Hazardous Materials Survey Report - Utilidor H.pdf

Eielson AFB, Arctic Utilidor H Page 1 of 15

HAZARDOUS MATERIALS

ASSESSMENT

EIELSON AFB, ARCTIC UTILIDOR REPAIRS

Utilidor H

EIELSON AFB, ALASKA

Surveyed October 2024

Report Date

December 3, 2024

EHS-ALASKA, INC.

ENGINEERING, HEALTH & SAFETY CONSULTANTS

11901 BUSINESS BLVD., SUITE 208

EAGLE RIVER, ALASKA 99577-7701

Eielson AFB, Arctic Utilidor H Page 2 of 15

HAZARDOUS MATERIALS ASSESSMENT

EIELSON, ALASKA

TABLE OF CONTENTS

PAGE NO.

OVERVIEW

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

B. UTILIDOR DESCRIPTION

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. Testing of Paints and Sealants for PCB’s

D. SURVEY RESULTS

1. Asbestos-Containing Materials

2. Asbestos in Dusts

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

G. LIMITATIONS

1. Accuracy of Information

2. Site Conditions

3. Changing Regulatory Constraints

APPENDICES

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

Eielson AFB, Arctic Utilidor H Page 3 of 15

HAZARDOUS MATERIALS ASSESSMENT

EIELSON, ALASKA

OVERVIEW

Portions of the Arctic Utilidors, section H, located on Eielson Air Force Base, Alaska, were surveyed for the presence of asbestos-containing materials (ACM), and other potentially hazardous materials as a part of the design services for the Eielson AFB, Arctic Utilidor Repairs Project. 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. Mr. Robert A. French, P.E. of EHS- Alaska, Inc. (EHS-Alaska) conducted the inspections in October 2024. It will be the contractor’s responsibility to take this baseline data, and to conduct hazardous materials removal in compliance with all regulatory requirements.

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

Potentially hazardous materials have been identified in Utilidor s H that will be affected by the proposed renovations. Those materials include asbestos, and lead. Not all materials were tested for potentially hazardous components, other potentially hazardous materials, including those exterior to the building, such as contamination from underground fuel tanks may be present, but are not part of this report.

Buildings or portions of buildings that were constructed prior to 1978 which are residences, or contain day care facilities, kindergarten classes or other activities frequently visited by children under 6 years of age are classified as child occupied facilities. All work which is NOT classified as “minor repair and maintenance activities” (as defined by the regulations), that takes place in the “child occupied” portions of facilities must comply with the requirements of 40 CFR 745. These Utilidors are not classified as a child occupied facility and therefore the requirements of 40 CFR 745 are not applicable.

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 removal and disposal of asbestos, lead and chemical hazards 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 present throughout the utilidors, including 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 maintenance workers doing activities that do not disturb those materials. 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).

The settled and concealed dusts were examined by an EPA Certified Building Inspector but were not sampled. The inspector determined that the dusts are not “asbestos debris” from an asbestos-containing building material (ACBM). Based on similar sampling from buildings and other utilidors, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM). Reference 40 CFR 763.83.

NOTE: There was ample evidence of periodic flooding which as occurred in the Utilidors, and those floods are known to have distributed asbestos-containing debris from damaged pipe insulation, and it is likely that

Eielson AFB, Arctic Utilidor H Page 4 of 15 the dusts in these areas may contain more than one percent (1%) asbestos by weight, and therefore would be classified as an asbestos-containing material (ACM). Reference 40 CFR 763.83.

“Awareness training” (typically 2 hours) and possibly respiratory protection will be required for all Contractor Personnel who will be disturbing the dusts. The extent of the training and protective measures will depend upon the airborne concentrations measured during air monitoring of the contractors work force, which depends on the means and methods employed to control the dusts. The air monitoring may be discontinued following a “negative exposure assessment” showing that worker exposures are below the OSHA permissible exposure limits for the type of work and means and methods employed. Previous air monitoring from similar jobs with similar conditions may be used as historical data to establish a “negative exposure assessment”.

B. UTILIDOR DESCRIPTION

The buried Arctic Utilidors at Eielson Air Force Base serve the base steam system, and will typically include Steam and Condensate piping, Cold Water piping, and Sewage piping. Utilidor H was a smaller utilidor, or utiliduct, where the piping between manholes was located in a concrete utilidor, but it was not possible to walk or crawl from one manhole to the next inside of the utilidor. Many of the manholes along Section H had enough standing water, so that it was not possible to enter the manholes to conduct the survey.

The Utilidors are considered “Confined Spaces”. Access to the Utilidors was obtained after testing the atmosphere to determine that Oxygen, Carbon Monoxide, Lower Explosion Limit and Hydrogen Sulfide gasses were not present at potentially hazardous concentrations.

Only partial “As-Built” information was provided to EHS-Alaska to document the age and renovations to the Utilidors. The “As-Built” information that was provided, typically showed where an additional man-hole had been installed to facilitate new utility connections to added buildings, but did not include information on the original construction.

The walls and floors of the Utilidors appeared to have been cast-in place concrete. The “Lids” to the utilidors were of pre-cast concrete segments. The seams between the walls and “Lids”, and between the sections of the “Lids” had tarry waterproofing, that often had “melted” enough for the tars to be dripping onto walls, floors, and interior piping.

The Utilidors also typically had electrical, communication and controls elements which were not investigated as part of this survey.

Despite the lack of complete “As-Built” documentation, it was evident that previous abatement projects had occurred, and at least some of the asbestos-containing pipe insulation that had likely been present, had been previously removed. The steam and condensate piping in the manhole portion of most of Utilidor H had a “hard and chalky” insulation which did not contain asbestos. That harder insulation was likely used in the manholes to protect the insulation from damage during maintenance, along with an aluminum jacket.

The steam and condensate piping on the long runs in between the manholes was typically of fiberglass insulation. The cold water piping in Utilidor H was typically of a greenish foam insulation with a white vapor barrier, and covered with an aluminum jacket in the manhole areas. The older manholes MH788 and MH789-1 had some abandoned steam and condensate piping which was covered with fiberglass insulation.

As described above, data from previous projects conducted in the Eielson AFB Arctic Utilidors indicate that periodic flooding occurs, and has resulted in distribution of asbestos debris in the utilidors. The Utilidors also had debris that would be consistent with past sewage leaks.

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials The survey included sampling of suspect ACM materials. No previous asbestos survey or sample data were provided to EHS-Alaska. The Eielson AFB Civil Engineering Squadron may have data from previous

Eielson AFB, Arctic Utilidor H Page 5 of 15 sampling which is not included in this report. Additional testing of materials pertinent to the project, was conducted and is included in this report.

The bulk samples were analyzed for the presence of asbestos using polarized light microscopy (PLM), analysis, as recommended by EPA, to determine the composition of suspected ACMs (EPA method 600/M4-82-020). Only materials containing more than 1% total asbestos were classified as “asbestos-containing” based on EPA and OSHA criteria. Samples analyzed to have less than 10% asbestos were “point-counted” by the laboratory for more accuracy. Samples 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.

No sampling of the settled dusts was conducted as part of this survey, and, due to the past flooding events discussed elsewhere, the dusts in the utilidors are assumed to have measurable concentrations of asbestos.

The Bulk Asbestos samples were analyzed for asbestos content by Eurofins Built Environment Testing / iATL, Mt. Laurel, New Jersey, a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.

EPA regulations under 40 CFR 763 require the use of PLM to determine whether or not a material contains asbestos. While PLM analysis does a good job for most materials, it does have some limitations. Fibers may be undetectable if their small size prevents visibility under a standard optical microscope, or if they are bound in an organic matrix to the point that the fibers are obscured. At the discretion of the building inspector and the client, some types of samples may be analyzed or re-analyzed by what is called Transmission Electron Microscopy for Non-Friable Organically Bound (TEM NOB) materials. TEM NOB is the definitive method for determining if asbestos is present, but TEM NOB use is not required by the EPA.

TEM NOB analysis was not done for this project.

Field survey data sheets and laboratory reports of the bulk samples are included in Appendix A. Drawings showing sample locations are included as Appendix D.

2. Lead-Containing Materials

Most interior surfaces of the utilidors were unpainted. Some of the exposed surfaces at the Manholes were coated with paint and most surfaces had been repainted. EHS-Alaska tested representative paints using a SciAps X-550 Pb X-Ray Fluorescence (XRF) lead paint analyzer (Serial # 01052 with firmware version 2.6.1.4). The lead testing conducted was not a Lead-Based Paint Inspection or Screening as defined by Department of Housing and Urban Development (HUD) or EPA regulations, but was done to test surfaces that may be representative of those likely to be affected by this project. If surfaces and materials other than those tested are identified, the Contractor shall test and treat appropriately. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. All surfaces affected by this project may not have been tested and therefore additional sampling may be required to refute the presence of lead-containing materials regulated by 29 CFR 1926.62 The Lead Test Locations are shown in Appendix D.

EPA and 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 SciAps X-550 Pb 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 of the HUD

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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.

3. Testing of Paints and Sealants for PCB’s

Representative paint and sealant samples were collected from exposed painted areas at the Manholes and analyzed for total PCBs. Samples of paint were collected by scraping the paint down to bare substrate, or by cutting out a portion of the sealants. Samples were analyzed for total PCBs by EMSL Analytical, Inc, 200 Route 130 North, Cinnaminson, New Jersey. Results of the total PCB analysis for each sample was used to determine if the dried paint or sealants are considered PCB bulk product waste. Field Survey Data Sheets and Lab results are included in Appendix B. Drawings showing sample locations are provided in Appendix D.

D. SURVEY RESULTS

1. Asbestos-Containing Materials

UTILIDOR H SAMPLING:

The following Table 1A lists the samples taken in October 2024 in the Utilidor Section H, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included as Appendix A. Refer to Appendix D for sample locations.

TABLE 1A

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

H-1024-A01 Black rubbery sealant between concrete lid and SAM membrane (over tan sealant)

Exterior of Newer manhole south of MH747 and west of Building 4115.

Photos 150 & 151

None Detected

H-1024-A02 Tan rubbery sealant between concrete lid and SAM membrane

Exterior of Newer manhole south of MH747 and west of Building 4115.

Photos 150 & 151

None Detected

H-1024-A03 Gray caulking at joint of metal hatch rim to top of concrete Manhole Lid

Exterior of Newer manhole south of MH752, Photos 181, 187

None Detected

H-1024-A04 White sealant and black and gray tar at joint between Manhole lid and base

Exterior of Older manhole south of MH752. Photo 189

None Detected white sealant. 6% chrysotile in black tar

H-1024-A05 Black and gray tar, possible grout, at joint between Manhole lid and base

Exterior of MH789-1, with Hydrant. Photo 198

4% chrysotile

H-1024-A06 Hard and chalky pipe insulation on Steam pipe

Inside MH747, On steam pipe under aluminum jacket. Photo 312

None Detected

H-1024-A07 Greenish foam and white vapor barrier coating

Inside MH747, On cold water pipe under aluminum jacket at flange cover. Photo 314

None Detected, Both Layers

H-1024-A08 Greenish foam and white vapor barrier coating

Inside MH747, lower level, On cold water pipe under aluminum jacket at flange cover. Photos 328 & 329

None Detected, Both Layers

H-1024-A09 Hard and chalky pipe insulation on Condensate pipe

Inside MH747, On condensate pipe under aluminum jacket. Photo 330

None Detected

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SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

H-1024-A10 Hard and chalky pipe insulation on Steam pipe

Inside Manhole south of driveway to Bldg 4115 parking lot, On abandoned steam pipe under aluminum jacket. Photo 334

None Detected

H-1024-A11 Hard and chalky pipe insulation on Condensate pipe

Inside Manhole south of driveway to Bldg 4115 parking lot, Falling off condensate pipe under aluminum jacket. Photo 337

None Detected

H-1024-A12 Black tar at joint of utilidor lid Inside Manhole south of driveway to Bldg 4115 parking lot, at north side exit. Photo 345

None Detected

H-1024-A13 Thin black coating on cold water pipe

Inside Manhole south of driveway to Bldg 4115 parking lot. Aluminum Jacket. Photo 346

None Detected

H-1024-A14 Hard and chalky pipe insulation on Steam pipe

Inside Manhole south of driveway to Bldg 4115 parking lot. Aluminum Jacket. Photo 347

None Detected

H-1024-A15 Hard and chalky pipe insulation on Steam pipe

Inside 1st Manhole south of Inner Loop Drive. Aluminum Jacket.

Photo 361

None Detected

H-1024-A16 Hard and chalky pipe insulation on Condensate pipe

Inside 1st Manhole south of Inner Loop Drive. Aluminum Jacket.

Photo 362

None Detected

H-1024-A17 Hard and chalky pipe insulation on Steam pipe

Inside 2d Manhole south of Inner Loop Drive. Aluminum Jacket.

Photo 378

None Detected

H-1024-A18 Hard and chalky pipe insulation on Condensate pipe

Inside MH752, at branch piping.

Aluminum Jacket. Photo 388

None Detected

H-1024-A19 Hard and chalky pipe insulation on Steam pipe

Inside MH752, at branch piping.

Aluminum Jacket. Photo 392

None Detected

H-1024-A20 Thin black coating on cold water pipe

Inside MH752, at main piping.

Photo 393

Insufficient material to analyze

H-1024-A21 Green foam insulation Inside MH752, at CW main piping with green foam insulation, Aluminum Jacket. Photo 393

None Detected

H-1024-A22 Shiny white fiber insulation Inside MH752, at Victaulic fitting on CW main piping, Aluminum Jacket.

Photo 394

None Detected

H-1024-A23 Hard and chalky pipe insulation on Steam pipe

Inside MH752, at main steam piping, Aluminum Jacket. Photo

None Detected

H-1024-A24 Hard and chalky pipe insulation on Steam pipe

Inside 1st manhole south of MH752, at main steam piping, Aluminum Jacket. Photo 410

None Detected

H-1024-A25 Hard and chalky pipe insulation on Steam pipe

Inside 1st manhole south of MH752, at branch steam piping, Aluminum Jacket. Photo 419

None Detected

H-1024-A26 Tar paper on fiberglass insulation

Inside MH788, abandoned piping.

Photo 436

None Detected, Both Layers

H-1024-A27 Fiberglass insulation on steam piping

Inside MH789-1, aluminum jacket.

Photo 445

None Detected

H-1024-A28 Fiberglass insulation on condensate piping

Inside MH789-1, aluminum jacket.

Photo 446

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NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

H-1024-A29 Hard and chalky pipe insulation on Steam pipe

Inside 1st manhole south of MH747, at main steam piping, Aluminum Jacket. No Photo, too hot for camera.

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, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following materials in Utilidor H have been found to contain asbestos in this or previous surveys, or were assumed to contain asbestos.

1. Tarry sealants at Manhole and Utilidor “Lid” joints (confirmed and assumed asbestos).

2. Flange gaskets on piping (assumed asbestos).

3. Exterior tarry damp-proofing (assumed asbestos).

The following materials have been found to be “asbestos-free” in this survey, but is not to be considered a complete list of asbestos-free materials.

• White “Hard & Chalky” insulation on steam and condensate piping

The effects of the above asbestos-containing materials on the proposed renovation are discussed below.

Tarry Sealant at Manhole and “Lid” joints Two samples of the tarry sealants at the exterior of Manholes of Utilidor H contained asbestos. Few samples of the tarry sealants at the “Lid” joints were taken, and based on asbestos-containing “Lid” joint sealants found by this survey and other surveys at Eielson AFB, the “Lid” joint sealants are assumed to contain asbestos. The tarry sealants may require partial disturbance, depending on the eventual scope of work for this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on piping throughout Utilidor H are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently no sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings may be partially removed, depending on the eventual scope of work for this project.

Exterior Utilidor Damp-proofing Sealant The (assumed tarry) water-proofing at the exterior of the walls, “Lids” and floor of Utilidor H was not accessible for sampling, and is assumed to contain asbestos, based on sampling of similar materials at different utilidors at Eielson AFB. The sealants are assumed to be not friable and in good condition. The tarry sealants may require partial disturbance, depending on the eventual scope of work for this project.

2. Asbestos in Dusts

The settled and concealed dusts were examined by an EPA Certified Building Inspector but no samples for asbestos in dusts were authorized for this project. Based on their visual inspection and experience from similar buildings, the inspector determined that the typical settled and concealed dusts are not “asbestos debris” from an asbestos-containing building material (ACBM). Based on similar sampling from similar buildings, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM).

Note that periodic flooding of the Utilidors is assumed to have introduced asbestos-contamination from other areas of the Base Utilidor System.

Eielson AFB, Arctic Utilidor H Page 9 of 15

3. Lead-Containing Materials

Lead-Testing EHS-Alaska tested paint throughout the exposed areas of the Utilidors using a SciAps XRF lead paint analyzer. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. The Lead Test Locations are shown in the Drawings in Appendix D.

Paints There were varying lead contents found in the paints, based on what surfaces they are on, with many surfaces containing little lead (but are still classified as lead-containing materials by OSHA). The highest levels of lead were found on what appeared to be older concrete manhole shafts and metal access hatches to the manholes.

Lead-based paints (paint containing more than 1.0 mg/cm2 of lead) were identified in the project on steel hatch covers, however, it is anticipated that other components, such as older angle iron pipe supports, etc.

may also be classified as lead-based paint. XRF testing is not able to “prove” that “no” lead exists in the paint. Low levels of lead found by XRF testing does not mean that the paints are free of lead, the paints may contain lead. At least an initial exposure determination of potential worker exposures for all disturbance of lead-containing materials is required unless laboratory analysis shows that there is zero detectable lead in the materials being disturbed (which requires special analysis). However, these paints may not present a hazard to occupants or workers performing renovation or demolition if lead-safe work practices are followed.

Metallic Lead Metallic lead items are assumed to include poured lead sealants at bell and spigot joints of cast iron waste (sewer) piping. If removed during renovation or demolition they should be recycled or disposed of as hazardous waste.

Lead Dusts The settled and concealed dusts were examined but no samples for lead in dusts were authorized for this project. Based on their visual inspection, area with deteriorated paints, the dusts and debris from that paint is likely to have measurable concentrations of lead in the dusts.

4. PCB-Containing Materials

Light Ballasts Older fluorescent lights typically have PCB-containing ballasts, and older HID lights may have PCB-containing ballasts. No fluorescent lights or HID light fixtures are likely to be disturbed by this project.

Bulk Products Representative paint and sealant samples were collected from the above ground portions of the manholes etc.

The following Table 4A summarizes the PCB Bulk samples taken October 2024 by EHS-Alaska, Inc. Field Survey Data Sheets and Lab results are included in Appendix B. Drawings showing sample locations are provided in Appendix D.

TABLE 4A

SAMPLE

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

H-1024-P01 Multi-Color, black, tan & orange Paint on Metal

Utilidor H, Manhole SW of Bldg 4115, Photo 145 & 148

None Detected

H-1024-P02 Tan Paint on Concrete Utilidor H, Manhole 747, on Concrete Base of manhole. Photo 153

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NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

H-1024-P03 Gray caulk at joint btwn concrete and hatch rom

Utilidor H, Manhole S of MH 752, Photo 181 & 187

None Detected

H-1024-P04 Multi-Color, Black & Orange on metal

Utilidor H, Manhole 789, on top of hatch. Photo 205

None Detected

H-1024-P05 Multi-Color, Tan & Red on metal

Utilidor H, Manhole 789-1, on top of hatch. Photo 206

None Detected

H-1024-P06 Tan Paint on Concrete Utilidor H, Manhole 795, on concrete base Photo 211

None Detected

Total PCB’s listed herein includes the sum of all cogeners of PCB’s. Refer to the laboratory reports for the concentrations of the various cogeners of PCBs found in the samples.

None of the samples had detectable concentrations of PCBs. Refer to Regulatory Constraints discussion below for more information.

5. Mercury-Containing Materials

Fluorescent Lamps Fluorescent lamps use mercury to excite the phosphor crystals that coat the inside of the lamp. These lamps contain from 15 to 48 milligrams of mercury depending on their age and manufacturer. The Fluorescent light fixtures are unlikely to be disturbed by this project.

High Intensity Discharge Lamps High Intensity Discharge (HID) lamps use mercury and sodium vapors in the lamp, and also typically have lead-containing solders at the bases. These lamps contain varying amounts of mercury depending on their age and manufacturer. The HID light fixtures are unlikely to be disturbed by this project.

All mercury-containing items being removed by this project are required to be disposed of as hazardous waste or recycled.

6. Other Hazardous Materials

Soil Contamination The scope of work for EHS-Alaska, Inc. did not include investigation of soils for petroleum or other contaminations.

Heat Transfer Fluids The existing steam system is assumed to contain heat transfer fluids, including boiler treatment chemicals.

Any heat transfer fluids removed from the heating system shall be recovered, tested and properly disposed of or recycled.

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.

The EPA regulations, issued as Title 40 of the Code of Federal Regulations, Part 61 (40 CFR 61), Subpart M under the National Emission Standards for Hazardous Air Pollutants (NESHAP), established procedures

Eielson AFB, Arctic Utilidor H Page 11 of 15 for handling ACM during asbestos removal and waste disposal. It is recommended that clearance sampling which complies with the EPA’s Asbestos Hazard Emergency Response Act (AHERA) protocol be required following interior removal of asbestos-containing materials to document that the asbestos has been properly removed. Exterior asbestos removal typically does not require clearance air sampling, but do require visual inspection reports documenting that the asbestos removal has been properly completed.

The EPA regulations require 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-containing materials.

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. Dusts with Asbestos

Settled dusts in the Utilidors (such as on the floor, walls and other surfaces, etc.) are assumed to have measurable concentrations of asbestos. Those dusts are assumed to contain less than 1 percent asbestos.

Background levels of asbestos in dusts for a particular location will depend on many factors, including whether or not asbestos occurs naturally in soils in the area.

Likely sources of asbestos in dusts include natural occurrences of asbestos

The types of asbestos found in settled and concealed dusts often contain actinolite, anthophyllite and tremolite forms of asbestos which are not commonly found in bulk samples taken of materials from buildings. Those forms of asbestos may come from natural occurrences of asbestos in an outside source, such as rock or ore deposits, which appear to be common in Alaska.

Because the type of disturbance, concentration of asbestos in the dusts, cohesiveness of the dusts and room sizes will change, the airborne asbestos levels expected during the project will depend on the contractor’s means and methods of conducting the work. The mere presence of asbestos in the dusts does not necessarily imply that a “hazard” exists which would require the use of specially trained workers to “abate” the “hazard”. All dusts will likely be required to be removed from the areas where asbestos-containing materials are being removed (abatement areas) in order to achieve clearances. The dusts in the other areas are to be controlled so as to limit worker exposures and prevent contamination of occupied areas of the building.

There is no established correlation between settled or adhered dusts with measurable concentrations of asbestos and airborne concentrations. The definition in the OSHA regulations of asbestos-containing materials as those materials that contain 1 percent or more asbestos by weight, apply to cohesive materials and not to dusts. The OSHA regulations are essentially “performance based”, if workers are exposed above the permissible exposure limits, then all of the requirements in the regulations become effective.

3. Lead-Containing Materials

The EPA Standard 40 CFR 745, Lead-Based Paint Poisoning Prevention in Certain Residential Structures, defines lead–based paint hazards and regulates lead based paint activities in target housing and child-occupied facilities. The requirements of this regulation include training certification, pre-work notifications, work practice standards and record keeping. Areas typically classified as child occupied facilities may include but are not limited to: day care facilities, preschools, kindergarten classrooms, restrooms, multipurpose rooms, cafeterias, gyms, libraries and other areas routinely used by children under 6 years of age. Training requirements for Firms (Contractors) and Renovators (Workers) became effective on April 22, 2010. The Utilidors are not classified as a child occupied facility, therefore the requirements of 40 CFR 745 do not apply.

Eielson AFB, Arctic Utilidor H Page 12 of 15

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. Experience has shown that some paints in most buildings will contain low concentrations of lead and disturbance of those paints are still regulated under the OSHA lead standard, 29 CFR 1926.62. Low levels of lead found by XRF testing does not mean that the paints are free of lead, the paints may contain lead, and OSHA regulations apply anytime measurable amounts of lead are present in paints.

Settled and concealed dust above ceilings, and at other areas that are not routinely cleaned are assumed to have measurable concentrations of lead. Background levels of lead in dusts for a particular location will depend on many factors, including whether or not engines utilizing leaded gasoline were run in or near a building, and upon the age of the building, and thus the age of the dusts. Because the type of disturbance, quantity of lead dusts, cohesiveness of the dusts and room sizes will change, the airborne lead levels expected during the project will depend on the contractor’s means and methods of conducting the work.

The mere presence of lead in the dusts does not necessarily imply that a “hazard” exists which would require the use of specially trained workers to “abate” the “hazard”.

There is no established correlation between settled or adhered lead dust concentrations and airborne concentrations. The OSHA regulations are essentially “performance based”, if workers are exposed above the permissible exposure limits, then all of the requirements in the regulations become effective.

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 test 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.

If the TCLP tests done on the waste stream(s) that are produced by the contractor are found to contain more than 5.0 mg/liter or 5.0 ppm of lead, they are classified as hazardous wastes, then those waste stream(s) will have to be packaged for shipping and disposal in accordance with hazardous waste and transportation regulations. Because there are no hazardous waste landfills in Alaska, this report assumes that any hazardous waste disposal will take place in Seattle or elsewhere in the Pacific Northwest.

4. PCB-Containing Materials

The EPA has promulgated regulations (40 CFR Part 761) that cover the proper handling and disposal of PCB-containing materials. PCB-containing “Bulk Product” materials (defined by the EPA as Bulk Products that contain more than 50 ppm PCBs) were not found by this survey. All 6 samples from Utilidor H had no detectable concentrations of PCB’s.

Materials containing PCB’s at any detectable concentrations are not allowed to be disposed of in Alaska Landfills under current Alaska Department of Conservation landfill permits, which exceeds the EPA regulations for disposal of PCB Bulk Products. The EPA regulates liquid PCBs differently from non-liquid materials, such as PCB Bulk Products.

Bulk product wastes that contain PCBs at 50 ppm or greater are regulated by the EPA, however, even at concentrations higher than 50 ppm, PCB bulk products are allowed by the EPA to be disposed of at municipal or non municipal, non-hazardous waste landfill because the PCBs in bulk products are not likely to leach out of the solid material. The following citation of 40 CFR 761.62(b) illustrates this: “Disposal in solid waste landfills. (1) Any person may dispose of the following PCB bulk product waste in a facility permitted, licensed, or registered by a State as a municipal or non-municipal non-hazardous waste landfill:

(i) Plastics (such as plastic insulation from wire or cable; radio, television and computer casings; vehicle parts; or furniture laminates); preformed or molded rubber parts and components; applied dried paints, varnishes, waxes or other similar coatings or sealants; caulking; Galbestos; non-liquid building demolition debris; or non-liquid PCB bulk product waste from the shredding of automobiles or household appliances

Eielson AFB, Arctic Utilidor H Page 13 of 15 from which PCB small capacitors have been removed (shredder fluff). (ii) Other PCB bulk product waste, sampled in accordance with the protocols set out in subpart R of this part, that leaches PCBs at <10 µg/L of water measured using a procedure used to simulate leachate generation.”

On October 24, 2012, EPA issued a Memorandum on the proposed reinterpretation of the PCB bulk product waste definition noting that building materials or substrates that are “coated or serviced with PCB Bulk Product Waste (e.g., caulk, paint, mastic, sealants) at the time of designation of disposal are to be managed as a PCB bulk product waste, even if the PCBs have migrated from the overlying bulk product waste into the substrate, provided there is no other source of PCB contamination on or in the substrate.”

The EPA’s 2012 Memorandum included the requirement that the potentially contaminated substrate (such as concrete or bricks or wood) be identified as PCB bulk product waste, prior to the material being designated as wastes, otherwise those materials would be classified as PCB remediation wastes, and be required to be disposed of at an EPA permitted hazardous waste landfill. If PCBs have migrated out of the PCB bulk product into the soils, then any soils containing more than 1 ppm, those soils are considered PCB remediation wastes and are subject to the cleanup and disposal requirements of 40 CFR 761.61.

Alaska regulations prohibits the disposal of PCB waste with detectable concentrations of PCB’s. State of Alaska regulation 18 AAC 60.025 prohibits the disposal of materials that contain a hazardous substance in concentrations that exceed the applicable soil cleanup levels in 18 AAC 75.341 (Table B1 or B2) in unlined landfills. This regulation is being applied to lead-based paint and PCB-containing building materials (PCB Bulk Products) in renovation or demolition projects by the Alaska Department of Environmental Conservation (ADEC). Although we believe this is outside of the intent of the regulation, there are currently no options for disposal of PCB Bulk Product waste with measurable concentrations of PCB’s in Alaska.

Since EPA regulations would allow disposal of PCB bulk products at essentially unlimited concentrations, it is recommended that additional coordination with local landfills be conducted to determine if at least the PCB bulk product wastes that contain less than 50 ppm be allowed to be disposed of at a local landfill, since they likely already have millions of tons of wastes that are likely classified as PCB bulk product wastes disposed of in their landfills.

Under 40 CFR 761.62 any person disposing of PCB bulk product waste in a waste management facility that does not have a commercial PCB storage or disposal approval must provide written notice to the facility a minimum of 15 days in advance of the first shipment. Content of the required notice is specified in 40 CFR 761.62.

Workers who remove or handle PCB-containing or PCB-contaminated materials or who transport or dispose of PCB wastes must be trained and certified in hazardous waste operations and emergency response (HAZWOPER) as required by 29 CFR 1910.120 and the State of Alaska Department of Labor (8 AAC 61).

The Department of Transportation under 49 CFR Parts 100-199 regulates the marking, packaging, handling and transportation of hazardous materials. All federal, state and local standards regulating PCBs and PCB waste must be followed during this project.

5. Mercury-Containing Materials

No mercury-containing materials are anticipated to be disturbed or disposed of by this project.

6. Other Hazardous Materials

Chemical Hazards The EPA has promulgated regulations (40 CFR Parts 260 to 299 amongst others) that cover the proper handling and disposal of waste chemicals, including listed wastes, which are ignitable, corrosive, reactive, toxic, or an acute hazardous waste or wastes that exhibit the characteristics of toxicity. All construction workers who are required to remove or handle chemical hazards or to transport or dispose of chemical wastes shall be trained and certified as required by the U.S. Department of Labor (29 CFR 1910.120) and

Eielson AFB, Arctic Utilidor H Page 14 of 15 the State of Alaska Department of Labor (8 AAC 61). Transportation of chemical hazards are regulated by Department of Transportation regulations under 49 CFR Parts 171 to 178 amongst others.

Waste heat transfer fluids (such as steam system fluids) are a potentially hazardous waste and are required to be TCLP tested prior to disposal to determine if the fluids are classified as hazardous or non-hazardous waste per the EPA’s RCRA regulations governing hazardous wastes. According to a study performed by the University of Northern Iowa, standard TCLP analysis using ICP SW 6010 testing procedures commonly report levels of Arsenic and Selenium over regulatory thresholds due to interferences in the matrix. That report concluded that additional analysis should be performed to refute the presence of Arsenic or Selenium over the regulatory levels by either mass spectrometry using method SW 6020, or by graphite furnace using method SW 7060. Some heat transfer fluids may also contain potentially hazardous additives that modify the properties of the fluids for use in a particular system. It is recommended that the contractor consult with the persons responsible for maintaining the system to determine if any additives that may be potentially hazardous were used in the system to further determine disposal requirements.

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

The asbestos-containing materials identified 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.

2. Dusts with Asbestos

Dusts with measurable concentrations of asbestos are assumed to be present, but are not classified as asbestos-containing materials, or as debris from asbestos-containing materials. Workers disturbing dusts are required to have hazard communication training in accordance with OSHA regulations, but are not required to receive 40 hours of training, which is required for asbestos workers. The contractor will need to choose means and methods to control worker exposures to airborne contaminants. At least an initial exposure assessment or data from previous air monitoring is needed to show that worker exposures are maintained below the OSHA permissible exposure limits (PELs).

3. 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, including disturbance of paints with low concentrations of 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 contains lead be tested to determine if they must be treated as hazardous waste. A TCLP test of the waste stream(s) produced by the Contractor’s means and methods are required to be performed to determine if those wastes will be classified as hazardous or non-hazardous.

4. PCB-Containing Materials

If any PCB-containing ballasts are discovered, and they are removed or replaced, they will need to be removed, handled, packaged and disposed of in accordance with all regulations.

As stated above, the samples of the suspect PCB Bulk Product were found to have no detectable concentrations of PCB’s.

5. Mercury-Containing Materials

Eielson AFB, Arctic Utilidor H Page 15 of 15

No mercury-containing materials are known to be scheduled for removal or replacement by this project. If any mercury-containing materials are removed or replaced, they will need to be removed, handled, packaged and disposed of in accordance with all regulations. If mercury-containing lamps and thermostats are handled and disposed of in accordance with the Universal Waste Regulations, no TCLP test is required.

If the Contractor chooses to perform a TCLP test of fluorescent lamps, the test shall be conducted in accordance with the requirements of ANSI/NEMA Standard Procedure for Fluorescent Lamp Sample Preparation and Toxicity Characteristic Leaching Procedure, C78.LL 1256-2003 or latest version.

6. Other Hazardous Materials

Heat transfer fluids will need to be removed, handled, packaged and disposed of in accordance with all 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 did not include investigation of the entire site and may not be valid outside the survey area. The intent of this survey was to identify common hazardous materials that may be disturbed during the proposed renovations. This survey is not intended to be utilized as the sole design document for abatement. This survey was conducted while the site was occupied. All inspections were performed with equipment and/or stored items in place. The scope of work for this survey did not include identification of all potentially hazardous materials that may be present at this site, and was limited to the scope of work agreed upon with our client. Although a concerted effort was made to identify those common hazardous materials likely to be affected by this project, some hazardous materials may have been hidden and may not have been identified. The survey investigated representative materials and items, such as mechanical components. Variations may occur between materials and items that appear to be the same, but are actually of different construction or materials. Other asbestos-containing or potentially hazardous materials may be present in the facilities that were concealed by structural members, walls, ceilings or floor coverings, or in materials where testing was not conducted.

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

APPENDIX A

Asbestos Bulk Sample Field Survey Data Sheets and Laboratory Reports

Approved by:

Approved Signatory Frank Ehrenfeld

Report for:

Mr. Robert French EHS-Alaska, Inc.

11901 Business Blvd, Suite 208 Eagle River, AK 99577

Regarding:

Eurofins EPK Built Environment Testing, LLC Project: 8154-01 - Utilidor H, Eielson AFB

EML ID: 3838922

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received and tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins EPK Built Environment Testing, LLC ("the Company"), a member of the Eurofins Built Environment Testing group of companies, shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct…