_4_Amendment_0002_Section_02_41.00_Attachment_.pdf

HAZARDOUS BUILDING MATERIALS ASSESSMENT

Naval Air Station Jacksonville Replace Airfield Lighting/ Electrical System Buildings 114, 766, 854, 881 Jacksonville, FL

Prepared For:

Ms. Amy Hoffer Project Manager NAVFAC Southeast

Prepared By:

URS Corporation 4168 Southpoint Parkway South, Suite 205 Jacksonville, FL 32216 904.281.9251 URS Project # 12010716

September 5, 2012

URS Corporation 4168 Southpoint Parkway South, Suite 205 Jacksonville, FL 32250 Tel: 904.281.9251 Fax: 904.281.9892

September 5, 2012

Commanding Officer NAVFAC Southeast Ajax Street, Building 135 Jacksonville, FL 32212-0030 Attn: Ms. Amy Hoffer

Re: Hazardous Building Materials Assessment

Replace Airfield Lighting/ Electrical System Buildings 114, 766, 854, 881 Naval Air Station Jacksonville Jacksonville, FL

Dear Ms. Hoffer, URS Corporation (URS) has prepared this Hazardous Building Materials Assessment report for the above referenced structure. We trust this report provides you with the information you require at this time. If you have any questions about the information presented within this report, please do not hesitate to contact J.J. Calamari in our Tampa Office at 813.286.1711.

Respectively submitted, URS Corporation

Graham Hayes, CAI Michael Emilio Staff Environmental Scientist Senior Geologist URS- Jacksonville URS- Jacksonville

Tim DeBord J.J. Calamari Vice President Project Manager URS- Jacksonville URS- Tampa

Hazardous Building Material Assessment NAS-Jacksonville: Replace Airfield Lighting and Electrical System

Page iii

TABLE OF CONTENTS

EXECUTIVE SUMMARY ....................................................................................................................... iv

1.0 INTRODUCTION & BACKGROUND

1.1 Site Description

1.2 Limitations

2.0 METHODOLOGY

2.1 Survey Methods

2.2 Sampling Methods

2.2.1 Asbestos Containing Materials

2.2.2 Lead Based Paint

2.2.3 Polychlorinated Biphenyls

2.3 Analytical Methods

3.0 FINDINGS

3.1 Asbestos Containing Materials

3.2 Lead Based Paint

3.3 Polychlorinated Biphenyls

4.0 CONCLUSIONS & RECOMMENDATIONS

4.1 Category I Non-friable (NF-1) ACM

4.2 Lead Based Paint

4.3 Polychlorinated Biphenyls

4.4 General Asbestos Recommendations

5.0 REFERENCES

TABLES

TABLE 1 SUSPECT ACM-BULK SAMPLE SUMMARY

TABLE 2 PAINT CHIP SAMPLE SUMMARY

TABLE 3 DIELECTRIC FLUID ANALYTICAL SUMMARY

FIGURES

FIGURE 1 SITE MAP: ELECTRICAL VAULT BUILDINGS 114, 766, 854 & 881

FIGURE 2 SAMPLE LOCATION MAP- BUILDING 114

FIGURE 3 SAMPLE LOCATION MAP- BUILDING 766

FIGURE 4 SAMPLE LOCATION MAP- BUILDING 854

FIGURE 5 SAMPLE LOCATION MAP- BUILDING 881

APPENDICES

APPENDIX A INSPECTOR ACCREDITATIONS

APPENDIX B ANALYTICAL REPORTS and CHAIN-OF-CUSTODIES

NAS-Jacksonville: Replace Airfield Lighting/ Electrical

Page iv

EXECUTIVE SUMMARY

URS Corporation (URS) conducted a Hazardous Building Materials Assessment of the four electrical vault buildings at the Naval Air Station- Jacksonville in Jacksonville, Florida (the Site).

The objective of this assessment was to identify asbestos-containing materials (ACM), lead-based paint (LBP), and polychlorinated biphenyl (PCB) dielectric fluids in the four electrical vault buildings for abatement and disposal purposes prior to demolition of the buildings associated with the replacement of airfield lighting and electrical system. The four electrical vault buildings are designated as Buildings 114, 766, 854, and 881. During the assessment URS collected the following samples from the four electrical vault buildings: 20 bulk samples for asbestos analysis, 26 paint chip samples for lead analysis, and 48 dielectric fluid samples for PCB analysis.

The following ACMs were identified at the Site during this assessment:

ACM

ACM Location(s) Analytical Results

Flat Gravel Roof – Brown/Black Roof, Building 881 15% Chrysotile Flat Gravel Roof – Brown/Black Roof, Building 881 15% Chrysotile Built-up Flat Roof – Black Roofing Roof, Building 854 5% Chrysotile Built-up Flat Roof – Black Felt Roof, Building 854 5% Chrysotile Built-up Flat Roof – Black Roofing Roof, Building 854 2% Chrysotile

The ACM identified during this survey is expected to be impacted during the planned demolition of the structure. The owner has the option of removing this Category I non friable ACM to minimize any potential liability and ensure full compliance with EPA and OSHA regulations.

However, the EPA will generally allow this type of ACM to remain in place as long as such materials remain in a non-friable state and are not subjected to mechanical drilling, sanding, abrading, grinding, or sawing during demolition activities. If the building is demolished with this type of ACM in place, there are several requirements of the building owner and demolition contractor that must be met in order to be in full compliance with the NESHAP regulation 40 CFR Part 61. Refer to Section 4.1 for additional information.

The following LBP at concentrations greater than 0.5% by weight was identified at the Site during this assessment.

Paint Color

Paint Location(s)

Analytical Results

(% lead by weight)

Brown Paint Building 766, doors and window trim 2.5

Page v

Eight additional samples contained lead at detectable concentrations less than 0.5% by weight.

These paint samples included the interior paint (silver) and door paint (gray and brown) in building 114, the exterior walls (yellow) of building 881, and the exterior walls (yellow) and interior door (gray) of building 766. Demolition activities involving the previously identified painted surfaces that contain LBP in buildings 114, 881, and 766, should be performed in accordance with the OSHA Lead in Construction Standard 29 CFR 1926.62. Individual LBP coated components (i.e. doors and window frames) may be removed and segregated, with the entire LBP component being disposed of properly. Toxicity Characteristic Leaching Procedure (TCLP) sampling should be performed to characterize the waste as hazardous or non-hazardous.

All 48 dielectric fluid samples analyzed during this assessment have a PCB concentration that was non-detect or below the 50 ppm, milligram per kilogram (mg/kg), Non-PCB threshold value.

However, five of the 48 dielectric samples from building 766 have a low PCB concentration between 2 ppm and 50 ppm. Dielectric fluid from the four switches and one voltage regulator in building 766 (sample numbers: 766-PCB-2, 766-PCB-8, 766-PCB-9, 766-PCB-10, and 766- PCB-15) that contain PCBs greater than 2 ppm and less than 50 ppm; these items should be disposed of properly per the Toxic Substance Control Act (TSCA) 40 CFR 761.

Refer to the main report and appendices for more detailed findings and supporting documentation.

HAZARDOUS BUILDING MATERIAL ASSESSMENT

Replace Airfield Lighting/ Electrical System

Buildings 114, 766, 854, 881 Naval Air Station- Jacksonville

Jacksonville, FL

1.0 INTRODUCTION & BACKGROUND

URS Corporation Southern (URS) is pleased to submit this report for the Hazardous Building Materials Assessment conducted between August 8th and August 11th, 2012, at the above referenced site. The objective of this assessment was to identify asbestos-containing materials (ACM), lead-based paint (LBP), and polychlorinated biphenyl (PCB) dielectric fluids in the four electrical vault buildings for abatement and disposal purposes prior to demolition of the buildings associated with the replacement of airfield lighting and electrical system. The four electrical vault buildings, Buildings 114, 766, 854, and 881, are located south of the airfield and west of the Saint Johns River. The location of the four vault buildings on Naval Air Station (NAS)- Jacksonville are depicted on Figure 1. URS’ ACM and LBP survey was conducted by Mr.

Graham Hayes and the PCB survey was conducted by Mr. Hayes and Mr. Michael Emilio. Mr.

Hayes has received the following relevant training:

Asbestos Building Inspector Certification under AHERA Certification Number 120506-2469; Expiration Date: April 24, 2013.

Access to the Site was provided by NAS Jacksonville.

1.1 Site Description

The surveyed site consisted of four electrical vault buildings (Buildings 114, 766, 854, and 881) associated with the airfield lighting and electrical system on NAS-Jacksonville. It should be noted that Buildings 766, 854, and 881 are freestanding structures. The following interior and exterior building materials were identified at the four electrical vault buildings at the time of the survey:

Building 114 - The vault assessed at this building consisted of only a single room within a larger building. It was URS’ understanding that only the electrical systems within this vault are scheduled for removal and that the entire Building 114 was not scheduled for demolition in conjunction with airfield lighting replacement. Interior finishes within this space consisted of unpainted concrete floors and ceilings and the walls consisted of painted brick tiles.

Building 766 - This building is constructed of concrete block walls with a flat roof. The interior spaces of the building consisted of bare concrete floors, walls, and ceilings. Except for an interior door, no painted surfaces were observed inside this building. The exterior walls, doors and windows were painted.

e

Building 854 - This building is constructed of concrete block walls with a built-up flat roof. The interior spaces of the building consisted of bare concrete floors, painted concrete block walls, and fibrous ceiling material. The exterior walls, doors and windows were painted.

Building 881 - This building is constructed of concrete block walls with a flat gravel roof. The interior spaces of the building consisted of bare concrete floors with painted concrete walls and ceiling. The exterior walls, doors and windows were painted.

1.2 Limitations

URS’ survey and assessment was limited to observation and minimal destructive sampling and analysis of potentially hazardous building materials in accessible portions of the building.

However, common construction techniques render portions of any building inaccessible. As a result, additional asbestos-containing building materials may be present in inaccessible areas (i.e., between walls, ceiling spaces enclosed by paneling, interior of metal fire doors, etc.) of the building that were not observed during the survey. In addition, electrical and mechanical equipment were not sampled for asbestos. Inaccessible areas should be presumed to contain asbestos until extensive destructive sampling is performed in those areas.

URS exercised due care during the sampling to minimize destruction of building materials and collected samples from inconspicuous places when possible. However, URS accepts neither responsibility nor liability for repair or restoration of building materials damaged during asbestos sample collection activities. As the building is planned to be demolished, roofing materials were collected, potentially nullifying guarantees/warranties. Sample locations from the roofs were repaired with roofing cement. While due care was taken in patching the roof sample locations, URS does not provide a warranty or guarantee for these patches.

URS services were provided in accordance with generally accepted environmental science, industrial hygiene, and engineering practices at the time the work was performed. No expressed or intended representation of warranty is included or intended in our reports, except that our services were performed with the customary thoroughness and competence of our profession.

Lead testing results are applicable for the time that testing was conducted and for the condition of surfaces at the time they were tested. If questions arise regarding lead content in or on surfaces that were not tested by URS, then additional testing should be performed on those surfaces.

The conclusions of this report are URS’ professional opinions, based solely upon visual site observations and interpretations of laboratory analyses, as described in this report. The opinions presented herein apply to the site conditions existing at the time of URS’ investigation and interpretation of current regulations pertaining to asbestos, lead-based paint, and polychlorinated biphenyls. Therefore, URS’ opinions and recommendations may not apply to future conditions that may exist at the site which we have not had the opportunity to evaluate. All applicable Federal, State and local regulations should always be verified prior to any work that will disturb materials containing asbestos, lead-based paint, and polychlorinated biphenyls.

2.0 METHODOLOGY

Supporting documentation for the survey activities described in this report is provided in the Tables, Figures, and Appendices presented at the end of this report. Prior to the assessment URS developed a Safe Work Plan (SWP) and coordinated with the appropriate on-site personnel.

2.1 Survey Methods

In order to identify suspect ACM and presumed ACM (PACM), loose paint surfaces, and determine the number and accessibility of electrical components filled with dielectric fluid, URS conducted a walk-through survey of accessible portions of the four electrical vault buildings.

URS performed destructive sampling where applicable to investigate concealed areas and ACM materials in the building.

URS’ asbestos survey was performed in general accordance with the sampling protocol as outlined under AHERA (40 CFR 763). Approximate quantities of suspect materials were estimated by field measurements and/or drawing scale. The condition and friability (i.e., able to be readily crumbled, pulverized, or reduced to powder by hand pressure when dry) of suspect ACM were also noted. Friability of each sampled material was determined by hand-touch.

2.2 Sampling Methods

The following sample methods for ACM, LBP and PCB sample collection were employed.

2.2.1 Asbestos Containing Materials

Suspect ACMs were grouped into homogeneous sampling areas (HSA) and categorized, according to AHERA 40 CFR 763, as thermal system insulation (TSI), surfacing material, or miscellaneous material. URS developed a sampling plan, which, at a minimum, included the collection and analysis of samples as follows:

Thermal System Insulation

In a randomly distributive manner, a minimum of three (3) samples of each suspect material in each HSA (not already presumed to contain asbestos) were collected. At least one (1) bulk sample from HSAs of TSI with less than 10 square feet (sf) or 20 linear feet (lf) was collected and submitted for analysis. HSAs the with less than the minimal requirements included:

vibration clothes in Building 881 and 854; and pipe cloths, insulation, and jackets; and muffler cloths and insulation in Building 854. A limited number of samples were collected from these homogenous areas to preserve the functionality of the still operational mechanical systems.

Additional samples of these homogeneous areas may be collected to confirm the analytical results in this report as the demolition date nears.

Surfacing Material

In a randomly distributive manner, a minimum of three (3) samples were collected from each HSA that was 1,000 sf or less; a minimum of five (5) samples were collected from each HSA that was greater than 1,000 sf, but less than or equal to 5,000 sf; and a minimum of seven (7) samples were collected from each HSA that was greater than 5,000 sf.

Miscellaneous Material

Samples were collected in a randomly distributive manner as deemed sufficient by URS’ AHERA-accredited building inspector. At least three (3) samples were collected of each suspect miscellaneous material not presumed to contain asbestos.

Non-Suspect Materials

According to 40 CFR 763-86(4), sampling is not required where an AHERA-accredited building inspector has deemed TSI or miscellaneous materials to be fiberglass, foam glass, rubber, or other non-ACM.

Samples were collected in a non-abrasive manner by carefully removing small portions of the suspect material with a sharp knife or other hand tool suitable to the material being sampled.

Each sample was placed in a re-sealable plastic bag immediately after collection for transportation to the laboratory. The sampling instrument was subsequently wiped with a clean moist cloth to decontaminate the tool, prevent the potential release of asbestos fibers, and prevent contamination of subsequent samples. Following the collection of each roofing sample, the sample location was patched with roofing cement.

Samples were numbered in the order they were taken. Data pertinent to each sample (e.g., date, sample number, material description, material quantity, and material condition) was recorded on a field data sheet.

2.2.2 Lead Based Paint

Paint chip samples for the LBP inspection was collected from accessible areas by carefully removing portions of the suspect paint or other material with a sharp knife or other hand tool suitable to the material being sampled. Where possible, samples of individual paint layers were collected down to the substrate. If possible, samples were collected of loose materials or from materials with pre-existing damage. Each sample was placed in a pre-labeled plastic bag immediately after collection. Data pertinent to each sample such as date, sample number, paint description and material condition was recorded on a field data sheet.

2.2.3 Polychlorinated Biphenyls

URS collected dielectric liquid samples from 48 electrical transformers, voltage regulators, and switches observed to be located in the four buildings. Samples were collected by either cracking valves located at the bottom of the units, or by removing bolt-down tops, which provide access to the fluid reservoir, and using the straw-method with a piece of dedicated poly ethylene tubing to incrementally remove a small amount of fluid from each reservoir. URS collected these samples only after the main transformer to each vault building had been de-energized and properly locked-out and tagged-out by base personnel.

2.3 Analytical Methods

The asbestos bulk samples, paint chip samples, and completed chain-of-custody sheets were delivered to EMSL’s, Orlando, Florida laboratory for analysis. This laboratory is accredited for asbestos fiber analysis through successful participation in the National Voluntary Laboratory Accreditation Program (NVLAP) for quality control procedures and meets the requirements of section 206(d) of Title II of the USC Chapter 15, TSCA as stated in 40 CFR 763 dated April 30, 1987. Each bulk sample was analyzed using polarized light microscopy (PLM)/dispersion staining techniques, in accordance with EPA Method 600/R-93/116. The results of the asbestos analyses were reported on a percentage basis. The detection limit for this type of analysis is approximately 1% (by volume). Each paint chip analysis for lead content was conducted by flame atomic absorption (FAA) spectroscopy per EPA Method SW 846 3050B/7000B. Results for the lead concentration were reported in percent by weight.

Dielectric fluid from the various electrical equipment located in the four vault buildings were delivered to the Pace Analytical Services, Inc. laboratory in Ormond Beach, Florida for analysis of PCBs by EPA Method 8082. The samples were transported by courier along with the chain-of-custody.

3.0 FINDINGS

During the assessment URS collected the following samples from the four electrical vault buildings: 20 bulk samples for asbestos analysis, 26 paint chip samples for lead analysis, and 48 dielectric fluid samples for PCB analysis. Findings for each of potentially hazardous materials tested are presented in the following sections.

3.1 Asbestos Containing Materials

Of the 20 total bulk samples collected for asbestos analysis, four were collected from building 881, six from building 766, and 23 from building 854. A total of 33 sample analyses were performed including multiple layers in some samples. No suspect ACM building materials were identified in building 114; therefore, no samples were collected for analysis. The following ACM (>1%) and PACM were identified during the survey:

1. Roof – Building 881: Flat gravel roof – brown/black

Asbestos Content: 15% Chrysotile asbestos Approximate Quantity: 250 ft2 Locations: Roof

NESHAPS Category: Category I Non-Friable ACM Physical Assessment: Undamaged

2. Roof – Building 854: Built-up flat roof – black roofing

Asbestos Content: 2 - 5% Chrysotile asbestos Approximate Quantity: 1,200 ft2 Locations: Roof

NESHAPS Category: Category I Non-Friable ACM Physical Assessment: Undamaged

3. Roof – Building 854: Built-up flat roof – black felt

Asbestos Content: 5% Chrysotile asbestos Approximate Quantity: 1,200 ft2 Locations: Roof

NESHAPS Category: Category I Non-Friable ACM Physical Assessment: Undamaged

Refer to Table 1 located at the end of this report for a Bulk Sample Summary that includes:

analytical results, building & sample numbers, HSA & material descriptions, and sample locations. Refer to Appendix A for copies of the AHERA Building Inspector and Laboratory Certifications. Refer to Appendix B for copies of the laboratory analysis report and chain-of-custody documents.

3.2 Lead Based Paint

Of the 26 total paint chip samples collected for lead analysis, three were collected from building 114, seven were collected from building 881, five from building 766, and 11 from building 854.

The U.S. Environmental Protection Agency (EPA) and the U.S. Department of Housing and Urban Development (HUD) define "lead-based paint" as having a dried paint film with a lead concentration equal to or greater than 0.5 percent lead by weight (> 0.5 %) when measured by laboratory analysis. The Occupational Safety and Health Administration (OSHA) Lead in Construction Standard defines “lead paint” as paint containing any detectable level of lead. The following paint chip samples with LBP (>0.5%) were identified during the survey:

1. Building 766: Sample 766-2B, Brown Paint

Lead Content: 2.5% Approximate Quantity: 250 ft2 Locations: Doors and windows

Physical Assessment: Undamaged

Eight additional samples contained lead at detectable concentrations but were less than 0.5% by weight. These paint samples included the interior paint (silver) and door paint (gray and brown) in building 114, the exterior walls (yellow) of building 881, and the exterior walls (yellow) and interior door (gray) of building 766. The remaining 17 samples analyzed did not contain detectable amounts of lead above the laboratory detection limit. Refer to Table 2 located at the end of this report for a Paint Chip Sample Summary that includes: analytical results, sample numbers, material descriptions, and sample locations. Refer to Appendix B for copies of the laboratory analysis report and chain-of-custody documents.

3.3 Polychlorinated Biphenyls

Of the 48 total dielectric fluid samples collected for PCB analysis, two were collected from building 114; two were collected from building 881, 19 from building 766, and 25 from building

854. Per the Toxic Substance Control Act (TSCA) - 40 CFR 761, dielectric fluid from electrical equipment is designated as “Non-PCB”, if PCB concentrations are less than 50 parts per million (ppm). Fluid and electrical equipment where the fluid concentration is greater than 50 ppm are considered PCB-materials and must be disposed of per 40 CFR 761.60 once they are declared a waste. All 48 samples analyzed during this assessment have a PCB concentration that was non-detect or below the 50 ppm, milligram per kilogram (mg/kg), Non-PCB threshold value.

However, five of the 48 dielectric samples from building 766 have a low PCB concentration between 2 ppm and 50 ppm. The five samples with low PCB concentrations include 766-PCB-2, 766-PCB-8, 766-PCB-9, 766-PCB-10, and 766-PCB-15 which have concentrations of 2.5 ppm,

10.5 ppm, 4.3 ppm, 7.1 ppm, and 24.5 ppm, respectively. Sample 766-PCB-15 was collected from a voltage regulator; the remaining four samples with low PCB concentrations were collected from their respective electrical switches.

Refer to Table 3 located at the end of this report for the Dielectric Fluid Analytical Summary that includes: sample numbers, building location, equipment type, and individual PCB compound concentration and total PCB concentrations for the nine samples that had laboratory detections.

PCB concentrations for the remaining 39 dielectric fluid samples were all below the laboratory detection limit and, therefore below 2 ppm. Refer to Appendix B for copies of the laboratory analysis report and chain-of-custody documents.

4.0 CONCLUSIONS & RECOMMENDATIONS

The Hazardous Building Materials Assessment conducted of electrical vault buildings 114, 766, 854, and 881 at the NAS- Jacksonville in Jacksonville, Florida, revealed the presence of the following hazardous materials.

1. Category I non-friable ACMs: Building 881 – brown/black Flat Gravel Roof, Building 854 – Built-up Flat Roof (Black Roofing & Black Felt); NF-1

2. Lead Based Paint: Brown paint on the doors and windows of Building 766

3. Low PCB dielectric fluid in four switches and one voltage regulator in Building 766

Based on the conclusions made, URS recommends the following:

4.1 Category I Non-friable (NF-1) ACM

As the building is scheduled for demolition, the owner has the option of removing any NF-1 ACM to minimize any potential liability and ensure full compliance with EPA and OSHA regulations.

However, the EPA will generally allow NF-1 ACM to remain in place as long as such materials remain in a non-friable state and are not subjected to mechanical drilling, sanding, abrading, grinding, or sawing during demolition activities. If the building is demolished with this type of ACM in place, there are several requirements of the building owner and demolition contractor that must be met in order to be in full compliance with the NESHAP regulation 40 CFR Part 61, these may include but are not necessarily limited to:

• Wet demolition methods must be employed to prevent any visible emissions

• 10 day notification must be submitted along with fee payment, as applicable

• The work must supervised by a person trained in the NESHAP regulation

• Warning signs and labels must be used as specified.

• The landfill must be notified that the waste contains non-friable asbestos.

In addition to the EPA requirements stated above, the owner and demolition contractor must comply with applicable OSHA regulations for Class II work as per 29 CFR 1926.1101, these may include but are not necessarily limited to:

• Use of wet methods

• Establishment of a regulated area

• Worker exposure monitoring

• Respiratory protection

• Worker training

• Use of leak-tight containers

• Use of a competent person

If the owner elects to leave the Category I non-friable asbestos in place during demolition, it is recommended that demolition oversight be performed by a Florida licensed asbestos consulting firm to help ensure compliance with the various EPA and OSHA requirements.

4.2 Lead Based Paint

Detectable amounts of lead were measured in nine of the 26 samples analyzed. Of the nine samples with detectable lead concentrations, one sample (766-2B) of brown paint that covers the doors and window trim of building 766 were above the HUD threshold of 0.5% by weight. Eight additional samples contained lead at detectable concentrations less than 0.5% by weight. These paint samples included the interior paint (silver) and door paint (gray and brown) in building 114, the exterior walls (yellow) of building 881, and the exterior walls (yellow) and interior door (gray) of building 766. The remaining 17 samples analyzed did not contain detectable amounts of lead above the laboratory detection limit. Demolition activities involving the previously identified painted surfaces that containing LBP in buildings 114, 881, and 766, should be performed in accordance with the OSHA Lead in Construction Standard 29 CFR 1926.62.

Individual LBP coated components (i.e. doors and window frames) may be removed and segregated, with the entire LBP component being disposed of properly. Toxicity Characteristic Leaching Procedure (TCLP) sampling would be needed to characterize the waste as hazardous or non-hazardous.

4.3 Polychlorinated Biphenyls

Low PCB waste, such as dielectric fluid and electrical equipment containing the dielectric fluid, which has a concentration greater than 2 ppm and less than 50 ppm, have minimal disposal requirements per TSCA, 40 CFR 761. Wastes containing less than 50 ppm PCBs must be disposed of in a responsible manner; that is they may be disposed of in a municipal waste landfill or equivalent. Specifically PCB wastes with a concentration less than 50 ppm may not be disposed of by using the PCB material in any way prohibited under 40 CFR 7601.20(d), such as road oiling, general dust control, use as a pesticide or herbicide carrier, or as rust preventative on pipes. In addition, although burning of waste oil containing any quantifiable level of PCBs is permitted, such burning is subject to the TSCA requirements in 40 CFR 761.20(e). Materials containing PCB concentrations less than 50 ppm are subject to the anti-dilution rule in 40 CFR 761.1(b).

Dielectric fluid from the four switches and one voltage regulator in building 766 (766-PCB-2, 766-PCB-8, 766-PCB-9, 766-PCB-10, and 766-PCB-15) that contain PCBs greater than 2 ppm and less than 50 ppm should be disposed of properly as indicated in the above paragraph.

Likewise, the dielectric fluid in the remaining electrical equipment should also be disposed of properly as a Non-RCRA regulated petroleum waste consistent with state and local regulations.

Non-PCB ( <50 ppm) transformers and electrical equipment are not regulated for disposal, meaning that they do not have to be incinerated or disposed of in a TSCA-approved landfill, or by an EPA alternate method.

4.4 General Asbestos Recommendations

• Additional ACM may be present in inaccessible or concealed spaces. These spaces include, but are not limited to: pipe chases, spaces between wall/ceiling/door cavities, interior of mechanical components such as boiler cavities, interior ducts, areas beneath the foundation, etc. If future maintenance/renovation/demolition activities make these areas accessible, URS recommends that a thorough assessment of these spaces be conducted at that time to identify and confirm the presence or absence of additional ACMs. Until then, all such unidentified materials should be treated as presumed ACM

(PACM).

• Subcontractors and employees working within the structures at the site should be made aware of the locations of the ACMs and the possibility of concealed suspect ACMs that could be found during renovation/demolition activities. They should be advised not to disturb the ACMs.

• For non-friable materials, when the amount of asbestos in the sample material is reported as "Non-Detect" or "Trace Asbestos" by PLM analysis, due to the difficulty in analyzing "small, thin fibers" associated with vinyl/asphalt or resinously bound materials, URS recommends that these types of materials, which were reported as non-ACMs by PLM, be analyzed using TEM Chatfield.

• When demolition by toppling occurs, adequate wetting shall be employed to suppress the dust and reasonable enclosures for dust emission control (as compatible with the building character) shall be employed.

• Category I non-friable ACM waste debris generated during demolition can be generally disposed off-site in a landfill that accepts asbestos-containing demolition/construction debris wastes within the framework of local/state regulations. It is recommended that the demolition contractor and/or waste hauler verify with the local landfills about their policies on accepting such wastes prior to planning the demolition work.

• Category I non-friable ACM debris mixed with demolition debris should not be used as fill material on-site nor should it be sold or given away to others for the same use.

• If the substrate (such as concrete) on which these Category I non-friable ACMs are installed is intended for recycling, the non-friable ACMs shall be removed prior to the recycling process by a state-licensed asbestos abatement contractor prior to initiating substrate recycling activities.

• If the demolition contractor changes the means and methods of demolition and the environmental consultant is of the opinion that the Category I non-friable materials are being made friable, or if visible dust emissions are generated, the work should be stopped. In these situations, revised notification for removal of non-friable ACM may become necessary and the removal work will then need to be done by a State of Florida licensed abatement contractor.

• The proper notification shall be submitted to the Northwest District of the Florida

Department of Environmental Protection and local agency prior to building demolition or renovation involving ACM in excess of the threshold amounts.

5.0 REFERENCES

1. U.S. Environmental Protection Agency (EPA): Asbestos Hazard Emergency Response Act (AHERA), 40 CFR, Part 763.

2. U.S. Environmental Protection Agency (EPA): Asbestos School Hazard Abatement

Reauthorization Act (ASHARA), U.S. Code Title 15, Chapter 53, Subchapter II-2641 through 2656.

3. U.S. Environmental Protection Agency (EPA): National Emission Standards for

Hazardous Air Pollutants (NESHAP). Asbestos, 40 CFR, Part 61, November 20, 1990.

4. U.S. Environmental Protection Agency (EPA): Toxic Substance Control (Act), 40 CFR, Part 761.

5. Florida Statutes Chapter 469 Asbestos Abatement.

6. Florida Statutes Chapter 62—257.

7. Rule Chapter 61E1, Florida Administrative Code.

TABLES

Table 1

Suspect ACM – Bulk Sample Summary

NAS JAX

Airfield Lighting Electrical Vault Buildings

Bldg.

Sample # HSA Description Sample

Location

Asbestos Content

Approx.

Quantity (sf, lf)

881 881-10A Flat Gravel Roof – Brown/Black Southwest corner of Roof 15 250 sf

881 881-10B Flat Gravel Roof – Brown/Black West Side of Roof 15 250 sf 881 881-10C Flat Gravel Roof – Black Center of Roof NAD 250 sf 881 881-11A Vibration Cloth – Tan/White Emergency Generator NAD 10 sf 766 766-10A Flat Roof – Black Roofing South side of Roof NAD 1,000 sf 766 766-10A Flat Roof – Brown Insulation South side of Roof NAD 1,000 sf 766 766-10B Flat Roof – Gray/Black Roofing East side of Roof NAD 1,000 sf 766 766-10B Flat Roof – Brown Insulation East side of Roof NAD 1,000 sf 766 766-10C Flat Roof – Black Roofing West side of Roof NAD 1,000 sf 766 766-10C Flat Roof – Brown Insulation West side of Roof NAD 1,000 sf

854 854-10A Built-up Flat Roof – White/Black Shingle East side of Roof NAD 1,200 sf

854 854-10A Built-up Flat Roof – Tan/Black Shingle

East side of Roof NAD 1,200 sf

854 854-10A Built-up Flat Roof – Black Mastic East side of Roof NAD 1,200 sf 854 854-10A Built-up Flat Roof – Gray/Black

Shingle East side of Roof NAD 1,200 sf

854 854-10A Built-up Flat Roof – Black Roofing East side of Roof 5 1,200 sf 854 854-10B Built-up Flat Roof – Gray/Black

Shingle Center of Roof NAD 1,200 sf

854 854-10B Built-up Flat Roof – Black Mastic Center of Roof NAD 1,200 sf 854 854-10B Built-up Flat Roof – Black Roofing Center of Roof NAD 1,200 sf 854 854-10B Built-up Flat Roof – Brown Insulation Center of Roof NAD 1,200 sf 854 854-10C Built-up Flat Roof – Gray/Black

Tar/Gravel Northwest side of roof NAD 1,200 sf

854 854-10C Built-up Flat Roof – Black Shingle Northwest side of roof NAD 1,200 sf 854 854-10C Built-up Flat Roof – Black Felt Northwest side of roof 5 1,200 sf 854 854-10C Built-up Flat Roof – Black Roofing Northwest side of roof 2 1,200 sf 854 854-11A Vertical Pipe Cloth Emergency Generator NAD 12 lf 854 854-12A Vertical Pipe Insulation – Tan Emergency Generator NAD 12 lf 854 854-13A Pipe Jacket Cloth – White Emergency Generator NAD 5 lf 854 854-14A Pipe Jacket Insulation – White Emergency Generator NAD 5 lf 854 854-15A Muffler Cloth – White Emergency Generator NAD 30 sf 854 854-16A Muffler Insulation – Gray Emergency Generator NAD 30 sf 854 854-17A Vibration Cloth - Black Emergency Generator NAD 10 sf 854 854-18A Interior Ceiling – Brown/White Center of Ceiling NAD 1,200 sf 854 854-18B Interior Ceiling – Brown/White Center of Ceiling NAD 1,200 sf 854 854-18C Interior Ceiling – Brown/White West side of Ceiling NAD 1,200 sf

Key: NAD = No Asbestos Detected; HSA =Homogeneous Sample Area Positive results (> 1%) shown in bold; sf = square feet, lf = linear feet

Table 2

Paint Chip Sample Summary

NAS JAX

Airfield Lighting Electrical Vault Buildings

Bldg.

Sample # Paint Sample Description Sample Location

Lead Concentrati on (% weight)

Approx.

Quantity

(sf) 114 114-1A Walls and Ceiling – Silver North wall – Interior 0.19 200 sf 114 114-1B Walls and Ceiling – Silver North wall – Interior 0.21 200 sf

114 114-2A Door – 2 layers: Top – Gray;

Bottom – Brown Door 0.040 40 sf

881 881-1A Walls – Yellow East wall – Exterior 0.024 640 sf 881 881-1B Walls – Yellow North wall – Exterior 0.013 640 sf 881 881-2A Walls and Ceiling - Gray North wall – Interior <0.010 880 sf 881 881-2B Walls and Ceiling - Gray South wall – Interior <0.016 880 sf 881 881-3A Doors and Windows - Brown East window – Exterior <0.063 60 sf 881 881-3B Doors and Windows - Brown South door – Exterior 0.063 60 sf 881 881-4A Walls – Bottom layer - Blue North wall – Exterior <0.029 640 sf 766 766-1A Walls – Yellow North wall – Exterior 0.012 1,500 sf 766 766-1B Walls – Yellow East wall – Exterior <0.010 1,500 sf 766 766-2A Doors and Windows - Brown South door 0.014 250 sf 766 766-2B Doors and Windows - Brown North door 2.5 250 sf 766 766-3A Interior Door – Gray Interior Door 0.32 40 sf 854 854-1A Walls – Yellow North wall – Exterior <0.015 1,600 sf 854 854-1B Walls – Yellow East wall – Exterior <0.010 1,600 sf 854 854-1C Walls – Yellow South wall – Exterior <0.010 1,600 sf 854 854-1D Walls – Yellow West wall – Exterior <0.010 1,600 sf 854 854-2A Walls – White East wall – Interior <0.010 1,800 sf 854 854-2B Walls – White South wall – Interior <0.010 1,800 sf 854 854-2C Walls – White West wall – Interior <0.010 1,800 sf 854 854-2D Walls – White South wall – Interior <0.010 1,800 sf 854 854-3A Doors – Gray North door <0.010 150 sf 854 854-3B Doors – Gray West door <0.030 150 sf 854 854-4A Interior Door – Yellow Interior door <0.010 40 sf

Key

< = Result signifies that the analyte was not detected at or above the reporting limit Positive results (> 0.5% weight) shown in bold, (> detection limit) shown in italic.

sf = square feet

FIGURES

APPENDIX A

INSPECTOR & LABORATORY ACCREDITATIONS

APPENDIX B

ANALYTICAL REPORT and CHAIN-OF-CUSTODY RECORDS

EMSL Analytical, Inc.

5125 Adanson Street, Suite 900, Orlando, FL 32804 Phone/Fax: (407) 599-5887 / (407) 599-9063 http://www.emsl.com orlandolab@emsl.com

341206158 CustomerID: DAME76 CustomerPO:

ProjectID:

EMSL Order:

Attn: Graham Hayes URS Corporation 4168 Southpoint Pkwy Suite 205 Jacksonville, FL 32216

Received: 08/09/12 9:38 AM

NAS Jax/12010717

Fax: (904) 645-6243 Phone: (904) 645-6233

Project:

8/16/2012Analysis Date:

8/8/2012Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 and/or EPA 600/M4-82-020 Method(s) using Polarized Light Microscopy

881-10A

341206158-0001

Bldg. 881 - Flat Gravel Roof

Brown/Black Fibrous Heterogeneous

Chrysotile15%Non-fibrous (other)65% Ca Carbonate20%

881-10B

341206158-0002

Bldg. 881 - Flat Gravel Roof

Brown/Black Fibrous Heterogeneous

Chrysotile15%Cellulose20% Non-fibrous (other)65%

881-10C

341206158-0003

Bldg. 881 - Flat Gravel Roof

Black None Detected Fibrous Heterogeneous

Cellulose15% Non-fibrous (other)85%

881-11A

341206158-0004

Bldg. 881 - Vibration Cloth For Emer. Gen.

Tan/White None Detected Fibrous Heterogeneous

Glass30% Non-fibrous (other)70%

766-10A-Roofing

341206158-0005

Bldg. 766 - Flat Roof

Black None Detected Non-Fibrous Heterogeneous

Non-fibrous (other)100%

766-10A-Insulation

341206158-0005A

Bldg. 766 - Flat Roof

Brown None Detected Fibrous Heterogeneous

Cellulose85% Non-fibrous (other)15%

766-10B-Roofing

341206158-0006

Bldg. 766 - Flat Roof

Gray/Black None Detected Non-Fibrous Heterogeneous

Non-fibrous (other)100%

766-10B-Insulation

341206158-0006A

Bldg. 766 - Flat Roof

Brown None Detected Fibrous Heterogeneous

Cellulose85% Non-fibrous (other)15%

1Test Report PLM-7.16.0 Printed: 8/22/2012 10:12:27 AM

Jonathan Teda, Asbestos Lab Manager or other approved signatory

Analyst(s)

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. Orlando, FL NVLAP Lab Code 101151-0

Initial report from 08/16/2012 10:35:06

Jonathan Teda (33) http://www.emsl.com mailto:orlandolab@emsl.com

Phone/Fax: (407) 599-5887 / (407) 599-9063 http://www.emsl.com orlandolab@emsl.com

341206158 CustomerID: DAME76 CustomerPO:

ProjectID:

EMSL Order:

Attn: Graham Hayes URS Corporation 4168 Southpoint Pkwy Suite 205 Jacksonville, FL 32216

Received: 08/09/12 9:38 AM

NAS Jax/12010717

Fax: (904) 645-6243 Phone: (904) 645-6233

Project:

8/16/2012Analysis Date:

8/8/2012Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 and/or EPA 600/M4-82-020 Method(s) using Polarized Light Microscopy

766-10C-Roofing

341206158-0007

Bldg. 766 - Flat Roof

Black None Detected Non-Fibrous Heterogeneous

Non-fibrous (other)100%

766-10C-Insulation

341206158-0007A

Bldg. 766 - Flat Roof

Brown None Detected Fibrous Heterogeneous

Cellulose85% Non-fibrous (other)15%

854-10A-White Shingle 341206158-0008

Bldg. 854 - Built- Up Flat Roof

White/Black None Detected Fibrous

Heterogeneous

Glass10% Non-fibrous (other)90%

854-10A-Tan Shingle 341206158-0008A

Bldg. 854 - Built- Up Flat Roof

Tan/Black None Detected Fibrous

Heterogeneous

Glass15% Non-fibrous (other)85%

854-10A-Mastic

341206158-0008B

Bldg. 854 - Built- Up Flat Roof

Black None Detected Non-Fibrous Heterogeneous

Cellulose10% Non-fibrous (other)90%

854-10A-Gray Shingle 341206158-0008C

Bldg. 854 - Built- Up Flat Roof

Gray/Black None Detected Fibrous

Heterogeneous

Glass15% Non-fibrous (other)85%

854-10A-Roofing

341206158-0008D

Bldg. 854 - Built- Up Flat Roof

Black Fibrous Heterogeneous

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

2Test Report PLM-7.16.0 Printed: 8/22/2012 10:12:27 AM

Jonathan Teda, Asbestos Lab Manager or other approved signatory

Analyst(s)

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. Orlando, FL NVLAP Lab Code 101151-0

Initial report from 08/16/2012 10:35:06

Jonathan Teda (33)

Phone/Fax: (407) 599-5887 / (407) 599-9063 http://www.emsl.com orlandolab@emsl.com

341206158 CustomerID: DAME76 CustomerPO:

ProjectID:

EMSL Order:

Attn: Graham Hayes URS Corporation 4168 Southpoint Pkwy Suite 205 Jacksonville, FL 32216

Received: 08/09/12 9:38 AM

NAS Jax/12010717

Fax: (904) 645-6243 Phone: (904) 645-6233

Project:

8/16/2012Analysis Date:

8/8/2012Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 and/or EPA 600/M4-82-020 Method(s) using Polarized Light Microscopy

854-10B-Shingle

341206158-0009

Bldg. 854 - Built- Up Flat Roof

Gray/Black None Detected Fibrous Heterogeneous

Glass15% Non-fibrous (other)85%

854-10B-Mastic

341206158-0009A

Bldg. 854 - Built- Up Flat Roof

Black None Detected Non-Fibrous Heterogeneous

Non-fibrous (other)100%

854-10B-Roofing

341206158-0009B

Bldg. 854 - Built- Up Flat Roof

Black None Detected Fibrous Heterogeneous

Glass10% Non-fibrous (other)90%

854-10B-Insulation

341206158-0009C

Bldg. 854 - Built- Up Flat Roof

Brown None Detected Fibrous Heterogeneous

Cellulose60% Non-fibrous (other)20% Perlite20%

854-10C-Tar/Gravel

341206158-0010

Bldg. 854 - Built- Up Flat Roof

Gray/Black None Detected Non-Fibrous Heterogeneous

Cellulose2% Non-fibrous (other)98%

854-10C-Shingle

341206158-0010A

Bldg. 854 - Built- Up Flat Roof

Black None Detected Fibrous Heterogeneous

Glass15% Non-fibrous (other)85%

854-10C-Felt

341206158-0010B

Bldg. 854 - Built- Up Flat Roof

Black Fibrous Heterogeneous

Chrysotile5%Glass20% Non-fibrous (other)75%

854-10C-Roofing

341206158-0010C

Bldg. 854 - Built- Up Flat Roof

Black Fibrous Heterogeneous

Chrysotile2%Cellulose5% Glass5%

Non-fibrous (other)88%

3Test Report PLM-7.16.0 Printed: 8/22/2012 10:12:27 AM

Jonathan Teda, Asbestos Lab Manager or other approved signatory

Analyst(s)

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. Orlando, FL NVLAP Lab Code 101151-0

Initial report from 08/16/2012 10:35:06

Jonathan Teda (33)

Phone/Fax: (407) 599-5887 / (407) 599-9063 http://www.emsl.com orlandolab@emsl.com

341206158 CustomerID: DAME76 CustomerPO:

ProjectID:

EMSL Order:

Attn: Graham Hayes URS Corporation 4168 Southpoint Pkwy Suite 205 Jacksonville, FL 32216

Received: 08/09/12 9:38 AM

NAS Jax/12010717

Fax: (904) 645-6243 Phone: (904) 645-6233

Project:

8/16/2012Analysis Date:

8/8/2012Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 and/or EPA 600/M4-82-020 Method(s) using Polarized Light Microscopy

854-11A

341206158-0011

Bldg. 854 - Emergency Generator-Vert.

Pipe Cloth

Various None Detected Fibrous Heterogeneous

Glass20% Non-fibrous (other)80%

854-12A

341206158-0012

Bldg. 854 - Emergency Generator-Vert.

Pipe Insulation

Tan None Detected Fibrous Heterogeneous

Cellulose5% Glass2%

Non-fibrous (other)93%

854-13A

341206158-0013

Bldg. 854 - Emergency Generator-Pipe Jacket Cloth

White None Detected Fibrous Heterogeneous

Glass40% Non-fibrous (other)60%

854-14A

341206158-0014

Bldg. 854 - Emergency Generator-Pipe Jacket Insulation

White None Detected Fibrous Heterogeneous

Glass98% Non-fibrous (other)2%

854-15A

341206158-0015

Bldg. 854 - Emergency Generator-Muffler Cloth

White None Detected Fibrous Heterogeneous

Glass40% Non-fibrous (other)60%

854-16A

341206158-0016

Bldg. 854 - Emergency Generator-Muffler Insulation

Gray None Detected Fibrous Heterogeneous

Glass5% Non-fibrous (other)85% Ca Carbonate10%

854-17A

341206158-0017

Bldg. 854 - Emergency Generator- Vibration Cloth

Black None Detected Fibrous Heterogeneous

Glass50% Non-fibrous (other)50%

4Test Report PLM-7.16.0 Printed: 8/22/2012 10:12:27 AM

Jonathan Teda, Asbestos Lab Manager or other approved signatory

Analyst(s)

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. Orlando, FL NVLAP Lab Code 101151-0

Initial report from 08/16/2012 10:35:06

Jonathan Teda (33)

Phone/Fax: (407) 599-5887 / (407) 599-9063 http://www.emsl.com orlandolab@emsl.com

341206158 CustomerID: DAME76 CustomerPO:

ProjectID:

EMSL Order:

Attn: Graham Hayes URS Corporation 4168 Southpoint Pkwy Suite 205 Jacksonville, FL 32216

Received: 08/09/12 9:38 AM

NAS Jax/12010717

Fax: (904) 645-6243 Phone: (904) 645-6233

Project:

8/16/2012Analysis Date:

8/8/2012Collected:

Sample Description Appearance % Type

Asbestos…