Attch 7-Limited Asbestos Lead Haz Mat Survey.pdf

LIMITED ASBESTOS, LEAD, AND HAZARDOUS

MATERIAL SURVEYS

Cadet Gym, Building 2170 U.S. Air Force Academy Colorado Springs, Colorado

February 23, 2006

Prepared For:

RNL Design 1515 Arapahoe Street, Tower 3, Suite 700 Denver, Colorado 80202

Attention: Tom Hootman

Pinyon Project #1/04-377-02.8005

LIMITED ASBESTOS, LEAD, AND HAZARDOUS

MATERIAL SURVEYS

Of

Cadet Gym, Building 2170 U.S. Air Force Academy, Cadet Gym Colorado Springs, Colorado

February 23, 2006

Prepared For:

RNL Design 1515 Arapahoe Street, Tower 3, Suite 700 Denver, Colorado 80202

Prepared By:

Pinyon Environmental Engineering Resources, Inc.

Project #1/04-377-02.8005

Author:

Scott G. Epstein Environmental Scientist

Reviewer:

Lauren E. Evans, P.E.

President

9600 West Jewell Avenue, Suite #7 ! Lakewood, CO 80232-6357

(303) 980-5200 ! (303) 980-0089 (fax)

Colorado@Pinyon-Env.com ! www.pinyon-env.com

Z:\PROJECTS\10437702 AFA Cadet Gym 2006\8005 Report\AFA_Report.wpd February 23, 2006

Table of Contents

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 1

2.0 Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3

2.1 Limited Asbestos Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3

2.2 Limited Lead Based Paint Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 4

2.2.1 Quality Assurance/Quality Control . . . . . . . . . . . . . . . . . . . . . . . . . Page 5

2.2.2 Testing Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 5

2.3 Limited Hazardous Materials Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 7

3.0 Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

3.1 Phase II Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

3.1.1 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

3.1.2 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9

3.1.3 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . . Page 9

3.2 Phase III Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3.2.2 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3.2.3 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3.2.4 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . Page 10

3.3 Phase IV Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3.3.1 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10

3.3.2 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11

3.3.3 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . Page 11

3.4 Phase V Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11

3.4.1 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11

3.4.2 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12

3.4.3 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . Page 12

3.5 Phase VI Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12

3.5.1 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12

3.5.2 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12

3.5.3 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . Page 13

3.6 Phase VII Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 13

3.6.1 Asbestos Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 13

3.6.2 Lead Based Paint Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 13

3.6.3 Potential Hazardous Material Results . . . . . . . . . . . . . . . . . . . . . . Page 14

4.0 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15

4.1 Asbestos . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15

4.2 Lead Based Paint . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

4.3 Hazardous Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

4.3.1 Mercury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16

4.3.2 Chlorofluorocarbons (CFCs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

4.3.3 PCBs and DEHPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19

4.3.4 Chemical Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21

5.0 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23

6.0 Limitations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25

Table of Contents (continued)

Appendices

Appendix A Asbestos and Lead Based Paint Certifications Appendix B Glossary of Terms

Phase II Documents (separate cover)

Tables Table II-1 Summary of Asbestos Containing Building Materials Table II-2 Summary of OSHA Regulated Building Materials Table II-3 Summary of Non-Asbestos Containing Building Materials

Figures Figure II-1 Asbestos Sampling Locations, Lower Level B Figure II-2 Asbestos Sampling Locations, Lower Level A, #1 Figure II-3 Asbestos Sampling Locations, Lower Level A, #2 Figure II-4 Asbestos Sampling Locations, Lower Level A, #3 Figure II-5 Asbestos Containing Building Material, Lower Level B Figure II-6 Asbestos Containing Building Material, Lower Level A Figure II-7 Lead Based Paint Locations, Lower Level A Figure II-8 Potential Hazardous Material Locations, Lower Level B Figure II-9 Potential Hazardous Material Locations, Lower Level A Figure II-10 Fluorescent Light Locations, Lower Level B Figure II-11 Fluorescent Light Locations, Lower Level A

Appendices Appendix II-A Photographs of ACMs and OSHA Regulated Building Materials Appendix II-B Asbestos Analytical Results Appendix II-C Lead Based Paint Summary Reports

Phase III Documents (separate cover)

Tables Table III-1 Summary of Asbestos Containing Building Materials Table III-2 Summary of Non-Asbestos Containing Building Materials

Figures Figure III-1 Asbestos Sampling Locations, Lower Level B Figure III-2 Asbestos Sampling Locations, Lower Level A, #1 Figure III-3 Asbestos Sampling Locations, Lower Level A, #2 Figure III-4 Asbestos Sampling Locations, Lower Level A, #3 Figure III-5 Asbestos Sampling Locations, Lower Level A, TSI Figure III-6 Asbestos Sampling Locations, First Floor Figure III-7 Asbestos Containing Building Material, Lower Level A Figure III-8 Lead Based Paint Locations, Lower Level A Figure III-9 Potential Hazardous Material Locations, Lower Level A Figure III-10 Potential Hazardous Material Locations, First Floor Figure III-11 Fluorescent Light Locations, Lower Level B Figure III-12 Fluorescent Light Locations, Lower Level A Figure III-13 Fluorescent Light Locations, First Floor

Appendices Appendix III-A Photographs of ACBMs Appendix III-B Asbestos Analytical Results Appendix III-C Lead Based Paint Summary Reports

Phase IV Documents (separate cover)

Tables Table IV-1 Summary of Asbestos Containing Building Materials Table IV-2 Summary of Non-Asbestos Containing Building Materials

Figures Figure IV-1 Asbestos Sampling Locations, Lower Level B, #1 Figure IV-2 Asbestos Sampling Locations, Lower Level B, #2 Figure IV-3 Asbestos Sampling Locations, Lower Level A, #1 Figure IV-4 Asbestos Sampling Locations, Lower Level A, #2 Figure IV-5 Asbestos Sampling Locations, Lower Level A, #3 Figure IV-6 Asbestos Sampling Locations, First Floor Figure IV-7 Asbestos Containing Building Material, Lower Level B Figure IV-8 Asbestos Containing Building Material, Lower Level A Figure IV-9 Lead Based Paint Locations, Lower Level B Figure IV-10 Lead Based Paint Locations, Lower Level A Figure IV-11 Potential Hazardous Material Locations, Lower Level B Figure IV-12 Potential Hazardous Material Locations, Lower Level A Figure IV-13 Fluorescent Light Locations, Lower Level B Figure IV-14 Fluorescent Light Locations, Lower Level A

Appendices Appendix IV-A Photographs of ACBMs Appendix IV-B Asbestos Analytical Results Appendix IV-C Lead Based Paint Summary Reports

Phase V Documents (separate cover)

Tables Table V-1 Summary of Asbestos Containing Building Materials Table V-2 Summary of OSHA Regulated Building Materials Table V-3 Summary of Non-Asbestos Containing Building Materials

Figures Figure V-1 Asbestos Sampling Locations, Lower Level B Figure V-2 Asbestos Sampling Locations, Lower Level A Figure V-3 Asbestos Sampling Locations, Mezzanine Level Figure V-4 Asbestos Containing Building Material, Lower Level B Figure V-5 Asbestos Containing Building Material, Lower Level A Figure V-6 Asbestos Containing Building Material, Mezzanine Level Figure V-7 Lead Based Paint Locations, Lower Level B Figure V-8 Lead Based Paint Locations, Lower Level A Figure V-9 Lead Based Paint Locations, Mezzanine Level Figure V-10 Potential Hazardous Material Locations, Lower Level B Figure V-11 Potential Hazardous Material Locations, Lower Level A Figure V-12 Potential Hazardous Material Locations, Mezzanine Level Figure V-13 Fluorescent Light Locations, Lower Level B Figure V-14 Fluorescent Light Locations, Lower Level A Figure V-15 Fluorescent Light Locations, Mezzanine Level

Appendices Appendix V-A Photographs of ACBMs and OSHA Regulated Building Materials Appendix V-B Asbestos Analytical Results Appendix V-C Lead Based Paint Summary Reports

Phase VI Documents (separate cover)

Tables Table VI-1 Summary of Asbestos Containing Building Materials Table VI-2 Summary of OSHA Regulated Building Materials Table VI-3 Summary of Non-Asbestos Containing Building Materials

Figures Figure VI-1 Asbestos Sampling Locations, Lower Level B Figure VI-2 Asbestos Sampling Locations, Lower Level A Figure VI-3 Asbestos Sampling Locations, First Floor Figure VI-4 Asbestos Sampling Locations, Mezzanine Level Figure VI-5 Asbestos Containing Building Material, Lower Level A Figure VI-6 Asbestos Containing Building Material, First Floor Figure VI-7 Lead Based Paint Locations, Lower Level A Figure VI-8 Lead Based Paint Locations, First Floor Figure VI-9 Lead Based Paint Locations, Mezzanine Level Figure VI-10 Potential Hazardous Material Locations, Lower Level B Figure VI-11 Potential Hazardous Material Locations, Lower Level A Figure VI-12 Potential Hazardous Material Locations, First Floor Figure VI-13 Potential Hazardous Material Locations, Mezzanine Level Figure VI-14 Fluorescent Light Locations, Lower Level B Figure VI-15 Fluorescent Light Locations, Lower Level A Figure VI-16 Fluorescent Light Locations, First Floor Figure VI-17 Fluorescent Light Locations, Mezzanine Level

Appendices Appendix VI-A Photographs of ACBMs and OSHA Regulated Building Materials Appendix VI-B Asbestos Analytical Results Appendix VI-C Lead Based Paint Summary Reports

Phase VII Documents (separate cover)

Tables Table VII-1 Summary of Asbestos Containing Building Materials Table VII-2 Summary of OSHA Regulated Building Materials Table VII-3 Summary of Non-Asbestos Containing Building Materials

Figures Figure VII-1 Asbestos Sampling Locations, Lower Level B Figure VII-2 Asbestos Sampling Locations, First Floor Figure VII-3 Asbestos Sampling Locations, Mezzanine Level Figure VII-4 Asbestos Containing Building Material, Lower Level B Figure VII-5 Asbestos Containing Building Material, First Floor Figure VII-6 Asbestos Containing Building Material, Mezzanine Level Figure VII-7 Lead Based Paint Locations, First Floor Figure VII-8 Lead Based Paint Locations, Mezzanine Level Figure VII-9 Potential Hazardous Material Locations, Lower Level B Figure VII-10 Potential Hazardous Material Locations, First Floor

Figure VII-11 Potential Hazardous Material Locations, Mezzanine Level Figure VII-12 Fluorescent Light Locations, Lower Level B Figure VII-13 Fluorescent Light Locations, First Floor Figure VII-14 Fluorescent Light Locations, Mezzanine Level

Appendices Appendix VII-A Photographs of ACBMs and OSHA Regulated Building Materials Appendix VII-B Asbestos Analytical Results Appendix VII-C Lead Based Paint Summary Reports

Pinyon Environmental Engineering Resources, Inc.

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 1

1.0 Introduction

RNL Design (RNL) contracted with Pinyon Environmental Engineering Resources, Inc. (Pinyon), to complete a limited asbestos-containing building materials (ACBMs) survey; a limited lead based paint (LBP) survey; and a limited hazardous material survey for chlorofluorocarbon- (CFC), polychlorinated biphenyl- (PCB), mercury- and di (2-ethylhelx) phathatlate (DEHP)-containing equipment and chemicals at the Cadet Gym, Building 2170, at the U.S. Air Force Academy (AFA), Colorado Springs, Colorado. The purpose of this survey was to evaluate if building materials contain asbestos or lead based paint, and to document locations of CFC-, PCB-, mercury-, and DEHP-containing equipment and chemical storage areas in preparation for the planned renovation activities.

The five-level, 440,000-square-foot facility was completed in 1960 and was designed to meet the requirements of the Academy’s academic programs in the 1960s. Since the Cadet Gym was completed, a multitude of construction projects and additions have adapted this design to accommodate the ever-changing needs of the cadets and its design evolution. The goal of the overall project is to renovate the Cadet Gym to meet the current needs of cadets and of the academic programs.

The U.S. AFA contracted with RNL to create a six-phase master plan for the renovation of the Cadet Gym (RNL, 2006). The phased plan will allow normal activities to continue at the Cadet Gym during construction. The detailed phasing plan is discussed in Volume 1 of the Findings and Recommendations Report (RNL, 2006). Pinyon completed the survey by phase, based on the RNL phasing plans.

Pinyon previously completed a limited asbestos survey on select building materials if there were large quantities of the materials, or if they were in areas likely to be impacted by the renovation (Pinyon, 2005). Results from this previous survey have been used in this report.

INTRODUCTION

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2.0 Methodology

The limited asbestos, lead based paint and hazardous materials survey were completed phase by phase based on the following methodologies:

2.1 Limited Asbestos Survey

Pinyon performed the survey of suspect ACBMs between January 2, 2007, and February 2, 2007.

The limited survey was conducted in accordance with EPA National Emissions Standards for Hazardous Air Pollutants (NESHAPS), the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1926.1101, and Colorado Regulation No. 8, except where otherwise noted.

• This is considered a limited survey because the survey was only conducted on those areas of the Cadet Gym that are going to be impacted by the planned renovation activities, as outlined in the RNL Master Plan..

• The asbestos survey was completed by Environmental Protection Agency (EPA) Asbestos Hazard Emergency Act (AHERA); 40 CFR 763, accredited and State of Colorado certified inspector. Resumes and certifications are included in Appendix A.

• Pinyon only assessed and sampled those areas that were to be impacted during renovation activities, based on the RNL Master Plan, and direction from RNL.

• In general, a minimum of three samples were collected from each readily visible and accessible homogeneous material with exceptions for materials with less than 10 square feet of material.

• Pinyon generally followed the 3-5-7 rule under AHERA, specifying the collection of:

• 3 samples of surfacing materials less than 1,000 square feet in size;

• 5 samples of surfacing materials between 1,000 and 5,000 square feet in size; and

• 7 samples of surfacing materials greater then 5,000 square feet in size.

• In some cases, homogenous materials were assumed to be ACBMs, since access to potential asbestos materials was not possible, or sampling would interfere with the integrity of the system. These materials included:

• Phase II, Lower Level B

• Tile and mastic in the water polo pool

METHODOLOGY

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 4

• Phase III, Lower Level A

• Tile and mastic in the nanatorium pool

• Additional samples may need to be collected prior to or during demolition if hidden areas are revealed and materials are encountered that were not sampled earlier.

• Homogenous materials were qualified and the condition of the materials were assessed.

Samples were collected following AHERA procedures using a utility knife, chisels, a hammer, or similar tools. Each sample was assigned a unique number and logged on field sampling forms. Samples were then delivered to Reservoirs Environmental Services, Inc.

(Reservoirs), of Denver, Colorado. Chain-of-custody forms were submitted with the samples.

Reservoirs is certified by the National Institute of Standards and Technology (NIST) and is a participant under the National Voluntary Laboratory Accreditation Program (NVLAP).

• Samples were analyzed using polarized light microscopy (PLM) and were analyzed progressively. ACBMs are defined as materials with greater then or equal to one percent asbestos by weight. During progressive analysis, if the first sample analyzed of a material must be categorized as asbestos-containing. Results of samples collected from materials with layers, such as pipe insulation or drywall, are reported as composite samples. All samples found to contain trace to three percent asbestos by individual PLM analysis were reanlyzed by point counting. Point counting is a more precise measurement technique. Samples analyzed found to contain greater than three percent asbestos were not point counted.

A glossary of terms is included in Appendix B.

2.2 Limited Lead Based Paint Survey

The survey was conducted by Mr. Scott Epstein with Pinyon, a Colorado Certified LBP inspector, Certification Number 12334 (Appendix A), between January 15, 2007, and January 17, 2007. Pinyon has been certified as a Lead Evaluation Firm (LEF) by CDPHE, Air Pollution Control Division, to provide LBP services. Pinyon’s LEF Certification Number is 84-1243279 (Appendix A). Mr.

Epstein is also certified in the use of a radiation-source instrument by RMD Instruments, L.L.C., and he operated the x-ray flourescent (XRF) instrument that was used to read the lead content of paint layers. The instrument was an RMD LPA-2 XRF, Model Number LPA-1, Serial Number 01996.

The XRF is a direct-read instrument that uses a radioactive source. The XRF instrument exposes the painted surface to X-rays or gamma rays, which causes the lead atoms to emit X-rays with a characteristic energy. The intensity of the radiation emitted from the paint is measured by the instrument’s detector and is converted to a number that represents the amount of lead in the paint per unit area. The concentrations are measured in micrograms per cubic centimeter (mg/cm2).

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 5

The operating parameters for the XRF readings are standard mode and quick mode. The standard mode is used in the calibration of the instrument and the quick mode is used when taking readings.

In the quick mode, substrate of the instrument and the quick mode is used when taking readings. In the quick mode, substrate corrections are not needed for brick, concrete, plaster, metal, or wood. The XRF records the lead reading and classifications, positive, negative, or inconclusive. HUD regulations state that both positive and inconclusive data must be considered LBP. Positive readings are considered greater then or equal to 1.0 mg/cm2, as defined by CDPHE.

2.2.1 Quality Assurance/Quality Control

Based on CDPHE Regulation No. 19, at a minimum the instruments calibration must be checked at the beginning of each survey, at least every four hours during the survey, and at the end of an survey.

In addition, the RMD LPA-1 performs an internal calculation prior to every fifth reading to insure the instrument’s accuracy when readings are taken. According to the manufacturer, the instrument will not operate if the calibration do not meet standards set by the manufacturer.

2.2.2 Testing Procedures

The Cadet Gym does not meet the requirements of a “child occupied facility.” Pinyon completed the limited assessment by phase, only on areas that will be impacted by the planned renovation activities, based on the RNL Master Plan.

he following rooms were not accessible at the time of the Site survey:

Phase II ! Lower Level B

• One squash court ! Lower Level A

• Mens Soccer

• Mens Lacrosse

Phase III ! Lower Level B

• Office in Women’s Cadet Locker Room

• Women’s Volleyball Conference Room (A171a)

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 6

Phase IV ! Lower Level B

• One squash court Phase V

! Lower Level B

• Three squash courts

! Lower Level A

• SCUBA Room

Phase VII ! Lower Level B

• Eight squash courts

• Mezzanine Level

• Three offices In the areas where renovation activities were planned readings, were taken of the following:

• Each building component and substrate; and

• Each different color of paint.

During the survey, each sampling location was marked on a map, and the substrate, component, color and condition were marked on Pinyon field forms.

A total of 1,670 readings were taken at the Cadet Gym, excluding calibration. A breakdown of the number of readings by phase is listed below:

• Phase III: 257 readings

• Phase II: 172 readings

• Phase IV: 163 readings

• Phase V: 387 readings

• Phase VI: 316 readings

• Phase VII: 375 readings

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2.3 Limited Hazardous Materials Survey

Visual observation of all accessible interior spaces in Phases I through VI were observed for chemical storage, suspect PCBs, DEHPs, CFCs and mercury-containing devices on January 11 and 16, 2007.

Typical PCB-containing devices observed in the Site building, include electrical transformers and fluorescent and high intensity discharge (HID) light ballasts. The only suspect DEHP-containing items are light ballasts, manufactured between 1979 and 1991. CFCs are likely present in chilled drinking fountains, ice machines and vending machines. Mercury is present in on-Site fluorescent and HID light bulbs, thermostats, gages, and batteries in emergency or safety lighting. An in-depth survey of the mechanical and pool control rooms was not conducted, and it is likely that switches, relays and other controls located in these areas contain mercury.

Chemical storage was typically in the form of cleaning supplies in janitorial closets and storage rooms. As stated above, the pool control rooms were not observed, and likely contain pH control and pool management chemicals.

The following rooms were not accessible at the time of the Site observation:

Phase II ! Lower Level A

• Room AA - HVAC Duct Room Phase III

! Lower Level B

• Office and closet (1171) in Women’s Cadet Locker Room

• Women’s Volleyball Conference Room (A171a)

! First Floor

• Storage Closet (G110)

Phase IV ! Lower Level A

• Storage closets along south wall of weight room

Phase VI ! Lower Level B

• Courts S1, S2, S3, S4, S6

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 8

! Lower Level A

• Scuba Classroom

! First Floor

• Boxing Team Room

• Closet in west gym

! Mezzanine Level

• Office (M240f)

Phase VII ! Lower Level B

• High Voltage Room (B117)

• Court R1

• Closet across from B117

! First Floor

• Closet in East Gym

! Mezzanine Level

• Volleyball Video Room (M212)

• M215a (HVAC Access)

• M216 (Common Room/Storage)

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3.0 Results

3.1 Phase II Results

3.1.1 Asbestos Results

A total of 283 bulk samples were collected from 63 homogenous materials in the Phase II area of the building (Figures II-1 through II-4). Two building materials, baseboard adhesive and plaster, are considered ACBMs (Table II-1, Figures II-5 and II-6, and Appendix II-A). Tile and mastic in the water polo pool is considered an assumed ACBM since it was unable to be sampled without damaging the integrity of the pool. Accessible thermal system insulation (TSI) materials were sampled and are also considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel, all TSI will be treated as ACBMs. Asbestos was detected in the ceiling tile adhesive, but at less then one percent; therefore, although it is not classified as an ACBM, it is regulated by OSHA during construction activities (Table II-2, Appendix II-A). The remaining materials are not classified as ACBMs (Table II-3). Laboratory analytical results are attached in Appendix II-B

3.1.2 Lead Based Paint Results

Of the 257 total measurements in the Phase II area of the building, 16 measurements were above the CDPHE standard (Figure II-7, Appendix II-C). Lead based paint was detected on doors and door headers in the Phase II areas around the men’s locker rooms, the women’s staff lockers and the training room on lower level A.

3.1.3 Potential Hazardous Material Results

Cleaning supplies were observed in the Phase Ii areas (Figures II-8 and II-9). Mercury is present in thermostats, and is likely present in safety and emergency lighting batteries (Figures II-8 and II-9).

CFCs are likely present in chilled drinking fountains and the ice machine located on Lower Level A (Figures II-8 and II-9). PCB-containing oil may be present in the Atlantic Power Systems, Inc., transformers located in the electrical rooms on level B of Phase II (Figures II-8 and II-9). PCBs and possibly DEHP-containing light ballasts were located throughout Phase II. Mercury is present in fluorescent and HID light bulbs (Figures II-10 and II-11).

RESULTS

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 10

3.2 Phase III Results

3.2.2 Asbestos Results

A total of 212 bulk samples from 51 homogenous materials were collected in the Phase III areas (Figures III-1 through III-5). Three building materials, plaster and two types of duct insulation, are considered ACBMs (Table III-1, Figure III-7, and Appendix III-A). Tile and mastic in the nanatorium pool are considered an assumed ACBM, since it was unable to be sampled without damaging the integrity of the pool. Accessible TSI materials were sampled and are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel, all TSI will be treated as ACBMs. (Please note that only the ACBM locations of the plaster have been included on the ACBM Figure, because all thermal system insulation is being considered ACBMs.) The remaining materials are not classified as ACBMs (Table III-2). Laboratory analytical data is included in Appendix III-B.

3.2.3 Lead Based Paint Results

Of the 172 readings in the Phase II areas, six measurements were above the CDPHE standard (Figure III-8, Appendix III-C). All six readings were detected on lower level A, on doors and wallboards in the wrestling room, and on the diving board platform.

3.2.4 Potential Hazardous Material Results

Minor amounts of cleaning supplies were observed, and mercury is potentially present in thermostats and in safety and emergency lighting batteries (Figures III-9 and III-10). CFCs are likely present in chilled drinking fountains (Figures III-9 and III-10). PCBs and possibly DEHP-containing light ballasts and mercury containing fluorescent and HID light bulbs were observed (Figures III-11 through III-13).

3.3 Phase IV Results

3.3.1 Asbestos Results

A total of 268 bulk samples from 57 homogenous materials were collected in the Phase IV areas (Figures IV-1 through IV-6). Five building materials, two types of floor tile, floor tile mastic, rubber

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 11 floor mastic, and baseboard adhesive, are considered ACBMs (Table IV-1, Figure IV-7 and IV-8, and Appendix IV-A). Accessible TSI materials were sampled and are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel all TSI will be treated as ACBMs. The remaining materials are not classified as ACBMs (Table IV-2). Laboratory analytical results are included in Appendix IV-B.

3.3.2 Lead Based Paint Results

Of the 163 total readings taken in the Phase IV areas, ten readings were above the CDPHE Standards (Figure IV-9 and IV-10, Appendix IV-C). Lead based paint was detected on the baseboard, railing, and risers of the stairwells leading to the weight room (Figure IV-9). Additionally, lead was detected on the door jams of the closets, on the south side of the weight room (Figure IV-10).

3.3.3 Potential Hazardous Material Results

Mercury is likely present in thermostats and in safety and emergency lighting batteries (Figures IV-11 and IV-12). CFCs are likely present in chilled drinking fountains (Figures IV-11 and IV-12). PCBs and possibly DEHP-containing light ballasts and mercury containing fluorescent and HID light bulbs were observed (Figures IV-13 and IV-14).

3.4 Phase V Results

3.4.1 Asbestos Results

A total of 227 bulk samples from 57 homogenous materials were collected in the Phase V areas (Figures V-1 through V-3). One building material, carpet adhesive, is considered an ACBM (Table V-1, Figure V-4 through V-6, and Appendix V-A). Accessible TSI materials were sampled and are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel all TSI will be treated as ACBMs. Asbestos was detected in wood lathing, but at less then one percent; therefore, it is regulated by OSHA during construction activities (Table V-2, Appendix V- A). The remaining materials are not classified as ACBMs (Table V-3). Laboratory analytical data is included in Appendix V-B.

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3.4.2 Lead Based Paint Results

Of the 387 total readings taken from Phase V, 15 readings were above the CDPHE Standards (Figures V-7 through V-9, Appendix V-C). Lead was detected on the window casing and bleacher supports on two squash courts in lower level B (Figure V-7); on the rail, baseboard and risers of the stairs next to reconditioning; and on the door jams of storage closets on lower level A (Figure V-8).

Additionally, lead based paint was detected on the baseboard behind the tennis bleachers (Figure V- 9).

3.4.3 Potential Hazardous Material Results

Cleaning supplies were observed in the Phase V area of the building. Mercury is likely present in thermostats and in safety and emergency lighting batteries and CFCs are likely present in chilled drinking fountains (Figures V-10 through V-12). PCBs and possibly DEHP-containing light ballasts and mercury containing fluorescent and HID light bulbs were located throughout Phase V (Figures V-13 through V-15).

3.5 Phase VI Results

3.5.1 Asbestos Results

A total of 227 bulk samples from 65 homogenous materials were collected in the Phase VI areas (Figures VI-1 through VI-4). Three building materials, two types of floor tile, and two types of plaster are considered ACBMs (Table VI-1, Figure VI-4 through VI-6, and Appendix VI-A).

Accessible TSI materials were sampled are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel all TSI will be treated as ACBMs. Asbestos was detected in two types of baseboard adhesive and in linoleum flooring, but at less then one percent;

therefore it is regulated by OSHA during construction activities (Table VI-2, Appendix VI-A). The remaining materials are not classified as ACBMs (Table VI-3). Laboratory analytical results are attached in Appendix V-B.

3.5.2 Lead Based Paint Results

Of the 316 total readings taken in the Phase V areas, a total of five readings were above the CDPHE Standards (Figures VI-7 through VI-9, Appendix VI-C). In Lower Level A, lead was detected on the

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 13 bay door casing (Figure VI-7), and on doors on the main level (Figure VI-8). Lead based paint was also detected on the baseboard in the stairwell, located in the northeast corner of the mezzanine level (Figure VI-9).

3.5.3 Potential Hazardous Material Results

Cleaning supplies are stored in the Phase VI areas (Figures VI-10 through VI-13). Mercury is likely present in thermostats and in safety and emergency lighting batteries (Figures VI-10 through VI-13).

CFCs are likely present in chilled drinking fountains (Figures VI-10 through VI-13). PCBs and possibly DEHP-containing light ballasts and mercury containing fluorescent and HID light bulbs were observed throughout Phase VI (Figures VI-14 through VI-17).

3.6 Phase VII Results

3.6.1 Asbestos Results

In the Phase VII areas, 152 bulk samples from 42 homogenous materials were collected (Figures VII- 1 through VII-3). Three building materials, baseboard adhesive, plaster, and floor tile, are considered ACBMs (Table VII-1, Figure VII-4 through VII-6, and Appendix VII-A). Accessible TSI materials were sampled and are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel all TSI will be treated as ACBMs. Asbestos was detected in linoleum flooring, but at less then one percent; therefore, it is regulated by OSHA during construction activities (Table VII-2, Appendix VII-A). The remaining materials are not classified as ACBMs (Table VII-3).

Laboratory analytical data is included in Appendix VII-B

3.6.2 Lead Based Paint Results

Of the 375 total readings taken in the Phase VII areas, a total of 25 readings were above the CDPHE Standards (Figures VII-7 and VI-8 and Appendix VII-C). Lead based paint was detected on the doors behind the nanotorium on the main level and on the railing of the stairwell leading to the physical education offices (Figure VII-7). Also, lead based paint was detected on most doors and headers along the southern offices on the mezzanine level (Figure VII-8).

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3.6.3 Potential Hazardous Material Results

Cleaning supplies were located in Phase VII areas (Figures VII-9 through VII-11). Mercury is likely present in thermostats and in safety and emergency lighting batteries (Figures VII-9 through VII-11).

CFCs are likely present in chilled drinking fountains (Figures VII-9 through VII-11). PCBs and possibly DEHP-containing light ballasts and mercury containing fluorescent and HID light bulbs were located throughout Phase VII (Figures VII-12 through VII-14).

CONCLUSIONS

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4.0 Conclusions

4.1 Asbestos

Asbestos containing building materials were detected in each phase of the project. Building materials that are not considered ACBMs, but where asbestos was detected, are regulated by OSHA, and include materials in the areas of Phases II, V, VI and VII. Accessible thermal system insulation materials were sampled and are considered ACBMs. Based on these results, AFA drawings, and conversations with AFA personnel, all TSI will be treated as ACBMs. If additional materials are exposed during demolition activities which have not yet been samples, they should be assumed ACBMs until sampling proves otherwise.

Based on Colorado Regulation No. 8 and OSHA guidelines, the following procedures should be implemented:

• Prior to renovation activities, an asbestos project designer should complete asbestos abatement design documents for the building.

• An asbestos abatement contractor should be hired to remove the recognized friable asbestos containing materials that could be impacted.

• OSHA’s General Industry Asbestos Standard, 29 CFR 1910.1001 and Construction Asbestos Standard, 29 CFR 1923.1101, are the standards that guide ACBM regulations in the work place.

• If the ACBMs are to remain in place, and for the time period until abatement occurs, an Operations and Maintenance Plan (O&M) should be prepared in order to properly handle the ACBMs during daily operations.

• Rule 29 CFR 1919.1001 requires building owners to maintain records of information concerning the presence, location, and quantity of ACBMs and presumed ACBMs installed in their building.

• Homogenous materials that contain less than one percent asbestos should be addressed to protect workers’ safety according to OSHA’s General Industry standard for asbestos, 29 CFR 1926.1101.

• OSHA requires that a Negative Exposure Assessment (NEA) be performed to evaluate potential worker exposure to asbestos fibers that may be generated during maintenance operations of identified ACMs at the facility. Air samples should be collected and analyzed by transmission electron microscopy (TEM) to evaluate whether OSHA’s permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter of air (f/cc) has been exceeded.

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• Maintenance and custodial staff should receive asbestos awareness training in the proper care and handling of ACBMs and assumed ACBMs to prevent exposure to potential fiber releases from these materials.

4.2 Lead Based Paint

Lead based paint was detected on various substances in all six phases of the project; therefore, any work on these surfaces should follow Colorado Regulation No. 19 and OSHA 29 CFR 1926.62, Lead.

• Building materials that can be removed as intact units, such as doors, can be removed without any additional protection, if the LBP surfaces are not disturbed in a manner that would generate dust and fine LBP chips, which could be inhaled or ingested by workers.

• Building materials that will be disturbed during renovation activities need to be abated in accordance with Colorado Regulation No.19 by an approved abatement contractor to prevent the release of airborne lead. All abatement activities should be completed in conformance with OSHA 29 CFR 1926.62.

• Materials that are to be removed from the Site and disposed will have to be analyzed by the Toxic Characteristic Leachate Procedure (TCLP) to evaluate whether the waste streams will need to be disposed as a hazardous or non-hazardous waste.

• LBP chips that are inadvertently generated during construction activities should be generated and placed in 6-mil plastic containers for proper disposal.

4.3 Hazardous Materials

4.3.1 Mercury

4.3.1.1 Light Bulbs

Mercury is used in a variety of light bulbs, due to its contribution to the bulbs’ efficient operation and life expectancy. Light bulbs observed on Site which may contain mercury are: fluorescent lamps, including linear fluorescent, U-tube, high output and compact fluorescent; and high intensity discharge (HID) lamps, including metal halide, ceramic metal halide, high pressure sodium and mercury vapor. (From the observation distance, the type of HID lamps could not be distinguished and are hereby further referred to by the generic term of HID lamps.) Some of the linear fluorescent lamps which were observed on Site were low-mercury lamps. These low-mercury lamps are clearly marked with either green printing or green end caps to distinguish them from higher mercury products as shown below. Note that most lamps were obscured from view by the lighting fixtures. The Colorado Department of Health and Environment states the following regarding low-mercury lamps.

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“ Testing done by the manufacturers demonstrate that these low-mercury lamps do not tend to fail the toxicity test for metals and can therefore be managed as non-hazardous solid wastes, even by non-residential facilities.

Mercury-containing lighting wastes from nonresidential sources that are not hazardous may be disposed of in a properly managed municipal solid waste landfill or sent to a legitimate recycler. Landfills and recyclers may impose their own restrictions to regulate incoming wastes in accordance with local rules or company guidelines.” (CDPHE, 2002).

During renovation activities, any low-mercury lamps may be disposed with other demolition waste; however, a more beneficial disposal option would be to recycle these lamps. Several out-of-state contractors will recycle mercury-containing lamps.

In addition, lighting contractors will often provide this service.

Any lamps that are not identified as low-mercury must be handled as a universal waste. All waste lamps classified as a universal waste must be labeled as either “waste lamp(s),” “used lamp(s)” or “universal waste lamp(s).” If the lamps are placed into an accumulation container, only the accumulation container needs to be labeled. If an individual waste lamp is broken, leaking or damaged, it must be individually over-packed in a closed packing container that is properly labeled and capable of preventing leakage or release of hazardous constituents to the environment. Waste lamps must not accumulate on Site for longer than one year. Shipment of universal waste in Colorado does not require the use of the hazardous waste manifest system.

Therefore, universal waste is not considered hazardous waste under US Department of Transportation regulations (CDPHE, 2003).

There are two categories of universal waste handlers. Small Quantity Handlers and Large Quantity Handlers. If the entire Air Force Academy Colorado Springs Facility does not accumulate more than 5,000 kilograms of total universal waste in a given year, then they would be considered a small quantity handler. A large quantity handler accumulates more than 5,000 kilograms of total universal waste. In either case, a handler cannot accumulate more than 35 kilograms of elemental mercury at

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 18 one time (CDPHE, 2003). (A typical linear fluorescent lamp contains approximately

11.6 mg of elemental mercury while a typical low-mercury lamp contains approximately 3 mg of mercury (NEMA, 2001).)

Small quantity handlers of universal waste are not required to notify the CDPHE or EPA of their universal waste management activities. Large quantity handlers are required to notify the CDPHE, Hazardous Materials and Waste Management Division and obtain an EPA identification number using EPA Form 8700-12. This must be done even if the facility has an EPA identification number for its hazardous waste activities.

Disposal of mercury-containing lighting waste which exceed CERCLA thresholds are subject to notification requirements under 40 CFR 302. If waste disposal is above the reportable quantity (RQ) limit, disposal of such requires notification to the National Response Center (800-424-8802). The RQ under CERCLA is one pound of mercury in a 24-hour period (EPA, 1999). The EPA estimates that approximately 11,000 four-foot T12 florescent lamps would constitute one pound of mercury (CDPHE, 2002).

4.3.1.2 Mercury in Other Building Components

Other mercury containing devices observed on Site include thermostats, gauges, and batteries in emergency or safety lighting. An in-depth survey of the mechanical and pool control rooms was not conducted, and it is likely that switches, relays and other controls located in these areas may contain mercury. According to federal regulations, these devices can also be handled as universal wastes.

During demolition, Pinyon advises that contractors do not remove elemental mercury from the device. Removing mercury requires compliance to Part 273.13 or 272.33 of the Colorado Hazardous Waste Regulations and a written procedure detailing safe removal procedures, equipment operation and maintenance and worker protection measures (CDPHE, 2003). A simpler solution is to collect all suspect mercury-containing devices, over-pack in a sealed container to prevent breakage, spillage or release, label as mercury containing thermostats, batteries, etc., and ship to a licensed disposal or recycling contractor under the universal waste regulations, if it is

Limited Asbestos , LEAD BASED PAINT AND HAZARDOUS MATERIALS SURVEY February 23, 2006 U.S. Air Force Academy, Cadet Gym Page 19 estimated that greater than one pound of mercury from thermostats and batteries will be removed.

4.3.2 Chlorofluorocarbons (CFCs)

Effective July 1, 1992, Section 608 of the Clean Air Act prohibits individuals from knowingly venting ozone-depleting compounds (i.e. CFCs) used as refrigerants into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment (EPA, 2003). Pinyon observed the following items which may contain CFCs: chilled drinking fountains, ice machines, vending machines, and refrigerators. Only those items that are an integral part of the building and are not movable, specifically chilled drinking fountains, were identified as CFC-containing in this survey.

During renovation activities, a certified technician is required to evacuate air-conditioning and refrigeration equipment to established vacuum levels when opening the equipment. Technicians are required to recover 90 percent of the refrigerant. If refrigerants are recycled or reclaimed, they are not considered hazardous under federal law.

4.3.3 PCBs and DEHPs

4.3.3.1 Light Ballasts

Polychlorinated biphenyls (PCBs) are hazardous to human health and the environment due to their toxicity, persistence, and bioaccumulation in the food chain. Ballasts are small metal box-shaped devises in fluorescent and HID light fixtures that control the flow of electricity to the light. All florescent light ballasts manufactured through 1979 contain PCBs. Ballasts manufactured after 1979 that do not contain PCBs are often labeled, “No PCBs.” If the ballast is not labeled that it must be assumed that it is PCB-containing (CDPHE, 2002). Lighting fixtures which contain ballasts are located throughout the Site building.

Di (2-ethylhexyl) phathatlate (DEHP) was used in the manufacture of some light ballasts from 1979 through 1991. DEHP, as a pure commercial waste, is listed as hazardous under the Resource Conservation Recovery Act (RCRA) (CDPHE, 2002).

However, once it has been used in a lighting ballast, it is not longer considered to be hazardous. Other regulations, as outlined below, still apply.

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PCB-containing light ballasts are regulated under the Toxic Substances Control Act (TSCA) and disposal of such is also regulated under the Comprehensive Environmental Response, Compensation , and Liability Act (CERCLA). The EPA and the CDPHE recommend that non-leaking PCB-containing and DEHP-containing ballasts be disposed of at a TSCA approved incinerator, disposal facility, or recycler.

High-temperature incineration is the method preferred because it destroys PCBs. The EPA suggests that certificates of destruction be obtained from the TSDF for PCB and DEHP disposal.

If the ballast has been damaged, an oily, tar-like substance may be exposed. If this substance contains PCBs, the ballast and all materials it contacts are considered hazardous waste and must be disposed in an EPA permitted treatment, storage and disposal facility (TSDF). All leaking ballast material and waste must be properly packaged for transportation according to EPA and Department of Transportation regulations. This includes utilizing the manifest system to track the waste and verify its proper disposal.

Disposal of PCB wastes, mercury-containing lighting waste, or DEHP-containing wastes which exceed CERCLA thresholds are subject to notification requirements under 40 CFR 302. If waste disposal is above the reportable quantity (RQ) limit, disposal of such requires notification to the National Response Center (800-424- 8802). The RQ under CERCLA is one pound of PCBs or 100 pounds of DEHP in a 24-hour period. The EPA estimates that small PCB-containing light ballasts typically contain approximately 0.1 pound of PCBs. Therefore, disposal of 10 or more light ballasts is likely subject to CERCLA reporting requirements. In addition, EPA estimates that approximately 1,600 fluorescent DEHP-light ballasts would equal 100 pounds of DEHP (CDPHE, 2002).

4.3.3.2 Dielectric Fluid

Oil-filled transformers may also contain PCBs. If any oil-filled transformers are to be removed or relocated, the oil must be removed and disposed of according to CERCLA regulations.

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4.3.4 Chemical Storage

Small quantities of chemicals, typically cleaning or maintenance supplies, were observed on Site.

It…