Fire Detection System Hazardous Material Survey_12022016.pdf

FINAL

REPORT OF FINDINGS

HAZARDOUS MATERIAL SURVEY

For

WESTOVER AIR RESERVE BASE

BUILDING 1850

439th AIRLIFT WING HEADQUARTERS

Westover Air Reserve Base Chicopee, Massachusetts 01022

Prepared for

United States Army Corps of Engineers, Louisville District 600 Dr. Martin Luther King Jr. Place

Louisville, Kentucky 40202-2232

December 2, 2016

Contract No. W912QR-12-D-001 Task Order No. 0027

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DBB-READY TO ADVERTISE

W912QR17B0009-0000

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STATEMENT OF INDEPENDENT TECHNICAL REVIEW

Hazardous Materials Survey Report for Building 1850 at the Westover Air Reserve Base

Plexus Scientific Corporation and Professional Service Industries, Inc. have completed the preparation of this Hazardous Materials Survey Report which included an assessment of asbestos-containing materials, polychlorinated biphenyl and other Hazardous Material including batteries, pesticides and mercury-containing bulbs and equipment. This survey was conducted within Building 1850 at Westover Air Reserve Base (WARB) in Chicopee, Massachusetts. Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project. During the independent technical review, compliance with established policy principles and procedures, utilizing justified and valid assumptions, was verified. This included review of data quality objectives; technical assumptions; methods, procedures, and materials to be used; the appropriateness of data used and level of data obtained; and reasonableness of the results, including whether the product meets the customer’s needs consistent with law and existing United States Army Corps of Engineers policy.

Significant concerns and explanation of the resolutions are documented within the project file.

As noted above, all concerns resulting from independent technical review of the project have been considered.

12/2/16 Ali Sadrieh Date Program Manager

12/2/16 Nand Kaushik Date Department Manager – Environmental Services

12/2/16 Samuel Norton Date Project Manager

12/2/16 Joseph Kuchnicki, CIE, CHMM Date Independent Technical Review Team Leader

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Westover ARB, MA

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Executive Summary Plexus Scientific Corporation (Plexus) in conjunction with Professional Service Industries, Inc.

(referenced as the “Plexus Survey Team”) conducted surveys for asbestos-containing material (ACM), polychlorinated biphenyl (PCB) and Universal Wastes, including batteries, pesticides, and mercury-containing equipment and bulbs (further referenced to as “other Hazardous Materials”) within Building 1850 at Westover Air Reserve Base (WARB) (also referenced as the “Facility”) in Chicopee, Massachusetts. These surveys were conducted in accordance with information contained in the “Abbreviated Accident Prevention Plan for NESHAP/Hazardous Materials Survey (Building 1850 – 439th Airlift Wing Headquarters)” (Accident Prevention Plan;

Plexus, 2016).

Asbestos inspection and sampling procedures were performed in accordance with the NESHAP, as adopted by the USEPA and the Asbestos Hazard and Emergency Response Act of 1986 protocols published in 40 CFR Part 763 Subpart E; October 30, 1987, and ASTM E2356, “Standard Practice for Comprehensive Building Asbestos Surveys”.

The Hazardous Materials survey documented in this report focused on Building 1850 within the Facility (further referenced to as “the building”).

The ACM, PCB, and other Hazardous Materials surveys were conducted at the building on November 8 and 9, 2016. The survey was conducted for the United States Army Corps of Engineers (USACE), Louisville District (CELRL) under Contract No. W912QR-12-D-0010, Task Order No. 0027. After arrival at the Facility, the Plexus Survey Team conducted a walk-through of each accessible room of the buildings to identify Homogeneous Materials for sampling purposes for the ACM survey, to identify PCB-containing ballasts associated with light fixtures, and other Hazardous Materials. All areas within the building were accessible and inspected during the ACM, PCB, and other Hazardous Material surveys. The surveys included the interior, and roof of the building.

Asbestos-Containing Material Survey Based on survey observations and sample analytical results, a summary of the Plexus Survey Team’s findings is presented in the following sections. Survey results from the ACM survey are presented in Table 1 (refer to Appendix A). Figures depicting sample collection points and sampling results are included in Appendix B; Photographic examples of identified Homogeneous Materials are included in Appendix C; laboratory reports with chain-of-custody forms are presented in Appendix D; and the survey certifications are presented in Appendix E.

Building 1850

Confirmed Asbestos-Containing Material

The PLM results for the following Homogeneous Materials were >1% asbestos:

• Homogenous Material #17 – Asbestos containing gray mudded pipe fitting was observed in above the drop ceiling between Rooms 1137 and 1138 in Building 1850. It should be noted that while the survey team conducted a throrough inspection above the drop ceiling and accessibile void spaces, it is likely that additional fittings exist within the wall cavities.

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All other observed pipe fittings and associated pipe insulation were observed to be fiberglass. The approximate area where Homogenous Material #17 was observed is estimated at 1 fitting. An example of this material is shown in Photograph 17 of the Building 1850 Photolog.

• Homogenous Material #22 – Asbestos containing white magnesia pipe insulation was observed in above the drop ceiling between Rooms 1137 and 1138 in Building 1850. It should be noted that while the survey team conducted a throrough inspection above the drop ceiling and accessibile void spaces, it is likely that additional pipe insulation exist within the wall cavities. All other observed pipe insulation and associated pipe fittings were observed to be fiberglass. The approximate area where Homogenous Material #22 was observed is estimated at 5 linear foot (lf). An example of this material is shown in Photograph 22 of the Building 1850 Photolog.

Presumed Asbestos-Containing Material

The ACM survey identified no presumed asbestos-containing materials in Building 1850.

Presumed ACM (PACM) includes materials that could not be sampled but are presumed to contain asbestos unless it is demonstrated that PACM does not contain asbestos. PACM is defined by 29 CFR 1910.1001(b) as “Thermal system insulation and surfacing material found in buildings constructed no later than 1980”. These presumed materials could not be sampled because sampling activities would result in significant damage to the building materials (e.g., heating, ventilation, and air conditioning (HVAC) vibration / expansion joints and fire doors).

Polychlorinated Biphenyl Inspection and other Hazardous Materials Survey The Plexus Survey Team utilized a Phillips Advance Ballast Checker (further referenced as the “ballast checker”) to ascertain if a light fixture contained either magnetic or electronic ballasts.

Light fixtures containing electronic ballasts are PCB-free and light fixtures that contain magnetic ballasts can either be PCB-containing or PCB-free. No light fixtures within the buildings were identified to have magnetic ballasts.

A potential PCB containing pad-mounted transformer was observed adjacent to Building 1850 by the Mechanical Rooms.

In addition, the Team also conducted a survey for other hazardous materials (Universal Wastes) including batteries, pesticides, and mercury-containing equipment and bulbs as defined by 40 CFR Part 273. No mercury containing equipment, or pesticides were noted within the buildings.

Batteries associated with emergency lighting were noted within the building.

Survey results from the PCB and other hazardous materials survey are presented for the buildings in Section 3.3.

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Table of Contents Executive Summary ................................................................................................................................... I

Asbestos-Containing Material Survey ................................................................................................. I Polychlorinated Biphenyl Inspection and other Hazardous Materials Survey ............................ II

Table of Contents ....................................................................................................................................III Acronyms and Abbreviations ................................................................................................................ V

1.0 Introduction

2.0 Facility Description

2.1 Building 1850

3.0 Survey Findings

3.1 Asbestos-Containing Material

3.1.0 Building 1850

3.1.2 Recommendations

3.2 Polychlorinated Biphenyl and other Hazardous Materials

3.2.0 Building 1850

3.2.1 Exterior Transformers

4.0 Field Survey and Analytical Protocols

4.1 Asbestos-Containing Material

4.2 Polychlorinated Biphenyl and other Hazardous Materials

5.0 References

Appendices

A Summary Table of Asbestos-Containing Material Survey Results B Figures for Asbestos-Containing Material Survey C Survey Photograph Log (Asbestos-Containing Material) D Laboratory Reports and Chain-of-Custody Forms (Asbestos-Containing Material) E Inspector and Laboratory Certifications

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Westover ARB, MA

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Acronyms and Abbreviations ≤ Less Than or Equal To > Greater Than % Percent ACM Asbestos-Containing Material CELRL United States Army Corps of Engineers, Louisville District CFR Code of Federal Regulations CH Chrysotile CR Crocidolite CMU Concrete Masonry Unit EDPM Ethylene Propylene Diene Terpolymer F Friable ft² Square Foot HM Homogenous Material HVAC Heating, Ventilation, and Air Conditioning LED Light-Emitting Diode lf Linear Foot mg/cm2 Milligrams per Square Centimeter N/A Not Applicable ND None Detected NESHAP National Emission Standards for Hazardous Air Pollutants NF Non-Friable NVLAP National Voluntary Laboratory Accreditation Program PACM Presumed Asbestos Containing Material PCB Polychlorinated Biphenyl P.E. Professional Engineer Plexus Plexus Scientific Corporation PLM Polarized Light Microscopy PMP Project Management Professional POC Point-of-Contact PSI Professional Service Industries, Inc.

RACM Regulated Asbestos Containing Material ft Square Foot USACE United States Army Corps of Engineers USEPA United States Environmental Protection Agency WARB Westover Air Reserve Base

Westover ARB, MA

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Westover ARB, MA

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1.0 Introduction

Plexus Scientific Corporation was tasked by the CELRL, under USACE Contract W912QR-12-D- 0010, Task Order 0027, to complete an ACM, PCB, and other Hazardous Materials survey at Building 1850 at WARB in Chicopee, Massachusetts. The Project Manager for the project is Ali Sadrieh, P.E., PMP of Plexus. The ACM survey activities were completed by USEPA accredited asbestos inspectors. The surveys were performed in accordance with the contractual scope of work and the “Abbreviated Accident Prevention Plan for NESHAP/Hazardous Materials Survey (Buildings 1850 – 439th Airlift Wing Headquarters)” (Accident Prevention Plan; Plexus, 2016), developed and approved by CELRL prior to implementation in the field. All areas within the building were accessible and were surveyed for ACM, PCB, and other Hazardous Materials.

ACM Surveys

The Plexus Survey Team conducted the ACM survey at Building 1850 (further referenced to as “the building”) from November 8, to November 9, 2016. The Plexus Survey Team conducted an initial walk-through of the Facility to determine if any areas were inaccessible. All areas within the Building were accessible and inspected during the survey. The ACM survey included the collection and laboratory analysis of suspect ACM samples utilizing USEPA Method 600/R- 93/116; July 1993 (PLM with dispersion staining). In addition, per NESHAP standards, a friable material that is found to be <1 – 10% Asbestos should be retested with a 400 point-count, or must be considered an Asbestos-Containing Material, based on the EPA’s concern that an analyst might consistently underestimate the amount of asbestos in a friable sample when “eyeballing” it under the scope, resulting in the potential for a material that is considered to be <1% to be 1% or greater when point counted, and therefore, an ACM. If a material is determined to be <1% with a 400 point count, it is considered a Non-ACM. However, OSHA indicates in the guidance document:

Asbestos Standard for the Construction Industry that best worker practices and other regulations will still apply during renovation and demolition activities.

The ACM survey was performed to identify ACM on the interior, and roof of the building. It should be noted that exterior window caulking was sampled, as the site point-of-contact (POC) indicated that window replacements will be included in renovation efforts. The ACM survey was also intended to provide information in preparation for proposed renovation activities to be conducted at the building. The ACM survey evaluated the building for the presence, quantity, location, and condition of suspect ACM. This information is required to determine if there are areas of the building that may require pre-renovation asbestos abatement in accordance with Local, State, and Federal regulations to protect the public and workers by controlling the potential release of asbestos fibers during activities involving the handling and disposal of presumed, suspect, and confirmed ACM.

It should be noted that destructive sampling, such as behind finished surfaces (drywall, above hard ceilings, inside mechanical chases, etc.) was generally performed during this ACM survey in accordance with the Work Plan. Destructive sampling was not conducted within the interior of the building, as the samples collected were small and unobtrusive. Roofing samples collected from the building were destructive, as all layers of the EDPM roof were collected and submitted for analysis. Per the Scope of Work, roofing samples were patched after sampling activities, and

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02 82 33 APPENDIX A Page 11 the roofing samples were collected from edge of the building to minimize damage. As previously indicated, all areas within the building were accessible and inspected during the ACM survey.

PCB and other Hazardous Material Surveys

The Plexus Survey Team performed the PCB and other Hazardous Materials surveys from November 8, to November 9, 2016. The PCB and other Hazardous Material surveys was performed to assess potential PCB hazards and other Hazardous Materials on the interior of the Facility, and also to provide information in preparation for proposed renovation activities. The PCB survey consisted of evaluating all accessible light fixtures and their associated ballasts, including any transformers at the Facility, to determine if the ballasts contained PCB. It was a visual survey only, and no sampling of potential PCB-containing fluids was conducted. The PCB survey was conducted on the light fixtures located in interior areas of the Facility and any immediately adjacent transformers that serve the Facility. The Hazardous Material survey was conducted to inventory hazardous materials (Universal Wastes) including batteries, pesticides, and mercury-containing equipment and bulbs as defined by 40 CFR Part 273.

This consolidated, ACM, PCB and other Hazardious Materials survey report (Report) is organized into the following sections:

• Section 2 discusses the Facility description;

• Section 3 discusses survey findings;

• Section 4 discusses field survey and analytical protocols; and

• Section 5 contains references for works cited in this report.

The following appendices were added to this report as supplemental information:

• Appendix A contains a summary table of ACM survey results;

• Appendix B contains figures that illustrate building floor plans, ACM sample locations, and results;

• Appendix C contains survey Photograph logs for the ACM surveys;

• Appendix D contains the laboratory reports and chain-of-custody forms that were produced for the ACM survey;

• Appendix E contains the inspector and laboratory certifications .

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2.0 Facility Description

The ACM, PCB, and other Hazardous Materials survey at Westover Air Reserve Base was performed within Building 1850. All areas within the building were accessible and inspected during the survey. The Plexus Survey Team was provided with renovation records before the ACM survey. The building that comprised the survey is described in the following subsection.

2.1 Building 1850

Building 1850 is a 28,123 square foot, one-story building, with a load-bearing concrete masonry unit (CMU) with a brick exterior and interior steel bearing columns. The roof is an adhered Ethylene Propylene Diene Terpolymer (EDPM) system over ridged insulation and a metal deck.

Interior finishes include standard framed walls with gypsum wall board, and ceilings are suspended acoustical ceiling tile and gypsum wall board. The interior of the building includes offices, restrooms, common areas, two mechanical rooms, conference rooms, and serves as the 439th Airlift Wing Headquarters. The building was originally constructed in 1956 and renovated in 1988.

The floor plan for Building 1850, including ACM survey locations are presented in Appendix B.

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Westover ARB, MA

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3.0 Survey Findings

The findings of the hazardous materials survey conducted under Task Order 0027 are summarized in the following subsections.

3.1 Asbestos-Containing Material

The Plexus Survey Team reviewed available facility drawings and as-built floor plans for the buildings to assist in identifying confirmed ACM and/or presumed ACM before and during the ACM survey. No prior asbestos survey reports were provided to the Plexus Survey Team for review. As previously indicated, the inspectors performed a walk-through of each accessible room to identify Homogenous Materials that were visually similar in color, texture, general appearance, and date of installation. In addition, interior, and roof areas were inspected. As indicated previously, exterior window caulking was sampled, as planned renovations will include the replacement of windows.

The USEPA considers a material to be an ACM, if a single sample from a Homogenous Material contains >1% asbestos utilizing PLM with dispersion staining in accordance with the sampling methodology detailed in the guidance document: Method for the Determination of Asbestos in Bulk Building Materials; USEPA Method 600/R-93/116: July 1993.

Therefore, samples in each defined Homogenous Material were analyzed until the first positive sample (>1%) was identified. Once a positive (Confirmed) sample from each Homogeneous Material was determined, any remaining bulk samples collected from that Homogeneous Material were not analyzed in general accordance with 40 Code of Federal Regulations (CFR) 763.87(c)(2). Per industry standard, when suspect ACM samples contained more than one layer, each layer was analyzed separately by the laboratory for its asbestos content.

If a friable material is found to be greater than (>) 0.1% or less than (<) 10% asbestos, the sample must be retested (Per the Scope of Work, USACE, 2016) using the above method with a 400 point count, or must be considered an ACM.

Presumed ACM (PACM) includes materials that could not be sampled but are presumed to contain asbestos unless it is demonstrated that PACM does not contain asbestos. PACM is defined by 29 CFR 1910.1001(b) as “Thermal system insulation and surfacing material found in buildings constructed no later than 1980”. These presumed materials could not be sampled because sampling activities would result in significant damage to the building materials (e.g., heating, ventilation, and air conditioning (HVAC) vibration / expansion joints and fire doors). During this ACM survey, no Presumed ACMs were identified within any of the buildings.

Non-asbestos-containing material includes suspect ACM that was sampled, and asbestos was either not detected or was detected at a concentration ≤1% according to the methodology detailed above, i.e., PLM with dispersion staining.

3.1.0 Building 1850

At Building 1850, the Plexus Survey Team’s asbestos inspectors identified 13 Homogeneous Materials. A total of 85 samples were collected and analyzed by PSI’s NVLAP-accredited ACM bulk sample testing laboratory. Sample locations of each Homogenous Material were randomly

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02 82 33 APPENDIX A Page 15 chosen; however, samples were preferentially collected from obscure or previously damaged locations. Analytical results are presented in Table 1 of Appendix A. Sample locations with analytical results are illustrated in Figure 1 of Appendix B. Example Photographs of Homogeneous Materials are included in Appendix C, the laboratory report with the chain-of-custody forms are presented in Appendix D.

The results of the ACM survey at Building 1850 reveal the following findings:

Confirmed Asbestos-Containing Material

The PLM results for the following Homogeneous Materials were >1% asbestos:

• Homogenous Material #17 – Asbestos-containing gray mudded pipe fitting was observed in above the drop ceiling between Rooms 1137 and 1138 in Building 1850. It should be noted that while the survey team conducted a throrough inspection above the drop ceiling and accessibile void spaces, it is likely that additional fittings exist within the wall cavities.

All other observed pipe fittings and associated pipe insulation were observed to be fiberglass. The approximate area where Homogenous Material #17 was observed is estimated at 1 fitting. An example of this material is shown in Photograph 17 of the Building 1850 Photolog.

• Homogenous Material #22 – Asbestos-containing white magnesia pipe insulation was observed in above the drop ceiling between Rooms 1137 and 1138 in Building 1850. It should be noted that while the survey team conducted a throrough inspection above the drop ceiling and accessibile void spaces, it is likely that additional pipe insulation exist within the wall cavities. All other observed pipe insulation and associated pipe fittings were observed to be fiberglass. The approximate area where Homogenous Material #22 was observed is estimated at 5 lf. An example of this material is shown in Photograph 22 of the Building 1850 Photolog.

Presumed Asbestos-Containing Material

The ACM survey identified no presumed asbestos-containing materials in Building 1850.

Non Asbestos-Containing Material

The Plexus Survey Team identified building materials at Building 1850 that were not suspect ACM and, therefore, were not sampled. These materials included:

• Fiberglass insulation; and

• Rubber pipe wrappings.

As part of the inspection and in accordance with National Emission Standards for Hazardous Air Pollutants (NESHAP) protocols, PSI’s asbestos inspectors conducted a tactile inspection of the insulation associated with piping, and HVAC duct work, to determine if the visibly identified synthetic materials (i.e., non-ACM) were covering / obscuring the presence of suspect ACM.

The PLM results for the following Homogeneous Materials were non-detect, or; <1%; therefore, the materials are non-ACM:

• Homogenous Material #1 - Yellow mastic associated gray carpet squares with white spots was observed throughout the building, including offices, hallways, and common areas in Building 1850. The approximate area where Homogenous Material #1 was observed is estimated at 16,130 square feet (ft2). It should be noted that carpeting is not considered a

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02 82 33 APPENDIX A Page 16 suspect material, and therefore, was not sampled. An example of this material is shown in Photograph 1 of the Building 1850 Photolog.

• Homogeneous Material #2 – Gray drywall and associated white joint compound was observed throughout the building, including offices, hallways, and common areas of Building 1850. The approximate area where Homogenous Material #2 was observed is estimated at 21,585 ft2. An example of this Homogenous Material is presented in Photograph 2 of the Building 1850 Photolog.

• Homogeneous Material #3 – 6” blue vinyl cove base and associated yellow mastic was observed in Hallway 1167 by Room 1161 of Building 1850. The approximate area where Homogenous Material #3 was observed is estimated at 10 lf. An example of this Homogenous Material is presented in Photograph 3 of the Building 1850 Photolog.

• Homogeneous Material #4 – Light gray grout associated with ceramic floor tile was observed in Hallway 1167, and the lobby of Room 1161 in Building 1850. The approximate area where Homogenous Material #4 was observed is estimated at 130 ft2. It should be noted that ceramic floor is not considered a suspect material, and therefore, was not sampled. An example of this Homogenous Material is presented in Photograph 4 of the Building 1850 Photolog.

• Homogenous Material #5 – Yellow mastic associated with blue carpet with red and white specks was observed within Rooms 1162, 1160, 1159, 1157, 1161.5, 1161, 1156 in Building 1850. The approximate area where Homogenous Material #5 was observed is estimated at 2,806 ft2. It should be noted that carpeting is not considered a suspect material, and therefore, was not sampled. An example of this material is shown in Photograph 5 of the Building 1850 Photolog.

• Homogeneous Material #6 – 2’x2’ white stucco patterned ceiling tile was observed in the throughout the building, including offices, halways, and common areas in Building 1850.

The approximate area where Homogenous Material #6 was observed is estimated at 22,086 ft2. An example of this Homogenous Material is presented in Photograph 6 of the Building 1850 Photolog.

• Homogeneous Material #7 – White door frame caulking was observed in Room 1162 on the doorframe of the exterior exit and room entrance doors in Building 1850. The approximate area where Homogenous Material #7 was observed is estimated at 15 lf. An example of this Homogenous Material is presented in Photograph 7 of the Building 1850 Photolog.

• Homogeneous Material #8 – Dark gray grout associated with ceramic floor tile in Rooms 1170, 1178, 1185, 1165, and 1189 in Building 1850. The approximate area where Homogenous Material #8 was observed is estimated at 450 ft2. It should be noted that ceramic floor is not considered a suspect material, and therefore, was not sampled. An example of this Homogenous Material is presented in Photograph 8 of the Building 1850 Photolog.

• Homogeneous Material #9 – 6” brown vinyl cove base and associated yellow mastic was observed in Room 1170 of Building 1850. The approximate area where Homogenous Material #9 was observed is estimated at 20 lf. An example of this Homogenous Material is presented in Photograph 9 of the Building 1850 Photolog.

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• Homogeneous Material #10 – Tan HVAC duct sealant was observed in Rooms 1176 and 1187 of Building 1850. The approximate area where Homogenous Material #10 was observed is estimated at 40 lf. An example of this Homogenous Material is presented in Photograph 10 of the Building 1850 Photolog.

• Homogeneous Material #11 – White fiberglass pipe mastic was observed in Rooms 1176 and 1187 in Building 1850. The approximate area where Homogenous Material #11 was observed is estimated at 60 lf. It should be noted that fiberglass pipe insulation is not considered a suspect material, and therefore, was not sampled. An example of this Homogenous Material is presented in Photograph 11 of the Building 1850 Photolog.

• Homogenous Material #12 – Gray expansion joint was observed in Room 1187 in Building 1850. The approximate area where Homogenous Material #12 was observed is estimated at 40 lf. It should be noted that initial PLM testing indicated that the material was considered to be an ACM, but per the scope of work, subsequent point counting was conducted, and the material was found to contain less than one percent asbestos. An example of this material is shown in Photograph 12 of the Building 1850 Photolog.

• Homogeneous Material #13 – Gray cinderblock mortar was observed in Rooms 1187, 1185, 1162, 1175, 1178, 1170, 1189, and 1165 in Building 1850. The approximate area where Homogenous Material #13 was observed is estimated at 1,821 ft2. It should be noted that cinderblock is not considered a suspect material, and therefore, was not sampled An example of this Homogenous Material is presented in Photograph 13 of the Building 1850 Photolog.

• Homogeneous Material #14 – 6” blue vinyl cove base and associated yellow mastic was observed in Room 1126 in Building 1850. The approximate area where Homogenous Material #14 was observed is estimated at 120 lf. An example of this Homogenous Material is presented in Photograph 14 of the Building 1850 Photolog.

• Homogeneous Material #15 – 12”x12” white floor tile with gray specks and associated yellow mastic was observed in Room 1130 in Building 1850. The approximate area where Homogenous Material #15 was observed is estimated at 200 ft2. An example of this Homogenous Material is presented in Photograph 15 of the Building 1850 Photolog.

• Homogeneous Material #16 – Brown mastic dots associated with 1’x1’ acoustical fiberglass will tiles was observed in Rooms 1130 and 1140 in Building 1850. The approximate area where Homogenous Material #16 was observed is estimated at 300 ft2.

It should be noted that the 1’x1’ acoustical fiberglass wall tile is not considered a suspect material, and therefore, was not sampled An example of this Homogenous Material is presented in Photograph 16 of the Building 1850 Photolog.

• Homogeneous Material #18 – White sheetrock was observed in above the drop-ceiling throughout Building 1850. The approximate area where Homogenous Material #18 was observed is estimated at 26,000 ft2. An example of this Homogenous Material is presented in Photograph 18 of the Building 1850 Photolog.

• Homogeneous Material #19 – Tan vinyl flooring was observed in Rooms 1184, and 1108 in Building 1850. The approximate area where Homogenous Material #19 was observed is estimated at 104 ft2. An example of this Homogenous Material is presented in Photograph 19 of the Building 1850 Photolog.

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• Homogeneous Material #20 – 6” black vinyl cove base and associated yellow mastic was observed in Rooms 1184, and 1171 in Building 1850. The approximate area where Homogenous Material #20 was observed is estimated at 30 lf. An example of this Homogenous Material is presented in Photograph 20 of the Building 1850 Photolog.

• Homogeneous Material #21 – Gray grout associated with ceramic floor tile was observed in Rooms 1171, 1182, 1169, and 1180 in Building 1850. The approximate area where Homogenous Material #21 was observed is estimated at 378 ft2. It should be noted that ceramic floor is not considered a suspect material, and therefore, was not sampled. An example of this Homogenous Material is presented in Photograph 21 of the Building 1850 Photolog.

• Homogeneous Material #23 – White wall plaster was observed in Rooms 1171, and 1180 in Building 1850. The approximate area where Homogenous Material #23 was observed is estimated at 120 ft2. An example of this Homogenous Material is presented in Photograph 23 of the Building 1850 Photolog.

• Homogeneous Material #24 – White ceiling plaster was observed in Rooms 1171, and 1180 in Building 1850. The approximate area where Homogenous Material #24 was observed is estimated at 120 ft2. An example of this Homogenous Material is presented in Photograph 24 of the Building 1850 Photolog.

• Homogeneous Material #25 – EDPM built-up roof was observed on the roof of Building 1850. The approximate area where Homogenous Material #25 was observed is estimated at 28,500 ft2. An example of this Homogenous Material is presented in Photograph 25 of the Building 1850 Photolog.

• Homogeneous Material #26 – Gray flashing caulk was observed on the roof of Building 1850. The approximate area where Homogenous Material #26 was observed is estimated at 30 lf. An example of this Homogenous Material is presented in Photograph 26 of the Building 1850 Photolog.

• Homogenous Material #27 – Tan window caulking was observed on the window exteriors in Building 1850. The approximate area where Homogenous Material #27 was observed is estimated at 450 lf. It should be noted that initial PLM testing indicated that the material was considered to be an ACM, but per the scope of work, subsequent point counting was conducted, and the material was found to contain less than one percent asbestos. An example of this material is shown in Photograph 27 of the Building 1850 Photolog.

3.1.2 Recommendations

Regulated ACM (RACM) must be properly removed by a licensed asbestos abatement contractor prior to renovations or demolition that would disturb the material. Federal, State and Local regulations and guidelines should be strictly adhered to when removing the ACM. NESHAP defines a “Regulated Asbestos Containing Material” (RACM) as any friable manufactured asbestos material (ACM) containing >1% asbestos using PLM, which can be crumbled, pulverized, or reduced to a powder by hand pressure when dry, or a Category I non-friable ACM that has become friable OR a Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading OR Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on a material in the course of demolition or renovation activities.

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Category I & II Non-Friable asbestos containing material may often be left in place during demolition if not made friable by cutting, grinding or sanding. If left in place, these materials cannot be recycled or used as clean fill. Materials verified to contain low concentrations of asbestos (trace to 1%) are not considered ACM, and are not regulated by the EPA; however, some OSHA regulations will still apply based on the employee’s airborne exposure. In addition, prior to any future maintenance, renovation or demolition activities, any assumed ACMs should be tested.

Prior to the initiation of a project that would involve abatement, a detailed engineering cost estimate and project design is recommended. The engineering cost estimate will incorporate such variables as scheduling and phasing of the project, the size and extent of the project, seasonal factors, operational factors and other restrictions, respiratory protection, alternate abatement options, and type of replacement material. An engineering cost estimate would also include professional fees, such as for project design and management, and other expenses, such as on-site air monitoring and construction supervision.

3.2 Polychlorinated Biphenyl and other Hazardous Materials

The PCB and other Hazardous Material survey results for the buildings are presented in the following sections. Each light fixture at the Building was surveyed using the ballast checker to determine if it was powered by either magnetic ballasts, or electronic ballasts. Light fixtures containing electronic ballasts are PCB-free and light fixtures that contain magnetic ballasts can either be PCB-containing or PCB-free.

3.2.0 Building 1850

The PCB and other Hazardous Material survey results for Building 1850 are presented in the Table below.

Building 1850 Hazardous Materials Summary

Material Observed

Yes/No

Estimated Quantity

General Location

*Mercury Bulbs: Room Number (Quantity)

PCB Fluorescent Light Ballasts

No N/A N/A

PCB Containing Equipment Yes 1 Pad Mounted Transformer – Exterior of Building by Mechanical Room (No “Non-PCB Containing” Label present)

Mercury Containing Equipment

No N/A N/A

Mercury Bulbs Yes 295 *Rm 1142 (2), Rm 1143 (2), Rm 1144.9 (2), Rm

1144.8 (8). Rm 1144.7 (2), Rm 1144.6 (2), Rm 1144.5 (2), Rm 1144.3 (2), Rm 1144 (10), Rm 1181 (4), Rm 1188 (2), Rm 1164 (6), Rm 1163 (4), Rm 1167 (13), Rm 1155 (4), Rm 1161 (13), Rm 1161 (6), Rm 1162

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Material Observed

Yes/No

Estimated Quantity

General Location

*Mercury Bulbs: Room Number (Quantity)

(7), Rm 1160 (10), Rm 1159 (6), Rm 1158 (4), Rm 1157 (6), Rm 1156 (6), Rm 1154.1 (1), Rm 1149 (2), Rm 1154 (4), Rm 1151 (2), Rm 1152 (2), Rm 1153 (2), Rm 1127 (8), Rm 1128 (2), Rm 1129 (2), Rm 1130 (2), Rm 1131 (2), Rm 1132 (4), Rm 1136 (4), Rm 1137 (2), Rm 1138 (2), Rm 1139 (6), Rm 1140 (6), Rm 1133 (6), Rm 1135 (4), Rm 1134 (4), Rm 1124 (11), Rm 1124.2 (2), Rm 1123 (4), Rm 1124.1 (2), Rm 1122 (2), Rm 1121 (2), Rm 1174 (20), Rm 1109 (3), Rm 1106 (4), Rm 1105 (6), Rm 1105.1 (1), Rm 1186 (1), Rm 1104.1(1), Rm 1108 (1), Rm 1179 (1), Rm 1104 (4), Rm 1107.1 (1), Rm 1107.2 (6), Rm 1107 (3), Rm 1103 (3), Rm 1101 (6), Rm 1114 (2), Rm 1111 (2), Rm

1113.1 (4), Rm 1113.2 (4), Rm 1113.4 (2), Rm 1113.3 (4), Rm 1115 (2), Rm 1119 (3)

Batteries Yes 5 Emergency Lights (Rm 1161, Rm 1167, Rm 1126, Rm 1172, Rm 1174)

Pesticides No N/A N/A

As indicated in the table above, PCB containing ballasts, Mercury containing equipment and pesticides were not identified within the building, as the light fixture ballasts were found to be electronic, and not magnetic. Mercury-containing light fixtures were identified within the building. The remainder of the lights were equipped with incandescent fixtures which do not contain ballasts No other mercury containing equipment or pesticides were noted within the building.

3.2.1 Exterior Transformers

A potential PCB containing pad-mounted transformer was observed adjacent to the Mechanical Rooms of Building 1850.

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4.0 Field Survey and Analytical Protocols

Each hazard survey was conducted in accordance with the applicable, approved Work Plan that addressed each specific hazard (Plexus, 2016). The field survey and analytical protocols for each topical hazard are discussed in the following subsections.

4.1 Asbestos-Containing Material

Asbestos inspection and sampling procedures were performed in accordance with the NESHAP, as adopted by the USEPA and the Asbestos Hazard and Emergency Response Act of 1986 protocols published in 40 CFR Part 763 Subpart E; October 30, 1987, and ASTM E2356, “Standard Practice for Comprehensive Building Asbestos Surveys”.

Homogeneous Materials were identified by conducting an initial building walk through to assess material that was visually similar in color, texture, general appearance, and date of installation.

The walk through consisted of visually inspecting each accessible space within the buildings, and identifying Homogenous Materials. If the inspectors determined that a material was not similar in appearance and texture to other material in a building / structure (e.g., wall texturing and vinyl floor tile / mastic), the inspectors distinguished the material as a unique Homogenous Material and collected samples accordingly. The number of samples collected were in accordance with AHERA regulations and ASTM E2356. In addition, the inspectors made a note if a material is considered a PACM. PACM is defined by 29 CFR 1910.1001(b) as “Thermal system insulation and surfacing material found in buildings constructed no later than 1980”. The material is considered “presumed” to contain asbestos unless it is demonstrated to not contain asbestos through testing.

Surfacing plaster was noted within the building, and was sampled and tested accordingly. PACM TSI was noted within the building, and was sampled and tested accordingly.

Following USEPA inspection protocols, the inspectors placed each Homogenous Material (suspect ACM) that was confirmed as an ACM into one of the following USEPA classifications:

• RACM: NESHAP defines a “Regulated Asbestos Containing Material” (RACM) as any friable manufactured asbestos material (ACM) containing >1% asbestos using PLM, which can be crumbled, pulverized, or reduced to a powder by hand pressure when dry, or a Category I non-friable ACM that has become friable OR a Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading OR Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on a material in the course of demolition or renovation activities;

• Category I Non-friable ACM: NESHAP defines a Category I non-friable ACM as packing, gaskets, resilient floor coverings, and asphalt roofing products, which contain >1% asbestos using PLM; and

• Category II Non-friable ACM: NESHAP defines a Category II non-friable ACM as any material, except for a Category I non-friable ACM, which contains >1% asbestos using PLM and cannot be reduced to a powder by hand pressure when dry.

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Additionally, suspect ACM was assessed for general condition, using the terms good, fair, or poor according to the Work Plan (refer to Appendix A):

• Good is defined as a material that is not damaged and / or largely intact;

• Fair is defined as material that is less than 25% or evenly damaged over its entirety; and

• Poor is defined as any material that is >25% damaged.

The inspectors estimated the quantity of suspect ACM using visual estimation. The visual estimation was conducted using facility drawings (provided by the client), pacing, counting tiles and panels, rather than measured take-offs. As a result, actual quantities may differ between visually estimated values and physical measurements. Estimated quantities of confirmed ACM identified within the buildings are included in Appendix A.

As described in the Work Plan, the Plexus Survey Team collected suspect ACM samples from areas that were in obscure locations or areas of pre-existing damage. When sampling could only be conducted within highly visible locations, the inspectors obtained permission from the Facility POC prior to sampling. The inspectors applied water to friable surfaces before sample collection to reduce the potential for fiber release. All residual debris from sampling of friable suspect ACM was cleaned using a vacuum equipped with a high-efficiency particulate air filter. The sampled locations were not repaired or patched, but were left free of any rough or exposed edges. All samples collected were placed in individual plastic bags and sealed immediately upon collection.

Each sample was labeled with a unique sample identification number. The sampling instruments were wiped clean using a wet, lint-free cloth after use to prevent cross-contamination. As indicated previously, material samples were collected from the interior, exterior, and roof of each building.

All samples remained in the inspectors’ custody until completion of the ACM survey when all of the bulk samples and the associated chains-of-custody were shipped to PSI’s NVLAP-accredited laboratory (NVLAP code 101350-0) in Pittsburgh, Pennsylvania for analysis. The laboratory analytical results and chain-of-custody forms for the suspect ACM samples collected within the building are presented in Appendix D. In addition, per NESHAP regulations (40 CFR 61.141) if the asbestos content is greater than 1 percent, but less than 10 percent as determined by a method other than point counting by PLM, the asbestos content should be verified by a 400 Point Count, or assumed to be an ACM. Per the Scope of Work, point counting is required for any friable sample that is greater than 1 percent asbestos, but less than 10 percent.

4.2 Polychlorinated Biphenyl and other Hazardous Materials

Each observed, accessible light fixture and associated ballast and transformer (if present) was surveyed at the buildings to determine if the light fixture and associated ballast and/or transformers contained PCB. The Plexus Survey Team conducted an initial walk-through of the Facility to determine if any areas were inaccessible; all areas within the Buildings were accessible and were inspected during the PCB survey.

A ballast checker was used to check if each light ballast was electronic or magnetic. A Phillips Advance Ballast Checker was used for this survey. The ballast checker is a hand-held device and can confirm light fixture ballast type from a distance of up to 15 feet. Light fixtures were surveyed by pointing the ballast checker at the light source, and pressing and holding the grey button. The

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02 82 33 APPENDIX A Page 24 ballast checker was calibrated prior to each use and operated in accordance with manufacturer’s instructions.

If the ballast checker indicator light turned red, then the light fixture contained a magnetic ballast and required visual examination because it might contain PCB. If the ballast checker indicator light turned green, then the light fixture contains a high frequency electronic ballast, and a visual examination was not required because it does not contain PCB.

In order to visually inspect a ballast within a light fixture, the following activities were performed:

• Outside light cover was removed;

• Fluorescent light bulb(s) was removed; and

• Interior housing was removed.

The survey was conducted on the interior light fixtures of the building and any immediately adjacent transformers that serve the Facility. The PCB survey findings are summarized in Section 3.1.

In addition, a hazardous material survey was conducted to inventory hazardous materials (Universal Wastes) including batteries, pesticides, and mercury-containing equipment and bulbs as defined by 40 CFR Part 273. The survey was conducted by counting the number of each items present in each building, and noting the exact location of each item.

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5.0 References

Plexus, 2016. Abbreviated Accident Prevention Plan for NESHAP/Hazardous Materials Survey (Building 1850 – 439th Airlift Wing Headquarters). Final, November.

USEPA, 1987. Asbestos-Containing Materials in Schools; Final Rule and Notice, 40 CFR Part 763, Subpart E. October 30.

USEPA, 1995. 40 CFR 273. Universal Waste Rule (Hazardous Waste Management System; Modification of the Hazardous Waste Recycling Regulatory Program). 11 May, 1995

USEPA, 1993. Method for the Determination of Asbestos in Bulk Building Materials, USEPA 600/R- 93/116. July.

ASTM E2356-14, 2014. Standard Practice for Comprehensive Building Asbestos Surveys.

USACE, 2008. U.S Army Corps of Engineers Safety and Health Requirements Manual EM-385-1-1. 30 November, 2014.

OSHA, 2002. 29 CFR 1926.1101. Asbestos Standard for the Construction Industry. 2002.

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