Exh_-_C__HAZMAT_Survey._pg._1-28.pdf

TEMF Renovations – Building 26041 Fort Hood, Texas

Submittal

Submittal 2019

Attachment I Asbestos Survey Report-Bulk Sample Data Sheets and Lead Based Paint Survey Report

ASBESTOS SURVEY &

LEAD-BASED PAINT SURVEY

FORT HOOD, TX

TEMF 26041

KENALL FREESE & NICHOLS - JV

CONTRACT # W9126G17D0017

TASK ORDER # W9126G17F0110

KENALL JOB # 8018

PREPARED FOR:

KFNI - JV

6200 SAVOY DRIVE, SUITE 600

HOUSTON, TX 77036

PREPARED BY:

MICRO AIR OF TEXAS, INC.

P. O. Box 1225

Dickinson, TX 77539

(281) 280-9965

Eric Eitzen, I.H. Melissa Kiser, I.H.

EPA Certified Asbestos Inspector EPA Certified Asbestos Inspector

DSHS Licensed Asbestos Consultant DSHS Licensed Asbestos Consultant

EPA Certified Lead Inspector EPA Certified Lead Inspector

DSHS Licensed Lead Inspector EPA Certified Lead Risk Assessor

DSHS Licensed Lead Risk Assessor

DECEMBER, 2018

TABLE OF CONTENTS

I. Comprehensive Asbestos and Lead-Based Paint Survey Report

A. General Survey Information Facility Description Background Information Asbestos Sampling Methodology Lead-Based Paint Sampling Methodology Limitations

B. Comprehensive Asbestos Survey Findings Executive Summary of Findings Summary of the Comprehensive Asbestos Survey Homogeneous Material Sampling Area Summary

C. Lead-Based Paint Survey Findings Executive Summary of Findings Paint Sampling Summary Table

D. Conclusions / Recommendations Asbestos-Containing Materials Lead-Based Paint Other Environmental Issues

II. Photographs

III. Sample Location Drawing

IV. Laboratory Reports

V. Applicable DSHS License(s)

Appendix 1

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 1

Asbestos Survey and

Lead-Based Paint Survey

A. General Survey Information

This Asbestos Survey and Lead-Based Paint Survey was prepared for Kenall Freese and Nichols, JV

(KF&N, JV), as a portion of the design phase work they are contracted to complete for the U.S.

Army Corps of Engineers Fort Worth Division. The facility referred to as Tactical Equipment

Maintenance Facility (TEMF) 26041 is located on Fort Hood Army Base located in Killeen, Texas, and this facility is scheduled to be renovated and brought up to current code. As such, KF&N, JV shall provide analysis, designs, and specifications to renovate each TEMF. Micro Air’s scope of work for this project was to provide a general “Hazmat” inspection, including potential asbestos and lead-based paint issues. The survey relates to sampling and analysis of suspect building materials for asbestos, as well as testing various painted surfaces and other fixtures for total lead content, both inside and outside of the building. This survey was performed on February 21, 2018. The scope of work is outlined below.

FACILITY DESCRIPTION

The scope of work for this survey includes all accessible interior and exterior portions of TEMF

Building 26041, with the exception of the roof, which was not included in the scope of work for this project. This building is a warehouse type structure that has certain sections that are two-story construction that contain office build-outs. The facility is approximately 19,592 square feet in size, comprised of a combination of CMU block and corrugated metal exterior walls. The floor is concrete throughout, and the roof of the building is metal, and it is constructed with I-beams. This building was constructed in 1980's, and it is currently used as a maintenance facility for various types of military vehicles. The building interior consisted of a combination of CMU, metal, and sheetrock walls. The roof deck and upper walls, located primarily in the Maintenance and Repair areas, had a sprayed-on insulation. The floors were generally covered with floor tile and an adhesive. Drop ceilings, consisting of ceiling tile and grid, were located throughout the office areas located in the building. Heating and cooling of the building was provided by a centralized system. Pipes were located above the drop ceiling in the shop office. All of the pipes appeared to be insulated with a fiberglass insulation, with the exception of the pipes located in Mechanical Room 111, and the pipe insulation in this room was foam. The air exhausts located in the Maintenance and Repair areas had rubber vibration joints. The rubber was not considered a suspect material for asbestos, and therefore, was not sampled. Access to the roof deck, including the overhead yellow crane, was not possible during this inspection due to the height of the deck.

BACKGROUND INFORMATION

Micro Air of Texas, Inc. was not provided with any previous asbestos or lead-based paint documentation. The authority to perform this inspection was provided by Mr. Ram Rao with Kenall, MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 2

Inc., and access to the building was provided by Fort Hood personnel working in the building.

ASBESTOS SAMPLING METHODOLOGY

The objective of this asbestos survey was to determine, as accurately as possible, the nature and extent of all accessible interior and exterior facility asbestos-containing material (ACM), through non-destructive sampling techniques. Therefore, no demolition of structures was performed in order to gain access to areas which were otherwise inaccessible.

Materials were grouped together into Homogeneous Sampling Areas with materials of similar appearance, function, and location. Samples of the suspect materials were collected in accordance with the Asbestos Hazard Emergency Response Act (AHERA), 40 CFR 763, Subpart E. Materials were collected in sufficient quantities to determine the potential asbestos content for each

Homogeneous Sampling Area. The Asbestos Inspectors used their experience and best judgement to determine the appropriate number of samples to collect of each type of suspect material, while adhering to all state and federal requirements for bulk sample collection. The sampling strategy was devised by the Asbestos Inspectors in an effort to collect enough data on which to base accurate conclusions, while keeping the total number of samples to a minimum.

The survey was performed by Melissa Kiser, licensed by the Texas Department of State Health

Services (TDSHS) as an Individual Asbestos Consultant (license # 10-5436) and Eric Eitzen, also licensed by the TDSHS as an Individual Asbestos Consultant (license #10-5349). Micro Air of

Texas, Inc. is licensed as an Asbestos Consulting Agency (license #10-0110) in the state of Texas.

All material samples were sealed in airtight containers and documented on field data forms. Strict chain of custody procedures were adhered to between the sample site and the laboratory. All samples were analyzed by J Resources, Inc., a Texas licensed (license #30-0273), NVLAP3 accredited (accreditation #200525-0) Asbestos Laboratory. Polarized Light Microscopy (PLM) was utilized to analyze the bulk samples (EPA Method 600/R-93/116), and standard quality control procedures were adhered to during the analyses. The laboratory analytical report is included in this section following the asbestos survey findings.

A total of 37 bulk material samples were collected from the subject site. All collected bulk samples were analyzed by PLM.

LEAD-BASED PAINT SAMPLING METHODOLOGY

This survey was conducted using a portable DELTA Tube Based Handheld X-Ray Fluorescence

Analyzer (XRF) (serial #540715) to determine the levels of lead present in painted surfaces. The

DELTA Handheld XRF analyzer uses X-ray tube sources, rather than radioactive isotope sources

(which are much slower at analysis, and the radioactive source weakens over time, requiring replacement of the radioactive source and / or factory re-calibrations). Additionally, based on the newer technology of the DELTA Handheld XRF and the fact that it does not use a radioactive source, a Performance Characteristic Sheet (PCS) does not exist for this type of XRF (required by

HUD regulations). The TEMF buildings do not fall under the HUD regulatory requirements. The

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 3

XRF utilized for this lead inspection was factory calibrated by Olympus Scientific Solutions

Americas on March 15, 2017 (see Appendix 1 for additional information). Field calibrations are conducted on known concentrations of lead before and after the XRF is used for testing in the field.

The absolute sensitivity for this particular model DELTA Handheld XRF is 0.0001 mg/cm (also2 known as the LOD or Limit of Detection).

The objective of this lead survey was to determine, as accurately as possible, the nature and extent of all paint which may be lead-containing. Paints were grouped by the “Room Equivalent” (room number / function, etc.), “Building Component” (wall, door, window frame, etc.), “Substrate”

(plaster, metal, wood, brick, etc.), and “Paint Color”. This survey was conducted by Eric Eitzen, an

EPA Certified Lead Inspector and a Texas Department of State Health Services (DSHS) Certified

Lead Inspector (Certification # 2060568), who was assisted by Melissa Kiser, an EPA Certified Lead

Inspector and Lead Risk Assessor and a Texas Department of State Health Services Certified Risk

Assessor (Certification #2070957). Micro Air of Texas, Inc. is licensed by the DSHS as a Lead Firm in the state of Texas (TDSHS license #2110550).

The Department of Housing and Urban Development (HUD) testing protocol was not used for this inspection, as this facility is not considered to be included in the definition of “Target Housing” or

“Child-Occupied Facility”; therefore, not every painted surface of every Room Equivalent was tested. A total of 77 XRF readings were collected at this facility during this inspection.

LIMITATIONS

Micro Air’s scope of services was limited primarily to accessible interior and exterior building materials. While Micro Air made every effort to perform a thorough survey, the possibility exists that materials containing asbestos were not identified, inaccessible (i.e., pipes located in walls, chases, or above plaster ceilings), or different from those identified at other locations. The findings and opinions presented are indicative of conditions on the date of our site inspection and should not be relied upon to represent conditions at substantially later dates, due to possible changes in the condition of building materials, renovations, and repairs. Micro Air could not obtain access to the upper roof deck, including the overhead yellow crane. Additionally, Rooms 101, 104, 107, and 112 were locked and unaccessible at the time of this inspection.

The asbestos and lead-based paint surveys performed at this facility were not designed to determine exact quantities of asbestos-containing materials (ACM) or lead-based paint (LBP), nor to develop removal cost estimates. This survey report is limited primarily to those building materials located inside and outside TEMF Building 26041 that were accessible at the time of this survey. This report is for the exclusive use of the client and its agents; any use by unauthorized parties in whole or in part, except as directed by legal jurisdiction, is at the sole risk of the user.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 4

B. Comprehensive Asbestos Survey Findings

Executive Summary of Findings

There were found NO asbestos-containing materials (ACM) identified during this asbestos survey.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 5

SUMMARY OF THE COMPREHENSIVE ASBESTOS SURVEY

TEMF BUILDING 26041 - FORT HOOD; KILLEEN, TEXAS

BUILDING

MATERIAL

HA # # OF

SAMPLES

COLLECTED

ASBESTOS-

CONTAINING

MATERIAL?

LOCATION

Sprayed-On Deck

Insulation

HA-01 8 No Located in the

Maintenance &

Repair Areas primarily

Pipe Insulation, Straight Runs

HA-02 3 No Located in the Shop

Office above the drop ceiling

Pipe Fitting Insulation with White Mastic

HA-03 3 No Located in Mech Rm

123 and in the Shop

Office

HVAC Duct Insulation with White Mastic

HA-04 3 No Located in the

Mechanical Rooms

103, 111, & 123

2' x 2' White

Ceiling Tile

HA-05 2 No Located in the West

Shop Office and In

Rm 124

12" x 12" White

Floor Tile

HA-06 5 No Located throughout the building in various locations

Sheetrock, Joint

Compound, and Texture

HA-07 4 No Located throughout the building in various locations

Cove Base Adhesive HA-08 4 No Located throughout the building in various locations

Exterior CMU Joint

Caulking

HA-09 3 No Located on the

Exterior of the building in various locations

Exterior Caulking by

Exterior Pipe Penetration

HA-10 1 No Located on the

Exterior of the

Building by Mech Rm

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 6

SUMMARY OF THE COMPREHENSIVE ASBESTOS SURVEY

TEMF BUILDING 26041 - FORT HOOD; KILLEEN, TEXAS

BUILDING

MATERIAL

HA # # OF

SAMPLES

COLLECTED

ASBESTOS-

CONTAINING

MATERIAL?

LOCATION

Red Fire Stop HA-11 1 No Located in Mech Rm

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 7

HOMOGENEOUS MATERIAL SAMPLING AREA SUMMARY

SURFACING MATERIALS

HA-01 Sprayed-On Deck Insulation

This homogeneous sampling area includes all sprayed-on deck insulation located primarily in the Maintenance and Repair areas of the building. A total of eight samples of this material were collected during this survey, and all of the samples tested negative for asbestos.

THERMAL SYSTEM INSULATING MATERIALS

HA-02 Pipe Straight Run Insulation

This homogeneous sampling area includes pipe straight run insulation located in the shop office above the drop ceiling. A total of three samples of this material were collected during this survey, and all of the samples tested negative for asbestos. It is possible, due to the age of the building, that older pipe insulation could be located behind brick walls, all of which were inaccessible at the time of this inspection without conducting destructive sampling. If during renovation activities, additional pipe insulation is found inside a wall chase, it should be assumed asbestos-containing until it can be tested and proven otherwise.

HA-03 Pipe Fitting Insulation with White Mastic

This material was found in Mechanical Room 123 and above the drop ceiling in the shop office. Three samples of this material were collected and analyzed, and it tested negative for asbestos. It is possible, due to the age of the building, that older pipe insulation could be located behind brick walls, all of which were inaccessible at the time of this inspection without conducting destructive sampling. If during renovation activities, additional pipe insulation is found inside a wall chase, it should be assumed asbestos-containing until it can be tested and proven otherwise.

HA-04 HVAC Duct Insulation with White Mastic

This material was found in Mechanical Room 123, 111, and 103. Three samples of this material were collected and analyzed, and it tested negative for asbestos.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 8

MISCELLANEOUS MATERIALS

HA-05 2' x 2' White Ceiling Tile

This material was found in the West Side Shop Office and in Room 124. Two samples of this material were collected and analyzed, and this material was found not to be asbestos-containing.

HA-06 12"x 12" White Floor Tile

This homogeneous sampling area is located in various locations on both the first and second floors of the building. Five samples of this material were collected and analyzed, and this material was found not to be asbestos-containing.

HA-07 Sheetrock, Joint Compound, and Texture

This material was found in various locations throughout the building. Four samples of this material were collected and analyzed, and all of the samples tested negative for asbestos.

HA-08 Cove Base Adhesive

This material was found in various locations of the building, including Room 117, Room 109, Room 101, and on the second floor in the Maintenance Area. Four samples of this material were collected and analyzed, and it was found to be negative for asbestos.

HA-09 Exterior CMU Joint Caulking

This material was found on the exterior of the building near Mechanical Room 123, the

North Side of the building, and the East End of the Repair Area. Three samples of this material were collected and analyzed, and it was found to be negative for asbestos.

HA-10 Caulking on Exterior of Building at Pipe Penetration

This homogeneous area was found on the exterior of the building by Mechanical Room

123 where the pipes penetrate the exterior wall. One sample of this material was collected and analyzed, and it tested negative for asbestos.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 9

HA-11 Red Fire Stop

This homogeneous area was found in Mechanical Room 123. One sample of this homogenous area was collected and analyzed, and the material was found to be negative for asbestos.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 10

C. Lead-Based Paint Survey Findings

Executive Summary of Findings

According to the HUD Lead-based Paint Interim Guidelines for Hazard Identification and 40 CFR Part

745, Environmental Protection Agency Lead-based Paint in Target Housing and Child-Occupied

Facilities, the definition of lead-based paint is paint which has a lead content of 5000 mg/kg (0.5% by weight) or greater, or 1.0 milligrams per square centimeter (mg/cm ) of painted surface area. All XRF2 results have been reported in mg/cm (weight of lead per surface area). There were 13 XRF readings2 on various building components with results greater than 0.00 mg/cm (LOD for this group of XRF2 readings was 0.001 mg/cm ). A total of 77 XRF readings were collected during this lead-based paint2 inspection. Below is a summary of the sample locations and results for the XRF testing.

XRF LEAD-BASED PAINT SAMPLING

SUMMARY TABLE

FORT HOOD - TEMF BUILDING 26041

Sample ID # Room

Equivalent

Component Substrate Color XRF Result

(mg/cm )2

L01 Mechanical

Room # 123

Door Metal Brown 0.0

L02 Mechanical

Room # 123

Door Frame Metal Brown 0.0

L03 Mechanical

Room # 123

South Wall CMU Block White 0.0

L04 Mechanical

Room # 123

Sprinkler Pipe Metal Red 0.0

L05 Mechanical

Room # 123

Water Heater Metal Gray 0.0

L06 Mechanical

Room # 123

Electrical

Panel

Metal Gray 0.0

L07 Mechanical

Room # 123

Column Metal White 0.0

L08 Mechanical

Room # 123

Gas Line Metal Yellow 0.0

L09 Mechanical

Room # 123

Air

Compressor

Metal Tan 0.0

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 11

Sample ID # Room

Equivalent

Component Substrate Color XRF Result

(mg/cm )2

L10 Exterior South

Side

Gas Line Metal Yellow 0.0

L11 Exterior South

Side

Bumper Post Concrete Yellow 0.02

L12 Exterior South

Side

South Wall CMU Block Yellow 0.0

L13 South Repair

Area

Bumper Post Concrete Yellow 0.13

L14 South Repair

Area

Exterior

Siding

Metal Yellow 0.04

L15 South Repair

Area

Gutter Metal White 0.0

L16 South Repair

Area

Overhead

Door

Metal Brown 0.0

L17 South Repair

Area

Overhead

Door Frame

Metal Brown 0.0

L18 South Repair

Area

Threshold Metal Red 0.90

L19 South Repair

Area

Southeast

Door

Metal Brown 0.0

L20 South Repair

Area

Southeast

Door Frame

Metal Brown 0.0

L21 South Repair

Area

Southeast

Floor

Concrete Yellow 3.7

L22 Room 124 South Wall Sheetrock White 0.0

L23 Room 124 North Wall CMU Block White 0.0

L24 Repair Area North

Overhead

Door

Metal Silver 0.0

L25 Repair Area North

Overhead

Door Frame

Metal Black 0.0

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 12

Equivalent

Component Substrate Color XRF Result

(mg/cm )2

L26 Repair Area North Column Metal White 0.05

L27 Repair Area North Door

Threshold

Metal Red 1.36

L28 North Exit by

Repair Area

Bumper Post Concrete Yellow 1.24

L29 North Exit by

Repair Area

East Wall CMU Block Yellow 0.0

L30 Repair Area

Northeast End

Pipe Metal Red 0.0

L31 Repair Area East Door Metal Brown 0.0

L32 Repair Area East Door

Frame

Metal Brown 0.0

L33 Repair Area

East End

North Wall CMU Block White 0.0

L34 Repair Area

East End

Exhaust Fan

Base

Concrete White 0.0

L35 Repair Area

South Side

Wall Metal with

Spray-On

Gray 0.0

L36 Repair Area

North Side

Air Hose Reel Metal Red 0.0

L37 Main Area Bumper Post Concrete Yellow 4.74

L38 North End

Main Area

Sprinkler Pipe Metal Red 0.0

L39 Main Area Overhead

Door Frame

Metal Brown 0.0

L40 Exterior North

Side

Staircase Metal Brown 0.06

L41 Exterior North

Side

Columns

Under Stairs

Metal Brown 0.08

L42 Exterior North

Side by 103

Mech Room

Handrails Metal Brown 0.05

L43 Mechanical

Room 103

North Wall Sheetrock White 0.0

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 13

Equivalent

Component Substrate Color XRF Result

(mg/cm )2

L44 Mechanical

Room 103

South Wall CMU Block White 0.0

L45 Mechanical

Room 103

Fire Alarm

Pull Box

Metal Red 0.0

L46 2 Floor, Northnd

End

East Wall Sheetrock White 0.0

L47 Shop Office Door Metal Brown 0.0

L48 Shop Office Door Frame Metal Brown 0.0

L49 Shop Office Fire Alarm

Box

Metal Red 0.0

L50 Shop Office West Wall Sheetrock White 0.0

L51 Shop Office First Aid Box Metal White 0.0

L52 Shop Office

Men’s Restroom

Floor Ceramic Tile Gray 0.0

L53 Shop Office

Men’s Restroom

Sink Porcelaine White 0.0

L54 Shop Office

Men’s Restroom

Toilet Porcelaine White 0.0

L55 Shop Office

Men’s Restroom

Lockers Metal Gray 0.0

L56 Room 103 North Wall Sheetrock White 0.0

L57 Room 105 East Wall CMU Block White 0.0

L58 Room 105 Ceiling Sheetrock White 0.0

L59 Room 105 Door Metal Brown 0.0

L60 Room 105 Door Frame Door Frame Brown 0.0

L61 Room 106 East Wall CMU Block White 0.0

L62 Room 106 North Wall Sheetrock White 0.0

L63 Room 110 Door Metal Brown 0.0

L64 Room 110 Door Frame Metal Brown 0.0

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 14

Equivalent

Component Substrate Color XRF Result

(mg/cm )2

L65 Room 110 South Wall Sheetrock White 0.0

L66 Bay Area Exhaust Fan

Base

Concrete White 0.0

L67 Bay Area West

Overhead

Door

Metal Silver 0.0

L68 Bay Area Column Metal White 0.0

L69 Bay Area Air Hose Reel Metal Red 0.0

L70 Bay Area Fire Alarm

Junction Box

Metal Red 0.0

L71 Mechanical

Room 111

East Wall CMU Block White 0.0

L72 Mechanical

Room 111

South Wall Sheetrock White 0.0

L73 Bay Area Pipe Above

Offices

Metal Yellow 0.0

L74 Shop Office I-Beam Above

Ceiling Tile

Metal Olive Green 0.04

L75 Shop Office Sprinkler Pipe Metal Red 0.0

L76 Bay Area Pipe Above

Office

Metal Yellow 0.0

L77 Bay Area Foam

Insulation

Foam Gray 0.0

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 15

D. Conclusions / Recommendations

ASBESTOS

This comprehensive asbestos survey determined that there were NO asbestos-containing materials identified at the time of this asbestos inspection. It is possible, due to the age of the building, that older pipe insulation could be located behind CMU walls or above plaster ceilings, all of which were inaccessible at the time of this inspection without conducting destructive sampling. If during renovation activities, additional pipe insulation is found inside a wall chase, it should be assumed asbestos-containing until it can be tested and proven otherwise.

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 16

LEAD-BASED PAINT

According to the HUD Lead-Based Paint Interim Guidelines for Hazard Identification and 40 CFR Part

745, Environmental Protection Agency Lead-based Paint in Target Housing and Child Occupied

Facilities, the definition of Lead-Based Paint is paint (or surface coating) which has a lead content of

5000 mg/kg (0.5% by weight) or greater, or 1.0 milligrams per square centimeter (mg/cm ), and this2 standard applies to “Target Housing” and “Child-Occupied Facilities”. The HUD Guidelines define

Target Housing as “any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is six years of age or younger resides or is expected to reside in such housing) or any zero bedroom dwelling”. A Child-Occupied Facility is defined as “a building or part of a building constructed before 1978, including but not limited to, a day-care center, preschool, or kindergarten classroom, that is visited regularly by the same child, six years of age or younger, at least two days in any calendar week if the visits are for at least three hours each day and 60 hours each year”. At this time, the above referenced HUD regulations do not apply to the building inspected in this survey because it does not meet either definition of “Target Housing” or “Child-Occupied

Facility”.

There are currently no federal or state regulations requiring abatement of lead-based paint in buildings which are not considered to be Target Housing or Child Occupied Facilities; however, state and federal disposal requirements apply to all demolished structures that include lead-based paint components.

If any structural components of the building that have lead-based paint are going to be demolished and disposed of, the paint from these substrates must be further tested prior to demolition and disposal for leachable lead (TCLP analysis), which will determine whether any hazardous waste disposal requirements apply.

It should be noted that the OSHA Construction Industry Standard, 29 CFR, 1926.62 does apply to any employee involved with demolition / renovation work that might occur in the above building. The

Construction Industry Standard for Lead regulates occupational exposures to airborne lead, which includes demolition or salvage of structures where lead or materials containing lead are present, and any amount of lead present in painted surfaces, including those which fall below the above definition of lead-based paint, could result in regulated occupational exposures and should therefore be monitored according to OSHA 1926.62 whenever they are disturbed in a manner that could result in exposure to airborne lead particulates. It is the responsibility of the employer to comply with 29 CFR,

1926.62 to protect the safety and health of his / her employees involved in the demolition or renovation of the structure. According to OSHA, the Permissible Exposure Limit (PEL) for lead is 50 micrograms per cubic meter (μg/m ) (8 hour Time Weighted Average (TWA)) with an action limit of 30 μg/m 83 3 hour TWA.

Federal employees who are not covered by 29 CFR, 1926.62 (i.e., those that are involved in non-construction / demolition related work) are subject to the OSHA General Industry Standard, 29 CFR,

1910.1025. This standard was promulgated by OSHA to protect workers who could potentially be exposed to inorganic lead, including metallic lead, all inorganic compounds, and organic lead soaps.

Again, the occupational exposure to inorganic lead is to be limited to 50 micrograms per cubic meter

(μg/m ), on an 8-hour Time-Weighted Average.3

MICRO AIR OF TEXAS, INC. Fort Hood; Killeen, TX - TEMF 26041 17

A total of 77 XRF readings were collected during this lead-based paint inspection. There were a total of 13 XRF readings on various building components with results greater than 0.00 mg/mg/cm (LOD2 for this group of XRF readings was 0.001 mg/cm ). 2

OTHER ENVIRONMENTAL ISSUES

There were no other environmental issues identified at the time of this building inspection. All interior lighting present was fluorescent light fixtures that did not appear to be very old. It is therefore unlikely that the fluorescent light ballasts in these fixtures would contain polychlorinated biphenyls (PCBs);

however, such cannot be ruled out without performing further investigation and/or testing. There were no lighting fixtures on the interior or exterior of the building that were observed to be of the mercury-lamp type, nor were there any thermostats observed to contain mercury.

SECTION II

PHOTOGRAPHS

TEMF BUILDING 26041

PHOTO PLATES OF

LEAD-CONTAINING PAINT

LOCATED INSIDE & OUTSIDE TEMF

BUILDING 26041 AT FORT HOOD

Photo 1 This photo depicts a typical yellow concrete bumper located inside and outside the Maintenance and Repair areas of the building. The yellow paint is lead-containing.

Photo 2 This photo depicts a typical yellow stripe painted on the concrete floor located inside the Maintenance and Repair areas of the building. The yellow paint is lead-containing.

Photo 3 At the bottom of many of the overhead doors, the threshold is made of metal and it has been painted with a red paint. This paint is lead-containing.

PHOTO 1

PHOTO 2

PHOTO 3

SECTION III