pre-Renovation Hazardous/Regulated Material Inspection" was to identify, locate, and quantify certain hazardous/regulated materials likely to be impacted by the proposed project titled “MEDCOM HQ Building (2792) Repairs, Fort Sam Houston, San Antonio, TX”.

Specifically, those materials to be addressed, within the subject project area, are as follows: 1) asbestos containing materials (ACM), 2) lead containing paints (LCP), 3) PCB containing lighting/electrical items, and 4) mercury containing lighting/electrical items. A summary of the scope of services to be provided by SELC is presented below:

a) Review any available records of previous hazmat surveys, specific material testing, and abatement activities.

b) Collect samples of accessible suspect building materials and paints (unless previously identified as ACM or LCP) that are anticipated to be demolished or significantly disturbed by the proposed project.

c) Perform visual inspections to provide information on the suspect material’s conditions, locations, and quantities.

d) Analyze representative bulk samples for asbestos content utilizing Polarized Light Microscopy (PLM) and Dispersion Staining Techniques performed in accordance with EPA Bulk Analysis Method EPA/600/R-93/116.

e) Analyze representative paint samples (if necessary) to determine lead content utilizing appropriate EPA SW 846 Methods or conduct paint testing with a portable XRF instrument.

f) Collect and analyze representative surface dust samples to determine lead content utilizing appropriate EPA SW 846 Methods.

g) Inspect electrical and lighting system components for the presence of mercury and PCB containing items.

h) Prepare a composite sample of building materials to represent the anticipated demolition waste stream and make a preliminary waste classification for lead containing waste by TCLP analysis. Alternatively, present data to support a “knowledge of process” waste classification using calculations involving XRF testing data and waste material volumes and/or mass.

i) Make recommendations (specific to the proposed work) as to response actions pertaining to those materials identified as containing PCBs, mercury, ACM, and those items coated with LCP.

j) Assist SSA with preparation of related design documents.

k) Compilation of a report (contained herein) which presents all sampling and analytical results, hazardous and regulated material descriptions, and generally identifies their locations and quantities in accordance with OSHA "Communication of Hazards" requirements.

2.0 PROJECT AREA DESCRIPTION

This pre-renovation inspection addressed all spaces on the basement, 1st, 2nd, 3rd, and 4th (attic) floors of Building 2792, the MEDCOM HQ. Building 2792 was constructed in 1939 as a troop barracks, but was later converted to an administrative building. Based upon our understanding of the project, the proposed work will essentially involve complete interior floor plan demolition and will include modifications to the perimeter walls and structural systems.

Perimeter/exterior walls are predominately structural clay tile finished with plaster on the interior and stucco on the exterior. Most interior walls are finished with painted gypsum board. Ceilings are predominately “lay in” acoustical tile and “T” grid system. The floors are mostly a mixture of carpet and vinyl composition floor tiles along with scattered ceramic tiles.

In addition to the architectural work, this project includes almost a complete replacement of electrical, plumbing, and mechanical systems. Various alterations and repairs are being made to the exterior such as roof eave repairs, entrance modifications, and repainting. Exterior work also includes underground utility, lighting, and landscaping modifications, mostly relatively near to the building.

3.0 ASBESTOS INSPECTION AND SAMPLING RESULTS

Appendix A contains a table listing descriptions of all suspect homogeneous materials, general locations of suspect materials, sample numbers corresponding to each homogeneous material, general sample analysis results, and a listing of sample collection sites (rooms). SELC collected 34 bulk samples in November 2008, and 138 bulk samples in October 2010, and 36 bulk samples in July 2011, for a total of 208 bulk samples. SELC analyzed all 208 bulk samples by the EPA’s standard PLM method. Also some samples were split and sent to Schnieder Laboratories, Inc. for comparison PLM analysis. Additional QA/QC work was performed by EMSL Analytical via TEM analysis of two samples. Details of all laboratory analysis can be found in Appendix B. Sample location plans can be found in Appendix E.

SELC’s investigation was basically non-destructive in nature. Therefore, only materials readily accessible within the project were evaluated. If any additional suspect materials are identified during future repair, renovation, or demolition they should be analyzed for asbestos content.

Each time suspect ACM was sampled; it was classified as either a friable or a non-friable material. Friable materials, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Friable ACM is potentially more hazardous than non-friable ACM because friable material can release airborne asbestos fibers more easily.

All bulk samples were analyzed at SELC’s Birmingham facility by polarized light microscopy utilizing dispersion staining and/or Becke line techniques in accordance with EPA method EPA/600/R-93/116 July 1993. This type of analysis requires the analyst to take a portion of the bulk sample and treat it with an oil of specific refractive index. The prepared slide is then subjected to a variety of optical tests. Percentages of the identified types of asbestos are determined by visual estimation. Even though this is a process of estimation, any material that contains greater than one percent of any type of fibrous asbestos is considered ACM and must be handled according to OSHA and EPA regulation if disturbed during maintenance, renovation, demolition or removal.

SELC participates in the U.S. EPA National Voluntary Laboratory Accreditation Program (NVLAP) for asbestos identification by polarized light microscopy. SELC is rated proficient under NVLAP’s quality assurance program and our accreditation number is 200873-0. Please see appropriate Certificates in Appendix G.

A narrative description of all "Friable ACM" and "Non-Friable ACM" identified during this inspection is given below.

3.1 FRIABLE ACM

Those ACM identified during this Pre-Renovation Inspection were classified as either friable or non-friable based upon their potential to be crumbled, pulverized or reduced to powder by hand pressure when dry. The following is a list of those ACM that can be crumbled, pulverized or reduced to powder by hand pressure when dry (i.e. friable):

ACM surface coating/paint found over non-friable ACM stucco, concrete, and plaster on exterior of building at all levels, including elevator shafts.

3.2 NON FRIABLE ACM

Based upon physical inspections the following ACM were classified as non-friable:

Grey/silver ACM undercoating applied to the bottom of a double basin stainless steel sink within wooden cabinetry found in Room G135A.

White window pane glazing putty on roll-out metal units in cupolas.

12”X 12” ACM vinyl composition floor tiles (light brown with white and brown marbling, & beige with tan marbling) and black ACM mastic. These are the two predominant types of floor tile in the building. They are easily identifiable in the main east/west corridors.

These tiles are also present in offices and misc spaces where it is often covered by carpet.

Black ACM flooring mastic found beneath carpet pad and carpet on the west side of the second floor.

Beige textured stucco-like surfacing ACM found on exterior of building. The exterior ACM stucco is approx. 1/8 thick and is covered by a thick layering of ACM paint. Exterior ACM stucco is present over non-ACM plaster/mortar on clay tile walls above the ground floor concrete foundation wall. It is located on floors 1 – 3 except areas on the south side of the building where former porches were located which are identifiable by areas with arched window openings. This ACM stucco is also present on the interior of the building along the north wall of the main E/W corridors which were originally part of the porches.

The ACM stucco is also present in the existing stacked mechanical rooms on floors 1 – 3 on the wall opposite the exterior wall. Scattered sections of beams and walls above ceilings and/or behind gypsum board are also still coated with the ACM stucco extending from the mechanical rooms southward to the end of the south wings where porches were formerly located. NOTE! This ACM is non-friable in its current intact condition.

However, the proposed interior demolition and certain exterior work will certainly crumble and/or pulverize the ACM stucco making it a Regulated ACM (RACM). Those work activities will have to be conducted as OSHA Class 1 asbestos work pursuant to 29 CFR

1926.1101 because the stucco is a surfacing ACM.

Off-white/beige ACM mastic applied to kraft-faced fiberglass insulation on floor drain pipes. These drains are AHU condensate drains and the insulated sections of piping are located underneath the slab/deck below the AHUs such that the ACM mastic is located on the ground through second floors.

Off-white mastic on kraft-faced fiberglass insulation on chilled water pipes in main central basement/ground floor mechanical room and as routed to air handler rooms. See note below.

Off-white mastic on kraft-faced fiberglass insulation on heating water pipes in main central basement/ground floor mechanical room and as routed to air handler rooms. See note below.

Off-white mastic on kraft-faced fiberglass insulation on domestic water pipes primarily located above ceilings in the main east/west corridors and some branches as routed to various fixtures. See note below.

NOTE! Most of the domestic water and HVAC piping are insulated with kraft-faced fiberglass that has mastic applied to various seams / joints; but it is generally located at fittings (bends, valves, Tees, ends, hangers, & controls). Generally the newer whiter types of mastic do not contain asbestos and the older off-white / beige types do contain asbestos. Therefore, along the main distribution routes where the two types are mixed it will be necessary to remove all pipe insulation mastic as ACM.

4.0 LEAD CONTAINING PAINT INSPECTION AND SAMPLING RESULTS

Information presented herein is based upon multiple sources as follows: 1) previous XRF testing data obtained from the Army, 2) limited paint chip testing conducted by SELC, and 3) limited dust wipe testing conducted by SELC.

In 1973, the Consumer Product Safety Commission (CPSC) established a maximum lead content in paint of 0.5% by weight in a dry film of newly applied paint. The CPSC lowered the allowable lead level in paint to 0.06% in 1978. To date the USEPA and HUD have developed the most comprehensive lead hazard identification and elimination programs which set the threshold lead level in paints at 0.5% lead by weight and 1.0 mg/cm² lead by area concentration.

However, the EPA and HUD standards do not apply to the work of this project. OSHA regulates occupational exposure to lead, but the allowable lead content in materials is not specified by that agency. However, directives from OSHA indicate that any detectable concentration of lead may trigger certain provisions of the Lead Standard 29 CFR 1926.62 depending upon the nature of the construction activities. As such employers are required by the 29 CFR 1926.62 to assume that where any lead is involved in workplace activities, the employees exposure will be above the action level, and shall protect them until an exposure assessment proves otherwise, unless they have recent (within 12 months) data for the same work under the same conditions.

4.1 LEAD PAINTS

For the purposes of this assessment all paints that contain greater than 0.5% by weight lead and/or 1.0 mg/cm² lead by area concentration are referred to as paints with relatively high lead concentrations. During SELC’s inspections, paint in poor condition (cracking or peeling) were noted in various locations. As a result, lead paint samples were collected from some spots representative of those conditions. However, the main source of lead testing data relied upon during this inspection is the previous XRF report prepared by another firm (refer to Appendix D).

SELC's lead paint testing data is included in Appendix C.

Below is a summary of paints/coatings sampled by SELC that exceeded the threshold of 0.5% by weight lead content.

Grey and yellow paint applied to concrete and plaster walls in mechanical rooms Lead Content - 5.8% to 7.2%

Cream paint applied to concrete beam and wall extending from floor to underside of deck above ceiling at former exterior porch areas, as indicated on 1930s drawings.

Those porch areas are now the main E/W corridor and mechanical rooms on 1st floor through 3rd floor. Also sections of the walls and/or beams are still present above ceilings and behind gypsum board in the spaces directly south of the mechanical rooms.

Lead Content - 8.9% to 10.0%

White / tan layered paint on exterior concrete walls, extending up to 1st floor elevation around entire building and from ground to roof at south side sections with arched window openings.

Lead Content - 0.11% to 17.6%

White / tan layered paint over textured stucco on clay tile exterior walls (1st floor through 3rd floor) above concrete foundation .

Lead Content - 0.21% to 4.4%

White / tan layered paint on metal downspouts.

Lead Content - 0.18% to 1.29%

White / tan layered paint over exterior of elevator shafts.

Lead Content - 9.0% to 18.1%

Paint applied to exterior basement windows.

Lead Content - 8.4%

Yellow paint applied to exterior concrete steps.

Lead Content - 5.3%

Black paint applied to exterior metal handrails.

Lead Content - 14.5%

Paint applied to exterior metal gate at chiller enclosure east of building.

Lead Content - 12.7%

Paint applied to handrails on attic access stair / ladder.

Lead Content - 20.4%

Paint applied to attic access stair / ladder steps.

Lead Content - 53.5%

Paint applied to metal air handling units.

Lead Content - 3.0%

Paint applied to exterior metal roof ladder and handrail.

Lead Content - 7.6%

Paint applied to exterior wooden eave components.

Lead Content - 0.649%

The previous XRF testing is summarized below. Copies of the XRF testing data is included as Appendix D. Specifically, Appendix D-1 contains a list of building components, sorted by location, that have detectable quantities of lead (greater 0.0 mg/cm2). Appendix D-2 provides all testing locations and associated lead concentrations. According to this data, lead was detected in coatings applied to the following building components:

Concrete columns, walls and ceilings: lead content ranges from 0.00 to 31.39 mg/cm² Metal doors & frames: lead content ranges from 0.00 to 14.14 mg/cm² Wood doors & frames: lead content ranges from 0.00 to 5.10 mg/cm² Concrete window aprons: lead content ranges from 0.01 to 12.69 mg/cm² Wood window components: lead content ranges from 0.00 to 7.73 mg/cm² Concrete window casings: lead content ranges from 0.00 to 8.83 mg/cm² Metal and concrete stair components: lead content ranges from 0.01 to 15.69 mg/cm² Elevator doors: lead content ranges from 0.01 to 0.07 mg/cm² Drywall walls and ceilings: lead content ranges from 0.00 to 15.69 mg/cm² Wood cabinets & counters: lead content ranges from 0.03 to 0.06 mg/cm² Exterior concrete walls: lead content ranges from 0.00 to 6.53 mg/cm² Exterior wood door casing: lead content ranges from 0.20 to 0.20 mg/cm² Exterior metal & concrete stair components: lead content ranges from 0.02 to 1.88 mg/cm² Exterior ground level metal window components & security bars: lead content ranges from 0.00 to 12.79 mg/cm²

4.2 LEAD DUST WIPES

In November 2008, SELC collected 7 dust wipe samples for the purpose of providing the contractor with additional information that might aid in the development of an initial exposure assessment and lead compliance program for this proposed project. SELC also collected a dust wipe sample during the July 2011 site visit. Wipe testing results are included in Appendix C. It should be noted that there are no regulatory standards for lead dust levels for military facilities;

however, the lead content in the dust on the attic ladder closet floor and atop the HVAC ducts above ceilings is far greater than the EPA & HUD hazards thresholds for any type of surface that would be accessible to children. The analytical results are as follows:

Lead dust atop HVAC ducts above ceilings = 1,100 to 1,700 ug/sf Lead dust atop drop tile ceilings = 20 to 170 ug/sf Lead dust atop light fixtures = <10 to 26 ug/sf Lead dust on attic stairwell floor = 3,340 ug/sf

5.0 PCB AND MERCURY INSPECTION RESULTS

SELC did not observe any major components of the electrical distribution system such as transformers that would likely contain elements with PCBs, but fluorescent light fixtures were observed. Almost all fluorescent light ballast manufactured prior to 1976 were the PCB oil types.

According to information obtained during this project it is our understanding that the building was constructed prior to 1976. Pursuant to 40 CFR 761, manufactures of those types of ballast were required after 1976 to provide labels with the words “No PCBs”. SELC examined a representative number of fluorescent light fixtures where applicable and accessible throughout the building. During the inspection, the light fixtures were opened and inspected for labels that would declare the light fixtures to be absent of PCB’s. Some of the ballasts were found to be labeled as PCB free; however, the majority of the ballasts appeared to be newer electronic types that don’t require said labeling. Given that it is common practice in active military buildings to have the lighting systems upgraded, especially within a building approximately 70 years old, it is unlikely that the building still contains any of the original ballast. All fluorescent light ballast should be carefully collected and packaged for recycling or disposal in accordance with “universal waste” regulations.

To this day most fluorescent lamps are manufactured with an internal coating that contains mercury. Even the green label lamps contain low concentrations of mercury. As such SELC’s investigation was limited simply to confirming that fluorescent fixtures are the main type of lighting at the subject buildings. All fluorescent lamps should be treated as mercury containing items and should be carefully collected and packaged for recycling or disposal in accordance with “universal waste” regulations.

6.0 OTHER HAZARDOUS / REGULATED MATERIALS

SELC did not conduct inspections for any other types of hazardous or regulated materials.

However, other regulated substances and/or items of environmental concern are likely to be present, such as batteries in various equipment and emergency lights, fire extinguishers, LED exit lights, hydraulic fluids, and various refrigerants (HVAC equipment & water fountains).

7.0 DEMOLITON WASTE STEAM CHARACTERIZATION

EPA regulations at 40 CFR 262.11 state that a person who generates a solid waste must determine if that waste is hazardous waste. One process for making that determination is to collect samples of the actual waste at the time of renovation/demolition and analyze those samples by the TCLP method. Another method that can be performed, prior to construction, is to collect representative samples of the materials that will be demolished/removed during renovation, and then composite those materials in ratios approximating the anticipated waste stream, and finally analyze the composite sample(s) by the TCLP method. A third option is to utilize “knowledge of the process” information, as authorized under 40 CFR 262.11 (c) (2), in lieu of TCLP testing. SELC offers the following information in lieu of TCLP testing during the project.

Most states will accept either of those approaches provided that the data and process used to make the waste determination are accurate, sensible, and clearly described and recorded. The basic approach to collecting building material samples and compositing them in ratios approximating their mass and/or volumetric proportions of the building or portions of building to be removed has been recognized by the Army Corp of Engineers for many years and was published in the Federal Register on January 17 and August 18, 1992. An Army protocol document describing the process is presented herewith in Appendix F. A detailed description of the “knowledge of process” methodology applicable to the subject situation is contained in the Connecticut Department of Environmental Protection, November 1994 document titled Guidance for the Management and Disposal of Lead Contaminated Materials Generated in the Lead Abatement, Renovation, and Demolition Industries. Relevant excerpts from that guidance document are also presented herewith in Appendix F.

Our experience with both of the procedures described in Appendix F, coupled with our knowledge of the lead in paint content at Building 2792, results in our conclusion that the demolition waste stream generated by the renovation work will not be hazardous with respect to leachable lead. Although there are some coatings present at the building that contain relatively high lead content, the average lead in paint content for all building surfaces / components will be relatively low. Given how thin paint coatings are, the end result is a very low lead mass in relation to the overall mass of the demolition debris. According to the Connecticut guidance, building debris waste streams containing coatings with an average of less than 10 mg/cm² typically do not fail the TCLP. Based upon that statement and our previous experience with this type of work, SELC concludes that a properly composited sample of the renovation/interior demolition waste stream cannot fail a TCLP analysis with respect to lead paint. The excerpts from the Connecticut guidance presented in Appendix F, coupled with the paint testing data presented in Appendices C and D, can be used to make the calculations necessary to provide appropriate “knowledge of process” documentation.

8.0 CONCLUSIONS AND RECOMMENDATIONS

The purpose of this inspection was to identify hazardous/regulated building materials that must be handled in specific manners in conjunction with the renovations / alterations designed by SSA, Inc. Because the simple presence of the identified ACM & LCP at Building 2792 does not constitute a regulatory or code violation there is no mandatory requirement to completely remove those materials.