FinalBldg27ACMUpdate.pdf

PARS

Environmental Inc.

LIMITED ASBESTOS-

CONTAINING MATERIAL

REVIEW – BUILDING #27

Defense Supply Center Columbus 3990 East Broad Street Columbus, OH 43213

CONTRACT # W912QR-11D-0022

TASK ORDER # 0001

PREPARED FOR

US Army Corps of Engineers – Louisville District 600 Dr. Martin Luther King, Jr. Place Louisville, Kentucky 40202

And:

Defense Logistics Agency Defense Supply Center – Columbus 3990 East Broad Street Columbus, Ohio 43213

PREPARED BY

PARS Environmental, Inc.

500 Horizon Drive, Suite 540 Robbinsville, New Jersey 08691 609-890-7277 609-890-9116 (fax)

PARS PROJECT NO. 773-24a

OCTOBER 2012

PARS

Limited Asbestos-Containing Material Review

Building # 27 October 2012

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 APPLICABLE REGULATIONS

3.0 ASBESTOS SURVEY RATIONALE AND REQUIREMENTS

4.0 BUILDING RECONNAISSANCE

5.0 FINDINGS

6.0 SURVEY ESTIMATE

7.0 CONCLUSIONS

8.0 LIMITATIONS

9.0 RELIANCE

APPENDIX A

Site Photographs

APPENDIX B

Available Historical Asbestos Survey Data i

PARS Limited Asbestos-Containing Material Review Building # 27 October 2012

1.0 INTRODUCTION

PARS Environmental, Inc. (PARS), under contract to the US Army Corps of Engineers (USACE), Louisville District, has prepared this Historical Asbestos Report Review and Site Reconnaissance Report for the Defense Logistics Agency, Defense Supply Center-Columbus (DLA-DSCC), Building #27, located at 3990 East Broad Street, Columbus, Ohio.

The purpose was to review historical asbestos reports and determine the presence of suspect ACM or confirmed ACM in the building, summarize our findings and propose any additional services needed to determine the work necessary to comply with current National Emission Standards for Hazardous Air Pollutions (NESHAP), Occupational Safety and Health Administration (OSHA), Ohio Department of Health (ODH), Ohio Environmental Protection Agency (OEPA), and Department of Transportation (DOT) regulations prior to the renovation or demolition of the subject buildings.

Specifically, PARS provided the following services:

• Onsite review of historical asbestos reports available for each building.

• Conduct a reconnaissance of accessible areas of each building for the presence of suspect

ACM (sampling was not included in this SOW).

• Evaluate the completeness and validity of the historical asbestos survey information and data in the respective asbestos reports, as it pertains to current regulations, to what was observed during the building reconnaissance.

• Summarized the findings of the evaluation of the current site conditions in the building, and identify what information and/or data are needed to comply with the current applicable regulations regarding ACM management during renovation or demolition of the building.

The subject building encompasses approximately 139,000 square feet and is a one-story mixed-use building. The building is steel-framed with brick exterior. There are, effectively, two roofs on this building. The original built-up arched roof was enclosed and covered with another pitched built-up roof and membrane. A layer of blown-in fibrous insulation covers the enclosed original built-up arched roof. The interior finishes consist of numerous finishes including carpet, vinyl floor tile, ceiling tile, and drywall with joint compound. The structure is primarily heated with a natural gas boiler and supplemental heat is provided by forced-air, natural gas furnaces.

Photographs from the May 18, 2012 site reconnaissance are included in Appendix A.

2.0 APPLICABLE REGULATIONS

The following asbestos-related regulations are potentially applicable during future renovation or demolition of the subject structure.

Occupational Safety and Health Administration’s (OSHA) Asbestos General Industry Standard

(29 CFR 1910.1001)

OSHA’s Asbestos in Construction Standard (29 CFR 1926.1101)

U.S. Environmental Protection Agency’s (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR 61 subpart M)

U.S. Department of Transportation’s (DOT) Emergency Response Communication Standards

(49 CFR 171)

DOT’s Emergency Response Information (49 CFR 172, Subpart G)

Ohio Department of Health’s (ODH) Asbestos Hazard Abatement Rules (OAC 3701-34)

Ohio Environmental Protection Agency’s (OEPA) Asbestos Emissions Control

OAC 3745-20

3.0 ASBESTOS SURVEY RATIONALE AND REQUIREMENTS

According to NESHAP, OEPA and ODH regulations, an owner or operator of a facility must thoroughly inspect a facility for the presence, type, quantity and condition of ACM where demolition or renovation activities will occur. ACM is any material that contains more than one percent asbestos.

The U.S. EPA and OSHA requires the use of Asbestos Hazard Emergency Response Act (AHERA) sampling protocols for building surveys to ensure a thorough survey of the facility is conducted.

PARS used these sampling protocols and requirements, in part, to determine the completeness and/or validity of previous asbestos assessments conducted on this building.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=29:6.1.1.1.1.1.1.2&idno=29 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=29:6.1.1.1.1.1.1.2&idno=29 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=29:8.1.1.1.1.26.25.2&idno=29 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div6&view=text&node=40:8.0.1.1.1.13&idno=40 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div6&view=text&node=40:8.0.1.1.1.13&idno=40 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr171_main_02.tpl http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title49/49cfr171_main_02.tpl http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=3579d9bd7cb58870fc402a65e98f3317&rgn=div6&view=text&node=49:2.1.1.3.8.7&idno=49 http://www.odh.ohio.gov/rules/final/f3701-34.aspx http://www.epa.ohio.gov/dapc/regs/3745_20.aspx http://www.epa.ohio.gov/dapc/regs/3745_20.aspx

4.0 BUILDING RECONNAISSANCE

Prior to performing the building reconnaissance, available historical asbestos reports and records were provided for review of Building #27. The documents are included in Appendix A. The contents of the historical asbestos reports were compared to the findings of the building reconnaissance to determine what, if any, additional assessment is necessary to comply with current applicable regulations for renovation and/or demolition.

During the review, suspected ACM were grouped into homogeneous areas. A homogeneous area contains material that is uniform in color and texture.

Wade C. Morris, Ohio-Certified Asbestos Hazard Evaluation Specialist (No. ES35408), conducted the site reconnaissance on May 18, 2012, and determined that fifteen (15) homogeneous areas (in accessible areas of the building) exist in or on this building. Table 1 inventories these homogeneous areas.

5.0 FINDINGS

Based on historical bulk sampling activities and laboratory reports and the reconnaissance of this building, homogeneous areas were further classified as ACM, non-ACM, or presumed ACM (PACM). PACM is the classification used when no bulk samples, or an insufficient amount of bulk samples were collected per regulations to adequately determine if the suspect material is ACM. Table 1 presents the findings of this review. The quantities are general estimates and should only be used for general estimation purposes.

Table 1. Summary of ACM and PACM at Building 27

Hom.

Area

ID

Homogeneous Area Location(s)

Identified in Historical

Survey Report?

ACM/

Non-

ACM/

PACMa

Photob Approx.

Quantity

Action Required

Approx.

Abatement

Costc

12”x12”pinkish floor tile w/ associated mastic Section 5 No PACM 1 550 ft2

Complete Assessmentd

$1,238

12”x12” tan textured floor tile w/ associated mastic

Section 5 No PACM 1 250 ft2 Complete

Assessment $563

12”x12” orange floor tile w/ associated mastic Section 5 No PACM 2 1,000 ft2

Complete Assessment

$2,250

4 1.5’x4’ tectum ceiling tile Sections 1, 2 and 3 No PACM 4 70,000 ft2

Complete Assessment

$140,000

Thermal System

Insulation (TSI) – Aircell Section 3 Yes ACM 5 750 ft2 None $7,500

6 TSI – Mud fittings Section 3 Yes ACM 5 250 each None $6,250

Drywall and joint compound Sections 4 and

No PACM 6 10,000 ft2

Complete Assessment

$45,000

8 Tan cove base mastic Section 4 No PACM 6 200 ft Complete

Assessment $400

9 Grey cove base mastic Section 4 No PACM 7 200 ft Complete

Assessment $400

10 Fire doors (standard size) Throughout structure No PACM 8 20 each

Complete Assessment

$2,000

11 Fire doors (industrial size) Throughout structure No PACM 8 2 each

Complete Assessment

$400

12 Floor filler Throughout structure No PACM 2 13,900 ft2

Complete Assessment

$55,600

13 Window glazing Sections 1 and

No PACM 9 windows

Complete Assessment

$30,000

14 Blown-in insulation Throughout structure No PACM -- 139,000 ft2

Complete Assessment

$41,700

15 Roofing material Throughout structure No PACM -- 139,000 ft2

Complete Assessment

$278,000 aACM/Non-ACM/PACM – As determined from historical laboratory results.

bPhotographs are presented in Appendix A cApproximate abatement cost does not include the cost for the required asbestos survey.

d Complete Assessment – Homogeneous area was not identified in historical survey reports and requires a complete assessment to determine as ACM or Non-ACM.

6.0 SURVEY ESTIMATE

According to NESHAP, OEPA and ODH regulations, an owner or operator of a facility must thoroughly inspect a facility for the presence, type, quantity and condition of ACM where demolition or renovation activities will occur. PARS estimates the cost of a full asbestos survey (survey, sampling, and report) for Building #27 to be approximately $4,100. This is a rough estimate only and should not be construed as a cost proposal. Additional samples may be necessary depending on site conditions.

7.0 CONCLUSIONS

The historical asbestos documents are not compliant with current regulatory requirements applicable to renovation and/or demolition activities at Building #27.

In addition to the required actions listed in Table 1, the following information is needed:

a) Findings of an intrusive investigation for ACM.

b) Bulk sample chains-of-custody.

8.0 LIMITATIONS

This review was limited to available historical asbestos reports, records, and the reconnaissance of accessible areas of the building and, therefore, is subject to change as further investigation is performed. Sampling was not part of the SOW and therefore, ACM may be present in concealed areas.

9.0 RELIANCE

The information contained herein was compiled from historical asbestos documentation supplied by DLA-DSCC and is assumed to be reliable for the time the information was gathered. This report is for the benefit of DLA-DSCC for informational purposes only. Reliance on this document by any other party is forbidden without the written consent of PARS and that party's acceptance of mutually agreeable terms and conditions. Use of this report for purposes beyond those reasonably intended by PARS Environmental will be at the sole risk of that party.

APPENDIX A

Site Photographs

Photograph 1:

12”x12” pinkish and 12”x12” tan textured floor tiles w/ associated mastic as found in restrooms in section 5 of Building #27.

Photograph 2:

12”x12” orange floor tile w/ associated mastic and floor filler (indicated by red arrow) as found in the gymnasium in section 5 of Building #27.

Photograph 3:

2’x4’ textured fiberglass ceiling tiles (old & new) as found in restrooms in section 5 of Building #27.

Photograph 4:

1.5’x4’ tectum ceiling tiles as found in restrooms in sections 1-3 of Building #27.

Photograph 5:

TSI – aircell and mud fittings as found in the section 3 of Building #27.

**Note both the damaged aircell and exposed mud fitting as indicated by the red arrows.

Photograph 6:

Drywall and joint compound, and tan cove base mastic as found in section 4 of Building #27.

Photograph 7:

Grey cove base mastic indicated by red arrow as found in section 4 of Building #27.

Photograph 8:

Standard and industrial-sized fire doors as found in section 2 of Building #27.

Photograph 9:

Window glazing as found in section 2 of Building #27.

APPENDIX B

Available Historical Asbestos Survey Data

LIMITED ASBESTOS-CONTAINING MATERIAL REVIEW – BUILDING #27