04_Appendix D_Hazardous Material Survey.pdf

DRAFT FINAL ASBESTOS-CONTAINING MATERIALS SURVEY, LEAD-BASED

PAINT

SURVEY, HAZARDOUS MATERIAL ASSESSMENT AND WASTE

CHARACTERIZATION

FY25 MCON PROJECT P-683

FIELD ENGINEERING SERVICES FOR ENGINE REPAIR FACILITY

BUILDINGS 4, 6F, 6G, 7H, AND 12

NAVAL AIR STATION JACKSONVILLE

JACKSONVILLE, DUVAL COUNTY, FLORIDA

A/E CONTRACT NUMBER N69450-21-D-0003

TASK ORDER NUMBER N6945022F0376

PREPARED FOR:

Merrick-RS&H Joint Venture, LLP

PREPARED BY:

Aerostar SES LLC 3550 St. Johns Bluff Road South

Jacksonville, Florida 32224

(904) 565-2820

ASL Project # M3010.1801.0006.17

August 22, 2022

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

This is to certify that the Draft Final Report for the Asbestos-Containing Materials Survey, Lead-Based Paint Survey, Hazardous Material Assessment, and Waste Characterization Field Engineering Services for the Engine Repair Facility, Buildings 4, 6F, 6G, 7H, and 12, located at Naval Air Station Jacksonville, Jacksonville, Duval County, Florida, has been examined by the undersigned.

DATE: August 22, 2022 SIGNATURE:

Patrick McCarthy Aerostar SES LLC AHERA Inspector Certification No. D8I9R7QLXX US EPA Risk Assessor Certification No. LBP-R-917-2

John Flanagan Aerostar SES LLC AHERA Inspector Certification No. H647W81QRB US EPA Risk Assessor Certification No. LBP-R-I208414-1

John H. Hubbard Jr., CIH, LAC, CSP

Aerostar SES LLC Senior Program Manager

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page i

TABLE OF CONTENTS

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

LIST OF ACRONYMS AND ABBREVIATIONS ................................................................... iv

1.0 EXECUTIVE SUMMARY

1.1 Site Name

1.2 Name and Certifications of Inspectors

1.3 Site Description and Activities

1.4 Findings and Results

1.5 Handling and Disposal of Identified Materials

2.0 INTRODUCTION

2.1 Building Descriptions

3.0 REGULATORY SUMMARY

3.1 Asbestos

3.1.1 Environmental Protection Agency

3.1.2 Occupational Safety and Health Administration

3.1.3 State of Florida

3.2 Lead-Based Paint

3.2.1 Environmental Protection Agency

3.2.2 Occupational Safety and Health Administration

3.2.3 U.S. Department of Housing and Urban Development

3.2.4 State of Florida

3.3 RCRA Metals

3.3.1 Occupational Safety and Health Administration

3.4 Hazardous Materials

3.4.1 Environmental Protection Agency

3.4.2 United States Department of Transportation

3.4.3 State of Florida

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

4.2 Lead-Based Paint Survey

4.3 Hazardous Materials Survey

4.4 Waste Characterization

5.0 RESULTS

5.1 Asbestos Survey Results

5.2 Lead-Based Paint Survey Results

5.3 Hazardous Materials Survey Results

5.4 Waste Characterization Results

6.0 LIMITATIONS

7.0 CONCLUSIONS

7.1 Asbestos-Containing Materials

7.2 Lead-Based Paint

7.3 Hazardous Materials

7.4 Waste Characterization

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page ii

TABLES

TABLE 1-1 Summary of Asbestos Survey – Building 4 TABLE 1-2 Summary of Asbestos Survey – Building 6F TABLE 1-3 Summary of Asbestos Survey – Building 6G TABLE 1-4 Summary of Asbestos Survey – Building 7H TABLE 1-5 Summary of Asbestos Survey – Building 12 TABLE 2-1 Summary of XRF Survey – Building 4 TABLE 2-2 Summary of XRF Survey – Building 6F TABLE 2-3 Summary of XRF Survey – Building 6G TABLE 2-4 Summary of XRF Survey – Building 7H TABLE 2-5 Summary of XRF Survey – Building 12 TABLE 3 Summary of Metal-Based Coatings Sample Results TABLE 4-1 Summary of Hazardous Materials Survey – Building 4 TABLE 4-2 Summary of Hazardous Materials Survey – Building 6F TABLE 4-3 Summary of Hazardous Materials Survey – Building 6G TABLE 4-4 Summary of Hazardous Materials Survey – Building 7H TABLE 4-5 Summary of Hazardous Materials Survey – Building 12 TABLE 5 Summary of TCLP Sample Results

FIGURES

FIGURE 1-1 Building 4 – Homogeneous Area Sample Locations – Northwest Corner FIGURE 1-2 Building 4 – Homogeneous Area Sample Locations – Northeast Corner FIGURE 1-3 Building 4 – Homogeneous Area Sample Locations – South FIGURE 1-4 Building 4 – Homogeneous Area Sample Locations – Roof FIGURE 1-5 Building 4 – Asbestos-Containing Materials Locations – Northwest Corner FIGURE 1-6 Building 4 – Asbestos-Containing Materials Locations – Northeast Corner FIGURE 1-7 Building 4 – Asbestos-Containing Materials Locations – South FIGURE 1-8 Building 4 – Asbestos-Containing Materials Locations – Roof FIGURE 1-9 Building 4 – XRF and MBC Paint Chip Sample Locations – Northwest

Corner FIGURE 1-10 Building 4 – XRF Sample Locations – Northeast Corner FIGURE 1-11 Building 4 – XRF and MBC Paint Chip Sample Locations – South FIGURE 1-12 Building 4 – XRF Sample Locations – Roof FIGURE 1-13 Building 4 – Hazardous Materials Locations – Northwest Corner FIGURE 1-14 Building 4 – Hazardous Materials Locations – Northeast Corner FIGURE 1-15 Building 4 – Hazardous Materials Locations – South FIGURE 2-1 Building 6F – Homogeneous Area Sample Locations – First and Second

Floors FIGURE 2-2 Building 6F – Homogeneous Area Sample Locations – Roof FIGURE 2-3 Building 6F – Asbestos-Containing Materials Locations – First and Second

Floors FIGURE 2-4 Building 6F – Asbestos-Containing Materials Locations – Roof FIGURE 2-5 Building 6F – XRF and MBC Paint Chip Sample Locations – First and

Second Floors

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page iii

FIGURE 2-6 Building 6F – Hazardous Materials Locations – First and Second Floors FIGURE 2-7 Building 6F – Hazardous Materials Locations – Roof FIGURE 3-1 Building 6G – Homogeneous Area Sample Locations – First and Second

Floors FIGURE 3-2 Building 6G – Homogeneous Area Sample Locations – Roof FIGURE 3-3 Building 6G – Asbestos-Containing Materials Locations – First and Second

Floors FIGURE 3-4 Building 6G – Asbestos-Containing Materials Locations – Roof FIGURE 3-5 Building 6G – XRF and MBC Paint Chip Sample Locations – First and

Second Floors FIGURE 3-6 Building 6G – Hazardous Materials Locations – First and Second Floors FIGURE 3-7 Building 6G – Hazardous Materials Locations – Roof FIGURE 4-1 Building 7H – Homogeneous Area Sample Locations – First and Second

Floors FIGURE 4-2 Building 7H – Homogeneous Area Sample Locations – Roof FIGURE 4-3 Building 7H – Asbestos-Containing Materials Locations – First and Second

Floors FIGURE 4-4 Building 7H – Asbestos-Containing Materials Locations – Roof FIGURE 4-5 Building 7H – XRF and MBC Paint Chip Sample Locations – First and

Second Floors FIGURE 4-6 Building 7H – Hazardous Materials Locations – First and Second Floors FIGURE 5-1 Building 12 – Homogeneous Area Sample Locations – First Floor FIGURE 5-2 Building 12 – Homogeneous Area Sample Locations – Roof FIGURE 5-3 Building 12 – Asbestos-Containing Materials Locations – First Floor FIGURE 5-4 Building 12 – Asbestos-Containing Materials Locations – Roof FIGURE 5-5 Building 12 – XRF and MBC Paint Chip Sample Locations – First Floor FIGURE 5-6 Building 12 – Hazardous Materials Locations – First Floor

APPENDICES

APPENDIX A Certifications APPENDIX B Laboratory Analytical Results APPENDIX C Asbestos Photographic Documentation APPENDIX D Lead-Based Paint and Metal-Based Coatings Photographic Documentation APPENDIX E Hazardous Materials Photographic Documentation

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LIST OF ACRONYMS AND ABBREVIATIONS

ACM Asbestos-Containing Materials AHERA Asbestos Hazard Emergency Response Act ASL Aerostar SES LLC C&D Construction and Demolition CAA Clean Air Act of 1990 CFC Chlorofluorocarbon CFR Code of Federal Regulations CVAA Cold Vapor Atomic Absorption DBPR Department of Business and Professional Regulation DOT Department of Transportation ELLAP Environmental Lead Laboratory Accreditation Program EMSL EMSL Analytical, Inc.

EPA Environmental Protection Agency FLEHaz Florida Electronic Hazardous Waste Regulations HAs Homogeneous Areas HCFC Hydrochlorofluorocarbon HEPA High Efficiency Particulate Air HID High-Intensity Discharge HMTA Hazardous Materials Transportation Act HUD U.S. Department of Housing and Urban Development HVAC Heating, Ventilation, and Air Conditioning ICP Inductively Coupled Plasma LAC Licensed Asbestos Consultant LBP Lead-Based Paint LED Light-Emitting Diode MBC Metal-Based Coatings mg/cm2 Milligrams per centimeter squared NAS Naval Air Station NESHAP National Emission Standards for Hazardous Air Pollutants NiCad Nickel-Cadmium NIST National Institute of Standards and Technology NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration Pbc Lead Corrected PCB Polychlorinated Biphenyl PHMSA Pipeline and Hazardous Materials Safety Administration PLM Polarized Light Microscopy RACM Regulated Asbestos-Containing Material RCRA Resource Conservation and Recovery Act RSPA Research and Special Provisions Administration SCT Suspended Ceiling Tile SDS Safety Data Sheet TCLP Toxicity Characteristic Leaching Procedure TPO Thermoplastic Polyolefin TSCA Toxic Substances Control Act TSI Thermal System Insulation U.S.C. United States Code VCB Vinyl Cove Base VFT Vinyl Floor Tile XRF X-Ray Fluorescence % wt. Percent by Weight

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1.0 EXECUTIVE SUMMARY

1.1 Site Name

FY25 MCON Project P-683 Field Engineering Services for Engine Repair Facility Buildings 4, 6F, 6G, 7H, and 12 Naval Air Station Jacksonville Jacksonville, Duval County, Florida A/E Contract Number N69450-21-D-0003 Task Order Number N6945022F0376

1.2 Name and Certifications of Inspectors

John Flanagan Patrick McCarthy AHERA Asbestos Inspector AHERA Asbestos Inspector Certificate No. H647W81QRB Certificate No. D8I9R7QLXX EPA Risk Assessor EPA Risk Assessor Certificate No. LBP-R-I208414-1 Certificate No. LBP-R-917-2

Jessica Gibson AHERA Asbestos Inspector Certificate No. EU3YQDUYAS EPA Lead Inspector Certificate No. LBP-I-I195542-2

1.3 Site Description and Activities

Between May 16 and June 28, 2022, Aerostar SES LLC (ASL) conducted an Asbestos-Containing Materials (ACM) Survey, Lead-Based Paint (LBP) Survey, Hazardous Materials Assessment, and Waste Characterization Field Engineering Services for Engine Repair Facility, Buildings 4, 6F, 6G, 7H, and 12, located at Naval Air Station (NAS) Jacksonville, Jacksonville, Duval County, Florida. The surveys included all accessible areas throughout the buildings’ exterior and interior.

The buildings were assessed for potential demolition.

Asbestos Hazard Emergency Response Act (AHERA)-Certified Asbestos Inspectors conducted an asbestos survey to identify the locations, quantities, and conditions of ACMs.

Environmental Protection Agency (EPA)-licensed Inspector/Risk Assessors conducted an LBP survey using an X-Ray Fluorescence (XRF) portable spectrum analyzer to identify coatings considered to be LBP. Metal-Based Coatings (MBC) samples were collected from surfaces which may be subject to torch cutting, grinding, abrasive blasting, or other processes which may create a dust hazard during demolition.

ASL inspected light fixtures, thermostats, and other building components and systems throughout the building to evaluate for the presence of, and inventory, hazardous materials which may require special handling.

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Building materials to be demolished and disposed of during demolition were sampled from the buildings to represent the anticipated waste streams and determine proper disposal. Samples were analyzed for 8 Resource Conservation and Recovery Act (RCRA) metals after extraction by the Toxicity Characteristic Leaching Procedure (TCLP) in accordance with the provisions of 40 Code of Federal Regulation (CFR) 261, Subpart C.

1.4 Findings and Results

The following tables summarize the findings throughout the buildings and identifies materials requiring special handling:

Building Friable

ACM

Non-friable Category I

ACM

Non-friable Category II

ACM

Material Containing

<1% Asbestos

LBP

≥1.0 mg/cm2

Hazardous Material

Hazardous Waste for

8 RCRA

by TCLP

4 Yes* Yes* Yes* No Yes† Yes** No

6F No Yes* No No Yes† Yes** No

6G No Yes* No No Yes† Yes** No

7H No Yes* No No Yes† Yes** No

12 No No Yes* No Yes† Yes** No

* Materials must be handled in accordance with EPA Standard 40 CFR 61 Subpart M and OSHA 29 CFR 1926.1101 ** Material must be handled in accordance with applicable sections of EPA Standards 40 CFR 260-299 or 40 CFR 761 † Lead concentrations were also detected <1.0 mg/cm2 which must be handled in accordance with OSHA Standard 29 CFR 1926.62

Building Arsenic Barium Cadmium Chromium Lead Selenium Silver Mercury

4 Yes†† Yes†† Yes†† Yes†† Yes† No Yes†† Yes††

6F No No Yes†† Yes†† Yes† No No No

6G No Yes†† Yes†† Yes†† Yes† No No Yes††

7H No No No Yes†† Yes† No No No

12 No Yes†† Yes†† Yes†† Yes† No Yes†† Yes††

† Lead concentrations above threshold were detected and must be handled in accordance with OSHA Standard 29 CFR 1926.62 †† Must be handled in accordance with applicable OSHA standards

Building 4

A total of 59 homogeneous areas (HAs) were identified and sampled throughout Building 4. The laboratory separated layered materials and analyzed each layer as a single material. Analytical results revealed that 17 of the 86 materials analyzed were found to contain greater than 1% asbestos by Polarized Light Microscopy (PLM), which includes Thermal System Insulation (TSI), window glaze, furring strip mastic, paneling mastic, Vinyl Floor Tiles (VFT), VFT mastic, pipe insulation, pipe insulation mastic, insulation covers, Vinyl Cove Base (VCB) mastic, and caulks. Two HAs were not sampled due to the systems being energized and operational or inaccessible and are assumed to contain asbestos, which includes ceiling mastic and gaskets.

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Lead concentrations equal to or greater than 1.0 milligrams per square centimeter (mg/cm2) were identified on 29 components, which includes metal beams, a wood deck, wood doors, metal door frames, wood door frames, metal door jambs, a metal hatch door, a metal hatch door frame, a metal pipe, metal rails, concrete walls, a plaster wall, a metal window, and a metal steam line footer.

A total of seven MBC samples were collected from paints and coatings for laboratory analysis by Inductively Coupled Plasma (ICP) or by Cold Vapor Atomic Absorption (CVAA) for the 8 RCRA metals. Analytical results revealed detectable concentrations of at least one RCRA metal above the laboratory reporting limit was found in all samples collected by ICP or CVAA, which includes a brown metal pipe, a gray metal pipe, a beige metal pipe, a white metal support, a brown metal stair rail, a brown metal rail, and a gray metal door frame.

Identified building components which require special handling included fluorescent bulbs; High- Intensity Discharge (HID) bulbs; exit signs and emergency light fixtures which contain Nickel- Cadmium (NiCad) or lead-acid back-up batteries; a thermostat assumed to contain mercury; and Heating, Ventilation, and Air Conditioning (HVAC) systems that contain R124A, R-22 or R410A, HFC-410A, and unknown refrigerants.

One composite sample of the anticipated waste stream was collected and analyzed to determine if the waste stream would be considered hazardous waste. The composite sample included concrete, concrete block, acoustic ceiling tile, gypsum board, VFT, VCB, plaster, and stucco. Based on the waste characterization analytical results of the composite sample for the building, construction debris generated by demolition or renovation activities which is comprised of the materials included in the sample may be disposed of as non-hazardous waste.

Building 6F

A total of 18 HAs were identified and sampled throughout Building 6F. The laboratory separated layered materials and analyzed each layer as a single material. Analytical results revealed that one of the 26 materials analyzed was found to contain greater than 1% asbestos by PLM, which includes flashing.

Lead concentrations equal to or greater than 1.0 mg/cm2 were identified on 13 components, which includes a metal beam, concrete walls, and stucco walls.

One MBC sample was collected from paints and coatings for laboratory analysis by ICP or by CVAA for the 8 RCRA metals. Analytical results revealed detectable concentrations of at least one RCRA metal above the laboratory reporting limit was found in the sample collected by ICP or CVAA, which includes a green metal rail.

Identified building components which require special handling included fluorescent bulbs;

fluorescent light ballasts; exit signs which may contain NiCad back-up batteries; HVAC systems that contain unknown, R-22 or R410A refrigerants; and lead-lined roof vents.

One composite sample of the anticipated waste stream was collected and analyzed to determine if the waste stream would be considered hazardous waste. The composite sample included concrete, concrete block, acoustic ceiling tile, gypsum board, VFT, and VCB. Based on the waste

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Building 6G

A total of 18 HAs were identified and sampled throughout Building 6G. The laboratory separated layered materials and analyzed each layer as a single material. Analytical results revealed that one of the 27 materials analyzed was found to contain greater than 1% asbestos by PLM, which includes flashing.

Lead concentrations equal to or greater than 1.0 mg/cm2 were identified on 11 components, which includes a metal walkway beam, concrete walls, and stucco walls.

A total of two MBC samples were collected from paints and coatings for laboratory analysis by ICP or by CVAA for the 8 RCRA metals. Analytical results revealed detectable concentrations of at least one RCRA metal above the laboratory reporting limit was found in both samples collected by ICP or CVAA, which includes a green metal rail and a brown metal beam.

Identified building components which require special handling included fluorescent bulbs;

fluorescent light ballasts; exit signs and emergency light fixtures which may contain NiCad back-up batteries; HVAC systems that contain R134A and HCFC-22 refrigerants; and lead-lined roof vents.

One composite sample of the anticipated waste stream was collected and analyzed to determine if the waste stream would be considered hazardous waste. The composite sample included concrete, concrete block, acoustic ceiling tile, gypsum board, VFT, and VCB. Based on the waste characterization analytical results of the composite sample for the building, construction debris generated by demolition or renovation activities may be disposed of as non-hazardous waste.

Building 7H

A total of 26 HAs were identified and sampled throughout Building 7H. The laboratory separated layered materials and analyzed each layer as a single material. Analytical results revealed that none of the 36 materials analyzed were found to contain greater than 1% asbestos by PLM. One HA was not sampled due to the systems being energized and operational and is assumed to contain asbestos, which includes gaskets.

Lead concentrations equal to or greater than 1.0 mg/cm2 were identified on 38 components, which includes a concrete ceiling, concrete columns, concrete overhangs, and concrete walls.

One MBC sample was collected from paints and coatings for laboratory analysis by ICP or by CVAA for the 8 RCRA metals. Analytical results revealed detectable concentrations of at least one RCRA metal above the laboratory reporting limit was found in the sample collected by ICP or CVAA, which includes brown metal stairs.

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Identified building components which require special handling included fluorescent bulbs;

fluorescent light ballasts; exit signs which contain NiCad back-up batteries; and HVAC systems that contain R134A and R410A refrigerant.

One composite sample of the anticipated waste stream was collected and analyzed to determine if the waste stream would be considered hazardous waste. The composite sample included concrete, concrete block, acoustic ceiling tile, gypsum board, VFT, and VCB. Based on the waste characterization analytical results of the composite sample for the building, construction debris generated by demolition or renovation activities may be disposed of as non-hazardous waste.

Building 12

A total of 24 HAs were identified throughout Building 12. The laboratory separated layered materials and analyzed each layer as a single material. Analytical results revealed that one of the 38 materials analyzed was found to contain greater than 1% asbestos by PLM, which includes window glaze.

Lead concentrations equal to or greater than 1.0 mg/cm2 were identified on 20 components, which includes wood beams, a wood door frame, a wood door jamb, a metal pipe, a metal pole, a concrete pole footer, concrete walls, concrete block walls, a wood window frame, and a wood windowsill.

A total of two MBC samples were collected from paints and coatings for laboratory analysis by ICP or by CVAA for the 8 RCRA metals. Analytical results revealed detectable concentrations of at least one RCRA metal above the laboratory reporting limit was found in both samples collected by ICP or CVAA, which includes a beige metal pipe and a silver metal pipe.

Identified building components which require special handling included fluorescent bulbs; HID bulbs; exit signs which contain NiCad back-up batteries; and HVAC systems that contain R410A and unknown refrigerants.

One composite sample of the anticipated waste stream was collected and analyzed to determine if the waste stream would be considered hazardous waste. The composite sample included concrete, concrete block, acoustic ceiling tile, gypsum board, VFT, VCB, and plaster. Based on the waste characterization analytical results of the composite sample for the building, construction debris generated by demolition or renovation activities may be disposed of as non-hazardous waste.

1.5 Handling and Disposal of Identified Materials

ASL has completed an asbestos survey throughout each building. Materials containing asbestos must be handled in accordance with the OSHA Asbestos Construction Standard (29 CFR 1926.1101). Material considered to be ACM must be handled and disposed of in accordance with the EPA Asbestos National Emissions Standards for Hazardous Air Pollutants (NESHAP) (40 CFR 61 Subpart M).

ASL has completed a lead-based paint survey throughout each building. If surfaces coated with paints/coatings containing lead are subject to processes which create a lead dust hazard (welding, cutting, heating, abrading, or other aggressive method), handling must be conducted in accordance

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ASL has completed sampling of metal-based coatings throughout each building. If surfaces coated with paints/coatings containing metals are subject to processes which create a lead dust hazard (welding, cutting, heating, abrading, or other aggressive method), handling must be conducted in accordance with applicable OSHA Standards specific to the metal identified. If coatings determined to contain metals are abated, residues and debris require handling and disposal in accordance with the EPA RCRA TC Rule (40 CFR 261.24).

ASL has completed a survey for building components which contain hazardous materials. Building components identified as containing hazardous material must be handled and disposed of in accordance with applicable sections of EPA Universal Waste Standards (40 CFR 260-299) and PCB Standard (40 CFR 761), as adopted by the Florida Department of Environmental Protection (FDEP) under Florida Administrative Code (FAC) Chapter 62-730. In accordance with EPA regulations (40 CFR Part 82, Subpart F) under Section 608 of the Clean Air Act restrict ozone-depleting refrigerants must be reclaimed and properly disposed of.

ASL has collected composite samples of the anticipated demolition waste stream from each building and submitted samples for analysis by the TCLP for 8-RCRA metals. Waste characterization analytical results of composite samples for the building, construction debris generated by demolition activities which is comprised of the materials included in the sample below the threshold levels set in the EPA Hazardous Waste regulation (40 CFR Part 261) may be disposed of as non-hazardous waste.

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2.0 INTRODUCTION

Between May 16 and June 28, 2022, ASL conducted an ACM Survey, LBP Survey, Hazardous Materials Assessment, and Waste Characterization Field Engineering Services for Engine Repair Facility, Buildings 4, 6F, 6G, 7H, and 12, located at NAS Jacksonville, Jacksonville, Duval County, Florida. The surveys included all accessible areas throughout the buildings’ exterior and interior. The buildings were assessed for potential demolition. ASL is a Licensed Asbestos Business Organization, recognized by the State of Florida Department of Business and Professional Regulation (DBPR), Asbestos Licensing Unit, License Number ZA455. The ACM surveys were performed by AHERA-certified Asbestos Inspectors under the direction of a DBPR- Licensed Asbestos Consultant (LAC). ASL is certified by the EPA (Lead, Heavy Metals, and Inorganics Branch) to conduct lead-based paint activities in the State of Florida, Certification Number LBP-1654-2. The LBP inspections were performed by EPA-Certified Inspector/Risk Assessors. Copies of licenses are included in Appendix A.

ASL followed the government approved Work Plan, Sampling and Analysis Plan, and Abbreviated Accident Prevention Plan which were submitted under separate covers. Where applicable, the survey followed the UFC 3-810-01N Navy and Marine Corp Environmental Engineering for Facility Construction.

2.1 Building Descriptions

Building 4 is a one-story, approximate 42,000-square foot building, with an unknown date of construction, and is currently used as a legal administration building. Exterior finishes include concrete block, stucco, and modified bitumen roofing. Interior finishes include concrete block, gypsum, and plaster walls; gypsum, suspended, and concrete ceilings; and VFT, ceramic tile, and carpet floors. The building is concrete block and steel frame construction with a crawl space foundation. The HVAC is multi-zoned and contains metal and fiberglass ducting. Pipe runs and elbows are insulated with fiberglass and foamglass lagging.

Building 6F is a two-story, approximate 16,800-square foot building, with an unknown date of construction, and is currently used as an administration building. Exterior finishes include concrete block, stucco, and built-up rock roofing. Interior finishes include concrete block, and gypsum walls; gypsum, suspended, and concrete ceilings; and VFT, ceramic tile, and carpet floors. The building is concrete block and steel frame construction with a crawl space foundation. The HVAC is multi-zoned and contains metal and fiberglass ducting. Pipe runs and elbows are insulated with fiberglass and foamglass lagging.

Building 6G is a two-story, approximate 16,800-square foot building, with an unknown date of construction, and is currently used as an administration building. Exterior finishes include concrete block, stucco, and built-up rock roofing. Interior finishes include concrete block, and gypsum walls; gypsum, suspended, and concrete ceilings; and VFT, ceramic tile, and carpet floors. The building is concrete block and steel frame construction with a crawl space foundation. The HVAC is multi-zoned and contains metal and fiberglass ducting. Pipe runs and elbows are insulated with fiberglass and foamglass lagging.

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Building 7H is a two-story, approximate 16,200-square foot building, with an unknown date of construction, and is currently used as an administration building. Exterior finishes include concrete block, stucco, and bitumen roofing. Interior finishes include concrete block, and gypsum walls;

gypsum, suspended, and concrete ceilings; and VFT, ceramic tile, and carpet floors. The building is concrete block and steel frame construction with a crawl space foundation. The HVAC is multi-zoned and contains metal and fiberglass ducting. Pipe runs and elbows are insulated with fiberglass and foamglass lagging.

Building 12 is a two-story, approximate 11,850-square foot building, with an unknown date of construction, and is currently used as an administration building for the Navy Band. Exterior finishes include concrete block, and thermoplastic polyolefin (TPO) roofing. Interior finishes include concrete block, plaster, and gypsum walls; gypsum, plaster, and suspended, ceilings; and VFT, ceramic tile, and carpet floors. The building is concrete block and steel frame construction and slab on grade. The HVAC is multi-zoned and contains metal and fiberglass ducting. No insulation was observed on pipe runs and elbows.

3.0 REGULATORY SUMMARY

The following sections outline federal and state regulations.

3.1 Asbestos

3.1.1 Environmental Protection Agency

The EPA has published a list of hazardous air pollutants and promulgated the NESHAP regulations. Since asbestos presents a significant risk to human health as a result of air emissions from one or more source categories, it is therefore considered a hazardous air pollutant. The Asbestos NESHAP Regulation (40 CFR 61, Subpart M) addresses milling, manufacturing and fabricating operations, demolition and renovation activities, waste disposal issues, active and inactive waste disposal sites and asbestos conversion processes.

Friable ACM is defined by the Asbestos NESHAP regulations as any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure (Sec. 61.141).

Non-friable ACM is any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure (Sec. 61.141).

EPA also defines two categories of non-friable ACM: Category I and Category II non-friable

ACM.

Category I non-friable ACM is any asbestos-containing packing, gasket, mastic, resilient floor covering or asphalt roofing product which contains greater than 1% asbestos as determined using PLM according to the method specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141).

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Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing greater than 1% asbestos as determined using PLM according to the methods specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141), that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos-Containing Material (RACM) is: (a) friable ACM, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

Category I non-friable ACM must be inspected and tested for friability if it is in poor condition prior to demolition to determine whether or not it is subject to NESHAP. If the ACM is friable, it must be handled in accordance with NESHAP. Asbestos-containing packings, gaskets, resilient floor coverings and asphalt roofing materials must be removed prior to demolition only if they are in poor condition and are friable.

NESHAP further requires that if a facility is demolished by intentional burning, all of the facility's ACM, including Category I and II non-friable ACM, must be removed prior to burning (Sec.

61.145(c)(10)).

If Category I or Category II non-friable ACM is to be sanded, ground, cut, or abraded, the material is considered RACM and the owner or operator must abide by the following (Sec. 61.145(c)(1)):

(i) Adequately wet the material during the sanding, grinding, cutting or abrading operations;

(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting would unavoidably damage equipment or present a safety hazard; and

(iii) Handle asbestos material produced by the sanding, grinding, cutting, or abrading, as asbestos-containing waste material subject to the waste handling and collection provisions of Section 61.150.

Except for the following, Section 61.145(c) of the Asbestos NESHAP regulation requires that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

ACM need not be removed before demolition or renovation if it:

(i) Is a Category I non-friable ACM that has not become friable;

(ii) Is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition or renovation;

(iii) Was not accessible for testing and therefore was not discovered until after demolition or renovation began and, as a result of the demolition or renovation, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page 10 contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at all times until disposed of; or

(iv) Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition or renovation.

3.1.2 Occupational Safety and Health Administration

OSHA regulates asbestos exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where asbestos is present;

Removal or encapsulation of materials containing asbestos;

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain asbestos;

Installation of products containing asbestos;

Asbestos spill/emergency cleanup; and Transportation, disposal, storage, containment of and housekeeping activities involving asbestos or products containing asbestos, on the site or location at which construction activities are performed.

The OSHA Standard 29 CFR 1926.1101 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to asbestos. The OSHA standard does not apply to asbestos-containing asphalt roof coatings, cements and mastics.

3.1.3 State of Florida

Florida Statutes 469.004 and 469.005 require licensure of asbestos consultants and contractors by the DBPR.

Florida Statute 553.79 requires that the Department of Environmental Protection be notified in writing before a local building permit is granted for any building demolition or renovation which would disturb asbestos material.

3.2 Lead-Based Paint

3.2.1 Environmental Protection Agency

Title IV of the Toxic Substances Control Act (TSCA), as well as other authorities in the Residential Lead-Based Paint Hazard Reduction Act of 1992, directs EPA to regulate LBP hazards.

The EPA requires Construction and Demolition (C&D) debris contaminated with LBP be managed dependent upon the source and type of debris and hazard characteristics. C&D debris from commercial or industrial sites that is contaminated with LBP must be managed as RCRA hazardous waste if a representative sample meets the EPA’s toxicity characteristic outlined in 40 CFR 261.24. LBP waste from removal or remediation activities, including debris, paint chips, dust, and sludges that exhibit the toxicity characteristic must be managed and disposed of as a RCRA

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page 11 hazardous waste. A representative sample of debris and waste should be characterized using the TCLP, test Method 1311 as described in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, as incorporated by reference in 40 CFR

260.11 and analyzed by an accredited testing laboratory.

3.2.2 Occupational Safety and Health Administration

OSHA regulates lead exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where lead is present;

Removal or encapsulation of materials containing lead;

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain lead;

Installation of products containing lead;

Lead spill/emergency cleanup; and Transportation, disposal, storage, containment of and housekeeping activities involving products containing lead, on the site or location at which construction activities are performed.

OSHA’s Standard 29 CFR 1926.62 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to lead.

3.2.3 U.S. Department of Housing and Urban Development

According to the Housing and Urban Development (HUD) guidelines 20 CFR Part 35, LBP is defined as paint containing a lead concentration greater than or equal to 0.5 Percent by weight (% wt.) by laboratory analysis. HUD’s definition of LBP cannot be used to determine safe working conditions under OSHA. OSHA’s Lead in Construction Standard, 29 CFR 1926.62, was intended to apply to any detectable concentration of lead in paint by laboratory analysis. OSHA’s only accepted methodology for determining an employee’s exposure to airborne lead contaminants is through personal air monitoring. Any paint with detectable concentrations of lead by laboratory analysis that is subjected to cutting, abrading, welding, scraping, and/or sanding, must be handled in accordance with 29 CFR 1926.62, to prevent employee exposure.

3.2.4 State of Florida

Title IV of the TSCA, as well as other authorities in the Residential Lead-Based Paint Hazard Reduction Act of 1992, directs EPA to regulate LBP hazards.

The EPA administers the LBP program only in areas where states, territories or tribes are not authorized by the EPA to operate their own lead abatement programs. Florida is a state administered by the EPA, and the provisions set forth under the EPA’s LBP regulations have been adopted by the State of Florida.

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3.3 RCRA Metals

3.3.1 Occupational Safety and Health Administration

Any paint coating with detectable concentrations of RCRA metals by laboratory analysis that is subjected to cutting, abrading, welding, scraping, and/or sanding must be handled in accordance with applicable OSHA standards. In addition to programs for safety and health, training, medical surveillance, decontamination, new technology, and emergency response, employers at RCRA sites also need the following:

A written hazard communication program meeting the requirements of 29 CFR 1910.1200.

Procedures to effectively control and handle drums and containers.

OSHA requirements for the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure are outlined in Standard 29 CFR 1926.62 for lead, 29 CFR 1926.1118 for arsenic, 29 CFR 1926.1126 for chromium, 29 CFR 1926.1127 for cadmium, and 29 CFR 1910.1000 for barium, selenium, silver, and mercury.

3.4 Hazardous Materials

3.4.1 Environmental Protection Agency

EPA's universal waste regulations streamline hazardous waste management standards for federally designated "universal wastes," which include:

Batteries Pesticides Mercury-containing equipment Bulbs (lamps) Ballasts

The regulations govern the collection and management of these wastes, thus facilitating environmentally sound collection and proper recycling or treatment.

The regulations also ease the regulatory burden on retail stores and others that wish to collect these wastes and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors. In addition, the regulations also ensure that the wastes subject to this system will go to appropriate treatment or recycling facilities pursuant to the full hazardous waste regulatory controls.

The federal universal waste regulations are set forth in 40 CFR part 260-299. Equipment found to contain mercury, such as switches or bulbs must be handled in accordance with 40 CFR Part 273.

Components and systems found to contain Polychlorinated biphenyls (PCBs), such as ballasts and electrical transformers, must be handled in accordance with 40 CFR Part 761. States can modify the universal waste rule and add additional universal waste(s) in individual state regulations.

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Under Section 608 of the Clean Air Act of 1990 (CAA), EPA has established regulations (40 CFR Part 82, Subpart F) that:

Require service practices that maximize recovery and recycling of ozone-depleting substances (both chlorofluorocarbons [CFCs] and hydrochlorofluorocarbons [HCFCs] and their blends) during the servicing and disposal of air-conditioning and refrigeration equipment associated with HVAC systems and refrigerators/freezers.

Set certification requirements for refrigerant recycling and recovery equipment, technicians, and refrigerant reclaimers.

Restrict the sale of refrigerant to certified technicians.

Require persons servicing or disposing of air-conditioning and refrigeration equipment to certify to EPA that they have acquired refrigerant recovery and/or recycling equipment and are complying with the requirements of the rule.

Require the repair of substantial leaks in air-conditioning and refrigeration equipment with a refrigerant charge greater than 50 pounds.

Establish safe disposal requirements to ensure removal of refrigerants from goods that enter the waste stream with the charge intact (e.g., motor vehicle air conditioners, home refrigerators, and room air conditioners).

Effective July 1, 1992, Section 608 of the Act prohibits individuals from intentionally venting ozone-depleting substances used as refrigerants (generally CFCs and HCFCs) into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment (appliances). Only four types of releases are permitted under the prohibition:

De minimis quantities of refrigerant released in the course of making good faith attempts to recapture and recycle or safely dispose of refrigerant.

Refrigerants emitted in the course of normal operation of air-conditioning and refrigeration equipment (as opposed to during the maintenance, servicing, repair, or disposal of this equipment) such as from mechanical purging and leaks. However, EPA requires the repair of leaks above a certain size in large equipment.

Releases of CFCs or HCFCs that are not used as refrigerants. For instance, mixtures of nitrogen and R-22 that are used as holding charges or as leak test gases may be released.

Small releases of refrigerant that result from purging hoses or from connecting or disconnecting hoses to charge or service appliances will not be considered violations of the prohibition on venting. However, recovery and recycling equipment manufactured after November 15, 1993, must be equipped with low-loss fittings.

3.4.2 United States Department of Transportation

The Secretary of the Department of Transportation (DOT) receives the authority to regulate the transportation of hazardous materials from the Hazardous Materials Transportation Act (HMTA), as amended and codified in 49 United States Code (U.S.C.) 5101 et seq. The Secretary is authorized to issue regulations to implement the requirements of 49 U.S.C. The Pipeline and Hazardous Materials Safety Administration (PHMSA) (formerly the Research and Special Provisions Administration [RSPA]) was delegated the responsibility to write the hazardous materials regulations, which are contained in 49 CFR Parts 100-180. In order to accomplish his

FY25 MCON Project P-683, Field Engineering Services, NAS Jacksonville, Jacksonville, Duval County, Florida August 22, 2022 Draft Final ACM, LBP, HazMat, and Waste Characterization Surveys, ASL Project Number M3010.1801.0006.17 Page 14 responsibilities under the HMTA the Secretary "...may authorize any officer, employee, or agent to enter upon inspect, and examine, at reasonable times and in a reasonable manner, the records and properties of persons to the extent such records and properties relate to: (1) the manufacture, fabrication, marking, maintenance, reconditioning, repair, testing, or distribution of packages or containers for use by any ‘person’ in the transportation of hazardous materials in commerce; or (2) the transportation or shipment by any ‘person’ of hazardous materials in ‘commerce.’”

The hazardous materials regulations are applicable to the transportation of hazardous materials in commerce and their offering to:

Interstate, intrastate, and foreign carriers by rail car, aircraft, motor vehicle and vessel.

The representation that a hazardous material is present in a package, container, rail car, aircraft, motor vehicle or vessel.

The manufacture, fabrication, marking, maintenance, reconditioning, repairing or testing of a package or container which is represented, marked, certified or sold for use in the transportation of hazardous materials (49 CFR 171.1(a)).

Most federal agencies are considered "offerors" when they ship hazardous materials by commercial carriers. In those rare instances where governmental agencies transport hazardous materials in commerce on government vehicles/aircraft, the agency is also considered a carrier.

Contractors are fully subject to the requirements of the Federal hazardous materials transportation law.

3.4.3 State of Florida

Florida Electronic Hazardous Waste Regulations (FLEHaz) are the federal hazardous waste regulations – 40 CFR 124 and 40 CFR 260-279, as adopted by the State of Florida in Rule 62-730, F.A.C. and Rule 62-710, F.A.C., effective 04-23-13, Rule 62-731, F.A.C., Rule 62-737, F.A.C., and Rule 62-740, F.A.C., effective 02-16-12. All rule changes as reflected in 62-730, F.A.C. are incorporated into the document which is designed to show what rules are in effect for hazardous waste in the State of Florida.

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

Sampling protocols set forth by the EPA under 40 CFR 763.86 and the ASTM International’s Standard Practice for Comprehensive Building Asbestos Surveys (E2356-18) were followed during the…