Attach 07 Building Materials Inspection_Haz Mat Report.pdf
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- Demolition Bldg. 404, Offutt AFB, NE
- Solicitation number
- FA460025B0001
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This document is a Hazardous Building Materials Inspection Report for Building 404 at Offutt Air Force Base, prepared by AMI Environmental for Nielsen-Baumert Engineering. The comprehensive report details findings from inspections of asbestos, lead-based paint, and miscellaneous hazardous materials (MHBM) within the building scheduled for demolition. Key inspection findings include the presence of asbestos-containing materials in various building components, lead-based paint, and potential hazards such as mercury, batteries, and ozone-depleting substances.
The report provides detailed recommendations for safe handling and removal of hazardous materials, emphasizing regulatory compliance with OSHA and other applicable standards. Specific recommendations include proper asbestos removal protocols, lead-based paint management, and handling of universal and regulated wastes. The inspection supports the broader demolition project (Solicitation FA460025B0001) for Building 404, which is a 100% small business set-aside with a project magnitude between $1-5 million, located at Offutt Air Force Base in Nebraska.
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HAZARDOUS BUILDING MATERIALS INSPECTION
REPORT
Demolish B404
Project SGBP 19-0018
OFFUTT AFB
December 1, 2021 Revised February 28, 2022
Prepared for:
Nielsen-Baumert Engineering, Inc.
Omaha, NE
Prepared by:
AMI Environmental 8802 South 135th Street, Suite 100
Omaha, Nebraska 68138
AMIE # 21-186
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TABLE OF CONTENTS
1. SURVEY OVERVIEW
1.1. Purpose and Scope
1.1.1. Inspection Area
1.1.2. Limitations
1.2. Regulatory Reference
2. BUILDING INFORMATION
2.1. General Construction
2.2. Pre-Existing Information
3. INSPECTION METHODOLOGIES
3.1. Asbestos Inspection
3.1.1. Key Definitions
3.1.2. Homogenous Material Numbering Convention
3.1.3. Bulk Sampling
3.2. Lead-Based Paint Inspection
3.2.1. Key Definitions
3.2.2. Homogenous Paint Applications Numbering Convention
3.2.3. Paint Chip Sampling
3.3. Miscellaneous Hazardous Building Materials (MHBM)
3.3.1. Applicable Definitions
3.3.2. Visual Observation
4. SUMMARY OF INSPECTION FINDINGS
4.1. Asbestos Inspection Findings
4.2. Lead-Based Paint Inspection Findings
4.3. Miscellaneous Hazardous Materials
5. RISKS AND HAZARDS
5.1. Asbestos
5.2. Lead-Based Paint
5.3. Miscellaneous Hazardous Materials
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5.3.1. Mercury
5.3.2. Batteries
5.3.3. Ozone-Depleting Substances
6. RECOMMENDATIONS
6.1. General Recommendations
6.1.1. Asbestos
6.1.2. Lead-Based Paint
6.1.3. Universal & Regulated Wastes
6.2. Hazardous Conditions Recommendations
6.3. Point Count Analysis / TEM Chatfield Analysis Recommendations
7. REGULATORY REQUIREMENTS
7.1. Asbestos-Containing Materials
7.1.1. Notification Requirements
7.1.2. Asbestos Removal Requirements
7.1.3. OSHA Regulation of <1 Percent Asbestos
7.1.4. State of Nebraska Asbestos Removal Regulations
7.2. Lead-Based Paint
7.2.1. Disposal Requirements
7.2.2. Construction Requirements
7.3. Universal & Regulated Wastes
7.3.1. Disposal Requirements
APPENDIX A: Tables APPENDIX B: Photo Logs APPENDIX C: Analytical Results APPENDIX D: Inspectors’ Credentials APPENDIX E: Schematics
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HAZARDOUS MATERIALS REPORT
ASBESTOS AND LEAD-BASED PAINT INSPECTION
Project SGBP 19-0018
Offutt Air Force Base
Bellevue, Nebraska
February 28, 2022
1. SURVEY OVERVIEW
On November 10th, 12th, and 15th, 2021 and February 14, 2022, Building B404 located on Offutt AFB, Bellevue, Nebraska, was inspected for asbestos-containing material (ACM), lead-based paint (LBP), and other miscellaneous hazardous building materials by representatives from AMI Environmental (AMIE). The inspection was conducted in preparation for demolition of the building. The demolition project is hereinafter referred to as “The Project.” The inspection was initiated at the request of Mr.
Mark Stillmock, PE, of Nielsen-Baumert Engineering, Inc.
The inspection was directed by Mr. Colin Lauenroth and the sampling was performed by Brook Miller, Colin Lauenroth, and Dustin Wessel of AMIE in accordance with regulatory requirements, and generally accepted industry methods. Copies of applicable requisite training certificates for AMIE representatives are provided in Appendix D.
1.1. Purpose and Scope
The purpose and scope of the inspection was to sample and document suspect ACMs, LBPs, and other hazardous materials present in defined project area that may be impacted by The Project.
1.1.1. Inspection Area
The hazardous building materials inspection included all accessible interior and exterior areas of B404. The defined area for The Project is hereinafter referred to as the Inspection Area.
1.1.2. Limitations
At the discretion of the inspector(s), certain spaces may not have been inspected and/or samples not collected from materials that were not accessible at the time of the inspection.
Examples of suspect materials that may not have been accessible include those which may exist inside finished interior walls and ceilings, and/or materials in areas not accessible due to locked doors, physical barriers, and/or safety, security, and related concerns. Materials requiring specialized equipment to access (e.g. lifts) are also considered not accessible unless prior arrangements were made. These materials, if present, should be identified at the time of renovation or demolition. Sampling of these materials may not be necessary if, 90% Hazardous Material Report -
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February 28, 2022 Page 2 in the case of suspect ACM, the materials are assumed to be ACM or if they are determined by a licensed asbestos inspector to be homogenous to other materials that were sampled.
The following limitation was encountered during the inspection:
• Some materials that were reported asbestos containing were located above ceiling and within walls, therefor estimated quantities are an approximation based on the inspectors’ observations.
1.2. Regulatory Reference
The asbestos inspection was conducted in accordance with USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (ref.: 40 CFR, Part 61), following criteria established for identifying asbestos-containing building materials that may be impacted by planned renovation activities; applicable protocols established by the Asbestos Hazard Emergency Response Act (AHERA) (ref.: 40 CFR 763), and the State of Nebraska Department of Health and Human Services.
There is no licensing requirement for lead paint sampling in non-HUD facilities.
2. BUILDING INFORMATION
2.1. General Construction
Building 404 was a multi-use building consisting of one main floor, one basement, and a crawlspace located on the East side of the basement crawlspace.
2.2. Pre-Existing Information
No previous hazardous materials inspection and/or sampling information was available at the time of the inspection.
3. INSPECTION METHODOLOGIES
3.1. Asbestos Inspection
The asbestos inspection included visual identification and bulk sampling of suspect materials. The inspection and sampling were conducted in accordance with the USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (ref.: 40 CFR, Part 61), following criteria established for identifying asbestos-containing building materials that may be impacted by planned renovation. Additional aspects of the inspection methodology are discussed below.
3.1.1. Key Definitions
3.1.1.1. Homogenous Material
Homogenous materials are unique applications of building materials uniform in color and texture. The homogeneity of a material can be further defined by area(s) of application. Bulk sampling is conducted to determine the asbestos content of a homogenous material.
3.1.1.2. Asbestos-Containing Material (ACM)
The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) define ACMs as any material that contains greater than one
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February 28, 2022 Page 3 percent asbestos, as determined by visual area estimation (microscopic analysis). The State of Nebraska follows the EPA standard. Some materials contain one percent or less asbestos. While these materials are not ACMs by definition, they are still regulated by OSHA for worker exposure.
3.1.1.3. Friable/Non-Friable ACM
Friable ACMs are materials that contain more than one percent asbestos and, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure, thereby releasing fibers into the air more readily. In contrast, non-friable ACMs are ACMs that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACMs are grouped into two categories: Category I and Category
II.
3.1.1.4. Regulated Asbestos-Containing Materials (RACM)
Regulated Asbestos-Containing Materials (RACM) include friable ACMs and non-friable ACMs that, depending on their category, have become friable, have been subjected to specific forms of impact damage, have a high probability of becoming friable, and/or may become friable during removal.
3.1.2. Homogenous Material Numbering Convention
All suspect asbestos materials are assigned a unique homogeneous material number (HM#). The HM# begins with two or three letters, denoting the type of material, followed by a sequential number that is assigned to every material identified within each material type (example: ABC-01). The HM# is referenced throughout the report to uniquely identify each material. AHERA identifies three basic material types: Surfacing Materials (SM), which include spray and trowel applied materials, such as fireproofing, ceiling texture, plaster, etc.; Thermal System Insulation (TSI), which includes insulating materials applied to mechanical and plumbing components for temperature preservation and condensation prevention purposes; and Miscellaneous Materials (MM), which includes all other materials, such as floor coverings and mastics, roofing materials, asbestos cement products, and many others. When a homogenous material has multiple layers, individual layers are identified with a suffix, e.g. MM-03A, MM-03B, etc.
3.1.3. Bulk Sampling
Bulk sampling must be performed to determine whether a certain homogenous material contains asbestos. Asbestos bulk sampling for the inspection was conducted in accordance with protocols established by the Asbestos Hazard Emergency Response Act (AHERA) (ref.: 40 CFR 763). All suspect homogenous materials and associated sampling of these materials are identified in Table 1 – Asbestos Material Sampling Table. Suspect materials not sampled are assumed to be ACM until properly sampled and determined otherwise.
Some suspect materials, such as lab tabletops, roofing systems, TSI, etc., may not be sampled to preclude damage. Friability of the suspect asbestos-containing materials was determined by touching and/or sampling of the material.
3.1.3.1. Polarized Light Microscopy Analysis (PLM)
Bulk samples collected during the inspection were submitted to an EPA accredited laboratory, EMSL Analytical, Inc. (EMSL), located at 6340 Castleplace Dr, Indianapolis, IN 46250. EMSL was instructed to perform Polarized Light Microscopy (PLM) analysis, utilizing dispersion staining techniques (ref: EPA Method 600/M4-
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82-020). PLM analysis is the least expensive and most commonly used visual estimate method. While PLM analysis is acceptable to EPA, OSHA, and most states for determining asbestos content, some states now require more sophisticated methods when analyzing certain types of materials.
A total of 129 asbestos bulk samples were collected and submitted for laboratory analysis from homogeneous materials identified during the asbestos inspection. PLM analysis was performed on 95 additional heterogeneous applications identified in the homogeneous materials. Heterogeneous applications are individual layers of different materials contained within a single bulk sample, each of which must be analyzed individually to determine its asbestos content (e.g. vinyl floor tiles and mastic; cove base and mastic).
Some samples and/or heterogeneous applications may not have been analyzed by the lab if a positive result was obtained from a sample that is among a group of samples representing a suspect material. This process, known as “stop on first positive,” is followed because if a single sample is found to be positive, that material is determined to be ACM, thus making it unnecessary to analyze any additional samples in the sampling group.
Please refer to the Table 1 – Asbestos Material Sampling Table in Appendix A for a complete listing of all materials sampled. The laboratory analytical reports may be found in Appendix C.
3.1.3.2. Quantification Method Analysis
EPA regulations allow materials determined to contain less than 10 percent asbestos utilizing a visual estimate quantification method, such as PLM analysis, to be treated as non-asbestos containing only if the material is re-analyzed using one of two quantification methods and determined to contain one percent or less of asbestos. The two acceptable quantification methods are point count analysis and TEM Chatfield analysis.
Quantification methods are more time-consuming and more expensive analytical procedures that are occasionally used to more accurately determine the amount of asbestos in certain samples. Because of their higher cost and the acceptable accuracy of the less expensive visual estimation method, laboratories do not typically perform quantification analyses unless specifically requested.
The quantification method known as point count analysis is used for most ACM types, except floor tile. The organic matrix composition of floor tile precludes the use of point count analysis to more accurately determine asbestos amounts within a sample.
Therefore, TEM Chatfield analysis—which effectively removes all organic materials, leaving only asbestos behind—is necessary to provide a more precise percentage of asbestos content in floor tile.
Please refer to section 6.0 Recommendations, for recommendations concerning supplemental analysis.
3.2. Lead-Based Paint Inspection
The LBP inspection included visual identification of homogenous paint applications and bulk (chip) sampling of the paint(s). While the U. S. Department of Housing and Urban Development (HUD)
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3.2.1. Key Definitions
3.2.1.1. Homogenous Paint Applications
Homogenous paint applications are significant paint applications that are visually distinct by their color and uniformity. Significant paint applications do not include incidental occurrences of paint such as isolated occurrences of accent trim, artistic paints, etc. While visual inspection alone cannot generally identify sub-layers of paint, these applications are often identified during the chip sampling process.
3.2.1.2. Lead-Based Paint (LBP)
Pursuant to Federal Register, Vol. 61, No. 169, LBP is defined as paint or other surface coatings containing more than 0.5 percent lead by weight.
3.2.2. Homogenous Paint Applications Numbering Convention
Homogenous paints and coatings are assigned a unique homogeneous material number (HM#). For paints, the HM# begins with the associated IS Space number then “L,” followed by a sequential number that is assigned to every paint identified (e.g. L-01). The HM# is referenced throughout the report to uniquely identify each paint application.
3.2.3. Paint Chip Sampling
Paint Chip samples and ceramic tile samples were collected. A total of 33 paint chips were collected from significant and visually distinct paint applications identified during the lead paint inspection in the inspection area. The samples were submitted to EMSL for laboratory analysis, utilizing Flame Atomic Absorption Spectrophotometry (SW 846 3050B/7000B).
EMSL’s NLLAP (National Lead Laboratory Accreditation Program) and AIHA ELLAP (Environmental Lead Laboratory Accreditation Program) accreditation number is 157245.
Additionally X-Ray Fluorescence Spectroscopy (XRF) analysis was performed on 7 bulk ceramic tile samples using method 16 CFR 1303/CPSC-CH-E1003-09.1. The XRF analysis was conducted by EMSL Analytical, Inc.
Please refer to Table 2 – Lead Paint Sampling Table in Appendix A for a complete listing of the paint applications identified and sampled for lead. The laboratory’s analytical reports are provided in Appendix C.
3.3. Miscellaneous Hazardous Building Materials (MHBM)
There are no recognized standards or methodologies for conducting visual inspections of suspect MHBMs.
3.3.1. Applicable Definitions
MHBMs, some of which are known as universal wastes, are certain commonly occurring hazardous wastes that are subject to fewer regulatory requirements than regular hazardous wastes to encourage their proper handling and disposal. Certain equipment, components and substances commonly found in buildings are regulated as universal wastes when they are demolished, decommissioned, or disposed of (e.g. batteries, mercury containing
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February 28, 2022 Page 6 instruments, mercury florescent light tubes, PCB ballasts, etc.). Moreover, there are certain additional substances that are not, technically, regulated hazardous or universal wastes but which require special handling and disposal or recycling (e.g. Freon and other ozone depleting substances).
3.3.2. Visual Observation
Suspect miscellaneous hazardous materials observed in the building that may require special handing or disposal were recorded and quantified, but not sampled. Please refer to the Miscellaneous Hazardous Building Materials Table in Appendix A for additional information concerning the materials observed.
4. SUMMARY OF INSPECTION FINDINGS
Key findings of the hazardous building materials inspection are summarized below. Please refer to the Appendices for complete details of the inspection findings and supporting documentation.
4.1. Asbestos Inspection Findings
Asbestos was detected in suspect materials identified and sampled during the inspection. Below is a summary table of all asbestos containing materials:
Material #/ Description Location Sample Result Estimated Quantity
MM-01: Flooring Mastic / Black 1st floor, Northeast and
Northwest entrances 2 % Chrysotile 300 Square Feet (SF)
MM-05: Black Mastic Under 12”x12” Floor Tile
North side of main floor 2 % Chrysotile 1350 SF
MM-09: Black Mastic Under Rolled vinyl floor tile / Tan / Speckled
West side bathroom and laundry room on first floor
2 % Chrysotile 380 SF
MM-12: 9” x 9” Floor Tile / Gray and Black Mastic
South side of classroom 1 on main floor under gray carpet
5 % Chrysotile 210 SF
MM-13: 12” x 12” Floor Tile Gray- Blue, Black Mastic
Top floor classroom 3 south side and Classroom 2
5 % Chrysotile 850 SF
MM-14: 9” x 9” Floor Tile / Tan with brown streaks
Closet north of classroom 3 3 % Chrysotile 10 SF
MM-15: 9” x 9” Floor Tile / Green Southeast HVAC room on top floor 3 % Chrysotile 250 SF
TSI-09: Mudded Pipe Fitting Mastic / White
Mid basement, room in southeast corner
2 % Chrysotile 4 Each
MM-22: Gray Ceiling noise dampener mastic
Sub-Basement ceiling throughout
2 % Chrysotile 1600 SF
MM-23: Fiber optic penetration filler / Black
Northeast corner room mid basement in server room
2 % Chrysotile 2 Linear Feet (LF)
MM-25: 9” x 9” Floor Tile Light Green and Black Mastic
Main floor south storage room 2-3 % Chrysotile 1700 SF
MM-27: 12” x 12” Floor Tile Light Brown and Black Mastic
South Main floor room by southwest entrance
2 % Chrysotile 200 SF
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Material #/ Description Location Sample Result Estimated Quantity
MM-29: 12” x 12” Floor Tile / Midnight blue
West storage room on main floor
2 % Chrysotile 140 SF
TSI-11: Pipe Fittings / Beige / Cracked
West room of freezer door on main floor south side
60 % Chrysotile 6 Each
MM-30: Ceiling Panels (Transite) / Gray
Main floor washer and dryer area
20 % Chrysotile 2680 SF
TSI-12: HVAC mastic / Red South crawl space of Sub-basement 15 % Chrysotile 100 LF
TSI-13: Pipe Insulation Wrap / Beige and Mudded Insulation at Pipe
Hangers / Gray
Sub-basement south crawlspace
15 % Chrysotile 360 LF
TSI-14: Duct Insulation Wrap / White
North side Sub-basement 2 % Chrysotile 50 LF
MM-37: Concrete wall seam caulking / Gray
Throughout exterior near the foundation
2 % Chrysotile 100 LF
MM-38: Exterior Window Glazing / Gray
South exterior windows 3 % Chrysotile 200 LF
MM-42: Cementitious paneling / Gray (Transite)
Soffit throughout exterior 20 % Chrysotile 700 SF
MM-43: Roof Base Felt / Gray Roof throughout 20 % Chrysotile 20,000 SF
*Please refer to the Table 1 – Asbestos Material Sampling Table in Appendix A for a complete listing of all materials sampled. The laboratory analytical reports may be found in Appendix C.
4.2. Lead-Based Paint Inspection Findings
Lead-Based Paint was detected in paint applications identified during the inspection. Below is a summary table documenting all paint applications found to contain lead:
Sample Location Description Lab Result (% by Weight) Estimated Quantity
L-15 Basement, West Stairway Black Drywall Paint 0.56 20 SF
L-26 Basement, East
Mechanical Space Yellow Pipe Paint 5.3 220 LF
L-33 Southeast Exterior
Railing Brown Exterior Railing 7.8 20 LF
LA-4
West Restroom, Main
Floor Tan Wall Tile 2.94 (XRF) 120 SF
LA-7
South Restrooms (Men and Women’s), Main
Floor Yellow Floor Tile 51.8 (XRF) 200 SF
*Please refer to Table 2 – Lead Paint Sampling Table in Appendix A for a complete listing of the paint applications identified and sampled for lead. The laboratory’s analytical reports are provided in Appendix C.
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4.3. Miscellaneous Hazardous Materials
The inspection identified a variety of common equipment, components and/or substances that will require special handling and disposal or recycling at the time of demolition. These items are identified and quantified in Table 3- Miscellaneous Hazardous Materials Inventory found in Appendix A.
Photographic documentation of Miscellaneous Hazardous Materials are found in Appendix B.
5. RISKS AND HAZARDS
5.1. Asbestos
To be a significant health concern, asbestos fibers must be inhaled. When asbestos fibers are inhaled, they become lodged in the lung tissue or alveoli. Here they clog and scar the tissues, causing the walls of the alveoli to lose their elasticity and useful function in respiration. Asbestosis (scarring of the lung), lung cancer, and Mesothelioma (cancer of the lining of the chest or lining of the abdominal wall) are diseases associated with asbestos exposure. Risks and hazards increase with increased exposure. ACM condition, proximity to building occupants, building use, and other factors can influence the potential for asbestos fibers to become airborne, and therefore increase exposure risks.
5.2. Lead-Based Paint
Inhalation and ingestion are the major routes of lead exposure. Once in the body, lead is distributed via the bloodstream to red blood cells, soft-tissue, and bone. The kidneys and gastrointestinal (GI) tract eliminate lead in the body very slowly, while minute amounts are lost through perspiration.
Lead in the body can cause serious damage to the central and peripheral nervous system, the cardiovascular system, and the kidneys. Exposure to high concentrations of lead can cause learning and behavioral disabilities, convulsions, coma, and sometimes death. Children are especially vulnerable and susceptible to lead poisoning. Even low levels of exposure persisting during childhood are known to slow a child’s normal development and cause learning and behavioral problems.
Exposure to lead can result from deteriorating surfaces and activities mechanically impacting lead surfaces. Preventing exposure requires proper work practices, monitoring, disposal and personal protective equipment during demolition, alteration and friction producing activities.
5.3. Miscellaneous Hazardous Materials
5.3.1. Mercury
Exposure to mercury can cause coughing, bronchitis, pneumonia, tremor, insomnia, irritability, headaches, fatigue, weakness, stomatitis, weight loss, GI disorder, and can irritate the skin and eyes. Exposure to mercury can occur through inhalation, ingestion, or absorption through the skin.
The most common routes are inhalation and ingestion.
While mercury lamps contain only a small fraction of mercury vapor, the vapor readily escapes when the bulb is broken The risk of mercury exposure is generally considered low to moderate, most of the risk is associated with the potential for light tubes, HID lamps and thermostat switch tubes to break during handling.
5.3.2. Batteries
Exposure to the hazardous substances in batteries can lead to severe skin burns, blindness, dermatitis, and cancer, and can cause damages to the kidney, lungs, brain, and nervous system. The
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February 28, 2022 Page 9 risk of exposure to personnel removing batteries containing hazardous substances is low, if properly handled. Improperly handling batteries during removal can lead to the batteries leaking or exploding of its contents, causing internal and external burns and irritations
5.3.3. Ozone-Depleting Substances
Freon is a tradename that has become synonymous with ozone-depleting substances used for air conditioning and cooling. The most serious side effect of Freon exposure would occur at the time of initial exposure. People who have a history of heart problems should be very concerned about Freon, because it can cause cardiac arrhythmia (irregular heartbeat), and palpitations at very high concentrations. For people who have a history of heart problems, being exposed to small amounts of Freon from leaking appliances should not pose any significant health risk.
Fortunately, Freon does not have serious, long-term health consequences. It is not a carcinogen, teratogen, or mutagen, and it does not damage the liver. When it is inhaled, it is rapidly excreted by exhalation, and it is not significantly accumulated in the body. This means that breathing low concentrations of Freon from a leaking refrigerator or air conditioner over a long period of time is unlikely to have a cumulative effect, and thus few, if any, long term health effects.
The risk of exposure to personnel recovering ODSs is extremely low.
6. RECOMMENDATIONS
The purpose of this section is to interpret survey findings and provide preliminary recommendations that may be relevant and appropriate at this time. Because this document is a presentation of investigative findings, recommendations related to future construction activities are inherently general in nature. More specific determinations concerning hazardous building materials to be impacted by construction should be made during the abatement project design process.
6.1. General Recommendations
6.1.1. Asbestos
State and/or federal regulations require that ACMs be removed prior to demolition or renovation activities that will impact the ACMs.
6.1.2. Lead-Based Paint
Facility owners are ultimately liable for their lead-containing hazardous waste from cradle to grave. EPA regulations provide two ways to determine whether a waste stream, such as demolition debris containing LBP, must be classified as hazardous waste. Waste generators can either test the waste using an approved testing method (Toxicity Characteristic Leaching Procedure [TCLP]), or they can apply knowledge of the hazardous characteristic of the waste.
AMIE recommends TCLP testing be conducted on the existing building materials, painted and unpainted, prior to the start of renovation or demolition activity to document that the waste stream is acceptable for disposal of as non-hazardous waste. In addition, trade contractors who work in the facility should be notified of the presence of paints containing lead so that they can appropriately monitor and protect their workers against lead exposure.
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6.1.3. Universal & Regulated Wastes
Universal Wastes (UWs) and other potentially regulated hazardous wastes require proper handling and disposal methods when no longer in use or prior to completing a renovation/demolition. As per 40 Code of Federal Regulations (CFR) 261 Subpart C, Universal Wastes (UWs) and other potentially regulated and hazardous wastes include any of the following six wastes that have at least one hazardous characteristic: batteries, pesticides, thermostats, cathode ray tubes, mercury containing devices, and mercury-containing lamps (e.gs., fluorescent tubes). These wastes and potentially regulated wastes must be handled, transported, and disposed of in accordance with applicable regulations.
6.2. Hazardous Conditions Recommendations
Potentially hazardous conditions were observed in the building and are described below. The conditions described are not intended to be a complete assessment of potential hazards. Additional hazards may be present:
• Visible mold was observed throughout the building.
6.3. Point Count Analysis / TEM Chatfield Analysis Recommendations No additional laboratory analysis is recommended.
7. REGULATORY REQUIREMENTS
7.1. Asbestos-Containing Materials
The removal and disposal of ACMs is regulated at the federal, state, and, sometimes, local level. While some states have developed their own regulatory standards for the various asbestos disciplines, many states have adopted the federal standards but have established licensing requirements and enforcement authority at the state level.
7.1.1. Notification Requirements
EPA’s NESHAP regulation, 40 CFR, Subpart M, 61.145, Standard for Demolition and Renovation, stipulates that an owner of a facility submit proper notification with either the EPA’s regional office and/or the state and local regulatory agency of intention to demolish or renovate. Notifications must be received by the appropriate regulatory agencies 10 working days prior to commencement of asbestos stripping or removal, or other site work.
If the demolition or renovation date changes, or the scope of work is increased by more than 20 percent, another notification must be made.
7.1.2. Asbestos Removal Requirements
Asbestos removal must be performed by a licensed abatement contractor. The contractor should follow all work practices, worker protection, and disposal requirements set forth in the contract specifications and by the Occupational Safety and Health Administration (OSHA) and the EPA. Key federal regulations concerning asbestos include 29 CFR 1910.1001, 29 CFR 1926.1101, 40 CFR Part 61, Subpart M, and 40 CFR 763.
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7.1.3. OSHA Regulation of <1 Percent Asbestos
While EPA and many states do not regulate materials containing less than one percent asbestos, OSHA regulates materials containing any amount of asbestos. (Ref. OSHA Construction Industry Standard, 29 CFR 1926.1101(a)(3))
7.1.4. State of Nebraska Asbestos Removal Regulations
State of Nebraska regulates the removal of friable asbestos-containing materials and non-friable asbestos containing materials that may become friable during removal, when affected quantities are greater than three square or three linear feet. For a complete understanding of the Nebraska governing asbestos projects, refer to Title 178, Chapter 22.
7.2. Lead-Based Paint
7.2.1. Disposal Requirements
The Resource Conservation and Recovery Act (RCRA) classifies lead-containing waste streams as hazardous materials if TCLP levels exceed five parts per million. If TCLP leachable lead levels exceed that threshold, EPA regulations (40 CFR 261) require the waste stream to be handled and disposed of as a hazardous waste. Waste streams containing less the five parts per million of leachable lead are classified as non-hazardous waste and can be disposed of in a construction and demolition landfill.
7.2.2. Construction Requirements
OSHA’s 29 CFR 1926.62 regulates worker exposure to lead during construction activities that include demolition or salvage of structures where lead or materials containing lead are present, as well as removal or encapsulation of lead-containing materials. The standard establishes maximum limits of exposure to lead, including a permissible exposure limit and action level, and should be adhered to during construction and demolition activities.
7.3. Universal & Regulated Wastes
7.3.1. Disposal Requirements
Mercury-containing items and PCB ballasts will require proper removal and disposal in accordance with EPA regulations listed in 40 CFR Part 273. As per 40 CFR 261 Subpart C, Universal Wastes require proper handling and disposal methods when no longer in use, prior to completing any demolition activities.
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 14 of 122
APPENDIX A
Table 1 Asbestos Material Sampling Results
Table 2 Lead Materials Sampling Results
Table 3 Misc. Hazardous Building
Materials Inventory
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 15 of 122
Table I
Table 1: Asbestos-Containing Material Sampling Table & Test Results Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-01: Flooring Mastic / Black 01A
Black
1st floor northeast and northwest entrance
2 % Chrysotile Fair N 300 SF 1
MM-01: Flooring Mastic / Black /
Dots 01B
Tan/ Black
1st floor northeast and northwest entrance
<1 % Chrysotile
SM-01: Popcorn Ceiling / White /
Rough 02A Brown/
White Northeast entrance
None Detected
SM-01: Popcorn Ceiling / White /
Rough 02B
White Northeast entrance
MM-02: Gypsum
Wallboard Composite /
White 03A Drywall Brown/ White
Throughout building
Wallboard Composite /
White 03A Joint
Compound White Throughout building
Wallboard Composite /
White 03B Brown/ White
Throughout building
Wallboard Composite /
White 03C Drywall Brown/ White
Throughout building
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 16 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-02: Gypsum Wallboard
Composite / White 03C
Joint Compound White
Throughout building
Wallboard Composite /
White 03D Drywall Brown/ White
Throughout building
Wallboard Composite /
White 03D Joint
Compound White Throughout building
MM-03: 12” x 12”
Ceiling Tile / White 04A Gray
Throughout building
MM-03: 12” x 12”
Ceiling Tile / White 04B
Gray/ White
Throughout building
MM-04: Base cover 4” / Tan 05 Mastic Tan
Throughout north side of the main floor cover 4” / Tan 05 Base Cove Tan
Throughout north side of the main floor cover 4” / Tan 05B Mastic Brown
Throughout north side of the main floor cover 4” / Tan 05B Base Cove Tan
Throughout north side of the main floor
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 17 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-05: 12” x 12” Floor Tile / tan with gray streaks 06A Mastic Black North side of main floor 2 %
Chrysotile Good N 1350 SF 6 MM-05: 12” x 12”
Floor Tile / tan with gray streaks 06A Floor Tile White
North side of main floor
None Detected 6
MM-05: 12” x 12” Floor Tile / tan with gray streaks 06B Floor Tile Gray North side of main floor None
Detected 6 MM-05: 12” x
12” Floor Tile / tan with gray streaks 06B Mastic Black North side of main floor 3 %
Chrysotile Good N
Included above, sample
06A 6 MM-05: 12” x 12”
Floor Tile / tan with gray streaks 06B Mastic Tan
North side of main floor
TSI-01: Batting
Insulation / White 07A Insulation White
North side of main floor
Insulation / White 07A
Tar Paper Brown North side of main floor
Insulation / White 07B Insulation Gray
North side of main floor
Insulation / White 07B Paper
Brown/ Black
North side of main floor
TSI-02: Duct Insulation /
Yellow 08A Insulation Yellow North side of main floor
Insulation /
Yellow 08A Sealant White North side of main floor
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 18 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
TSI-02: Duct Insulation /
Yellow 08B Wrap White/S ilver HVAC SE Room
Insulation /
Yellow 08B Insulation Yellow HVAC SE Room
MM-06: Mastic Adhesive / Tan 09A
Ceramic Tile Yellow
North janitor closet
Adhesive / Tan 09A
Mastic Tan North janitor closet
Adhesive / Tan 09B
Tan
North janitor closet
TSI-03: Tar wrapping / Black 10A
North side of main floor by HVAC units
TSI-03: Tar wrapping / Black 10B
North side of main floor by HVAC units
TSI-04: Duct mastic / Yellow
Yellow
North side throughout main floor
SM-02: Wall
Texture / Beige 12A Brown/
White Northwest main floor
SM-02: Wall
Texture / Beige 12B
White Northwest main floor
MM-07: Rolled vinyl tile / Gray 13A Mastic White
Northwest main floor vinyl tile / Gray 13A Vinyl tile
Brown/ Gray/ White
Northwest first floor
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 19 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-07: Rolled vinyl tile / Gray 13B Vinyl Tile Gray
Northwest first floor vinyl tile / Gray 13B Mastic Yellow
Northwest main floor
MM-08: 12” x 12” Ceiling Tile / White / Dots 15A
Brown
Daycare center throughout on the first floor
MM-08: 12” x 12”
Ceiling Tile / White / Dots 15B
Brown/ White
Daycare center throughout None
MM-09: Rolled vinyl floor tile / Tan / Speckled 16A Mastic Black
West side bathroom and laundry room on first floor vinyl floor tile / Tan / Speckled 16A Floor Tile
Tan/ White
West side bathroom and laundry room on first floor vinyl floor tile / Tan / Speckled 16B Mastic Black
West side bathroom and laundry room on first floor
2 % Chrysotile Good N 380 SF 15
MM-09: Rolled vinyl floor tile / Tan / Speckled 16B Floor Tile
Gray/ Tan/ Pink
West side bathroom and laundry room on first floor
MM-10: 4” Base cover / Black 17A
Base Cover Black
Throughout west entrance in main floor
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 20 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-10: 4” Base cover / Black 17A Mastic Tan
Throughout west entrance in main floor cover / Black 17B Mastic Tan
Throughout west entrance in main floor cover / Black 17B
Base Cover Black
Throughout west entrance in main floor
TSI-05: Duct
Insulation / White / Squares 18A Wrap
White/ Silver
Classroom 1 main floor
Insulation / White / Squares 18A Insulation Yellow
Classroom 1 main floor
Insulation / White / Squares 18B Wrap
White/ Silver
Classroom 1 main floor
Insulation / White / Squares 18B Insulation Yellow
Classroom 1 main floor
MM-11: 12” x 12” Floor Tile / Gray and Red / 2 layers 19A Mastic Yellow
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19A Floor Tile Gray
Classroom 1 north side
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 21 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-11: 12” x 12” Floor Tile / Gray and Red / 2 layers 19A Floor Tile Red
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19A Mastic Black
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19B Floor Tile Red
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19B Mastic Black
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19B Mastic Yellow
Classroom 1 north side
Floor Tile / Gray and Red / 2 layers 19B Floor Tile Gray
Classroom 1 north side
MM-12: 9” x 9” Floor Tile / Gray 20A Floor Tile Gray
South side of classroom 1 on main floor under gray carpet 5 %
Chrysotile Fair N 210 SF 19
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 22 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-12: 9” x 9” Floor Tile / Gray 20A Mastic
Blue/ Yellow
South side of classroom 1 on main floor under gray carpet None
Detected 19
MM-12: 9” x 9” Floor Tile / Gray 20A Mastic Black
South side of classroom 1 on main floor under gray carpet None
Detected 19
MM-12: 9” x 9” Floor Tile / Gray 20B Mastic Black
South side of classroom 1 on main floor under gray carpet None
Detected 19
MM-12: 9” x 9” Floor Tile / Gray 20B Floor Tile Gray
South side of classroom 1 on main floor under gray carpet 5 %
Chrysotile Fair N
Included above, sample
20A 19
MM-12: 9” x 9” Floor Tile / Gray 20B Mastic Yellow
South side of classroom 1 on main floor under gray carpet
MM-13: 12” x 12”
Floor Tile / Grayish /blue / 3 layers 21A Floor Tile Blue
Top floor classroom 3 south side and Classroom 2
None Detected 20
MM-13: 12” x 12” Floor Tile /
Grayish /blue / 3 layers 21A Floor Tile Red
Top floor classroom 3 south side and Classroom 2
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 23 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-13: 12” x 12” Floor Tile /
Grayish /blue / 3 layers 21A Mastic Black
Top floor classroom 3 south side and Classroom 2
MM-13: 12” x
12” Floor Tile / Grayish /blue / 3 layers 21A Floor Tile Brown
Top floor classroom 3 south side and Classroom 2
5 % Chrysotile Good N 850 SF 20
MM-13: 12” x 12” Floor Tile /
Grayish /blue / 3 layers 21A Mastic Yellow
Top floor classroom 3 south side and Classroom 2
12” Floor Tile / Grayish /blue / 3 layers 21B Floor Tile Green
Top floor classroom 3 south side and Classroom 2
3 % Chrysotile Good N
Included above, sample
21A 20 MM-13: 12” x 12”
Floor Tile / Grayish /blue / 3 layers 21B Mastic Yellow
Top floor classroom 3 south side and Classroom 2
12” Floor Tile / Grayish /blue / 3 layers 21B Mastic Black
Top floor classroom 3 south side and Classroom 2
2 % Chrysotile Good N
Included above, sample
21A 20 MM-13: 12” x 12”
Floor Tile / Grayish /blue / 3 layers 21B Floor Tile Red
Top floor classroom 3 south side and Classroom 2
MM-13: 12” x 12”
Floor Tile / 21B Floor Tile Blue Top floor classroom 3
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 24 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
Grayish /blue / 3 layers south side and Classroom 2
MM-13: 12” x 12” Floor Tile /
Grayish /blue / 3 layers 21B Mastic Black
Top floor classroom 3 south side and Classroom 2
MM-14: 9” x 9” Floor Tile / Tan with brown streaks 22A Floor Tile Brown
Closet north of classroom 3
3 % Chrysotile Good N 10 SF 21
MM-14: 9” x 9” Floor Tile / Tan with brown streaks 22A Mastic Black
Closet north of classroom 3
None Detected 21
MM-14: 9” x 9” Floor Tile / Tan with brown streaks 22B Floor Tile Brown
Closet north of classroom 3
3 % Chrysotile Good N
Included above, sample
22A 21 MM-14: 9” x 9” Floor Tile / Tan with brown streaks 22B Mastic Black
Closet north of classroom 3
None Detected 21
MM-15: 9” x 9” Floor Tile /
Green 23A Floor Tile Green
Southeast HVAC room on top floor 3 %
Chrysotile Good N 250 SF 22 MM-15: 9” x 9”
Floor Tile / Green 23A Mastic Black Southeast HVAC room on top floor
None Detected 22
MM-15: 9” x 9” Floor Tile /
Green 23B Floor Tile Green
Southeast HAVC room on top floor 3 %
Chrysotile Good N
Included above, sample
23A 22
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 25 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
MM-15: 9 x 9 Floor Tile / Green 23B Mastic Black
Southeast HAVC room on top floor
None Detected 22
TSI-06: Thermal Paper Products /
Black 24A
White/ Black/ Silver
Southeast HVAC room on top floor None
Detected 23 TSI-06: Thermal Paper Products /
Black 24B White/ Black
Southeast HVAC room on top floor None
Detected 23 TSI-07: Duct
Insulation / Gray 25A Wrap Black HVAC southwest room on top floor
None Detected 24
TSI-07: Duct Insulation / Gray 25A Insulation Gray
HVAC southwest room on top floor
None Detected 24
SM-03: Wall Texture / White 26A White
West stairway landing at mid basement <1 %
Chrysotile 25
SM-03: Wall Texture / White 26B White
West stairway landing at mid basement <1 %
Chrysotile 25
MM-16: 12” x 12” Floor Tile / Beige 27A Floor Tile
Gray/ Beige
North room west of mid basement stairway None
Detected 26
MM-16: 12” x 12” Floor Tile / Beige 27A Mastic Yellow
North room west of mid basement stairway None
Detected 26
MM-16: 12” x 12” Floor Tile / Beige 27B Floor Tile
Gray/ Beige
North room west of mid basement stairway None
Detected 26
MM-16: 12” x 12” Floor Tile / Beige 27B Mastic Yellow
North room west of mid basement stairway None
Detected 26
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 26 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
TSI-08: HVAC
dampener / Black/white 28A
White/ Black
HVAC room at north side of mid basement None
Detected 27
TSI-08: HVAC
dampener / Black/white 28B
White/B lack
HVAC room at north side of mid basement None
Detected 27 MM-17: Wood panel adhesive 29A Brown
West exit of mid basement
None Detected 28
MM-17: Wood panel adhesive 29B Brown
West exit of mid basement
None Detected 28
MM-18: 12” x 12” Floor Tile / Gray /
Thin 30A Mastic Tan east center mid basement with green carpet tile None
Detected 29 MM-18: 12” x 12” Floor Tile / Gray /
Thin 30A Floor Tile Gray east center mid basement with green carpet tile None
Detected 29 MM-18: 12” x 12” Floor Tile / Gray /
Thin 30A Mastic Black east center mid basement with green carpet tile None
Detected 29 MM-18: 12” x 12” Floor Tile / Gray /
Thin 30B Mastic Tan east center mid basement with green carpet tile None
Detected 29 MM-18: 12” x 12” Floor Tile / Gray /
Thin 30B Floor Tile Gray east center mid basement with green carpet tile None
Detected 29 MM-18: 12” x 12” Floor Tile / Gray /
Thin 30B Mastic Black east center mid basement with green carpet tile None
Detected 29
90% Hazardous Material Report -
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 27 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
TSI-09: Mudded fitting mastic /
White/black 31A White
Mid basement southeast corner room 2 %
Chrysotile Good N 4 Each 30
TSI-09: Mudded fitting mastic /
White/black 31B White
Mid basement southeast corner room 2 %
Chrysotile Good N
Included above, sample
31A 30 MM-19: 2’ x 4’ Ceiling Tile /
White / Rough 32A White
Mid basement center women restroom
MM-20: 18” x 18” vinyl floor tile / Red/green /
Squares 33A Floor Tile Gray
Men’s center mid basement restroom vinyl floor tile / Red/green /
Squares 33A Mastic Brown/ Gray
Men’s center mid basement restroom vinyl floor tile / Red/green /
Squares 33B Floor Tile Gray
Men’s center mid basement restroom vinyl floor tile / Red/green /
Squares 33B Mastic Brown/ Gray
Men’s center mid basement restroom
SM-04: Wall
Texture / White / Smooth 34A White
Men’s restroom on mid basement
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 28 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
SM-04: Wall Texture / White /
Smooth 34B White
Men’s restroom on mid basement
MM-21: 12” x 12”
Ceiling Tile / White / Elegant 35A
Gray/W hite center west room in mid basement
MM-21: 12” x 12”
Ceiling Tile / White / Elegant 35B
Gray/W hite center west room in mid basement
MM-22: Ceiling noise dampener / Yellow 36A Mastic Gray
Sub-basement floor ceiling throughout
2 % Chrysotile Poor N 1600 SF 35
MM-22: Ceiling noise dampener /
Yellow 36A Dampener Gray/ Yellow
Sub-basement floor ceiling throughout
None Detected 35
MM-22: Ceiling noise dampener
/ Yellow 36B Mastic Gray
Sub-basement floor ceiling throughout
2 % Chrysotile Poor N
Included above, sample
36B 35 MM-22: Ceiling noise dampener / Yellow 36B Dampener
Gray/ Yellow
Sub-basement floor ceiling throughout
TSI-10: Pipe Fittings / Beige 37A Insulation Yellow
Low pressure steam pipe in southeast corner
Fittings / Beige 37A Wrap White
Low pressure steam pipe in southeast corner
Fittings / Beige 37A Pipe fitting White
Low pressure steam pipe in southeast corner
NBE 21-047 (SGBP 19-0018, Demo B404, Offutt AFB) DA Appendix B Page 29 of 122
Demolish B404 Project Number: SGBP 19-0018 February 28, 2022
Material #/ Description
Sample Id Layers Id Color Location Sample
Result Condition Friable (Y/N)
Estimated Quantity Photo No.
TSI-10: Pipe Fittings / Beige 37B Insulation Yellow
Low pressure steam pipe in southeast corner
Fittings / Beige 37B Wrap White
Low pressure steam pipe in southeast corner
Fittings / Beige 37B Pipe fitting White
Low pressure steam pipe in southeast corner
MM-23: Fiber optic penetration filler
/ Black 38A Brown/ Gray
Northeast corner room mid basement in server room
2 % Chrysotile Good N 2 LF 37
MM-23: Fiber optic penetration filler / Black 38B
Brown/ Gray
Northeast corner room mid basement in server room
2 % Chrysotile Good N
Included above, sample
38A 37
MM-24: 12” x 12” Ceiling Tile /
Brown / Rough 39A Brown
West interior stair from mid basement to main floor
MM-25: 9” x 9”
Floo…
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