Environmental Report.pdf

NESHAP Asbestos Survey Report

Pre-Demolition Assessments at

Steam Tunnel Vaults adjacent to AFIT in Area B

Wright Patterson Air Force Base

Prepared For:

Wright Patterson Air Force Base

March 29, 2011

Prepared By:

LJB Inc.

3100 Research Boulevard

P.O. Box 20246

Dayton, Ohio 45420-0246

Report No. 0106542A.00

TABLE OF CONTENTS

EXECUTIVE SUMMARY

ASBESTOS SAMPLING

ANALYTICAL LABORATORY AND ANALYSIS

CONCLUSIONS

APPENDICES

A Laboratory Report with Chain of Custody Forms

B Inspector Certification

INDEX TO FIGURES

Figure 1 Vault Locations

INDEX TO TABLES

Table 1 Asbestos Sample Results

LJB Inc. Wright Patterson Air Force Base

Executive Summary

LJB Inc. (LJB) has completed the asbestos pre-demolition/renovation inspections in select vaults associated with buried steam pipes adjacent to and in the basement area of AFIT in Area B at

Wright Patterson Air Force Base. These inspections were done as required by U.S. EPA

National Emission Standards for Hazardous Air Pollutants (NESHAP) Regulations. The purpose of the surveys was to identify asbestos-containing materials (ACMs) that would require abatement prior to the demolition/renovation activities within and potentially between the buried vaults.

On February 20, 2012 two steam vaults were entered and samples of suspect ACMs were collected. On March 8, 2012 two additional areas were entered and samples of suspect ACMs were also collected.

As part of the asbestos inspections, LJB identified a number of suspect ACMs that required sampling and analysis to determine their asbestos content. The suspect ACMs identified in the vaults includes the following material types:

Thermal Insulation;

Miscellaneous Sealants;

Miscellaneous cloth-like materials inside the vault walls;

Miscellaneous cloth-like materials on steam pipes;

Tar Coatings; and

Other Materials.

Fifty-eight (58) samples of suspect ACMs were collected from homogeneous sampling areas in the various vaults. The location of each vault is identified is Figure 1. The results of the ACM sampling and analysis activities are included in Appendix A and summarized in Table 1.

Approximately one third of the sampled materials (i.e. 17 out of 58 samples) were determined to contain asbestos by laboratory analysis (i.e. at levels between 2% to 45%).

Asbestos abatement activities are warranted during the excavation and removal of the concrete vaults and/or associated piping. ACM were identified on the heating pipes located inside the vaults. ACM are also likely to be present on the buried pipes associated between these structures. As such, all coated pipes; gaskets, and joint filler exposed during the excavation activities should be treated as ACM and be abated/disposed of per applicable federal and state requirements. These requirements also extend to the pipes present inside the vaults.

Asbestos Sampling

Edward Council of LJB performed the asbestos inspections in the applicable vaults. Edward

Council is a certified Asbestos Hazard Evaluation Specialist (AHES) in the State of

Ohio (#34504). His Certification documentation is included in Appendix B.

The sampled vaults and number of samples collected during the inspections included:

S-218 (4 samples);

S-219 (8 samples);

Shallow Trench near S-218 (2 samples); and

Basement Vault Area (44 samples).

The purpose of the inspections were to determine if any regulated asbestos-containing materials were present on the steam pipes within the vaults evaluated or was anticipated to be present on the buried pipes located between the vaults.

Each sample was collected from suspect materials in homogeneous sampling areas. For this project homogeneous sampling areas were defined as a material that exhibited similar physical characteristics (e.g. texture, surface color and appearance). Due to a lack of detail construction information and previous renovations, limited information concerning the timing of installation of the potential ACMs was known. As such, the professional judgment and experience of the

AHES was used to select sampling areas and sample materials.

A large cross section of the suspect ACM was collected, per sample, using appropriate means.

Each sample was then placed in a clean and uniquely numbered sealable plastic container.

The sampled materials included potential friable ACM and potential Category I and Category II non-friable materials. Category I non-friable ACM includes asbestos-containing packings, gaskets, roofing, and resilient floor coverings containing greater than 1% asbestos as determined by Polarized Light Microscopy analysis (PLM).

Category II non-friable ACM refers to any material, excluding Category I non-friable ACM, containing greater than 1% asbestos as determined by PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

For this study, “Regulated Asbestos-Containing Materials” (RACM) are:

(a) Friable asbestos material;

(b) Category I non-friable ACM that has become friable;

(c) Category I non-friable ACM that will be, or has been, subjected to sanding, grinding, cutting or abrading; or

(d) 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 the material in the course of the demolition or renovation operations.

The EPA’s NESHAP requires that all friable ACM and all Category II non-friable ACM that will become friable during renovation/demolition activities be removed from a structure prior to any activity that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

In November of 1991, the U.S. EPA amended the analytical protocol for analysis of bulk samples for asbestos content to determine compliance with NESHAP regulations. The revised protocol mandates ACM results with less than 10% but greater than 1% asbestos may be assumed to be an ACM unless proven by other means.

Analytical Laboratory and Analysis

All bulk samples of suspected ACMs were sent to Environmental Hazards Services, LLC (EHS) in Richmond, Virginia for analysis. All samples were controlled under chair of custody procedures. EHS holds accreditation from the National Voluntary Laboratory Accreditation

Program (NVLAP).

The bulk samples were analyzed for asbestos content using procedures outlined in EPA 600/R-

93/116, “Method for Determination of Asbestos in Bulk Building Materials”. PLM with dispersion staining identified the type of asbestos. The percentage(s) of asbestos are estimated by low power stereomicroscopy.

The full laboratory reports can be found in Appendix A. Table 1 provides a summary of the complete sampling results.

Conclusions

Based on the analytical data, multiple samples tested positive for asbestos. As such, demolition activities that uncover or involve any coated materials (except fiberglass) should treat that material as a friable ACM unless an AHES determines it not to be an ACM. In addition, abatement of any RACM identified during the removal activities must be conducted by an asbestos abatement contractor who is licensed by the State of Ohio.

ACMs were identified on the pipes and cut-off pipes present through/on the walls of the vaults.

These older materials are anticipated to be present on the exterior buried sides of the vaults and if exposed, between the vaults. As such, all coated pipes; gaskets, and joint filler exposed during the excavation activities should also be treated as ACM and be abated/disposed of per applicable federal and state requirements.

Table 1. Asbestos Sample Results

Sample Asbestos % Description

1-1 (S-219) NAD Thermal material on pipe

1-2 (S-219) NAD Thermal material on pipe elbow

1-3 (S-219) NAD Thermal material on pipe

1-4 (S-219) NAD Thermal material on pipe

1-5 (S-219) NAD Thermal material on pipe

1-6 (S-219) NAD Gasket-like material at end of pipe

1-7 (S-219) NAD Gasket-like material at end of pipe

1-8 (S-219) NAD Cloth-like wrap on pipe

1-9 (1) (S-218) NAD Thermal material on pipe

1-9 (2) (S-218) NAD Thermal material on pipe

1-9 (3) (S-218) NAD Thermal material on pipe

1-10 (S-218) NAD Cloth-like wrap on wall

P-1 Elb a # NAD Thermal material on pipe elbow

P-1 Elbo-b # NAD Thermal material on pipe elbow

P-1 Elbo c # NAD Thermal material on pipe elbow

P-1 a # NAD Thermal material on pipe

P-1 b # NAD Thermal material on pipe

P-1 c # NAD Thermal material on pipe

S-218-1 # NAD Thermal material on smaller diameter pipe

S-218-2 # NAD Thermal material on larger diameter pipe

P-1 TAR A # 12% Tar coating on pipe

P-1 TAR B # 12% Tar coating on pipe

P-1 TAR C # 12% Tar coating on pipe

P-4 A # NAD Thermal material on pipe

P-4 B # NAD Thermal material on pipe

P-4 C # NAD Thermal material on pipe

P-4 TAR A # 12% Tar coating on pipe

P-4 TAR B # 12% Tar coating on pipe

P-4 TAR C # 12% Tar coating on pipe

P-3a Pipe # NAD Thermal material on pipe

P-3b Pipe # NAD Thermal material on pipe

P-3c Pipe # NAD Thermal material on pipe

P-3a Elbo # NAD Thermal material on pipe elbow

P-3b Elbo # NAD Thermal material on pipe elbow

P-3c Elbo # NAD Thermal material on pipe elbow

P-3C-TAR (2) # 45% Tar coating on pipe

P-3B-TAR (2) # 45% Tar coating on pipe

P-3A-TAR (2) # 45% Tar coating on pipe

P-3-TAR (A) # 45% Tar coating on pipe

P-3-TAR (B) # 45% Tar coating on pipe

P-3-TAR (C) # 45% Tar coating on pipe

NAD – No Asbestos Detected

* - Not Analyzed due to Insufficient Quantity

# - Steam Vault in Basement of AFIT

Table 1. Asbestos Sample Results (cont.)

Sample Asbestos % Description

P-3 Crust-B+C # NAD Gasket-like material at end of pipe

P-3 Crust A # NAD White crust on steel pipe

P-1/2 Tar(a) # 2% Tar coating on pipe

P-1/2 Tar(b) # 3% Tar coating on pipe

P-1/2 Tar(c) # 10% Tar coating on pipe

P-1/2 Pipe (a) # NAD Thermal material on pipe

P-1/2 Pipe (b) # NAD Thermal material on pipe

P-1/2 Pipe (c) # NAD Thermal material on pipe

P-1/2 elbo a # * Thermal material on pipe elbow

P-1/2 elbo b # NAD Thermal material on pipe elbow

P-1/2 Elbo (C) # NAD Thermal material on pipe elbow

P-2 Tar A # 15% Tar coating on pipe

P-2 Tar (B) # NAD Tar coating on pipe

P-2 Tar (C) # 10% Tar coating on pipe

P-2 Pipe A # NAD Thermal material on pipe

P-2 Pipe B # NAD Thermal material on pipe

P-2 Pipe C # NAD Thermal material on pipe

NAD – No Asbestos Detected

* - Not Analyzed due to Insufficient Quantity

# - Steam Vault in Basement of AFIT

4" HPS 3" CRP

963 964

966966

PROJECT No. ZHTV0810019

STEAM LINE REPLACEMENT AREA B

OF

DATEDRAWNDESIGNED CHECKED

M. Tibbs M. Tuss

02-27-2012PSB

J. Poorman

WRIGHT-PATTERSON AIR FORCE BASE IV

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US AF

88TH ABW

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COORDINATOR

DATE NO. REVISION

DESIGN CHIEF

BY DATE NO. REVISION

ENGINEERING CHIEF

BY

JAH PSB

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SCALE: 1’’= 30’-0"

0 30’30’ 10’20’

BUILDING

BUILDING

S te a m

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Steam Line

S t e a m

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Steam Line

FIGURE 1

S-218

STEAM VAULT

S-219

STEAM VAULT