Limited Hazardous Materials Report.pdf

Planning, Engineering, Construction Management, Technology 6350 Presidential Gateway, Columbus, Ohio 43231

P 614.823.4949 F 614.823.4990

FIRE ALARM REPLACEMENT

DAYTON FEDERAL BUILDING

200 WEST 2ND STREET

DAYTON, OHIO

LIMITED HAZARDOUS

MATERIALS SURVEY

Prepared for:

Metro CD Engineering, LLC

3510 Snouffer Road, Suite 200 Columbus, Ohio 43235

Middough, Inc.

1901 East 13th Street Cleveland, Ohio 44114

Prepared By:

Resource International, Inc.

6350 Presidential Gateway Columbus, Ohio 43231

Rii Project #W-17-162

May 2018

RESOURCE INTERNATIONAL, INC.

An ISO 9001:2008 QMS Certified Firm

Columbus, Cleveland, Cincinnati, Newark, Ohio Indianapolis, Indiana Pittsburgh, Pennsylvania

6350 Presidential Gateway Columbus, Ohio 43231

Phone: 614.823.4949 Fax: 614.823.4990

Planning

Engineering

Construction Management

Technology

May 8, 2018

Mr. Michael Chow, P.E., CEM, CxA, LEED AP BD+C Metro CD Engineering, LLC 3510 Snouffer Road Columbus, Ohio 43235 Phone: (614) 923-3930

Re: Limited Hazardous Materials Survey Fire Alarm Replacement Project Dayton Federal Building 200 West 2nd Street, Dayton, Ohio Rii Project No. W-17-162

Dear Mr. Chow:

Resource International, Inc. (Rii) is submitting this Limited Hazardous Materials Survey conducted for the Dayton Fire Alarm Replacement Project at 200 West 2nd Street in Dayton, Ohio 45402.

Our conclusions and recommendations are presented in their entirety in Section 5.0.

The entire report should be read to obtain a more complete understanding of the information provided, and to aid in any decisions made or actions taken based on our findings and conclusions.

If you have any questions concerning this report, please contact Kristy Engel-Shepard or Michelle Eckels at 614-823-4949 or email at kristye@resourceinternational.com and michellee@resourceinternational.com.

Sincerely, RESOURCE INTERNATIONAL, INC.

Kristy Engel-Shepard, MS Environmental Project Manager

Michelle L. Eckels, CPG, LEED Green Assoc.

Vice President – Environmental Services

Attachment: Hazardous Materials Report mailto:kristye@resourceinternational.com

Dayton Federal Building – Fire Alarm Replacement Project Resource International, Inc.

Limited Hazardous Materials Survey Engineering Consultant Rii Project #W-17-162 – May 8, 2018 i

TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................................. II

1.0 INTRODUCTION

1.1 GENERAL

1.2 SITE SUMMARY

2.0 ASBESTOS SURVEY

2.1 METHODOLOGY

2.2 ANALYTICAL RESULTS

2.3 ASBESTOS CLASSIFICATIONS

3.0 LEAD SURVEY

3.1 LEAD PAINT SURVEY

3.1.1 XRF FIELD TESTING

3.2 LEAD PAINT RESULTS

3.3 LIMITATIONS

4.0 QUALITY ASSURANCE/QUALITY CONTROL

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ASBESTOS

5.1.2 RECOMMENDATIONS

5.1.3 REGULATORY NOTIFICATION OF RENOVATION/DEMOLITION

5.2 LEAD SURVEY

5.2.1 WORKER PROTECTION

5.2.2 WASTE DISPOSAL

5.2.3 SCRAP METAL RECYCLING

6.0 RELIABILITY OF REPORT - DISCLAIMER

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL

TABLES

TABLE 1 SUSPECT ASBESTOS-CONTAINING MATERIALS

TABLE 2 ASBESTOS SAMPLE SUMMARY (AT END OF REPORT)

TABLE 3 SUSPECT SURFACING MATERIALS & QUANTITIES

TABLE 4 IDENTIFIED ACM AND CATEGORIES

TABLE 5 LEAD PAINT XRF RESULTS

LIST OF APPENDICES

APPENDIX A FIGURES

APPENDIX B SITE PHOTOGRAPHS

APPENDIX C ANALYTICAL RESULTS & CHAINS-OF-CUSTODY

APPENDIX D CERTIFICATIONS AND LABORATORY ACCREDITATIONS

APPENDIX E NOTIFICATION FORMS

APPENDIX F ODH ASBESTOS BUILDING INSPECTION REPORT

EVALUATION CHECKLIST

Dayton Federal Building – Fire Alarm Replacement Project Resource International, Inc.

Limited Hazardous Materials Survey Engineering Consultant Rii Project #W-17-162 – May 8, 2018 ii

EXECUTIVE SUMMARY

Resource International, Inc. (Rii) was retained by Middough, Inc. to complete a limited hazardous materials assessment as part of the Dayton Fire Alarm Replacement Project design, at the Dayton Federal Building located at 200 West 2nd Street in Dayton, Ohio 45402. The hazardous material survey included the assessment for the presence of asbestos-containing materials (ACM) and lead-based paint (LBP) identified during the sampling and evaluation that potentially will be disturbed as part of the renovation/demolition activities.

ASBESTOS SURVEY

Per NESHAP and OEPA, bulk samples were obtained from the facility, and categorized into thirty-three (33) suspect homogeneous materials. When using the PLM method of analysis, four

(4) building materials were identified as ACM from the areas assessed for this project.

Please refer to Section 5.0 for conclusions and recommendations for proper management and disposal of the materials.

The finish on the plaster walls in Jury Room 910C on the 9th floor was identified as containing less than 1% asbestos. Trace levels of asbestos, or less than 1%, are not regulated by the EPA.

However, these levels are regulated by OSHA and must be removed in a manner that will limit exposure if disturbed. To the extent practicable, asbestos materials shall be handled in a manner which prevents the emission of airborne fibers to levels in excess of the excursion limit.

Please refer to OSHA guidance for applicable exposure limit regulations and renovation/demolition procedures associated with asbestos materials.

LEAD PAINT SURVEY

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for paint removal and demolition. Rii determined that the tan paint on original holding cell bars on the 1st and 8th Floors was identified as lead-based paint.

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight. The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Paint with varying levels of lead, including trace levels of lead at very low levels (less than 1.0 mg/cm2, or 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding.

Please refer to Section 5.0 for conclusions and recommendations for proper management and disposal of the materials. The entire report should be read to obtain a full understanding in order to make informed business decisions about the structures.

Limited Hazardous Materials Survey Resource International, Inc.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

1.0 INTRODUCTION

1.1 GENERAL

Resource International, Inc. (Rii) was retained by Middough, Inc. to complete a limited hazardous materials assessment as part of the Dayton Fire Alarm Replacement project design, at the Dayton Federal Building located at 200 West 2nd Street in Dayton, Ohio 45402. Refer to the site location map as Figure 1 in Appendix A. The hazardous material survey included the assessment for the presence of asbestos-containing materials (ACM) and lead-based paint (LBP) identified during the sampling and evaluation that potentially will be disturbed as part of the renovation activities.

1.2 SITE SUMMARY

Rii was retained to provide environmental design services for the Fire Alarm Replacement Project at the Dayton Federal Building located at 200 West 2nd Street in Dayton, Ohio 45402. The 169,129-square foot building was constructed in 1975 as a nine-story, rectangular building, with a full basement and partial penthouse.

The design work includes a limited hazardous materials survey of existing building materials in portion of the facility that will be undergoing renovations. This project includes renovations to the existing walls and above ceiling grid systems for replacement of the fire alarm system. The remainder of the facility was not assessed, and the following building materials were excluded sampled as part of this survey:

Flooring, Exterior materials, Equipment such as boilers and elevator parts, Electrical wiring and equipment, Roof materials, and

Windows and doors.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

2.0 ASBESTOS SURVEY

2.1 METHODOLOGY

The asbestos building survey was conducted to determine if asbestos-containing material (ACM) is present within the project area and to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61 Subpart M – National Emission Standard for Asbestos), the Occupational Safety and Health Administration (OSHA) asbestos standard (29 CFR 1910.1001), and the Ohio Environmental Protection Agency (Ohio EPA) Ohio Asbestos Emission Control Rules (Ohio Administrative Code [OAC] 3745-20). The NESHAP requires an asbestos survey prior to demolition or renovation, and classification of suspect materials into Category I nonfriable ACM, Category II nonfriable ACM, or Regulated ACM (RACM).

Ohio EPA requires notification when buildings are demolished and when renovation activities disturb specific quantities of ACM. For regulatory purposes, a material is considered ACM by EPA if it contains more than 1% asbestos, and a material is considered as asbestos-containing by OSHA if it contains any percent of asbestos, including less than 1% asbestos.

Building materials suspect to be asbestos-containing were inspected and grouped as homogeneous if uniform in texture, color, date of application, and appears identical in other respects. A total of 33 homogeneous ACMs from the facility were visually inspected and sampled during the field inspections. The following table is a list of homogeneous building materials initially suspect to be ACM.

TABLE 1 – SUSPECT ASBESTOS-CONTAINING MATERIALS

Material Code

Homogeneous Area/Material Description

CB Brown cove base

CT1 2’x4’ Ceiling tile – newer with random fissures

CT2 2’x2’ ceiling tile – smooth

CT3 2’x4’ ceiling tile – older with rough wavy texture

CT4 2’x2’ ceiling tile – smooth with random fissures

CT5 2’x2’ ceiling tile – newer with random fissures

CT6 2’x2’ ceiling tile – beveled

CT7 2’x2’ ceiling tile – newer very smooth

DW Drywall

DW2 ½“ Thick Drywall

DWM Drywall panels on metal track

F Finish on plaster

F2 Finish on P2 – un-renovated Jury Room 910C

FT1 12”x12” floor tile, red

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

Material Code

Homogeneous Area/Material Description

GCDW Gray caulk on drywall seams

GDM Gray duct mastic

GWC Gravel wall covering

IN Insulation on pipe - fiberglass

JC Joint compound on DW

JC2 Joint compound on DW2

P Plaster – base coat

P2 Plaster in un-renovated Jury Room 910C

PES Pipe end sealant

PW Pipe wrap

RFS Red fire stop – on sprinkler pipe

SFP1 Spray-on fireproofing - original

SFP2

Spray-on Fireproofing – Basement air handling unit wall

SFP3 Spray-on fireproofing - patching

WC White caulk on ceiling grid

WFS White fire stop – on sprinkler pipe

WPB White plaster board - premanufactured

WSD White sealant on fiberglass insulated duct

YM Yellow mastic

Interior materials suspected of containing asbestos must be categorized in accordance with Asbestos Hazard Emergency Response Act (AHERA, 40 CFR Part 763) as one (1) of the following three (3) types:

1. Surfacing Materials – Interior ACM that has been sprayed on, troweled on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

2. Thermal System Insulation (TSI) – Insulation applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

3. Miscellaneous Materials – Interior building materials on structural components, structural members or fixtures, such as floor ceiling tiles. "Miscellaneous materials" do not include TSI or surfacing materials.

AHERA requires a minimum number of samples to be collected based on linear and square footage to demonstrate that a homogeneous area is non-ACM. The following bulk sampling requirements were used in determining the number of samples necessary

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018 to obtain from a homogeneous material.

BULK SAMPLING REQUIREMENTS

Type of Material Minimum Samples Recommended

Friable Surfacing Material

Area ≤ 1,000 sq ft

Area 1,000 sq ft but ≤ 5,000 sq ft

Area 5,000 sq ft

Thermal System Insulation (TSI)

Homogeneous area of TSI

Patched TSI (if patched section < 6 linear or sq ft

Each insulated area of insulating cement (mudded fittings such as elbows, tees or valves)

Sufficient number of samples determined by Inspector (usually 2-3)

Friable Miscellaneous Material Sufficient number of samples determined by Inspector (usually 2-3)

Nonfriable Suspected ACM Sufficient number of samples determined by Inspector (usually 2-3)

In accordance with AHERA, the quantity of friable surfacing materials determines the minimum number of samples that the inspector must obtain for the survey. Below is Table 3 which lists the suspect surfacing materials, homogeneous area codes and quantities.

TABLE 3 – SUSPECT SURFACING MATERIALS & QUANTITIES

Suspect Surfacing Material Homogeneous

Code Quantities

(square feet) Finish and plaster F & P 153,000

Finish and plaster in un-renovated Jury Room 910C

F2 & P2 500

Spray-on fireproofing - original SFP1 170,000

Spray-on fireproofing – Room B10 – north wall near air handling units

SFP2 200

Spray-on fireproofing - patching SFP3 Unknown

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

2.2 ANALYTICAL RESULTS

Three (3) certified Asbestos Hazard Evaluation Specialists (AHES) visually inspected the suspect materials, identified to determine the presence of ACM. The AHES inspectors included Kristy Engel-Shepard (Certification #ES34846), Michelle Eckels (Certification #ES33141), and Zachary Hamilton (Certification #ES34150). The field sampling was conducted on April 2 thru 4, and April 12, 2018. Materials identified as suspect ACM were bulk sampled for laboratory analysis to determine asbestos content, in accordance with 40 CFR 763.86.

Each suspect ACM was touched to determine whether the material was friable or nonfriable, and the condition of each suspect ACM was documented. Whenever possible, reasonably ascertainable quantities of suspect ACM were visually observed and recorded.

The bulk samples were placed in plastic bags, sealed and labeled with a unique sample identification number and a description of material. Floor plans are provided as figures in Appendix A. Refer to Table 2 for a summary of the asbestos samples that were obtained and the location of the samples.

The bulk samples were submitted to EMSL Analytical, Inc. (EMSL) in Cinnaminson, New Jersey, for analysis using polarized light microscopy (PLM). EMSL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for conducting asbestos analysis using PLM. The PLM analysis was performed in accordance with the Environmental Protection Agency (EPA) Method 600/R-93/116, as outlined in 40 CFR

763.109 Appendix A. A chain-of-custody was prepared to accompany bulk samples to the laboratory.

A summary of the samples taken and materials which were identified as ACM are listed in Table 2 at the end of this report. Copies of the analytical results can be found in Appendix C. When using the PLM method of analysis, five (5) homogeneous materials from the portions of the building assessed for this project were identified as having detectable asbestos fibers. However, only four (4) homogeneous materials had greater than 1% asbestos and are regulated by the EPA.

2.3 ASBESTOS CLASSIFICATIONS

ACMs are classified as either Category I nonfriable, Category II nonfriable, or Regulated Asbestos-containing Material (RACM) in accordance with the Ohio Administrative Code (OAC) 3745-20-01 and the NESHAP 40 CFR Part 61.141, Subpart M. Refer to below for a definition of each classification:

Category I Nonfriable ACM – Asbestos-containing packings, gaskets, resilient floor

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018 covering and asphalt roofing products containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1.

Category II Nonfriable ACM – Any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated ACM (RACM) –

a) Friable asbestos material;

b) Category I nonfriable ACM that has become friable;

c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or

d) Category II nonfriable 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 demolition or renovation operations regulated by 40 CFR Part 61.

TABLE 4 – IDENTIFIED ACM AND CATEGORIES

Material Code

Homogeneous Material Description ACM Category

PES Pipe end sealant Category II

Nonfriable ACM

PW Pipe wrap RACM

SFP2

Spray-on Fireproofing cracked –

Rm B10 – north wall near air handling units

RACM

WSD White sealant on fiberglass insulated duct Category II

Nonfriable ACM

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

3.0 LEAD SURVEY

The paint inspection was conducted on April 2 thru 4, and April 12, 2018 by Kristy Engel- Shepard (Certified Lead Risk Assessor and Innov-X Systems Radiation Safety Operator), Michelle Eckels (Innov-X Systems Radiation Safety Operator), and Zachary Hamilton (Innov-X Systems Radiation Safety Operator). The inspection was performed using an X-Ray Fluorescence (XRF) device manufactured by Innov-X. Currently, there are no federal or state regulations that specifically identify testing procedures via XRF in non-residential buildings. Rii followed the manufacturer’s testing methodology for procedures, and inspectors were trained in the use, calibration and maintenance of the XRF equipment, along with the necessary principles of radiation safety.

3.1 LEAD PAINT SURVEY

3.1.1 XRF FIELD TESTING

The XRF Analyzer is a complete lead paint coating analysis system which quickly, accurately, and non-destructively measures the concentration of lead on surfaces. The XRF relies on the measurement of the K-shell X-rays to determine the amount of lead present on the painted surface. K-shell X-rays can penetrate many layers of paint/coating and allow for a good measurement of the lead content to be made without being significantly affected by the thickness or number of layers of paint on the surface of the sample. Immediately prior to initiating field testing, once every (4) four hours, and after the day’s inspection work was completed, a "validation test" was performed to assure that the instrument was operating properly.

3.2 LEAD PAINT RESULTS

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight when analyzed by atomic absorption spectroscopy (AAS). The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for renovation. Rii determined that the component identified in Table 5 – Lead Paint XRF Results contain lead-based paint on the surfaces tested.

TABLE 5 – LEAD PAINT XRF RESULTS

Location Lead-based Paint and Surfaces

1st Floor & 8th Floor Tan paint on original holding cell bars

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

Paint with varying levels of lead, including trace levels of lead at very low levels (less than 1.0 mg/cm2, or 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding. The complete lead-based paint results are located in Appendix C.

3.3 LIMITATIONS

The scope of this inspection is limited to building components that were visible to the inspector/risk assessor at the time of the inspection. The project scope does not include components that may have been concealed from sight by irregular construction practices, or hidden by temporary procedures used to secure the unit or other circumstances that would prevent visual inspection of the component. These areas should be considered to contain lead-based paint, unless tested otherwise, and be treated and handled as such during future renovation/demolition activities.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

4.0 QUALITY ASSURANCE/QUALITY CONTROL

Rii utilizes several procedures to ensure a high standard of care throughout the project.

Such procedures include:

All asbestos inspectors are ODH certified Asbestos Hazard Evaluation Specialists.

Disposable nitrile gloves and new, sealable, plastic bags are used to minimize cross-contamination of samples.

Sampling equipment is cleaned between continuous uses with wet methods.

Chain-of-custodies are completed after each survey, prior to transporting the samples to a laboratory for analysis.

The laboratory used for analysis of asbestos samples is accredited by the National Institute of Standards and Technology under the NVLAP.

The laboratory staff checks the sample numbers with the chain-of-custody.

A written report is developed by the inspectors, and peer-reviewed by the project manager.

The XRF instrument was calibrated by the rental company, IE Monitoring Equipment, prior to receipt.

Rii standardized the instrument in the field prior to and after use.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ASBESTOS

This Asbestos Survey was conducted in order to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61 Subpart M) and the Ohio Environmental Protection Agency (Ohio EPA) Ohio Asbestos Emission Control Rules (Ohio Administrative Code [OAC] 3745-20). A total of thirty-three (33) homogeneous ACM from the facility were visually inspected and sampled during field inspections.

When using the PLM method of analysis, four (4) building materials were identified as ACM. Copies of the analytical results can be found in Appendix C.

LOCATION ACM MATERIAL HA CODE

ACM

CAT**

QUANTITIES*

Throughout building Pipe end sealant PES Cat. II Unknown

Throughout building Pipe wrap PW RACM Unknown

Rm B10 – north wall near air handling units

Spray-on Fireproofing -cracked

SFP2 RACM 200 sf

Throughout building White sealant on fiberglass insulated duct WSD Cat. II Unknown

*lf – linear feet, sf – square feet, cf – cubic feet **Category – Category I Nonfriable ACM, Category II Nonfriable ACM, Regulated ACM

The finish on the plaster walls in Jury Room 910C on the 9th floor was identified as containing less than 1% asbestos. Trace levels of asbestos, or less than 1%, are not regulated by the EPA. However, these levels are regulated by OSHA and must be removed in a manner that will limit exposure if disturbed. To the extent practicable, asbestos materials shall be handled in a manner which prevents the emission of airborne fibers to levels in excess of the excursion limit. Please refer to OSHA guidance for applicable exposure limit regulations and renovation/demolition procedures associated with asbestos materials.

The project includes a limited hazardous materials survey of existing building materials in portion of the facility that will be undergoing renovations. This project includes renovations to the existing walls and above ceiling grid systems to replacement the fire alarm system. The remainder of the facility was not assessed, and the following building materials were not sampled as part of this survey:

Flooring, Exterior materials, Equipment such as boilers and elevator parts, Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

Electrical wiring and equipment

Roof materials, and

Windows and doors.

5.1.2 RECOMMENDATIONS

As the identified ACM (including pipe wrap and fittings, spray-on fireproofing SFP2, and/or white duct sealant) is to be disturbed by the renovation activities, proper asbestos abatement procedures should be implemented prior to the commencement of all renovation/demolition work. All materials identified as RACM, or may become RACM during renovation/demolition activities, and will be disturbed must be abated by a State of Ohio licensed abatement contractor, transported, and disposed of at an EPA licensed asbestos landfill.

5.1.3 REGULATORY NOTIFICATION OF RENOVATION/DEMOLITION

Per Ohio Environmental Protection Agency (Ohio EPA) regulations, A Notification of Demolition and Renovation Form must be completed and submitted at least ten (10) working days prior to the following activities:

every demolition of a facility requires notification, regardless of whether asbestos is involved.

every renovation of a facility must be submitted when the amount of regulated asbestos-containing material (RACM) stripped, removed, dislodged, cut, drilled, or similarly disturbed exceeds 260 linear feet on pipes or 160 square feet on other facility components or 35 cubic feet off facility components.

every abatement, when the activity involves the removal, renovation, enclosure, repair or encapsulation of friable asbestos-containing material in an amount greater than 50 linear feet on pipes or 50 square feet on other facility components.

Therefore, the contractor will be required to complete and submit this Ohio EPA notification form in accordance with OAC 3745-20 if the listed quantities of identified ACM are to be disturbed by the renovation project. A copy of the Ohio EPA Notification of Demolition and Renovation Form is provided in Appendix E.

5.2 LEAD SURVEY

April 2-4 and 12, 2018 by Kristy Engel-Shepard (Certified Lead Risk Assessor and Innov- X Systems Radiation Safety Operator), Michelle Eckels (Innov-X Systems Radiation Safety Operator), and Zachary Hamilton (Innov-X Systems Radiation Safety Operator).

The inspection was performed using an X-Ray Fluorescence (XRF) device manufactured by Innov-X. At this time, there are no federal or state regulations that specifically identify testing procedures via XRF in non-residential buildings.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

Testing for lead-based paint was performed on a representative number of painted components in the areas scheduled for renovation. Rii determined that the component identified in Table 5 – Lead Paint XRF Results contain lead-based paint on the surfaces tested.

TABLE 5 – LEAD PAINT RESULTS

Location Lead-based Paint and Surfaces

1st Floor & 8th Floor Tan paint on original holding cell bars

The US Environmental Protection Agency (EPA) defines lead-based paint (40 CFR 745.103) as paint containing lead levels equal to or greater than 1.0 mg/cm2 when measured by field XRF analyzers, 5,000 ppm or 0.5% by weight. The Occupational Safety and Health Administration (OSHA) does not define lead-based paint, nor does it acknowledge any intrinsically safe levels of lead in paint.

Paint with varying levels of lead, including trace levels of lead at very low levels (less than 1.0 mg/cm2, or 0.5% or 5,000 ppm by weight) was identified on various components throughout the building. These components may create lead dust if the paint is turned into dust by abrasion, scraping or sanding. The complete lead-based paint results are located in Appendix C.

5.2.1 WORKER PROTECTION

Worker safety should be as per OSHA Safety and Health Regulations for Construction, Lead Rule, 29 CFR 1926.62. The contractor should be made aware of the presence of lead and the field results should be made available. The contractor should also follow lead-safe work practices to reduce potential exposure to high levels of lead. Additionally, disposal and handling of the LBP material should be in accordance with all applicable governmental regulations.

The implications of lead paint existing in a building are related to the future use of the facility and the need to impact these painted surfaces during the renovation/demolition process. Renovations and/or demolition will require the contractor and subcontractors to address worker exposure where the surfaces coated with lead paint are going to be disturbed.

The OSHA Lead in Construction Standard located at 29 CFR 1926.62 regulates workers in construction, demolition, and maintenance who may be occupationally exposed to lead-containing products. Lead-related construction work involves any construction, repair, painting, decorating, demolition, renovation, removal or encapsulation, alteration, installation of lead products, emergency cleanup, transportation, disposal, storage, Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018 containment, and maintenance work whereby the lead-containing material could be disturbed resulting in lead exposure.

OSHA defines any detectable concentration of lead paint or chromium/cadmium coating as a potential lead exposure hazard to workers doing construction/demolition-type work on these surfaces as even small concentrations of lead can result in unacceptable employee exposures depending upon the method of removal and other workplace conditions. Since these conditions can vary greatly, the standard requires all employers to make an initial determination of whether any employee’s exposure to lead exceeds the action level of 50 micrograms per cubic meter of air (µg/m3) averaged over an 8-hour day, the action level of 2.5 µg/m3 averaged over an 8-hour day for chromium and/or cadmium.

The exposure assessment involves sampling the air in the worker’s breathing zone to determine exposure. Employee exposure is that exposure which would occur if the employee were not using a respirator. This initial determination requires the employer to monitor workers’ exposures unless the employer has objective data that can demonstrate conclusively that no employee will be exposed to lead in excess of the action level. Where objective data is used in lieu of actual monitoring, the employer must establish and maintain an accurate record, documenting its relevancy in assessing exposure levels for current job conditions. If such objective data is available, the employer need proceed no further on employee exposure assessment until such time that conditions have changed and the determination is no longer valid.

However, if this initial determination shows that a reasonable possibility exists that any employee may be exposed, without regard to respirators, over the action level; the employer must set up an air monitoring program to determine the exposure level representative of each employee exposed to lead in the workplace.

OSHA states that until the employer performs an exposure assessment (or can supply prior data regarding the same type of work which may exempt them from the standard) and documents that employees are not exposed above the permissible exposure limit (PEL), the employer must treat employees as if they were exposed above the PEL for the following operations:

manual demolition of structures, manual scraping, manual sanding, and use of heat gun where hazardous coatings or paints are present;

abrasive blasting enclosure movement and removal;

power tool cleaning;

lead burning;

using hazardous mortar or spray paint;

abrasive blasting, rivet busting, or welding, cutting, or burning on any structure

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018 where hazardous coatings or paint are present;

cleanup activities where dry expendable abrasive are used; and any other task the employer believes may cause exposure in excess of the

PEL.

This means providing respiratory protection, protective work clothing and equipment, change areas, hand washing facilities, biological monitoring, and training until an exposure assessment has determined that the work activity will result in an exposure below the PEL. Additional requirements under this standard include a written compliance program as well as record keeping.

5.2.2 WASTE DISPOSAL

Waste disposal is governed by the Federal Resource Conservation and Recovery Act (RCRA) regulations, which distinguish between solid wastes and hazardous wastes.

Solid wastes include general construction debris and are subject to minimum handling, transportation, and landfill disposal requirements under RCRA regulations. Hazardous wastes are subject to restrictions designed to prevent the hazardous materials from entering the environment.

As of December 21, 2017, Ohio EPA’s Ohio-Specific Universal Waste rules allow hazardous paint-related waste to be classified as a universal waste in Ohio under OAC Chapter 3745-273. A universal waste is a unique category of hazardous waste that may be managed under less burdensome handler and transport requirements in the state of Ohio. The hazardous paint-related waste would not need to be managed and transported as hazardous waste. Quantities would not count towards the hazardous waste generator status; which includes conditionally exempt small quantity generators (CESQGs), small quantity generators (SQGs) and large quantity generators (LQGs). Thus, hazardous waste manifesting would also not be required, but tracked using the universal waste manifest.

Under the Ohio EPA’s Ohio-Specific Universal Waste (UW) rules, there are two (2) classes of handlers. A Small Quantity Handler of Universal Waste (SQHUW) may store less than 5000 kg of UW at any time and a Large Quantity Handler of Universal Waste (LQHUW) may store 5000 kg or more of UW. The handler’s management activities are limited to those specified in OAC rule 3745-273-13 for SQHUW and OAC rule 3745-273- 33 for LQHUW. A Universal Waste Transporter must transport the waste in accordance with all U.S. DOT requirements.

For disposal purposes, hazardous paint-related waste must still be classified as hazardous or non-hazardous, based on the results of the Toxic Characteristic Leachate Procedure (TCLP) testing, to determine the destination facility (non-hazardous or hazardous disposal facility). The leachability test measures whether or not

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018 lead/chromium leaches from the waste in excess of the regulated level of 5.0 mg/L, or

1.0 mg/L for cadmium. If the results of the TCLP analysis exceed this level, the waste must be handled, transported and disposed as a hazardous waste in an approved waste site, reclamation facility or incinerator site.

EPA’s regulations require the TCLP to be performed so that it represents the matrix and material of the waste stream. For the project, this can be in the form of a representative sample of debris taken either before or after the project begins. Since waste disposal is made up of a matrix of all debris that is to be disposed, combining painted surfaces with low XRF results with those surfaces with higher XRF results may classify the waste as non-hazardous for disposal purposes.

5.2.3 SCRAP METAL RECYCLING

Metal components that will be removed which contain lead are exempt from the requirements of RCRA if sent to a scrap facility for recycling and are, therefore, not considered waste. It is recommended that the owner receive a receipt or bill of lading from the scrap facility stating that the scrap metal was accepted and purchased by the scrap facility.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

6.0 RELIABILITY OF REPORT - DISCLAIMER

This report has been prepared to document findings of the hazardous material survey only, not for abatement design. Abatement design should be performed by appropriately experienced and credentialed personnel. Additional reconnaissance work, which may include minor demolition to access hidden areas and further sampling/analyses, should be expected as part of abatement design.

Our inspection excluded areas that require significant demolition of building surfaces and structures for access; therefore, should suspect asbestos-containing materials (e.g., pipe insulation, vermiculite, etc.) be discovered above fixed ceiling systems or within wall systems and inaccessible pipe chases, these materials should be properly sampled and removed by an abatement contractor if necessary

The opinions, conclusions, and recommendations presented in this report are put forth for a specific and proposed purpose and for the specific site discussed. Rii is not responsible for any other application, whether of purpose or location, of our opinions, conclusions, or recommendations, other than as specifically indicated in this report.

Conclusions reached in this report are based upon the objective data available to Rii at the time of forming the opinions as presented in this report. The accuracy of this report depends upon the accuracy of the data. The conclusions reached herein represent our opinions. Rii is not responsible for actual conditions proven to be materially at variance with the data that was available to them and upon which they relied, as presented in this report.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONAL

The state licenses of the personnel involved in this survey are provided in Appendix D.

The environmental professionals responsible for the Hazardous Material Survey are as follows:

Kristy Engel-Shepard, MS Environmental Project Manager Certified Asbestos Hazard Evaluation Specialist – No. ES34846 Certified Asbestos Hazard Abatement Project Designer – No. PD60776 Certified Lead Risk Assessor – No. LA9350

Michelle L. Eckels, CPG, LEED Green Assoc.

Vice President – Environmental Services Certified Asbestos Hazard Evaluation Specialist – No. ES33141 Certified Asbestos Hazard Abatement Project Designer – No. PD60600

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

DEFINITION OF TERMS

Abatement – Procedures to control fiber release from Asbestos-Containing Materials (ACM). Includes removal, encapsulation, and enclosure.

Asbestos – A generic name given to a number of naturally occurring hydrated mineral silicates that possess a unique crystalline structure, are incombustible in air, and separate into fibers. Asbestos includes the asbestiform varieties of chrysotile (serpentine); crocidolite (riebeckite); amosite (cummingtonite-grunerite);

anthophyllite; tremolite, and actinolite, in any combination.

ACM - Asbestos-Containing Material – Any material containing more than 1% by weight of asbestos of any type or mixture of types (AHERA, OSHA definition).

Asbestos Fiber – A particle of asbestos, 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1 (OSHA definition).

Ballasts – Both magnetic and electronic ballasts used to regulate the current and power to a fluorescent and HID lamps. Magnetic ballasts may or may not include capacitors containing PCBs. Prior to 1978, ballasts were commonly manufactured with PCBs in the capacitor oil and in a tar-like substance that surrounds ballast components called “potting compound”. Ballasts with no PCBs, will have an identifying sticker “No PCB”.

Category I nonfriable ACM – Asbestos-containing packings, gaskets, resilient floor covering and asphalt roofing products containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in appendix E, subpart E, 40 CFR part 763, section 1.

Category II nonfriable ACM – Any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using Polarized Light Microscopy, as specified in appendix E, subpart E, 40 CFR part 763, section 1, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

EPA – Environmental Protection Agency.

Fluorescent Lamps – Low intensity discharge lamps that contain mercury and are commonly used in commercial and industrial lighting. Fluorescent lamps include tubes, circular and compact fluorescent lighting products, whether they use separate or integral ballast.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

Friable Asbestos-Containing Material – Material that contains more than 1% asbestos by weight and that can be crumbled, pulverized, or reduced to powder, when dry, by hand pressure (ODH definition).

Hazardous Substance - a substance defined as a hazardous substance pursuant to CERCLA 42 USC part 9601(14), as interpreted by EPA regulations and the courts: (A) any substance designated pursuant to section 1321(b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to 42 USC part 9602, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (42 USC part 6921), (D) any toxic pollutant listed under section 1317(a) of Title 33, (E) any hazardous air pollutant listed under section 112 of the Clean Air Act (42 USC part 7412), and (F) any imminently hazardous chemical substance or mixture with respect to which the EPA Administrator has taken action pursuant to section 2606 of Title 15. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under the items listed above. The term also does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and synthetic gas).

Hazardous Waste – Any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act (42 USC 6921)(but not including any waste the regulation of which under the Solid Waste Disposal Act (42 USC 6901 et seq.) has been suspended by Act of Congress).

High Intensity Discharge or HID Lamps – Includes mercury, metal halide and high-pressure sodium lamps that contain mercury.

NESHAP – National Emission Standards for Hazardous Air Pollutants.

NIOSH – National Institute for Occupational Safety and Health.

NVLAP – National Voluntary Laboratory Accreditation Program

ODH – Ohio Department of Health

OSHA – Occupational Safety and Health Administration.

PCM – Phase Contrast Microscopy – An optical microscopic technique used for the counting of fibers in air samples, but which does not distinguish fiber types.

Dayton Fire Alarm Replacement Project Engineering Consultant Rii Project #W-17-162 – May 8, 2018

PLM – Polarized Light Microscopy – Bulk sample analysis of suspect asbestos sample using microscope equipped with dual polarizing filters to observe optical properties of the sample.

PPE – Personal Protective Equipment – Equipment worn to minimize exposure to a variety of hazards. Example of PPE includes such items as gloves, foot and eye protection, protective hearing devices, hard hats, respirators and full body suits.

RCRA – Resource Conservation and Recovery Act.

Regulated ACM (RACM) –

a) Friable asbestos material;

b) Category I nonfriable ACM that has become friable;

c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or

d) Category II nonfriable 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 demolition or renovation operations regulated by 40 CFR Part 61.

TCLP – Toxic Characteristic Leachate Procedure.

XRF – X-ray Fluorescence

APPENDIX A

FIGURES

Rii Project W-17-162

N

FIGURE 1 - SITE LOCATION MAP

Dayton Federal Building

200 West 2nd Street Dayton, Ohio

Site Location

APPENDIX B

SITE PHOTOGRAPHS

PHOTOGRAPHIC LOG

Project Name:

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

Date:

04/02/2018

Description:

Pipe end sealant was identified as asbestos-containing material.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

04/12/2018

The pipe wrap and pipe end sealant were identified as asbestos-containing material.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

04/02/2018

The pipe wrap and pipe end sealant were identified as asbestos-containing material.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-167

Photo No.

The white sealant on fiberglass insulated ductwork was identified as asbestos-containing

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

The white sealant on fiberglass insulated ductwork was identified as asbestos-containing

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

The Spray-on Fireproofing original (SFP1), throughout most of the building, was not

ACM.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

Spray-on Fireproofing (SFP2) on the wall by the air handling units in Room B10 was identified as asbestos-containing, and was visibly different than the spray-on fireproofing throughout the rest of the building.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

The holding cells had lead-based paint on the metal bars. 1st and 8th Floors.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

The finish on the plaster walls in Jury Room 910C on the 9th floor was identified as containing less than 1% asbestos. Trace levels of asbestos are not regulated by the EPA.

However, these levels are regulated by OSHA.

Dayton Fire Alarm Replacement Project

Location:

200 West 2nd Street, Dayton, Ohio

Project No.

W-17-162

Photo No.

Photo of Spray-on Fireproofing original (SFP1) and Spray-on fireproofing patching (SFP3). Both materials were non-ACM.

original (SFP1) patching (SFP3)

APPENDIX C

ANALYTICAL RESULTS &

CHAIN-OF-CUSTODIES

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041809865EMSL Order:

RESI25Customer ID:

W-17-162Customer PO:

Project ID:

Attention: Phone:Michelle Eckels (614) 390-5988

Fax:Resource International (614) 823-4990

Received Date:6350 Presidential Gateway 04/05/2018 9:30 AM

Analysis Date:Columbus, OH 43231 04/08/2018 - 04/09/2018

Collected Date: 04/04/2018

Project: GSA Dayton

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

041809865-0001

B10 A near Hatch -

Spray-on Fireproofing

Tan

Fibrous

Homogeneous

Chrysotile8%92% Non-fibrous (Other)

041809865-0002

Outside B11 -

Spray-on Fireproofing

Tan

Fibrous

Homogeneous

None DetectedCellulose

Glass

20%

5%

75% Non-fibrous (Other)

041809865-0003

B32 - Spray-on

Fireproofing

Tan

Fibrous

Homogeneous

None DetectedCellulose

Glass

20%

5%

75% Non-fibrous (Other)

041809865-0004

1st Fl 100A - Spray-on

Fireproofing

Tan

Fibrous

Homogeneous

None DetectedCellulose

Glass

30%

4%

66% Non-fibrous (Other)

041809865-0005

Penhouse - Spray-on

Fireproofing

Gray

Fibrous

Homogeneous

None DetectedCellulose

Glass

40%

20%

40% Non-fibrous (Other)

041809865-0006

Penhouse - Spray-on

Fireproofing

Gray

Fibrous

Homogeneous

None DetectedCellulose

Glass

40%

20%

40% Non-fibrous (Other)

041809865-0007

9th Fl - Courtroom 1 -

Spray-on Fireproofing

Gray

Non-Fibrous

Homogeneous

None DetectedCellulose

Glass

40%

20%

40% Non-fibrous (Other)

041809865-0008

B10 - Green Chilled

Water Pipe - Pipe Wrap

Green

Fibrous

Heterogeneous

Chrysotile5%Glass10% 85% Non-fibrous (Other)

041809865-0009

B10 - White Hot Water

Pipe - Pipe Wrap

White

Fibrous

Homogeneous

None DetectedCellulose35% 65% Non-fibrous (Other)

018-Wrap

041809865-0010

B10 - Green Water

Pipe - Pipe Wrap

Green

Fibrous

Homogeneous

Chrysotile3%97% Non-fibrous (Other)

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Report amended: 04/12/2018 06:58:43 Replaces amended report from: 04/10/2018 10:09:24 Reason Code: Data Entry-Change to Project

ASB_PLMwSigs_0007_0001 Printed:5/2/2018 2:47:20PM Page 1 of 20

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041809865EMSL Order:

RESI25Customer ID:

W-17-162Customer PO:

Project ID:

Attention: Phone:Michelle Eckels (614)…