5. 6705 Fed Bldg Hazmat Rpt Final Rev 3-09.pdf

Hazardous Materials Survey Report

GSA Anchorage Federal Building Appendix 1 Miscellaneous Renovation Projects Page 1 of 13

HAZARDOUS MATERIALS

SURVEY REPORT

ANCHORAGE FEDERAL BUILDING

222 W. 7TH AVENUE,

ANCHORAGE, ALASKA

MISCELLANEOUS RENOVATION PROJECTS

Penthouse Roof Replacement

Plenum Roof Replacement Cooling Tower Replacement

Fleet Service Renovation

Surveyed

September 2008

Report Revised

March 25, 2009

EHS-ALASKA, INC.

ENGINEERING, HEALTH & SAFETY CONSULTANTS

11901 BUSINESS BLVD., SUITE 208

EAGLE RIVER, ALASKA 99577-7701

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HAZARDOUS MATERIALS SURVEY REPORT

ANCHORAGE FEDERAL BUILDING

TABLE OF CONTENTS

PAGE NO.

OVERVIEW

A. EFFECTS ON PROPOSED RENOVATION

B. BUILDING DESCRIPTION

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

D. SURVEY RESULTS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. PCB-Containing Materials

4. Mercury-Containing Materials

5. Other Hazardous Materials

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. PCB-Containing Materials

4. Mercury-Containing Materials

5. Other Hazardous Materials

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. PCB-Containing Materials

4. Mercury-Containing Materials

5. Other Hazardous Materials

G. LIMITATIONS

1. Accuracy of Information

2. Site Conditions

3. Changing Regulatory Constraints

APPENDICES

Attachment A...................................................... Asbestos Bulk Field Survey Data Sheets and Lab Reports Attachment B.......................................................................................................Lead Analyzer Test Results Attachment C ................................................................................................. Drawings of Sample Locations

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HAZARDOUS MATERIALS SURVEY REPORT

ANCHORAGE FEDERAL BUILDING

OVERVIEW

A limited survey of the Anchorage Federal Building, located at 222 West 7th Avenue, Anchorage, Alaska, was performed in support of the Penthouse Roof Replacement, Plenum Roof Replacement, Cooling Tower Replacement and Fleet Service Renovation projects. The project areas were surveyed for the presence of asbestos-containing materials (ACM), and other potentially hazardous materials as part of the design services for the Anchorage Federal Building renovation projects. The survey also provided a “good faith” inspection for hazardous materials that may be disturbed during the construction. The proposed work includes the disturbance, demolition, removal and disposal of lead-containing paints and/or lead-containing materials that is incidental to the renovation and remodeling project. That work does not fall under the requirements of 40 CFR 745, Lead Based Paint Poisoning Prevention in Certain Residential Structures, and should not be interpreted as such. Mr. Martin Lindeke, Mr. Frank White and Mr. Stephen Littlejohn of EHS-Alaska, Inc. (EHS-Alaska) conducted the inspections in September 2008.

A. EFFECTS ON PROPOSED RENOVATION

With this limited survey potentially hazardous materials have been identified in the project areas of the Anchorage Federal Building (penthouse roofs, plenum roofs, roof top cooling tower and the fleet office) that will be affected by the proposed renovations. Those materials include asbestos, lead and mercury containing materials.

Only the materials that will be directly affected by this project are required to be removed. The quantities and types of materials are incorporated into the design documents for this renovation. The removal and disposal of potentially hazardous materials are highly regulated, and it is anticipated that asbestos, lead and chemical hazards removal and disposal will be conducted by a subcontractor to the general contractor who is qualified for such removal. It is anticipated that the general contractor and other trades will be able to conduct their work using engineering controls and work practices to control worker exposure and to keep airborne contaminants out of occupied areas of the building.

Settled and concealed dusts in areas not subject to routine cleaning are assumed present throughout the building, including the roof, and inside and on top of architectural, mechanical, electrical, and structural elements, and those dusts are assumed to contain regulated air contaminants. This should not be read to imply that there is an existing hazard to building occupants (normal occupants of the building as opposed to construction workers working in the affected areas). However, depending on the specific work items involved and on the means and methods employed when working in the affected areas, construction workers could be exposed to regulated air contaminants from those dusts in excess of the OSHA Permissible Exposure Limits (PELs).

B. BUILDING DESCRIPTION

GSA Federal Building located at 222 W. 7th Avenue was originally constructed in 1979 with an annex addition in the early 1980’s and various upgrades and repairs through the years.

The original building is six stories and divided into seven modules, designated Module A thru F. Each module contained a penthouse on the roof housing mechanical/air handling equipment. The annex is one story and houses the fleet maintenance function and other offices.

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The interior partitions of both buildings were primarily of framed construction. The interior walls were typically of gypsum wallboard. The floors were typically finished with 12”x12” vinyl composite tile or carpet.

The exterior walls were of tilt-up pre-cast concrete panels. The roofs were typically of concrete or steel beams and open web steel joists supporting a metal deck.

The penthouse roofs had multiple layers of built-up roofing and fiberglass insulation with an elastomeric roof coating over the top layer of built-up roofing. The plenum roofs were built-up type roofs covered with insulation and concrete pavers. The roofs showed evidence of previous roof repairs.

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

EHS-Alaska performed a limited survey of the Anchorage Federal Building penthouse roofs, plenum roofs, C5 cooling tower and the Fleet office space of Module G and collected 58 bulk samples of materials suspected of containing asbestos. The survey was completed in September 2008. The samples were analyzed for the presence of asbestos by polarized light microscopy (PLM), the method of analysis recommended by the U.S. Environmental Protection Agency (EPA) to determine the composition of suspected asbestos-containing materials (EPA method 600/M4-82-020). Only materials containing more than 1% total asbestos were classified as “asbestos-containing” based on EPA and the Occupational Safety and Health Administration (OSHA) criteria. Samples that were analyzed to have less than 10% asbestos were “point-counted” by the laboratory for more accuracy. Samples that are listed as having a “Trace by Point Count” had asbestos fibers found in the material, but the fibers were not present at the counting grids. Table 1 in Part D below contains a summary list of the asbestos bulk samples and the applicable results.

The Bulk Asbestos samples were analyzed for asbestos content by International Asbestos Testing Laboratories (IATL), Mt. Laurel, NJ, a National Voluntary Lab Accreditation Program (NVLAP) accredited laboratory.

Field survey data sheets and laboratory reports of the bulk samples are included in Attachment A.

Drawings showing sample locations are included as Attachment C.

2. Lead-Containing Materials

Nearly all surfaces in the building were coated with paint and most surfaces had been repainted. EHS- Alaska tested paint throughout the affected areas of the building using a NITON XLi303AW X-Ray Fluorescence (XRF) lead paint analyzer (Serial # 14311 with software version 5.1C Dual). Refer to the Lead Paint Screening Table in Attachment B that identifies the surfaces tested, and the results. The Paint Test Locations are shown on the drawings in Attachment C.

EPA and the Department of Housing and Urban Development (HUD) have defined lead-based paint as any paint or other surface coating that contains lead equal to or in excess of 1.0 milligram per square centimeter (mg/cm2) or 0.5 percent by weight. XRF results are classified as positive (lead is present at

1.0 mg/cm2 or greater), negative (less than 1.0 mg/cm2 of lead was present) or inconclusive (the XRF could not make a conclusive positive or negative determination). Tests that were invalid due to operator error are shown as void tests.

A Performance Characteristic Sheet (PCS) for the NITON XLi303AW is available upon request. This PCS data provides supplemental information to be used in conjunction with Chapter 7 of the “HUD Guidelines”. Performance parameters provided in the PCS are applicable when operating the instrument using the manufacturer’s instructions and the procedures described in Chapter 7 of the ”HUD Guidelines”. The instrument was operated in accordance with manufacturer’s instructions and Chapter 7

Miscellaneous Renovation Projects Page 5 of 13 of the HUD Guidelines. No substrate correction is required for this instrument. There is no inconclusive classification for this instrument when using the 1.0 mg/cm2 threshold.

D. SURVEY RESULTS

1. Asbestos-Containing Materials

Asbestos field survey data sheets and laboratory reports are included in Attachment A. Refer to Attachment C for drawings showing sample locations.

The following TABLE 1A lists the samples taken in September 2008 of the Penthouse roofs and the results of the laboratory analysis. Sample where the asbestos content was greater than 1% are shown in bold print

TABLE 1A

SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA091508-A08b Black roofing tar Mod. E penthouse, top layer of top roof, north end of roof

None Detected

GSA091508-A09b Black fibrous roofing Mod. E penthouse, 2nd top layer of top roof, north end of roof

None Detected

GSA091508-A10b Black roofing material Mod. E penthouse, bottom layer of top roof, north end of roof

None Detected

GSA091508-A11b Black roofing material Mod. E penthouse, top layer of bottom roof, north end of roof

None Detected

GSA091508-A12b Brown and black insulation backing

Mod. E penthouse, bottom layer of bottom roof, north end of roof

None Detected

GSA091508-A13b Black roof penetration sealant

Mod. E penthouse, penetration at south end of roof

None Detected

GSA091508-A14b Gray/white sealant Mod. E penthouse, parapet wall seam sealant south end of roof

None Detected

GSA091508-A15b Gray penetration sealant Mod. E penthouse, SE area of roof at duct vent

None Detected

GSA091508-A19b Black roofing tar Mod. F penthouse, Top layer of top roof south end of roof

None Detected

GSA091508-A20b Black roofing tar Mod. F penthouse, bottom layer of top roof south end of roof

None Detected

GSA091508-A21b Black roofing tar Mod. F penthouse, Top layer of bottom roof south end of roof

None Detected

GSA091508-A22b Black tar on brown insulation backing

Mod. F penthouse, bottom layer of top roof south end of roof

None Detected

GSA091508-A23b Gray roofing patching tar Mod. F penthouse, roof patching near center of roof

None Detected

GSA091508-A24b Gray roofing patching tar Mod. F penthouse, roof patching near center of roof

None Detected

GSA091508-A25b Black penetration sealant

Mod. F penthouse, roof patching near north end of roof

0.5% Chrysotile

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SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA091508-A28b Black roofing tar West end of walkway between C Mod. And E Mod. Top layers of roofing

ND-roofing

ND-insulation

GSA091508-A29b Black roofing tar West end of walkway between C Mod. And E Mod. Top layers of bottom roof

ND-roofing

ND-insulation

GSA091508-A30b Black roofing layers Mod C penthouse, Top layers of top roof, south end of roof

None Detected

GSA091508-A31b Black roofing layers Mod C penthouse, Top layers of bottom roof, south end of roof

ND-roofing

ND-insulation

GSA091508-A32b Black roofing layers Mod C penthouse, bottom layers of bottom roof, south end of roof

None Detected

GSA091508-A33b Gray/white parapet wall sealant

Mod. C penthouse parapet wall seam at south end of roof

None Detected

GSA091508-A34b Black roof patch Mod. C penthouse near parapet wall at south end of roof

None Detected

GSA091508-A35b Black roofing sealant Mod. C penthouse chiller opening on roof near NW corner of roof

4.2% Chrysotile

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following TABLE 1B lists the samples taken in September 2008 of the Plenum roofs and the results of the laboratory analysis.

TABLE 1B

SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA091508-A01b Black roofing tar Mod. E chiller tower on concrete roof deck under insulation foam NE area near wall

None Detected

GSA091508-A02b Black roof tar Mod. E chiller tower on equipment foundation NW corner of cooler

None Detected

GSA091508-A03b Black roofing tar Mod. E on rubber roofing west side of chiller

None Detected

GSA091508-A04b Gray cellular glass insulation

Mod. E, Equipment on south side of chiller room

None Detected

GSA091508-A05b Black roofing tar Mod. E on lead boot on south side of chiller room

10% Chrysotile

GSA091508-A06b Black sealant Mod. E on bottom of south wall of chiller room

None Detected

GSA091508-A07b Fibrous seam filler (brown, dirty)

Mod. E on bottom of east wall of chiller room

None Detected

GSA091508-A16b Black roofing tar Mod. F plenum, near north wall

2.2% Chrysotile

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SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA091508-A17b Black wall sealant Mod. F plenum, on bottom of north wall

2.4% Chrysotile

GSA091508-A18b Yellow mastic Mod. F plenum, near north wall on bottom of roofing insulation foam

None Detected

GSA091508-A26b Black roofing tar Mod. E plenum near north wall 2.3% Chrysotile

GSA091508-A27b Yellow mastic Mod. E plenum near north wall on insulation foam

None Detected

GSA091508-A38b Black roofing tar Mod C plenum near north wall 2.5% Chrysotile

GSA091008-A16 Dark brown sealant Mod. E SE bottom corner of chiller foundation

None Detected

GSA091008-A17 Light gray sealant Mod. E SE bottom corner of chiller foundation

None Detected

GSA091008-A18 Dark gray sealant Mod. E center of chiller foundation

None Detected

GSA091008-A19

Black rubber flashing material

Mod. E center of chiller foundation

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, The following TABLE 1C lists the samples taken in September 2008 of the C5 Cooling Tower and the results of the laboratory analysis.

TABLE 1C

SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA090908-A01 White joint compound South wall of air plenum of Mod.

C

None Detected

GSA090908-A02 Yellow duct pin mastic West side of cooling tower None Detected

GSA090908-A03 Gray duct sealant West side of cooling tower None Detected

GSA090908-A04 Gray duct sealant West side of cooling tower None Detected

GSA090908-A05 Gray duct sealant North side of cooling tower None Detected

GSA090908-A06

Black duct flex connector

NW corner of cooling tower None Detected

GSA090908-A07 White Gypsum board South wall of air plenum of Mod.

C

None Detected

GSA090908-A08 Black damp proofing Painted on Gypsum board south wall of air plenum of Mod. C

None Detected

GSA090908-A09 White joint compound North wall of cooling tower room of Mod. C

None Detected

GSA091508-A36b Gray duct sealant, hard

Mod. C Chiller, inside chiller vent to roof

Gray sealant - 4.6% Chrysotile

Tan sealant - ND

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SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA091508-A37b Gray duct sealant, rubbery

Mod. C Chiller, inside chiller vent to roof

None Detected

GSA091508-A39b Fire proofing, gray Mod. C plenum near chiller tower near NE corner of chiller

None Detected

GSA091508-A40b Fire proofing, gray Mod. C plenum near chiller tower near NW corner of chiller

None Detected

GSA091008-A15 Gray duct sealant Mod. C Chiller, outside chiller on duct

1.2% Chrysotile

GSA091508-A38b Black roofing tar Mod C plenum near north wall 2.5% Chrysotile The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, The following TABLE 1D list the samples taken in September 2008 in the Fleet Office Space of the Annex Building and the results of the laboratory analysis.

TABLE 1D

SAMPLE

NUMBER

MATERIAL LOCATION

ASBESTOS

CONTENT

GSA090908-

A10

White joint compound Fleet Space back wall next to mechanical room

None Detected

GSA090908-

A11

White joint compound Fleet Space wall on entrance side of the room above ceiling tile

None Detected

GSA090908-

A12

White Gypsum board Fleet Space wall on entrance side of the room above ceiling tile

None Detected

GSA090908-

A13

White joint compound Hallway outside Fleet Space None Detected

GSA090908-

A14

Dark brown cove base mastic

Fleet Space back wall next to mechanical room

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, The following materials have been found to contain asbestos in this survey, or were assumed to contain asbestos.

Penthouse Roofs Black penetration/patch sealants on the penthouse roofs.

Plenum Roofs Roofing tar on the plenum roof decks.

Wall sealant, bottom of walls in plenum.

Sealants around roof penetrations.

C5 Cooling Tower Sealants on cooling tower ductwork and sealants at roof/tower interface.

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Fleet Office Space The following materials were noted to be present and are suspect to be asbestos containing materials.

Those materials should be sampled prior to disturbance or assumed to contain asbestos unless previous sampling information is provided. No asbestos was detected in the limited sampling performed.

Carpeting mastics remnants under new carpeting.

Ventilation system duct sealants on duct above ceiling.

Incandescent light fixture heat shields.

Tarry sound lining in clock/speaker boxes.

Yellow mastic of ceiling tile “L” channel at concrete columns.

All 2’x4’ Ceiling Tiles.

The following materials have been found to be asbestos-free in this survey.

Penthouse Roofs Built up roofing materials on penthouse roofs except for sealants around roof penetrations and sealant at patches.

Plenum Roofs Yellow insulation mastic on plenum roofs.

C5 Cooling Tower Fireproofing in plenum of Mod. C.

Gypsum board.

Joint compound.

Black damp proofing on gypsum board.

Black duct flex connector.

Yellow duct pin mastic.

Fleet Office Space The following materials have been found to be asbestos-free where sampled in this survey of the two walls of the Fleet Space of Modular G. Due to the limited nature of the sampling and variability of materials used, results at other locations may be different.

Joint compound Gypsum board Cove base mastic.

The affects of the following asbestos-containing materials on the proposed renovation are discussed below.

Penthouse Roofing Sealants Roofing over the penthouses consisted of 2 layers of built-up roofing with fiberglass insulation beneath each layer with an Elastomeric coating over the top built-up roofing layer. The built-up roofing and Elastomeric coating does not contain asbestos. However, sealants at penetrations and patches contain asbestos. The roofing materials are scheduled to be removed by this project.

Plenum Roofing and Wall Sealants Roofing over this portion of the building is a built-up type roof covered with foam insulation and concrete pavers. Roofing sealants and tars on the roof deck contained asbestos as well as the sealants around roof penetrations and next to the plenum walls. These materials are scheduled to be removed during this renovation project.

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C5 Cooling Tower Roofing and Duct Sealants Roofing tars/sealants in this area contain asbestos; this will be removed with the plenum re-roofing project. If the cooling tower is removed prior to the roofing being removed, asbestos containing roofing sealants will likely be disturbed during the cooling tower replacement.

Sealants used inside and outside of the cooling tower and the cooling tower duct to the roof contain asbestos. These materials will be removed by this project.

2. Lead-Containing Materials

Paint EHS-Alaska tested paint throughout the affected areas of the building using a NITON XLi303AW X-Ray Fluorescence (XRF) lead paint analyzer (Serial # 14311 with software version 5.1CDual). Lead in paints tested ranged from below the level of detection to 0.07 mg/cm2. No Lead-Based Paints were identified.

Refer to the Lead Paint Screening Table in Attachment B that identifies the surfaces tested, and the results. The paint test Locations are shown in the drawings in Attachment C.

Metallic Lead Metallic lead items identified in the building included lead roof jacks. If removed during renovation or demolition they should be recycled or disposed of as hazardous waste.

3. PCB-Containing Materials

Light Ballasts Older fluorescent lights typically have PCB-containing ballasts. Unless ballasts were marked “No PCBs,” they must be assumed to contain PCBs and must be disposed of as a hazardous waste when removed for disposal. Inspection of fluorescent light fixtures was not part of the contract requirements and therefore not checked. Due to the date of building construction, it is not anticipated that any PCB ballast are present in the building. However, any fluorescent light fixtures removed during this project will need to be inspected for PCB’s prior to disposal.

4. Mercury-Containing Materials

Fluorescent Lamps Mercury containing lamps were present throughout the building. Most of the lamps noted were fluorescent lamps that contain from 15 to 48 milligrams of mercury depending on their age and manufacturer. Lamps removed for disposal are assumed to be hazardous waste under the EPA Universal Waste Standard, 40 CFR 273 unless a Toxicity Characteristic Leaching Procedure test of the waste lamps determines otherwise.

5. Other Hazardous Materials

No other hazardous materials were noted during this inspection.

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

The Federal Occupational Safety and Health Administration (29 CFR 1926.1101) and the State of Alaska Department of Labor (8 AAC 61) have promulgated regulations requiring testing for airborne asbestos fibers; setting allowable exposure limits for workers potentially exposed to airborne asbestos fibers;

establishing contamination controls, work practices, and medical surveillance; and setting worker certification and protection requirements. These regulations apply to all workplace activities involving asbestos-containing materials.

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The EPA regulations, issued as Title 40 of the Code of Federal Regulations, Part 61 (40 CFR 61) under the National Emission Standards for Hazardous Air Pollutants (NESHAP) established procedures for handling ACM during asbestos removal and waste disposal. These regulations required an owner (or the owner’s contractor) to notify the EPA of asbestos removal operations and to establish responsibility for the removal, transportation, and disposal of asbestos. GSA Federal Building will not fall under the EPA’s Asbestos Hazard Emergency Response Act (AHERA) law regulating asbestos in schools.

The disposal of asbestos waste is regulated by the EPA, the Alaska Department of Environmental Conservation, and the disposal site operator. Wastes being transported to the disposal site must be sealed in leak tight containers prior to disposal and must be accompanied by disposal permits and waste manifests.

2. Lead-Containing Materials

Federal OSHA (29 CFR 1926.62) and the State of Alaska (8 AAC Chapter 61) have promulgated regulations that apply to all construction work where employees may be exposed to lead. The disturbance of any surfaces painted with lead-containing paint requires lead-trained personnel, personnel protective procedures, and air monitoring until exposure levels can be determined. If initial monitoring verifies that the work practices being used are not exposing workers, monitoring and protection procedures may be relaxed.

The EPA requires that actual construction or demolition debris that contains lead or lead-containing paint or other heavy metals be tested using the TCLP to determine if the waste must be treated as hazardous waste. All federal, state and local standards regulating lead and lead-containing wastes are required to be followed during the renovation or demolition of portions of this building.

There are no hazardous waste landfills in Alaska and the lead-containing wastes (if shown to be hazardous waste) will have to be packaged for shipping and disposal. This report assumes that disposal will take place outside the state of Alaska.

3. PCB-Containing Materials

The EPA has promulgated regulations (40 CFR Part 761) that cover the proper handling and disposal of PCB-containing equipment. All construction workers who are required to remove or handle PCB-containing or PCB-contaminated equipment or to transport or dispose of PCB wastes shall be trained and certified as required by the U.S. Department of Labor (29 CFR 1910.120) and the State of Alaska Department of Labor (8 AAC 61).

4. Mercury-Containing Materials

Mercury and mercury-containing products are considered hazardous waste if TCLP testing of the waste for mercury confirms the mercury content to be greater than the EPA criteria of 0.2 mg/l. Mercury containing thermostats and lamps are regulated under the EPA Universal Waste Standard, 40 CFR 273.

5. Other Hazardous Materials

No other hazardous materials were noted in this survey.

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

The asbestos-containing materials identified in the building are typically in intact condition and are classified as non-friable ACM. All asbestos-containing materials that will be disturbed by the planned renovation work are required to be removed by trained asbestos workers.

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2. Lead-Containing Materials

Federal OSHA (29 CFR 1926.62) and the State of Alaska (8 AAC Chapter 61) have promulgated regulations that apply to all construction work where employees may be exposed to lead. Worker exposure to lead may be able to be controlled below the OSHA permissible exposure limit if proper engineering controls and procedures are used during renovation. Lead is a potentially hazardous waste and the EPA requires that all wastes that contain lead be tested to determine if they must be treated as hazardous waste. A TCLP test of the waste stream is required to be performed to determine if the waste will be hazardous or non-hazardous.

3. PCB-Containing Materials

PCB-containing ballasts scheduled for removal or replacement will need to be removed, handled, packaged and disposed of in accordance with all regulations.

4. Mercury-Containing Materials

Mercury-containing materials scheduled for removal or replacement will need to be removed, handled, packaged and disposed of in accordance with all regulations. Waste fluorescent lamps are assumed to be hazardous waste unless a TCLP test of the waste lamps determines they are non-hazardous.

5. Other Hazardous Materials

Other hazardous materials discovered during renovation will need to be removed, handled, packaged and disposed of in accordance with all applicable regulations.

G. LIMITATIONS

The conclusions and recommendations contained in this report are based upon professional opinions with regard to the subject matter. These opinions have been arrived at in accordance with currently accepted environmental consulting and engineering standards and practices and are subject to the following inherent limitations:

1. Accuracy of Information.

The laboratory reports utilized in this assessment were provided by the accredited laboratories cited in this report. Although the conclusions, opinions, and recommendations are based in part, on such information, our services did not include the verification of accuracy or authenticity of such reports.

Should such information provided be found to be inaccurate or unreliable, EHS-Alaska, Inc. reserves the right to amend or revise its conclusions, opinions, and/or recommendations.

2. Site Conditions.

This limited survey was conducted while the site was occupied. All inspections were performed with furniture, equipment and/or stored items in place. Although a concerted effort was made to identify all hazardous materials, some hazardous materials may have been hidden by furniture, equipment or stored items and may not have been identified. Other asbestos-containing or potentially hazardous materials may be present in the facilities that were concealed by structural members, walls, ceilings or floor coverings.

3. Changing Regulatory Constraints.

The regulations concerning hazardous materials are constantly changing, including the interpretations of the regulations by the local and national regulating agencies. Should the regulations or their

Miscellaneous Renovation Projects Page 13 of 13 interpretation be changed from our current understanding, EHS-Alaska, Inc. reserves the right to amend or revise its conclusions, opinions, and/or recommendations.

Miscellaneous Renovation Projects Attachment A

ATTACHMENT A

Asbestos Bulk Sample Field Survey Data Sheets and Laboratory Reports

Miscellaneous Renovation Projects Attachment B

ATTACHMENT B

Lead Analyzer Test Results

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Ta bl e H ea di ng

D es cr ip tio ns : S ee n ex t p ag e.

Re su lt s

SU

BS

TR

A

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CO

N D

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R D ur at io n

Ti m e

D ep th In de x

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A

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O M

G

SA

A nc ho ra ge F ed er al B ui ld in g

M is ce lla ne ou s Re no va tio n Pr oj ec ts

H az ar do us M at er ia ls S ur ve y Re po rt

Pa ge B of

LE

D B A

SE

D P A

IN

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EN

IN

G S U M M A

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LB

P m g/ cm

‐ E rr or

Re su lt s

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SI

TE

IN

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EC

TO

R

A

RE

A

RO

O M

Ta bl e H ea di ng

D es cr ip tio ns

D ur at io n:

Th is is th e no m in al ti m e in s ec on ds th at e ac h sa m pl e w as a na ly ze d.

D ep th In de x:

In di ca te s th e re la tiv e de pt h of th e le ad A D ep th In de x (D I) of le ss th an .5 in di ca te s le ad v er y ne ar th e su rf ac e la ye r of p ai nt A D I b et w ee n 1.

an d 4.

in di ca te s m od er at el y co ve re d le ad A D I g re at er th an .0 in di ca te s th e le ad p ai nt is d ee pl y b ur ie d be ne at h m ul tip le la ye rs o f p ai nt

LB

P:

Re su lts a re s ho w n as p os iti ve (P

O S .0 m g/ cm

2 ) , i nc on cl us iv e

(IN

C) o r ne ga tiv e (N

EG

.0 m g/ cm

2 ) Th e re su lts a re b as ed o n th e co m bi ne d re su lts of th e K an d L sh el l r ea di ng s.

L s he ll an d K sh el l r ea di ng s ar e no t p ro vi de d, b ut a re a va ila bl e up on r eq ue st Po si tiv e re su lts a re in b ol d pr in t.

m g/ cm

2 :

Th is is th e te st in g re su lts p ro du ce d by th e N

IT

O N X Li ‐3

A W in st ru m en t i n m ill ig ra m s of le ad p er s qu ar e ce nt im et er (m g/ cm

2 ) Th e

EP

A d ef in es le ad b as ed pa in t a s pa in t c on ta in in g le ad a t 1

.0 m g/ cm

2 o r gr ea te r.

A n eg at iv e nu m be r is a r es ul t o f a n in te rn al c om pu ta tio n m ad e by th e in st ru m en t a nd s ho ul d be in te rp re te d as z er o.

E ve n th ou gh p ai nt m ay b e te rm ed n eg at iv e ( l es s th an

.0 m g/ cm

2 ) b y

EP

A d ef in iti on di st ur ba nc e of th e pa in t m ay s til l b e re gu la te d by O

SH

A u nd er

CF

R

.6 2.

W he re le ad is p re se nt a t a ny le ve l, ap pr op ri at e en gi ne er in g co nt ro ls , w or k pr ac tic es a nd p er so na l p ro te ct iv e eq ui pm en t sh ou ld b e us ed u nt il a ne ga tiv e ex po su re a ss es sm en t c an b e de te rm in ed

VO

ID

Th is in di ca te s th at th e te st w as in te nt io na lly te rm in at ed b y th e op er at or d ue to o pe ra to r er ro r (e .g o pe ra to r m ov ed a na ly ze r w hi le te st in g)

Su bs tr at e:

W he re c er am ic is s ho w n as a s ub st ra te , l ea d co nt en t i s ty pi ca lly fr om th e gl az in g on th e til e un le ss th e til e is p ai nt ed

G

SA

A nc ho ra ge F ed er al B ui ld in g

M is ce lla ne ou s Re no va tio n Pr oj ec ts

H az ar do us M at er ia ls S ur ve y Re po rt

Pa ge B of

Miscellaneous Renovation Projects Attachment C

ATTACHMENT C

Drawings of Sample Locations