QWO ARSR London OH Limited Asbestos Lead Paint Survey Report.pdf

PSI Project Number: 06552718 April 8, 2022 www.intertek.com/building

Professional Service Industries, Inc.

4960 Vulcan Avenue

Columbus, Ohio 43228 Phone: (614) 876-8000

FAA ATO-W, CSA Technical Services EOSH Support Operations Group, AJW-C21B 1850 South Sigsbee Street Indianapolis, Indiana 46241

Attention: Mr. Todd Clayton, CSP, CEM Safety and Environmental Compliance Manager (SECM) Indianapolis

Subject: Limited Pre-Renovation Asbestos and Lead Paint Survey Federal Aviation Administration – QWO ARSR 1365 Old Xenia Road London, Ohio 43140

Dear Mr. Clayton

Thank you for choosing Professional Service Industries, Inc. (PSI), an Intertek company. PSI performed the Limited Pre-Renovation Asbestos and Lead Paint Survey that you requested in general accordance with our agreement dated March 10, 2022. PSI transmits one electronic copy of the final report with this letter.

We appreciate the opportunity to provide our services to you on this project and would be pleased to continue our role as your consultant. Please contact us at (614) 876-8000 if you have any questions or we may be of further service.

Respectfully Submitted, Tom Abbinante, AHES #ES34543 Christopher M. Hundley Department Manager Principal Consultant

LIMITED ASBESTOS AND LEAD PAINT SURVEY

Federal Aviation Administration – QWO ARSR 1365 Old Xenia Road London, Ohio 43140

PREPARED FOR

FAA ATO-W, CSA Technical Services EOSH Support Operations Group, AJW-C21B

1850 South Sigsbee Street Indianapolis, Indiana 46241

Tom Abbinante Department Manager

PREPARED BY

4960 Vulcan Avenue

Columbus, Ohio 43228

(614) 876-8000

Christopher M. Hundley Principal Consultant

PSI Project Number: 06552718

Project Number: 06552718 FAA – QWO ARSR, London, Ohio

TABLE OF CONTENTS

1 EXECUTIVE SUMMARY

2 INTRODUCTION

2.1 SCOPE OF SERVICES

2.2 PURPOSE

2.3 AUTHORIZATION

2.4 LIMITATIONS

2.5 WARRANTY

3 GENERAL BUILDING AND SURVEY INFORMATION

3.1 BUILDING INFORMATION

3.2 INSPECTION INFORMATION

4 METHODOLOGY

4.1 RECORD DOCUMENT REVIEW

4.2 VISUAL INSPECTION PROCEDURES

4.3 SAMPLING PROCEDURES

4.4 ANALYSIS PROCEDURES

4.5 QUANTIFICATION

4.6 DRAWINGS

5 FINDINGS

5.1 ASBESTOS RESULTS

5.2 LIMITED LCP SURVEY RESULTS

6 CONCLUSIONS & RECOMMENDATIONS

6.1 CONCLUSIONS

6.2 RECOMMENDATIONS

TABLES

TABLE 1 – SUMMARY OF ASBESTOS SAMPLING RESULTS

TABLE 2 – SUMMARY OF PAINT CHIP SAMPLING RESULTS

LIST OF APPENDICES

APPENDIX A – REPORT OF BULK SAMPLE ANALYSIS FOR ASBESTOS

APPENDIX B – ASBESTOS BULK SAMPLE LOG/CHAIN OF CUSTODY

APPENDIX C – LEAD PAINT CHIP SAMPLE ANALYSIS AND CHAIN OF CUSOTDY

APPENDIX D – SAMPLE LOCATION DRAWING

APPENDIX E – INSPECTOR AND LABORATORY CERTIFICATIONS

1 EXECUTIVE SUMMARY

Professional Service Industries, Inc. (PSI), an Intertek Company, was retained by the Federal Aviation Administration (FAA) ATO-W, CSA Technical Services to conduct a Limited Survey for Asbestos-containing Materials (ACM) and Lead Containing Paint (LCP) at the FAA – QWO ARSR located at 1365 Old Xenia Road in London, Ohio. The inspection was performed by Mr. Tom Abbinante, Ohio Environmental Protection Agency Certified Asbestos Hazard Evaluation Specialist (OEPA CAHES #ES34543) of PSI on March 23, 2022.

The scope of services included a visual inspection of the subject building, sample collection, polarized light microscopy (PLM) asbestos sample analysis, flame atomic absorption (FAA) lead paint chip analysis, quantification of ACMs and report preparation & review. The scope of services was limited to walls, ceilings, roof systems and interior/exterior HVAC components at the subject building.

The subject building consists of an approximately 2,814 square foot, 1-story, slab-on-grade, masonry building, constructed circa 1957. The purpose of the investigation was to provide general information for the subject building regarding the presence, condition, and quantity of accessible and/or exposed friable and non-friable, building materials that contain asbestos; and location of lead-containing painted surfaces prior to a planned Roof and HVAC Replacement Project.

This summary does not contain all the information presented in the full report. The report should be read in its entirety to obtain a more complete understanding of the information provided and to aid in any decisions made or actions taken based on this information.

Pre-Renovation Asbestos Survey

A total of twenty-four (24) bulk samples, with thirty-three (33) sample layers, were collected from eight (8) suspect asbestos-containing homogeneous materials during the survey. All 33 sample layers were analyzed by PLM. The U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA) and State of Ohio define an ACM as any material containing greater than one percent (>1%) asbestos.

The following ACM (>1%) was identified through PLM analysis during this investigation:

• HA #05 – White Sealant on Interior Ductwork (Category II Non-Friable ACM)

Limited Lead-Containing Paint Survey A total of two (2) paint chip samples were collected from the exterior concrete masonry unit (CMU) surface of the subject building. The EPA and the U.S. Department of Housing and Urban Development (HUD) define a lead-based paint (LBP) as any coating having least 0.5% lead by weight with laboratory analysis. OSHA does not have a definition for LBP and therefore regulates worker’s exposure to paint with any detectable levels of lead.

The following LBP (>0.5% lead by weight) was identified through FAA analysis during this investigation:

• Comingled Red, White and Blue Paint on Exterior CMU Walls

2 INTRODUCTION

2.1 SCOPE OF SERVICES

The scope of services for this project consisted of conducting a pre-renovation asbestos survey, including inspection, sampling and analysis of accessible and exposed interior and exterior areas; and a limited survey for lead-containing paints at the FAA – QWO ARSR facility located at 1365 Old Xenia Road in London, Ohio. The inspection was performed by Mr. Tom Abbinante, Ohio Environmental Protection Agency Certified Asbestos Hazard Evaluation Specialist (OEPA CAHES #ES34543) of PSI on March 23, 2022.

The scope of services included a visual inspection of the subject building, sample collection, polarized light microscopy (PLM) asbestos sample analysis, Flame AA lead paint chip analysis, quantification of ACMs and report preparation & review. The scope of services was limited to walls, ceilings, roof systems and interior/exterior HVAC components at the subject building.

Asbestos Survey

This survey was intended to identify ACM as required by the EPA National Emission Standards for Hazardous Air Pollutants (NESHAP), OSHA and the State of Ohio. Additional information relative to friability, quantity and condition is also provided to assist the owner or his representative in the appropriate decisions involved with renovation and demolition. Regulations pertaining to asbestos renovation and demolition surveys include 40 CFR Part 61 (NESHAP), 29 CFR 1926.1101 (Asbestos in Construction) and applicable State of Ohio regulations.

Lead Paint Survey

This limited survey was intended to identify LBP in general accordance with the EPA and OSHA following general sampling procedures found in the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition). Regulations pertaining to lead paint renovation and disposal include 40 CFR Part 261 (EPA Resource Conservation and Recovery Act) and 29 CFR 1926.62 (OSHA Lead in Construction Standard).

2.2 PURPOSE

The purpose of this survey was to provide general information for the subject building regarding the presence, condition, and quantity of accessible and/or exposed friable and non-friable, building materials that contain asbestos; and location of lead-containing painted surfaces prior to a planned Roof and HVAC Replacement Project.

2.3 AUTHORIZATION

Authorization to perform this work was given on March 15, 2022 by Mr. Brian Strickland, Program Management Analyst with the Federal Aviation Administration-NDP. The project was conducted in general accordance with the scope, terms and conditions of PSI proposal #0655-367346, dated March 10, 2022.

2.4 LIMITATIONS

This asbestos survey was intended to meet the requirements of the EPA NESHAP for Asbestos demolition or renovation. The inspection for lead-containing paints was not intended to be an exhaustive survey of all paints in the building but a representation of the type of materials and components painted with lead-containing paint. The scope was not intended to comply with the requirements of a HUD lead-based paint inspection.

The scope of services was limited to walls, ceilings, roof systems and interior/exterior HVAC components at the subject building projected to be impacted as part of the Roof and HVAC Replacement Project. This document is not to be construed as a remediation design.

PSI, in general, did not:

• Conduct destructive sampling, such as behind finished surfaces (plaster/drywall walls, above hard ceilings, within CMU walls, below grade materials, etc.), inside mechanical chases, etc. to assess inaccessible or concealed materials.

• Sample any system which presented a hazard to the inspection team such as energized electrical systems or within confined spaces.

• Collect samples from building elements where the intended use would be compromised by testing, such as fire rated doors, vapor barriers, piping gaskets, etc.

Small spaces that are not exposed or readily accessible occur in most buildings and may not be noted in a normal full survey. Our inspector may not note some such spaces because they appear likely to be represented by nearby or similar spaces that are accessible for observations and sampling.

Inaccessible is defined as areas of the building that were locked, or where admittance was not permitted. It also includes areas/materials that could not be tested (sampled) without destruction of the structure or a portion of the structure, and areas/materials that could not be safely reached by the inspector or inspection team. In the event that access to a portion of the building was not obtained (which otherwise would have been tested), such limitations specifically are identified in the Findings Section of this report.

2.5 WARRANTY

The field and laboratory results reported herein are considered sufficient in detail and scope to determine the presence of accessible and/or exposed suspect ACM/LCP for the building structure. PSI warrants that the findings contained herein have been prepared in general accordance with accepted professional practices at the time of its preparation as applied by professionals in the community. Changes in the state of the art or in applicable regulations cannot be anticipated and have not been addressed in this report.

The survey and analytical methods have been used to provide the client with information regarding the presence of accessible and/or exposed suspect ACM/LCP existing at the time of the inspection. Test results are valid only for the material(s) tested. There is a distinct possibility that conditions may exist which could not be identified within the scope of the study or which were not apparent during the site visit. This inspection covered only those areas that were exposed and/or physically accessible to the Inspector. The study is also limited to the information available from the client at the time it was conducted. No other warrantees are implied or expressed.

3 GENERAL BUILDING AND SURVEY INFORMATION

3.1 BUILDING INFORMATION

Facility Location: 1365 Old Xenia Road London, Ohio 43140

Facility Construction Date: Circa 1957

Previous Renovation Dates: Unknown

Number of Floors: 1-story

Construction Type CMU with metal decking, concrete-slab-on-grade, steel supports and flat roofing system

3.2 INSPECTION INFORMATION

Name of PSI Inspectors: Tom Abbinante, AHES #ES34543

Dates of Inspection: March 23, 2022

4 METHODOLOGY

Inspection and sampling procedures were performed in general accordance with the guidelines published by the EPA. The inspection and survey described below was performed by an EPA accredited and State of Ohio licensed asbestos hazard evaluation specialist.

4.1 RECORD DOCUMENT REVIEW

Prior to conducting the inspection, PSI reviewed the QWO ARSR: Roof and HVAC Replacement Project Mechanical Installation Drawing (M001), provided by the client on March 7, 2022.

4.2 VISUAL INSPECTION PROCEDURES

Asbestos Survey

An initial walkthrough of the structure was conducted to determine the presence of suspect asbestos-containing materials that were accessible and/or exposed in the areas defined within the scope of work.

The inspection and sampling was limited to those areas and materials that were accessible and did not involve destruction of walls, other building elements, physical barriers, or the structural integrity of the item being tested.

However, accessible concealed spaces such as ceiling plenums above drop ceilings was included in this effort.

Materials which were similar in color, texture, general appearance and which appear to have been installed at the same time were grouped in Homogeneous Sampling Areas. Such materials are termed "homogeneous materials" by the EPA. During this walkthrough, the approximate locations of these homogeneous materials were also noted.

The inspector evaluated the overall condition of the material and determined whether the materials were friable or non-friable by touching the material, where practical. A friable material is defined as any material able to be crushed, crumbled, pulverized or reduced to a powder by hand pressure when dry.

Each material was further assessed for overall condition. Conditions were rated as good, fair, damaged or significantly damaged. PSI’s inspector also identified the EPA NESHAP classification of the material: Regulated ACM (RACM), Category I non-friable ACM, and Category II non-friable ACM, based on the materials current condition. PSI’s inspector provided estimated quantities of the materials identified as ACM, based only on materials that were accessible and exposed.

Lead Paint Survey

A visual inspection for LCP was performed that were accessible and/or exposed in the areas defined within the scope of work. Hidden/inaccessible areas were not included. Based on observations, representative-building components such as windows and frames, doors and frames, columns, walls, and ceilings with homogeneous suspect paint were randomly selected for paint chip sampling.

4.3 SAMPLING PROCEDURES

Asbestos Survey

Following the walkthrough, the Inspector collected samples of identified suspect materials.

EPA guidelines were used to determine the sampling protocol. Sampling locations were chosen to be representative of the homogeneous sampling area. While an effort was made to collect samples randomly, samples were taken preferentially from areas already damaged or areas which were the least visible to minimize disturbance of the material.

Each sample location was sprayed with amended water and was kept wet during the entire sampling process.

Samples were collected by coring through the material from the surface down to the base substrate. All layers of the material were extracted and placed into a sample container for transport to the laboratory. Sample containers were sealed and labeled with a unique sample identification number. Where appropriate, sampled materials were sealed with an encapsulant or covered with tape after sampling. PSI is not responsible for restoring the sampled areas to their pre-sampled condition.

Lead Paint Survey

Paint chip samples were collected from accessible painted building materials in significant quantities and were tested for lead concentrations in the paint. For paint chip samples, an area of approximately one (1) to two (2) square inches was extracted from coated components down to but not including the substrate. Chip samples were placed in a sealed container and labeled for analysis. Restoration and repainting of sampled surfaces was not within the scope of PSI’s lead inspection protocol.

4.4 ANALYSIS PROCEDURES

Asbestos Survey

All samples were analyzed at Professional Service Industries, Inc. located at 850 Poplar Street, Pittsburgh, Pennsylvania 15220. The PSI Pittsburgh Asbestos Laboratory is a National Voluntary Laboratory Accreditation Program (NVLAP) Accredited (#101350-0) and an American Industrial Hygiene Association (AIHA) Accredited (#8222) Laboratory. A copy of the Laboratory’s Accreditation Certificate is included.

The samples were analyzed for asbestos by PLM and in accordance with the “EPA Method for the Determination of Asbestos in Bulk Building Materials” (EPA/600/R-93/116 July 1993). Analysis was performed by visually observing the bulk samples with a stereoscope followed by slide preparation(s) for microscopic examination and identification.

Using a stereoscope, the microscopist visually estimated relative amounts of each constituent by determining the volume of each constituent in proportion to the total volume of the sample. Next, the samples were mounted on slides and analyzed by PLM for asbestos (chrysotile, amosite, crocidolite, anthophyllite, actinolite/tremolite), and fibrous non-asbestos constituents (mineral wool, fiberglass, cellulose, etc.). Asbestos was identified by refractive indices, morphology, color, pleochroism, birefringence, extinction characteristics, and signs of elongation. The same characteristics were used to identify the non-asbestos constituents.

The EPA method allows samples which are visually determined to have less than 10% asbestos to be quantified using a Point Count procedure. An ocular reticule (cross hair or point array) is used to visually superimpose a point or points on the microscope field of view. A total of 400 points superimposed on either asbestos fibers or non-asbestos matrix material must be counted over at least eight different preparations of representative subsamples. If an asbestos fiber and matrix particle overlap so that a point is superimposed on their visual intersection, a point is scored for both categories. Point counting provides a quantification of the area percent asbestos. Point counted results supersede the results of the visual estimation. It should be noted samples containing 1 percent or less (trace) asbestos can be verified to be non-ACM only by the point counting procedure and must be treated as ACM until done so.

It should be noted that some ACM might not be accurately identified or quantified by PLM. As an example, the original fabrication of vinyl floor tiles routinely involved milling of asbestos fibers to extremely small sizes. As a result, these fibers may go undetected under the standard PLM method. Transmission Electron Microscopy (TEM) is recommended for a more definitive analysis of these materials.

Lead Paint Survey

The paint chip samples were submitted to PSI’s American Industrial Hygiene Association (AIHA), Environmental Lead Laboratory Accreditation Program (ELLAP) accredited industrial hygiene laboratory in Pittsburgh, PA (ID# 100373) for analysis of the lead concentration via FAA using the PSI WI-503-815 method modified from EPA SW846 Method 7420.

4.5 QUANTIFICATION

Quantification of suspect ACMs/LCPs was conducted using visual estimation by the accredited asbestos inspector. This visual estimation was performed in accordance with generally accepted practices in the asbestos industry based on materials that were accessible and exposed. These values are sufficiently accurate for the purpose of documenting the presence of asbestos within its space for the purpose of identifying abatement control conditions or for general policy considerations. Actual quantities may differ between visually estimated values and physical measurements. If a licensed asbestos/lead paint abatement contractor is engaged to remove ACMs/LCPs, the abatement contractor is responsible for verifying reported quantities to be removed.

4.6 DRAWINGS

Drawings were prepared to indicate the location of the samples that were collected during this investigation.

The drawings are not intended to be used for construction purposes. Drawings prepared during this investigation are included in the Appendix D.

5 FINDINGS

5.1 ASBESTOS RESULTS

A total of twenty-four (24) bulk samples, with thirty-three (33) sample layers, were collected from eight (8) suspect asbestos-containing homogeneous materials during the survey. All 33 sample layers were analyzed by PLM.

The following ACM (>1%) was identified:

• HA #05 – White Sealant on Interior Ductwork (Category II Non-Friable ACM)

The “Report of Bulk Sample Analysis for Asbestos,” the Sample Chain of Custody and Sample Location Drawing(s) are included in the Appendices. Table 1 on the following pages lists the materials that were sampled, along with the results of the inspection and laboratory analysis. Additionally, Table 1 gives a description of the materials, their general locations, condition, friability, EPA NESHAP Category and estimated quantity.

5.1.1 REGULATORY GUIDELINES:

ACM Definition – The EPA and OSHA consider a material to be ACM if at least one sample from the homogeneous area shows asbestos in an amount greater than 1%.

Point Count Quantification – If a material is found to contain less than 10% asbestos via visual estimation, it can be treated as non-ACM per EPA Regulations, if verified to contain 1% or less asbestos by the Point Count Quantification Procedure. If not point counted, a sample in which asbestos was visually detected and estimated (including trace to ≤1%) must be assumed to be greater than 1% and treated as ACM. Please refer to the laboratory analyses for a more detailed description of the microscopic analysis of individual samples.

Zero samples were point counted as part of this survey effort.

EPA NESHAP Category – EPA NESHAP classifies ACM into the following categories:

• Regulated Asbestos Containing Material (RACM) is any (a) Friable asbestos material, (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 includes packings, gaskets, resilient floor covering, and asphalt roofing products which contain more than one percent asbestos.

• Category II Non-friable ACM includes any material, except for a Category I non-friable ACM, which contains more than one-percent asbestos and cannot be reduced to a powder by hand pressure when dry.

OSHA – OSHA has a classification system (I thru IV) for ACM depending on the type of material and the disturbance as follows:

• Class I work is defined as activities involving the removal of ACM or presumed ACM (PACM) that is thermal system insulation (TSI) and surfacing materials.

• Class II activities involve removal of ACM/PACM other than TSI or surfacing material.

• Class III work includes repair and maintenance operations which are likely to disturb ACM/PACM.

• Class IV work includes maintenance and custodial activities during which employees contact but do not disturb ACM/PACM.

Materials where asbestos is detected, but where point counting is conducted and determined that the concentration is ≤1% asbestos, are not considered to be ACM by EPA or OSHA. These materials are considered unclassified asbestos work per OSHA; however, OSHA work control practices and prohibitions will still apply.

Additional details of the OSHA asbestos regulations related to the construction industry can be found in 29 CFR part 1926.1101.

TABLE 1 – SUMMARY OF ASBESTOS SAMPLING RESULTS

HA &

Sample # Sample Description Sample Location Friable

(Yes/No) Condition Asbestos Type & Percent 1

Approximate Quantity

EPA NESHAP

Category

01 – 1 01 – 2 01 – 3

White Roof Sealant Northeast Roof

Central Roof Southeast Roof

No Good

NAD

NAD

NAD

02 – 4 02 – 5 02 – 6

2-Ply Roof Core with Insulation

North Roof Central Roof Central Roof

No Fair

NAD / NAD

NAD / NAD

NAD / NAD

03 – 7 03 – 8 03 – 9

Roof Perimeter Grounding Wire Caulk

Southeast Roof Southwest Roof Northeast Roof

No Good

NAD

NAD

NAD

04 – 10 04 – 11 04 – 12

Black Membrane with Yellow Adhesive & Black

Caulk

Northeast Exterior Ductwork Northeast Exterior Ductwork Northeast Exterior Ductwork

No Good

NAD / NAD / NAD

NAD / NAD / NAD

NAD / NAD / NAD

05 – 13 05 – 14 05 – 15

White Interior Sealant East Interior Ductwork East Interior Ductwork East Interior Ductwork

No Good

CH 5%

CH 5%

CH 5%

4 square feet Category II Non-Friable

06 – 16 06 – 17 06 – 18

2’ x 2’ Textured Ceiling Tile East Interior East Interior

North-Central Interior Yes Good

NAD

NAD

NAD

07 – 19 07 – 20 07 – 21

2’ x 2’ Small Hole Ceiling Tile

North-Central Interior North-Central Interior West-Central Interior

Yes Good

NAD

NAD

NAD

08 – 22 08 – 23 08 – 24

Styrofoam Board Insulation Adhesive

West-Central Interior West-Central Interior West-Central Interior

No Good

NAD

NAD

NAD

1 NAD = No Asbestos Detected; CH = Chrysotile Asbestos.

5.2 LIMITED LCP SURVEY RESULTS

A total of two (2) paint chip samples were collected from the exterior CMU surface of the subject building. All samples were analyzed by Flame AA.

The following LBP (>0.5% lead by weight) was identified:

• Comingled Red, White and Blue Paint on Exterior CMU Walls

The “Analytical Report – Analysis of Paint for Lead Determination,” and the Sample Chain-of-Custody are included in the Appendices. Table 2 gives a description of the painted components, their general locations, and laboratory analysis.

TABLE 2 – SUMMARY OF PAINT CHIP SAMPLING RESULTS

Sample # Component Substrate Color Location Paint Condition

Lead Content (% by Weight)

PB-1 Exterior Wall CMU Comingled Red, White & Blue Northeast Exterior Deteriorated 0.076%

PB-2 Exterior Wall CMU Comingled Red, White & Blue North Exterior Deteriorated 7.8%

5.2.1 REGULATORY GUIDELINES:

Federal efforts to regulate LBP began with the enactment of the Lead-Based Paint Poison Prevention Act (LBPPPA) in 1971. In 1973, the Consumer Product Safety Commission (CPSC) defined lead-based paint as paint having lead content equal to or greater than 0.5 percent by weight in a dry film of newly applied paint. In 1978, the CPSC lowered the allowable lead levels in new paint to 0.06%.

LBP Definition – The EPA and HUD defines "lead-based paint" as any "paint, surface coating that contains lead equal to or exceeding one milligram per square centimeter (1.0 mg/cm2) or 0.5% lead by weight."

EPA – Renovation, Repair and Painting Program – EPA's Lead Renovation, Repair and Painting Rule (RRP Rule) requires that firms performing renovation, repair, and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978 have their firm certified by EPA (or an EPA authorized state), use certified renovators who are trained by EPA-approved training providers and follow lead-safe work practices.

EPA – Resource Conservation and Recovery Act (RCRA) Regulations – For LBP abatement wastes originating from sources not considered households, a Toxicity Characteristic Leaching Procedure (TCLP) test for lead may be required on a representative sample of lead based paint abatement waste to determine if the wastes are characteristically hazardous. Non-residential structures include public and commercial buildings, warehouses, bridges, water towers, and transmission towers. Large quantities, or concentrated lead based paint debris, generated by contractors during lead abatement, remodeling or rehabilitation work will require a TCLP test for lead. Abatement wastes from non-residential structures with a TCLP result for lead that is less than 5.0 parts per million (ppm) may be disposed at a construction and demolition Landfill (C&D). Abatement waste with TCLP results for lead that is 5.0 ppm or greater must be disposed as hazardous waste landfill.

OSHA – The current OSHA standard (29 CFR 1926.62) for lead exposure in construction has a permissible exposure limit (PEL) of 50 micrograms per cubic meter of air (50 µg/m3), measured as an 8-hour time-weighted average (TWA). As with all OSHA health standards, when the PEL is exceeded, the hierarchy of controls requires employers to institute feasible engineering and work practice controls as the primary means to reduce and maintain employee exposures to levels at or below the PEL. When all feasible engineering and work practice controls have been implemented but have proven inadequate to meet the PEL, employers must nonetheless implement these controls and must supplement them with appropriate respiratory protection. The employer also must ensure that employees wear the respiratory protection provided when it is required.

HUD – The Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition) enforce HUD’s vision to reduce hazards in housing in a cost-effective manner while protecting the health of children. These guidelines are used by those who are required to identify and control lead paint hazards, as well as property owners, landlords, and child-care center operators. Helpful advice on renovations in older housing, lead-based paint inspections and risk assessments, and where to go for help can be found in the guidelines. The guidelines also outline what users have to do to meet requirements and recommendations; identify training – and if applicable, certification – required for people who conduct the work; and describe how the work should be done.

The guidelines complement regulations that have been issued by HUD, the EPA, and OSHA.

6 CONCLUSIONS & RECOMMENDATIONS

6.1 CONCLUSIONS

ACM Survey

The following ACM was identified during this investigation:

• HA #05 – White Sealant on Interior Ductwork (Category II Non-Friable ACM)

Limited LCP Survey

The following LBP was identified:

• Comingled Red, White and Blue Paint on Exterior CMU Walls

6.2 RECOMMENDATIONS

Asbestos

ACM must be properly removed by a licensed asbestos abatement contractor prior to renovations that would disturb the material. Federal, State and Local regulations and guidelines should be strictly adhered to when removing the ACM.

ACMs, scheduled to remain, should be maintained in a good non-damaged condition and periodically inspected through use of an Operations and Maintenance (O&M) program. Damaged or significantly damaged ACMs should be repaired, encapsulated, enclosed or removed.

The client should consult the EPA’s NESHAP standard, OSHA, the State of Ohio asbestos regulations, and any local regulations, for additional details regarding asbestos-related demolition/renovation procedures and requirements.

Lead-Based Paint

All untested paint from buildings constructed before 1978 should be considered to contain lead.

Paint containing lead above and below the Federal standard for lead-based paint (LBP) of 0.5% lead by weight was identified in the subject building. OSHA regulates workers exposure to lead paint concentrations in any amount; therefore, in order to satisfy OSHA requirements, worker protection and monitoring may be required for work activities that disturb paints that contain lead in any amount. In accordance with the OSHA Construction Standard for Lead (29 CFR 1926.62), it is the contractors’ responsibility to protect their workers when an employee may be occupationally exposed to lead.

In addition, if painted materials are to be disposed off-site, they should be tested to determine if the lead in the paint is at a level considered to be a hazardous waste. This testing consists of a TCLP test.

APPENDIX A – REPORT OF BULK SAMPLE ANALYSIS FOR ASBESTOS

REPORT OF BULK SAMPLE ANALYSIS FOR ASBESTOS

TESTED FOR: PSI, Inc FAA-London, Ohio

Date Received: 3/25/2022 Date Completed: 4/1/2022

4960 Vulcan Avenue, Suite C Columbus, OH 43228 Attn: Tom Abbinante

Project ID: 06552718

Date Reported: 4/1/2022

Page: 1 of 3Analyst: Lori Huss Work Order: 2203763

Lab ID (Layer)

Asbestos Content

(Percent and Type)

Non-asbestos Fibers

(Percent and Type)

Client ID Sample Description (Color, Texture, Etc.)

Analyst's Comment

001A01-1 (1) White, Sealant, Homogeneous NO ASBESTOS DETECTED None Reported

002A01-2 (1) White, Sealant, Homogeneous NO ASBESTOS DETECTED None Reported

003A01-3 (1) White, Sealant, Homogeneous NO ASBESTOS DETECTED None Reported

004A02-4 (1) Black, Roof Core, Homogeneous 10% Synthetic FiberNO ASBESTOS DETECTED

(2) Black, Insulation, Homogeneous 75% Cellulose FiberNO ASBESTOS DETECTED

005A02-5 (1) Black, Roof Core, Homogeneous 10% Synthetic FiberNO ASBESTOS DETECTED

(2) Black, Insulation, Homogeneous 75% Cellulose FiberNO ASBESTOS DETECTED

006A02-6 (1) Black, Roof Core, Homogeneous 10% Synthetic FiberNO ASBESTOS DETECTED

(2) Black, Insulation, Homogeneous 75% Cellulose FiberNO ASBESTOS DETECTED

007A03-7 (1) Transparent, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

008A03-8 (1) Transparent, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

009A03-9 (1) Transparent, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

010A04-10 (1) Black, Other, Homogeneous NO ASBESTOS DETECTED None Reported

Membrane

(2) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

(3) Black, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

Quantitation is based on a visual estimation of the relative area of bulk sample components, unless otherwise noted in the "Comments" section of this report. The results are valid only for the item tested as received. This report may not be used to claim product endorsement by NVLAP or any agency of the U.S. Government. Method used: E.P.A.

Interim Method for the Determination of Asbestos in Bulk Insulation Samples (EPA 600/M4-82-020). Polarized Light Microscopy is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Quantitative Transmission Electron Microscopy is currently the only method that can be used to determine if the material can be considered or treated as non-asbestos containing. Samples will be disposed of within 30 days unless notified in writing by the client. No part of this report may reproduced, except in full, without written permission of the laboratory. The reporting limit is 1% by weight. NVLAP Lab Code 101350-0.

Respectfully submitted, Approved Signatory

PSI, Inc.

Professional Service Industries, Inc. 850 Poplar Street, Pittsburgh, PA 15220 Phone 412/922-4010 Fax 412/922-4014

George Skarupa

Page: 2 of 3Analyst: Lori Huss Work Order: 2203763

Lab ID (Layer)

Asbestos Content

(Percent and Type)

Non-asbestos Fibers

(Percent and Type)

Client ID Sample Description (Color, Texture, Etc.)

Analyst's Comment

011A04-11 (1) Black, Other, Homogeneous NO ASBESTOS DETECTED None Reported

Membrane

(2) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

(3) Black, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

012A04-12 (1) Black, Other, Homogeneous NO ASBESTOS DETECTED None Reported

Membrane

(2) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

(3) Black, Caulking, Homogeneous NO ASBESTOS DETECTED None Reported

013A05-13 (1) White, Sealant, Homogeneous Chrysotile5% None Reported

014A05-14 (1) White, Sealant, Homogeneous Chrysotile5% None Reported

015A05-15 (1) White, Sealant, Homogeneous Chrysotile5% None Reported

016A06-16 (1) Gray, Ceiling Tile, Homogeneous 10% Cellulose Fiber

75% Fibrous GlassNO ASBESTOS DETECTED

017A06-17 (1) Gray, Ceiling Tile, Homogeneous 10% Cellulose Fiber

75% Fibrous GlassNO ASBESTOS DETECTED

018A06-18 (1) Gray, Ceiling Tile, Homogeneous 10% Cellulose Fiber

75% Fibrous GlassNO ASBESTOS DETECTED

019A07-19 (1) Gray, Ceiling Tile, Homogeneous 10% Fibrous GlassNO ASBESTOS DETECTED

75% Cellulose Fiber

020A07-20 (1) Gray, Ceiling Tile, Homogeneous 10% Fibrous GlassNO ASBESTOS DETECTED

75% Cellulose Fiber

021A07-21 (1) Gray, Ceiling Tile, Homogeneous 10% Fibrous GlassNO ASBESTOS DETECTED

75% Cellulose Fiber

022A08-22 (1) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

023A08-23 (1) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

Quantitation is based on a visual estimation of the relative area of bulk sample components, unless otherwise noted in the "Comments" section of this report. The results are valid only for the item tested as received. This report may not be used to claim product endorsement by NVLAP or any agency of the U.S. Government. Method used: E.P.A.

Interim Method for the Determination of Asbestos in Bulk Insulation Samples (EPA 600/M4-82-020). Polarized Light Microscopy is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Quantitative Transmission Electron Microscopy is currently the only method that can be used to determine if the material can be considered or treated as non-asbestos containing. Samples will be disposed of within 30 days unless notified in writing by the client. No part of this report may reproduced, except in full, without written permission of the laboratory. The reporting limit is 1% by weight. NVLAP Lab Code 101350-0.

Respectfully submitted, Approved Signatory

PSI, Inc.

Professional Service Industries, Inc. 850 Poplar Street, Pittsburgh, PA 15220 Phone 412/922-4010 Fax 412/922-4014

Page: 3 of 3Analyst: Lori Huss Work Order: 2203763

Lab ID (Layer)

Asbestos Content

(Percent and Type)

Non-asbestos Fibers

(Percent and Type)

Client ID Sample Description (Color, Texture, Etc.)

Analyst's Comment

024A08-24 (1) Yellow, Adhesive, Homogeneous NO ASBESTOS DETECTED None Reported

Report Notes: (PT) Point Count Results

Quantitation is based on a visual estimation of the relative area of bulk sample components, unless otherwise noted in the "Comments" section of this report. The results are valid only for the item tested as received. This report may not be used to claim product endorsement by NVLAP or any agency of the U.S. Government. Method used: E.P.A.

Interim Method for the Determination of Asbestos in Bulk Insulation Samples (EPA 600/M4-82-020). Polarized Light Microscopy is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Quantitative Transmission Electron Microscopy is currently the only method that can be used to determine if the material can be considered or treated as non-asbestos containing. Samples will be disposed of within 30 days unless notified in writing by the client. No part of this report may reproduced, except in full, without written permission of the laboratory. The reporting limit is 1% by weight. NVLAP Lab Code 101350-0.

Respectfully submitted, Approved Signatory

PSI, Inc.

Professional Service Industries, Inc. 850 Poplar Street, Pittsburgh, PA 15220 Phone 412/922-4010 Fax 412/922-4014

APPENDIX B – ASBESTOS BULK SAMPLE LOG AND CHAIN OF CUSTODY

APPENDIX C – LEAD PAINT CHIP SAMPLE ANALYSIS AND CHAIN OF CUSOTDY

Analysis of Paint for Lead Determination

Analytical Report

TESTED FOR: PSI, Inc 4960 Vulcan Avenue, Suite C Columbus, OH 43228 Attn: Tom Abbinante

Date Received: 3/25/2022 Date Analyzed: 3/30/2022 Date of Issue: 3/30/2022

Project ID: 06552718 FAA-London, Ohio

1 of 1Analyst: Keith Potts Work Order: 2203750 Page:

Lab Sample # Client Sample #

Reporting Limit

% Lead by Weight % Lead by Weight

001A PB-1 0.0140.076

002A PB-2 0.0127.8

AIHA-LAP, LLC #100373; NYELAP ID #10930; CA Lab ID #2377.

Results are based on a representative subsample of the total sample submitted by the client.

Sample results are not corrected for blanks.

Reporting limit = 15µg Pb per representative subsample.

Respectfully submitted, Approved Signatory

PSI, Inc.

Professional Service Industries, Inc. 850 Poplar Street, Pittsburgh, PA 15220 Phone 412/922-4000 Fax 412/922-4014

Cathy McNamee

Analytical & Prep Method

PSI WI-506 mod. EPA SW846 7000B, Rev 2, 2007 PSI WI-502 mod. EPA SW846 3050B, Rev 2, 1996

Analysis was performed by flame AA using a PE AAnalyst 400.

All results are calculated using dry weight and based on 2 significant figures. Results relate only to items tested as received.

This report may not be reproduced, except in full, without written approval of PSI, Inc.

Unless otherwise noted, all samples were acceptable upon receipt.

All quality control sample results are within the acceptance range, unless noted.

Client submitted data is the determining factor in the accuracy of calculated results.

The attached Chain of Custody is incorporated into and becomes a part of the final report.

All results are calculated based on 2 significant figures. Results relate only to items tested as received.

APPENDIX D – SAMPLE LOCATION DRAWING

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AHES#: ES34543

Sample Date: 3/23/22

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APPENDIX E – INSPECTOR & LABORATORY CERTIFICATIONS

AIHA Laboratory Accreditation Programs, LLC acknowledges that

Intertek-PSI, Inc.

850 Poplar St Pittsburgh, PA 15220-2828

Laboratory ID: LAP-100373 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2017 international standard, General Requirements for the Competence of Testing and Calibration Laboratories in the following:

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE Accreditation Expires: July 01, 2022

ENVIRONMENTAL LEAD Accreditation Expires: July 01, 2022

ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: July 01, 2022

FOOD Accreditation Expires:

UNIQUE SCOPES Accreditation Expires:

Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:2017 and AIHA-LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA-LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.

Michael Breu Chairperson, Analytical Accreditation Board

Revision 18: 03/27/2020

Cheryl O Morton Managing Director, AIHA Laboratory Accreditation Programs, LLC

Date Issued: 06/30/2020

Effective: 11/21/2019 Revision: 8

SCOPE OF ACCREDITATION

Intertek-PSI, Inc. Laboratory ID: LAP-100373

850 Poplar St Pittsburgh, PA 15220-2828 Issue Date: 06/30/2020

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

The EPA recognizes the AIHA-LAP, LLC ELLAP program as meeting the requirements of the National Lead Laboratory Accreditation Program (NLLAP) established under Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 and includes paint, soil and dust wipe analysis. Air and composited wipes analyses are not included as part of the

NLLAP.

Environmental Lead Laboratory Accreditation Program (ELLAP)

Initial Accreditation Date: 06/01/1996

Component, parameter or characteristic tested

Technology sub-type/Detector Method Method Description

(for internal methods only)

Airborne Dust AA NIOSH 7082 N/A

EPA SW-846 3050B N/A

Paint AA

EPA SW-846 7000B N/A

EPA SW-846 3050B N/A

Settled Dust by Wipe AA

EPA SW-846 7000B N/A

EPA SW-846 3050B N/A

Soil AA

EPA SW-846 7000B N/A

A complete listing of currently accredited ELLAP laboratories is available on the AIHA-LAP, LLC website at: http:// www.aihaaccreditedlabs.org

Revision: 7

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

Environmental Microbiology Laboratory Accreditation Program (EMLAP)

Initial Accreditation Date: 07/01/2005

EMLAP Scope Category Field of Testing (FOT) Component, parameter or characteristic tested

Method Method Description

(for internal methods only)

Fungal Air - Culturable Viable Impaction Samples WI-618 In House: Processing Viable Air Samples

Fungal Air - Direct Examination Spore Trap Air Samples WI-620 In House: Direct Microscopic Examinaton of Spore Traps

Fungal Bulk - Culturable Swab, wipe, bulk, dust, etc. WI-616 In House: Processing Viable Surface and Bulk Samples

Fungal Bulk - Direct Examination Swab, wipe, bulk, dust, etc. WI-621 In House: Direct Microscopic

Examination of Surface and Bulk Samples

Fungal Surface - Culturable Swab, wipe, bulk, dust, etc. WI-616 In House: Processing Viable Surface and Bulk Samples

Fungal Surface - Direct Examination Tape, swab, wipe, bulk, dust, etc.

WI-621

In House: Direct Microscopic Examination of Surface and Bulk Samples

A complete listing of currently accredited EMLAP laboratories is available on the AIHA-LAP, LLC website at: http://

Revision: 9

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

Industrial Hygiene Laboratory Accreditation Program (IHLAP)

Initial Accreditation Date: 03/01/1987

IHLAP Scope Category Field of Testing (FOT) Technology sub-type/Detector

Published Reference Method/Title of

In-house Method

Component, parameter or characteristic tested

Asbestos/Fiber Microscopy Core

Phase Contrast Microscopy (PCM)

- NIOSH 7400 Asbestos/Fibers

Asbestos/Fiber Microscopy Core

Phase Contrast Microscopy (PCM)

- WI-307 Asbestos/Fibers

A complete listing of currently accredited IHLAP laboratories is available on the AIHA-LAP, LLC website at: http://