AMD 3 EIE439-Hazardous Materials Assessment-RTA.pdf

Eielson Fuels Management Lab Demolition Page 1 of 22

HAZARDOUS MATERIALS

ASSESSMENT

EIELSON FUELS MANAGEMENT LAB

EIELSON, ALASKA

Surveyed August 16-17, 2023

Report Date

October 10, 2023

Revised Date May 21, 2024

EHS-ALASKA, INC.

ENGINEERING, HEALTH & SAFETY CONSULTANTS

11901 BUSINESS BLVD., SUITE 208

EAGLE RIVER, ALASKA 99577-7701

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HAZARDOUS MATERIALS ASSESSMENT

TABLE OF CONTENTS

PAGE NO.

OVERVIEW

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

B. BUILDING DESCRIPTION

C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

2. Lead-Containing Materials

3. Testing of Paints and Sealants for PCB’s

4. Separate Hazardous Materials Sampling Conducted by HTRW LLC

D. SURVEY RESULTS

1. Asbestos-Containing Materials

2. Asbestos in Dusts

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

F. RECOMMENDATIONS

1. Asbestos-Containing Materials

2. Dusts with Asbestos

3. Lead-Containing Materials

4. PCB-Containing Materials

5. Mercury-Containing Materials

6. Other Hazardous Materials

G. LIMITATIONS

1. Accuracy of Information

2. Site Conditions

3. Changing Regulatory Constraints

APPENDICES

Appendix A ......................................................... Asbestos Bulk Field Survey Data Sheets and Lab Reports Appendix B ................................................... Bulk Product PCB Field Survey Data Sheets and Lab Reports Appendix C .......................................................................................................... Lead Analyzer Test Results Appendix D ..................................................................................................... Drawings of Sample Locations Appendix E .................................................................... Extracts From Sampling Conducted by HTRW, LLC

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HAZARDOUS MATERIALS ASSESSMENT

OVERVIEW

Fuels Management Lab, (Building 3242, and the adjacent Moveable Storage Building) located in Eielson, Alaska, was surveyed for the presence of asbestos-containing materials (ACM), and other potentially hazardous materials as a part of the design services for the Fuels Management Lab Demolition Project at the building for the United States Air Force. The survey also provided a “good faith” inspection for hazardous materials that may be disturbed during the construction. The proposed work includes the disturbance, demolition, removal and disposal of lead-containing paints and/or lead-containing materials that is incidental to the demolition project. Mr. John H. Lamont of EHS-Alaska, Inc. (EHS-Alaska) conducted the inspection in August 2023. This revised report includes additional “extracts” from sampling conducted by HTRW, LLC, for a separate project.

A. GENERALIZED REQUIREMENTS FOR HAZARDOUS MATERIALS

Potentially hazardous materials have been identified in the Fuels Management Lab (B3242) and the Moveable Storage Building that will be affected by the proposed demolitions. Those materials include asbestos, lead, polychlorinated bi-phenyls (PCBs), mercury, and radioactive materials. Not all materials were tested for potentially hazardous components, other potentially hazardous materials, including those exterior to the building, such as contamination from underground fuel tanks may be present, but are not part of this report.

Buildings or portions of buildings that were constructed prior to 1978 which are residences, or contain day care facilities, kindergarten classes or other activities frequently visited by children under 6 years of age are classified as child occupied facilities. All work which is NOT classified as “minor repair and maintenance activities” (as defined by the regulations), that takes place in the “child occupied” portions of facilities must comply with the requirements of 40 CFR 745. This building is not classified as a child occupied facility and therefore the requirements of 40 CFR 745 are not applicable.

Only the materials that will be directly affected by this project are required to be removed. The quantities and types of materials are incorporated into the design documents for this renovation. It is the Contractor’s responsibility to take this baseline data to coordinate and fully develop a hazardous materials removal design that will identify the presence, locations and quantities of asbestos and/or other hazardous materials that will be affected by this project. The removal and disposal of potentially hazardous materials are highly regulated, and it is anticipated that removal and disposal of asbestos, lead and chemical hazards will be conducted by a subcontractor to the general contractor who is qualified for such removal. It is anticipated that the general contractor and other trades will be able to conduct their work using engineering controls and work practices to control worker exposure and to keep airborne contaminants out of occupied areas of the building.

Settled and concealed dusts in areas not subject to routine cleaning are present throughout the building, including the roof, and inside and on top of architectural, mechanical, electrical, and structural elements, and those dusts are assumed to contain regulated air contaminants. This should not be read to imply that there is an existing hazard to building occupants (normal occupants of the building as opposed to construction workers working in the affected areas). However, depending on the specific work items involved and on the means and methods employed when working in the affected areas, construction workers could be exposed to regulated air contaminants from those dusts in excess of the OSHA Permissible Exposure Limits (PELs).

The settled and concealed dusts were examined by an EPA Certified Building Inspector but were not sampled. The inspector determined that the dusts are not “asbestos debris” from an asbestos-containing

Eielson Fuels Management Lab Demolition Page 4 of 22 building material (ACBM). Based on similar sampling from similar buildings, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM). Reference 40 CFR 763.83.

“Awareness training” (typically 2 hours) and possibly respiratory protection will be required for all Contractor Personnel who will be disturbing the dusts. The extent of the training and protective measures will depend upon the airborne concentrations measured during air monitoring of the contractors work force, which depends on the means and methods employed to control the dusts. The air monitoring may be discontinued following a “negative exposure assessment” showing that worker exposures are below the OSHA permissible exposure limits for the type of work and means and methods employed. Previous air monitoring from similar jobs with similar conditions may be used as historical data to establish a “negative exposure assessment”.

B. BUILDING DESCRIPTION

The Fuels Management Lab (B3242) was originally constructed in 1967 with various upgrades and repairs through the years. At some point an undocumented renovation occurred, with the previously removed walls still being present above the suspended ceiling tiles.

The interior partitions were primarily of framed construction. The interior walls were typically of gypsum wallboard with a vinyl wallpaper coated with a spray-applied texture. The gypsum wallboard was covered with a “Marlite” board on the restroom walls, and the gypsum wallboard was covered with ceramic wall tiles in the “kitchen” area. The original gypsum wallboard throughout the building had an asbestos-containing joint compound.

The exterior walls were of concrete masonry unit (CMU) walls furred out with gypsum wallboard on the interior. The roof was supported by open web steel trusses spanning off the exterior CMU walls supporting a metal deck with a corrugated metal roof.

Corridor and office room ceilings in the building were typically of 2’ x 2’ acoustic ceiling tiles. Toilets, storerooms, entrance vestibules, and the hidden ceiling above the suspended ceiling, had gypsum wallboard ceilings with asbestos-containing joint compound.

Floor finishes were mainly of carpet adhered to concrete with tan mastic contaminated with asbestos-containing remnant black mastic. There was a vinyl tile flooring in the restroom adhered to concrete with a black asbestos-containing mastic. Vinyl tile flooring and remnant asbestos-containing black mastic in some areas may also be covered with carpeting.

The building was heated by a hydronic heating system supplied throughout heat exchangers from the base steam utilidor system. The heating and domestic water piping was typically insulated with fiberglass covered by the PVC fitting covers. The piping in the mechanical room had "hard and chalky" asbestos-containing insulation on the valve covers and elbows, as well as asbestos-containing thermal system insulation on the pipe runs.

The Moveable Storage Building adjacent to the Fuels Management Lab (B3242) was constructed at an unknown date and most likely pre-fabricated off-site as it appeared to be a mobile temporary structure.

The interior and exterior partitions of the storage building were of framed construction. The walls were of faux wood wall panels with the main “laboratory” area having a second layer covered with moisture resistant fiber reinforced plastic (FRP) paneling, and the walls in the mechanical room were of unfinished gypsum wallboard. Ceilings in the building were interlocking cellulose panels over plywood, with an unfinished gypsum wallboard ceiling in the mechanical room. Floor finishes were mainly of sheet vinyl flooring over plywood, with a vinyl composite tile floor tile in the mechanical room. The building was heated by an electric furnace supplying heating and ventilation to the building. The roof of the building was nearly flat sheet metal with asbestos-containing mastics and sealants around the perimeter flashing and at penetration patching.

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C. SAMPLING AND ANALYSIS

1. Asbestos-Containing Materials

The samples were analyzed for the presence of asbestos using polarized light microscopy (PLM), analysis, as recommended by EPA, to determine the composition of suspected ACMs (EPA method 600/M4-82-020). Only materials containing more than 1% total asbestos were classified as “asbestos-containing” based on EPA and OSHA criteria. Samples analyzed to have less than 10% asbestos were “point-counted” by the laboratory for more accuracy. Samples listed as having a “Trace by Point Count” had asbestos fibers found in the material, but the fibers were not present at the counting grids. Table 1 in Part D below contains a summary list of the asbestos bulk samples and the applicable results.

The Bulk Asbestos samples were analyzed for asbestos content by International Asbestos Testing Laboratories (IATL), Mt. Laurel, New Jersey, a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.

EPA regulations under 40 CFR 763 require the use of PLM to determine whether or not a material contains asbestos. While PLM analysis does a good job for most materials, it does have some limitations. Fibers may be undetectable if their small size prevents visibility under a standard optical microscope, or if they are bound in an organic matrix to the point that the fibers are obscured. At the discretion of the building inspector and the client, some types of samples may be analyzed or re-analyzed by what is called Transmission Electron Microscopy for Non-Friable Organically Bound (TEM NOB) materials. TEM NOB is the definitive method for determining if asbestos is present, but TEM NOB use is not required by the EPA. TEM NOB analysis was not done for this project.

Field survey data sheets and laboratory reports of the bulk samples are included in Appendix A.

Drawings showing sample locations are included as Appendix D.

2. Lead-Containing Materials

Nearly all surfaces in the building were coated with paint and most surfaces had been repainted. EHS- Alaska tested representative paints throughout the affected areas of the building using a Heuresis Pb200i X-Ray Fluorescence (XRF) lead paint analyzer (Serial # 1770 with software version 4.0-21). The lead testing conducted was not a Lead-Based Paint Inspection or Screening as defined by Department of Housing and Urban Development (HUD) or EPA regulations, but was done to test surfaces that may be representative of those likely to be affected by this project. If surfaces and materials other than those tested are identified, the Contractor shall test and treat appropriately. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. All surfaces affected by this project may not have been tested and therefore additional sampling may be required to refute the presence of lead-containing materials regulated by 29 CFR 1926.62. The Lead Test Locations are shown in Appendix D.

EPA and HUD have defined lead-based paint as any paint or other surface coating that contains lead equal to or in excess of 1.0 milligram per square centimeter (mg/cm2) or 0.5 percent by weight. XRF results are classified as positive (lead is present at 1.0 mg/cm2 or greater), negative (less than 1.0 mg/cm2 of lead was present) or inconclusive (the XRF could not make a conclusive positive or negative determination). Tests that were invalid due to operator error are shown as void tests.

A Performance Characteristic Sheet (PCS) for the Heuresis Pb200i is available upon request. This PCS data provides supplemental information to be used in conjunction with Chapter 7 of the “HUD Guidelines”.

Performance parameters provided in the PCS are applicable when operating the instrument using the manufacturer’s instructions and the procedures described in Chapter 7 of the “HUD Guidelines”. The instrument was operated in accordance with manufacturer’s instructions and Chapter 7 of the HUD Guidelines. No substrate correction is required for this instrument. There is no inconclusive classification for this instrument when using the 1.0 mg/cm2 threshold.

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3. Testing of Paints and Sealants for PCB’s

Representative paint and sealant samples were collected and analyzed for total PCBs. Samples of paint were collected by scraping the paint down to bare substrate, or by cutting out a portion of the sealants.

Samples were analyzed for total PCBs by EMSL Analytical, Inc, 200 Route 130 North, Cinnaminson, New Jersey. Results of the total PCB analysis for each sample was used to determine if the dried paint or sealants are considered PCB bulk product waste. Field Survey Data Sheets and Lab results are included in Appendix B. A drawing showing sample locations are provided in Appendix D. Refer to the summary of additional sampling of suspect PCB Bulk Products conducted by HTRW, LLC located in Appendix E.

4. Separate Hazardous Materials Sampling Conducted by HTRW LLC.

A separate survey for hazardous materials was conducted in November 2023 by HTRW, LLC. related to the planned renovation project of Fuels Management Lab (B3242). The full report is available from the Alaska District of the United States Army, Corps of Engineers. Excerpts from that report are provided in Appendix E.

D. SURVEY RESULTS

1. Asbestos-Containing Materials

The following Table 1A lists the samples taken in August 2023 at the Fuels Management Lab (B3242), and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included as Appendix A. Refer to Appendix D for sample locations. Refer to the summary of additional sampling of suspect asbestos-containing materials conducted by HTRW, LLC located in Appendix E

TABLE 1A

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B3242-0823-A01 Off-white texture on CMU Exterior: southeast wall, on CMU block. Photo 362

None Detected

B3242-0823-A02 Off-white sealant Exterior: southeast window, between wood window frame and concrete sill. Photo 364

None Detected

B3242-0823-A03 Grey sealant Exterior: southeast window, between wood window frame and CMU wall. Photo 366

None Detected

B3242-0823-A04 Off-white texture on concrete Exterior: north window, on concrete sill. Photo 373

None Detected

B3242-0823-A05 White joint compound South entrance: southeast corner wall on paper over gypsum wall board. Photo 468

None Detected

B3242-0823-A06 WT-1: medium orange peel spray-applied wall texture on gypsum wall board

South entrance: southeast corner wall on gypsum wall board. Photo

None Detected

B3242-0823-A07 White gypsum wall board South entrance: southeast corner of room. Photo 468

None Detected

B3242-0823-A08 FT-1: beige 12x12 vinyl floor tile with off-white to brown streaks; with yellow mastic;

with remnant black mastic

Threshold between Restroom and Corridor: on concrete. Photo

Black Mastic = 1.0% Chrysotile;

Yellow Mastic=ND;

FT=ND

B3242-0823-A09 Yellow mastic to CPT-1: brown short shag; with remnant black mastic

Threshold between Corridor and Restroom: on concrete. Photo

Black Mastic = 1.1% Chrysotile;

Yellow Mastic=ND

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SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B3242-0823-A10 CB-1: brown 4” vinyl cove base; with brown mastic

Restroom: right side of door on “Marlite” panel. Photo 475

Both Layers None Detected

B3242-0823-A11 Brown mastic to CB-1; with remnant black flooring mastic

Restroom: right side of door on “Marlite” panel. Photo 475

Black Mastic = 1.4% Chrysotile;

Brown Mastic=ND

B3242-0823-A12 White joint compound; with white gypsum wall board

Restroom: east wall at light switch, gypsum wall board.

Photo 479

Joint Compound = 1.3% Chrysotile;

GWB = ND

B3242-0823-A13 Brown “Marlite” mastic Restroom: west wall adhering “Marlite” panel to gypsum wall board. Photo 485

10% Chrysotile

B3242-0823-A14 White sealant Restroom: west wall at top of “Marlite” panel to gypsum wall board. Photo 486

None Detected

B3242-0823-A15 Tan mastic Corridor: adhering furred gypsum wall board to west CMU wall. Photo

None Detected

B3242-0823-A16 Off-white gypsum wall board Corridor: on hidden gypsum ceiling above suspended ceiling system adjacent to lavatory. Photo 502

None Detected

B3242-0823-A17 LCT-2: textured 2’x2’ drop edge acoustic ceiling tile

Corridor: tile in suspended ceiling system adjacent to lavatory. Photo

None Detected

B3242-0823-A18 Light brown wallpaper mastic Corridor: at original vestibule entrance wall, adhering wallpaper to gypsum wall board. Photo 514

None Detected

B3242-0823-A19 Off-white joint compound Fuels Compliance Office: above suspended ceiling system original wall on metal nosing.

Photo 515

2.6% Chrysotile

B3242-0823-A20 Off-white joint compound;

with white gypsum wall board

Fuels Compliance Office: above suspended ceiling system at removed wall. Photo 517

Joint Compound = 0.25% Chrysotile;

GWB = ND

B3242-0823-A21 White joint compound Fuels Compliance Office: above suspended ceiling system at removed wall. Photo 517

None Detected

B3242-0823-A22 LCT-2: textured 2’x2’ drop edge acoustic ceiling tile

Corridor: tile in suspended ceiling system. Photo 534

None Detected

B3242-0823-A23 White joint compound Administration: west side of office above suspended ceiling system, on gypsum ceiling. Photo 540

None Detected

B3242-0823-A24 Tan mastic Administration: adhering furred gypsum wall board to CMU wall.

Photo 541

None Detected

B3242-0823-A25 Tan mastic to CPT-1: brown short shag; with remnant black mastic

Threshold between Administration and Communication Closet: on concrete. Photo 548

Black Mastic = 1.2% Chrysotile;

Tan Mastic=ND

B3242-0823-A26 Black tarry wood fiber joint filler

Threshold between Administration and Communication Closer:

between concrete pads. Photo 550

None Detected

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NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B3242-0823-A27 CB-2: black 4” vinyl cove base; with brown mastic; with white joint compound

Communication Closet: left side of door on gypsum wall board.

Photo 555

Joint Compound = 1.1% Chrysotile;

Brown Mastic=ND Cove Base=ND

B3242-0823-A28 Grey cementitious texture on

CMU

Communication Closet: left side of door on hidden CMU wall. Photo

None Detected

B3242-0823-A29 Grey sealant Communication Closet: left side of door, between metal door frame and CMU wall. Photo 560

1.1% Chrysotile

B3242-0823-A30 White joint compound; with white gypsum wall board

Kitchen: above suspended ceiling tile on original gypsum wall. Photo

Both Layers None Detected

B3242-0823-A31 White joint compound Kitchen: above suspended ceiling tile on gypsum wall. Photo 572

None Detected

B3242-0823-A32 LCT-3: 2’x2’ drop edge acoustic ceiling tile with random 1/4" fissures and 1/8” dense dot

Lab Office: center of room in suspended ceiling system. Photo

None Detected

B3242-0823-A33 White joint compound; with white gypsum wall board

Lab: on hidden gypsum ceiling above suspended ceiling system, 1st layer of gypsum. Photo 600

Both Layers None Detected

B3242-0823-A34 White joint compound Lab: on hidden gypsum ceiling above suspended ceiling system, 2nd layer of gypsum.

Photo 601

1.4% Chrysotile

B3242-0823-A35 Cream sink under coating Lab: bottom side of stainless steel double sink. Photo 613

None Detected

B3242-0823-A36 Cream construction adhesive Lab: between stainless steel double sink and lab countertop.

Photo 616

None Detected

B3242-0823-A37 CB-2: black 4” vinyl cove base; with cream mastic; with remnant black mastic; with grey leveling compound

Lab: threshold to Lab Office, on concrete. Photo 619

All Layers None Detected

B3242-0823-A38 Beige epoxy floor covering;

with grey leveling compound

Lab: threshold to Lab Office, on concrete. Photo 620

Both Layers None Detected

B3242-0823-A39 Grey leveling compound Lab: center of room at deteriorated flooring, on concrete. Photo 623

None Detected

B3242-0823-A40 Black lab countertop Lab: north side of room, black lab counter. Photo 626

None Detected

B3242-0823-A41 Black sealant Lab: north side of room, between black lab countertop and metal cabinetry. Photo 627

None Detected

B3242-0823-A42 WT-1: medium orange peel spray-applied wall texture on gypsum wall board

Fuels Compliance Office: north wall of office. Photo 629

None Detected

B3242-0823-A43 White joint compound Mechanical Room: west wall at nail head. Photo 639

1.3% Chrysotile

B3242-0823-A44 White joint compound Mechanical Room: west wall on gypsum wall. Photo 640

1.2% Chrysotile

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NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

B3242-0823-A45 Grey chalky hard fitting insulation

Mechanical Room: north side of room on domestic cold water line elbow. Photo 641

0.75% Chrysotile

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following materials have been found to contain asbestos in the Fuels Management Lab Building 3242 survey or previous surveys, or were assumed to contain asbestos.

1. Joint compound in gypsum wall board systems on the original ceilings and walls (confirmed asbestos-containing).

2. Black mastic of 12” x 12” floor tile (confirmed asbestos-containing).

3. Remnant black mastic under carpet (confirmed asbestos-containing).

4. Brown cove base mastic (contaminated by confirmed asbestos-containing black mastic).

5. Brown “Marlite” wainscot mastic (confirmed asbestos-containing).

6. Grey sealants at metal door frames to CMU block walls (confirmed asbestos-containing).

7. Hard and chalky insulation on pipe fittings (labeled as asbestos-containing).

8. T.S.I pipe insulation on pipe runs in the Mechanical Room and possibly within walls (labeled as asbestos-containing).

9. T.S.I insulation remnants at the Heat Exchanger, and assumed asbestos-containing insulation on the expansion tank in the Mechanical Room.

10. Flange gaskets on piping (assumed asbestos-containing).

11. Lab countertops (assumed asbestos-containing).

12. Exterior tarry damp-proofing (assumed asbestos-containing).

13. Assumed asbestos-containing patching tars and sealants at corrugated metal roofing (assumed asbestos-containing).

14. Assumed asbestos-containing underlayment under corrugated metal roofing (assumed asbestos-containing).

15. Assumed asbestos-containing vermiculite “block-fill” insulation in the un-grouted cells of the exterior CMU walls (assumed to be present and assumed to contain asbestos).

16. Light heat shields and insulated wires in the vestibules (confirmed asbestos-containing).

The effects of the above asbestos-containing materials on the proposed renovation are discussed below.

Joint Compound Joint compound on the original gypsum board walls, soffits and ceilings throughout the building contains asbestos. No asbestos has been detected in the gypsum board. The joint compound was in good condition and is not considered friable unless damaged. The joint compound will be removed by this project.

Black Mastic to Floor Tiles Black mastic to the vinyl floor tiles hidden under carpet throughout the project area contain asbestos. The floor tiles and mastics were mostly in good condition with a few localized areas of damage. The tile and mastic was not friable, and will be removed by this project.

Remnant Black Mastic Remnant black mastic underneath carpeting and on concrete floors throughout the building contains asbestos. The remnant black mastic likely originated from previously removed floor tiles mentioned previously in this report. The mastic was in good condition with few localized areas of damage. The mastic was not friable and will be removed by this project.

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Brown Mastic to Cove Base Mastics used to secure cove base to walls did not contain asbestos, but during sampling it was noted by the inspector that the brown mastics adhering the cove base to walls throughout the building were contaminated by an asbestos-containing black mastic which likely originated from the previously removed flooring. The mastic was in good condition with few localized areas of damage. The mastic was not friable and will be removed by this project.

“Marlite” Wainscot Mastics Mastics used to secure “Marlite” wainscots to walls contained asbestos. Mastics were in good condition and were not friable and will be removed by this project.

Door, Window and Penetration Sealants The sealants at door frames located at the CMU block walls had an asbestos-containing sealant, including around penetrations and window frames. The sealants are not friable and in good condition.

The sealants will be removed by this project.

Pipe Insulation Piping in the mechanical room was insulated with asbestos-containing insulation. Piping inspected in the rest of the project areas was insulated with fiberglass insulation. Piping was concealed above ceilings and walls in some areas. Due to the age of construction, some concealed asbestos-containing insulation may be uncovered during demolition. If any concealed piping is found to have hard and chalky or other insulation suspected of containing asbestos, those materials shall be sampled prior to disturbance. All piping will be removed by this project.

Pipe Fitting Insulation Piping in mechanical spaces and possibly concealed within walls was insulated at fittings with asbestos-containing insulation. The insulation was generally in good condition but is considered friable. A utilidor trench is assumed to contain pipes with asbestos containing insulation. The piping and the asbestos-containing insulation will be removed by this project. Pipe insulation in the utilidor will be removed as necessary to complete the work of this project.

Flange Gaskets and Valve Packing Due to their age, gaskets and valve packing on mechanical equipment throughout the building, but mostly in mechanical room are assumed to be asbestos-containing. These materials are difficult to sample without disassembly of equipment and consequently no sampling was performed. These materials were in good condition but may become friable during removal for replacement. The gaskets and packings will be removed by this project.

Laboratory Countertops and Backsplashes Black cement laboratory countertops and backsplashes in the laboratory are assumed to contain asbestos. This material was in good condition and was non friable and will be removed by this project.

Wall Damp-proofing Sealant An asbestos-containing damp-proofing sealant may have been used on the interior side of exterior CMU walls. The sealant is assumed to not be friable and in good condition. The sealants will be removed by this project.

Metal Roofing Sealants and Patching Tars Roofing over the building is a corrugated metal roof, which was not accessible by this survey. Patching tars and sealants which are assumed to be present at flashings, vents, and other equipment penetrating the roofing are assumed to contain asbestos and is assumed to not be friable. The roofing materials will be removed by this project.

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Roofing Underlayment The corrugated metal roofing was not accessible by this survey. An underlayment (tar paper or similar) is assumed to be present under the corrugated metal roofing and is assumed to contain asbestos, and is assumed to not be-friable. The roofing materials will be removed by this project.

Metal Roofing Sealants and Patching Tars Roofing over the building is a corrugated metal roof. Patching tars and sealants which are assumed to be present at flashings, vents, and other equipment penetrating the roofing are assumed to contain asbestos. The roofing materials will be removed by this project.

Vermiculite “Block-Fill” Insulation Vermiculite is assumed to be present inside the exterior CMU wall cells, and in accordance with EPA Guidance, is assumed to contain more than 1 percent asbestos and requires further investigation.

Vermiculite is friable, and is classified as RACM. The vermiculite if present will be need to be removed prior to demolition of the building.

Light Fixture Heat Sheilds Several incandescent light fixtures were identified that are shielded with an asbestos-containing heat shield. Although not tested during the initial survey, it is confirmed that wiring associated with these fixtures were also insulated with asbestos-containing insulation. This shield material was in good condition and is considered friable. Wiring insulation is in good condition and not friable. Both materials will be removed by this project.

Table 1B includes samples taken in August 2023 in the Moveable Storage Building, and the results of the laboratory analysis. Asbestos field survey data sheets and laboratory reports are included in Appendix A. Refer to Appendix D for sample locations.

TABLE 1B

SAMPLE

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

S-B342-0823-A01 White sealant Roof: southeast corner between metal flashing Photo 169

None Detected

S-B342-0823-A02 Black sealant Roof: east edge of roof, between galvanized steel and metal flashing. Photo 174

6.2% Chrysotile

S-B342-0823-A03 Silver sealant Roof: southwest side of roof, on metal deck. Photo 182

2.4% Chrysotile

S-B342-0823-A04 Black sealant Roof: southwest side of roof, at patch in roof. Photo 186

2.7% Chrysotile

S-B342-0823-A05 Black sealant; with silver sealant

Roof: southwest side of roof, black sealant over silver sealant on metal deck. Photo 187

3.5% Chrysotile

S-B342-0823-A06 White sealant; with silver sealant

Roof: south side of roof, between metal flashing and silver sealant on metal. Photo

1.3% Chrysotile

S-B342-0823-A07 Black sealant Roof: northwest edge of roof, between galvanized steel and metal flashing. Photo 195

5.9% Chrysotile

S-B342-0823-A08 Black sealant; with silver sealant

Roof: northwest side of roof, black sealant over silver sealant on metal deck. Photo 196

5.6% Chrysotile

S-B342-0823-A09 Black sealant Roof: northwest side of roof, on metal deck. Photo 198

5.2% Chrysotile

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NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

S-B342-0823-A10 White sealant Roof: northwest corner of roof, between metal flashings. Photo

None Detected

S-B342-0823-A11 Black fabric North wall of storage building: on rectangular metal duct flap. Photo

None Detected

S-B342-0823-A12 White sealant North wall of storage building: on rectangular metal duct and penetration through metal wall.

Photo 203

None Detected

S-B342-0823-A13 Off-white sealant East exterior wall of storage building: at south window penetration, between metal window frame and metal wall.

Photo 208

4.6% Chrysotile

S-B342-0823-A14 Off-white sealant East exterior wall of storage building: at north window penetration, between metal window frame and metal wall.

Photo 211

4.9% Chrysotile

S-B342-0823-A15 Black lab countertop East interior wall of storage building: north corner of lab counter. Photo 231

None Detected

S-B342-0823-A16 CB-1: beige 4” vinyl cove base; with cream mastic

Northwest interior wall of storage building: on FRP wall covering.

Photo 235

Both Layers None Detected

S-B342-0823-A17 SV-1: faux tile sheet vinyl flooring; with tan mastic; with remnant black mastic

Northwest interior wall of storage building: on plywood. Photo 238

Both Layers None Detected

S-B342-0823-A18 Off-white FRP wall mastic West interior wall of storage building: adhering FRP to faux wood wall panel. Photo 241

None Detected

S-B342-0823-A19 Black lab countertop East interior wall of storage building: south corner of lab counter. Photo 248

None Detected

S-B342-0823-A20 Off-white FRP wall mastic East interior wall of storage building: adhering FRP to faux wood wall panel. Photo 250

None Detected

S-B342-0823-A21 SV-1: faux tile sheet vinyl flooring; with tan mastic; with remnant black mastic

Southwest interior wall of storage building: on plywood. Photo 254

Both Layers None Detected

S-B342-0823-A22 CB-1: beige 4” vinyl cove base; with cream mastic

Southwest interior wall of storage building: on FRP wall covering.

Photo 255

Both Layers None Detected

S-B342-0823-A23 SV-2: off-white patterned sheet vinyl flooring; with cream mastic

Threshold between main area and smaller storage area: on plywood.

Photo 257

Both Layers None Detected

S-B342-0823-A24 White gypsum wall board Corner of gypsum wall in smaller storage area Photo 259

None Detected

S-B342-0823-A25 FT-1: off-white 12x12 vinyl floor tile; with black mastic

Mechanical Room: at base of furnace on plywood. Photo 268

None Detected

S-B342-0823-A26 White gypsum wall board Mechanical Room: north wall, gypsum wall board. Photo 272

Eielson Fuels Management Lab Demolition Page 13 of 22

NUMBER MATERIAL LOCATION ASBESTOS

CONTENT

S-B342-0823-A27 Hard white sealant (possibly white joint compound)

Mechanical Room: ceiling at stack penetration Photo 277

None Detected

The testing method used (polarized light microscopy [PLM]) is not consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials. Before this material can be considered or treated as non-asbestos containing, confirmation should be made by quantitative transmission electron microscopy (TEM).

The following materials have been found to contain asbestos in the Moveable Storage Building survey or previous surveys, or were assumed to contain asbestos.

1. Black and silver sealants at roof patches and edge flashing (confirmed asbestos-containing).

2. Off-white sealants at door and window penetrations (confirmed asbestos-containing).

3. Lab countertops (assumed asbestos-containing).

4. Fume hood cement asbestos board (assumed asbestos-containing).

The effects of the above asbestos-containing materials on the proposed renovation are discussed below.

Metal Roofing Sealants and Patching Tars Roofing over the building is a low-sloped sheet metal roof. Patching tars and sealants which are present at flashings, vents, and other equipment penetrating the roofing contain asbestos. The roofing materials will be removed by this project.

Black Mastic to Floor Tiles Off-white sealants at door, window and other penetrations through the exterior walls of the building contains asbestos. The sealants were in good condition and are not considered friable. The sealants will be removed by this project.

Laboratory Countertops and Backsplashes Black cement laboratory countertops and backsplashes in the storage building are assumed to contain asbestos. This material was in good condition and was non friable and will be removed by this project.

Fume Hood Cement Asbestos Board A fume hood was identified in the storage building that may contain cement asbestos board. The material is assumed to be in good condition and was not friable and will be removed by this project.

2. Asbestos in Dusts

The settled and concealed dusts were examined by an EPA Certified Building Inspector but no samples for asbestos in dusts were authorized for this project. Based on their visual inspection and experience from similar buildings, the inspector determined that the typical settled and concealed dusts are not “asbestos debris” from an asbestos-containing building material (ACBM). Based on similar sampling from similar buildings, the inspector also determined that the dusts are unlikely to contain more than one percent (1%) asbestos by weight, and therefore are not an asbestos-containing material (ACM).

3. Lead-Containing Materials

Lead-Testing EHS-Alaska tested paint and other materials throughout the affected areas of the buildings using a Heuresis XRF lead paint analyzer. Lead in paints at the Fuels Management Lab (B3242) tested varied from a trace amount to 8.1 mg/cm2. Lead in other materials at the Fuels Management Lab (B3242) tested varied from a trace amount to 0.6 mg/cm2. Lead in paints at the Moveable Storage Building tested varied from a trace amount to 0.3 mg/cm2. Lead in other materials at the Moveable Storage Building tested varied from a trace amount to 0.4 mg/cm2. Refer to the Lead Analyzer Test Results Table in Appendix C that identifies the surfaces tested, and the results. The Lead Test Locations are

Eielson Fuels Management Lab Demolition Page 14 of 22 shown in the Drawings in Appendix D. Refer to the Lead Testing conducted by HTRW, LLC. in Appendix E.

Paints There were varying lead contents found in the paints, based on what surfaces they are on, with most surfaces containing little lead (but are still classified as lead-containing materials by OSHA). The highest levels of lead were found on structural members and miscellaneous steel, with lower levels on walls and other painted surfaces, and lowest levels on pre-finished materials.

Lead based paints (paint containing more than 1.0 mg/cm2 of lead) were identified in the project on steel components such as structural steel and it is anticipated that other components which are hidden, concealed, or otherwise not tested may be painted with lead-based paint. Lead was detected at very low levels in most of the painted floor, wall and ceiling surfaces. XRF testing is not able to “prove” that “no” lead exists in the paint. Low levels of lead found by XRF testing does not mean that the paints are free of lead, the paints may contain lead. However, these paints may not present a hazard to occupants or workers performing renovation or demolition if lead-safe work practices are followed.

Metallic Lead in Batteries, Pipe Solder and Flashing Metallic lead items identified in both of the buildings included lead solder at copper piping, and poured lead sealants at bell and spigot joints of waste and vent piping and lead acid batteries in emergency lights and other battery backup equipment. They will be removed during demolition, and they should be recycled or disposed of as hazardous waste.

Lead Dusts The settled and concealed dusts were examined but no samples for lead in dusts were authorized for this project. Based on their visual inspection and similar sampling from similar buildings, the inspector also determined that the dusts are likely to have measurable concentrations of lead in the dusts.

4. PCB-Containing Materials

Light Ballasts Older fluorescent lights typically have PCB-containing ballasts. PCB-containing ballasts in fluorescent lights were banned in 1978, but manufacturers were allowed to use up existing stocks, and lights may have been reused from other facilities. The survey included examination of what were considered to be representative light fixtures, but not all fixtures were able to be accessed. All lights shall be inspected during removal. Unless ballasts were marked “No PCBs,” they must be assumed to contain PCBs and must be disposed of as a hazardous waste when removed for disposal. Fluorescent light fixtures with PCB-containing ballasts are assumed to be present in the building. The fluorescent light fixtures will be removed prior to demolition as shown on the drawings.

Older HID lights may have PCB-containing ballasts. Due to height restrictions and sealed ballast enclosures, the HID fixtures were not able to be accessed. All HID lights shall be inspected during removal or relocation. If ballasts are not marked “No PCBs,” we suggest contacting the manufacturer of the lights to determine if the ballasts contain PCB’s, or assume that they contain PCB’s and be disposed of as a hazardous waste. HID light fixtures with assumed PCB-containing ballasts will be removed prior to demolition as shown on the drawings.

Bulk Products Representative paint and sealant samples were collected from the buildings.

The following Table 2A summarizes the PCB Bulk samples taken August 2023 at the Fuels Management Lab (B3242) by EHS-Alaska, Inc. Field Survey Data Sheets and Lab results are included in Appendix B.

Sample locations drawings are provided in Appendix D. Refer to the PCB Bulk Product sampling conducted by HTRW, LLC. in Appendix E.

Eielson Fuels Management Lab Demolition Page 15 of 22

TABLE 2A

SAMPLE

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

B3242-0823-

PCB01

Beige paint over green paint over beige paint on concrete

Exterior: southeast foundation wall below CMU wall, on concrete. Photo

2.3 ppm

B3242-0823-

PCB02

Off-white sealant on CMU Exterior: southeast window, between wood window frame and CMU wall. Photo 367

2280 ppm

B3242-0823-

PCB03

Beige paint over green paint on concrete

Exterior: north window sill, on concrete. Photo 376

123 ppm

B3242-0823-

PCB04

White paint on gypsum wall board

South entrance vestibule: on gypsum wall. Photo 469

4.2 ppm

B3242-0823-

PCB05

Off-white paint on CMU West wall of Administration: above suspended ceiling system on CMU wall. Photo 544

1.51 ppm

B3242-0823-

PCB06

Beige paint on gypsum ceiling East wall above Lab: on hidden gypsum ceiling. Photo 601

1.39 ppm

B3242-0823-

PCB07

Beige paint on metal East wall of Lab: on removed fume hood duct. Photo 603

4.2 ppm

B3242-0823-

PCB08

Grey paint on gypsum wall board

North wall of Fuels Compliance Office: below windowsill on gypsum wall board. Photo 629

3.27 ppm

B3242-0823-

PCB09

Green paint on white paint on gypsum wall board

North wall of Mechanical Room: on gypsum wall board. Photo 640

2.9 ppm

Total PCB’s listed herein includes the sum of all cogeners of PCB’s. Refer to the laboratory reports for the concentrations of the various cogeners of PCBs found in the samples.

Two of the samples had PCB concentrations above 50 ppm which would be classified by the EPA as PCB Bulk Product Wastes. The other seven samples contained more than 1 ppm PCBs detected but had concentrations of PCB’s that were less than 50 ppm. Refer to Regulatory Constraints discussion below for more information. All of the 11 PCB Bulk Product samples taken by HTRW LLC. contained more than 1 ppm, PCB’s. Refer also to the PCB Bulk Product sampling conducted by HTRW, LLC. in Appendix E.

The following Table 2B summarizes the PCB Bulk samples taken August 2023 in the Moveable Storage Building by EHS-Alaska, Inc. Field Survey Data Sheets and Lab results are included in Appendix B.

Sample locations drawings are provided in Appendix D.

TABLE 2B

SAMPLE

NUMBER MATERIAL LOCATION TOTAL PCB

CONCENTRATION

S-B3242-0823-

PCB01

White paint over yellow paint on metal

Exterior: east wall of storage building, on corrugated metal wall panel. Photo 206

None Detected

Total PCB’s listed herein includes the sum of all cogeners of PCB’s. Refer to the laboratory reports for the concentrations of the various cogeners of PCBs found in the samples.

The sample from the Moveable Storage Building either had no PCBs detected, or had concentrations of PCB’s that were less than 50 ppm. Refer to Regulatory Constraints discussion below for more information.

Eielson Fuels Management Lab Demolition Page 16 of 22

5. Mercury-Containing Materials

Fluorescent Lamps Fluorescent lamps use mercury to excite the phosphor crystals that coat the inside of the lamp. These lamps contain from 15 to 48 milligrams of mercury depending on their age and manufacturer.

Fluorescent light fixtures will be removed as shown on the drawings.

Thermostats Older thermostats or other electrical switches that may contain mercury were noted in the laboratory portion of building 3242.

High Intensity Discharge Lamps High Intensity Discharge (HID) lamps use mercury and sodium vapors in the lamp, and also typically have lead-containing solders at the bases. These lamps contain varying amounts of mercury depending on their age and manufacturer. HID light fixtures will be removed as shown on the drawings.

All mercury-containing items being removed by this project are required to be disposed of as hazardous waste or recycled.

6. Other Hazardous Materials

Smoke Detectors Several radioactive smoke detectors were found in the demolition area. If any radioactive items are removed by this project, they are required be disposed of as hazardous waste or recycled.

Household Chemicals Common household chemicals, including quantities of construction repair materials, acids, paint products, paint thinners, caustics, cleaners, disinfectants, solvents, fuel, new or used lubrication products, and adhesives were present in the building. These loose containers were present in the Moveable Storage Building and lab portion of the Fuels Management Lab (B3242) and will be relocated by the owner.

Soil Contamination The scope of work for EHS-Alaska, Inc. did not include investigation of soils for petroleum or other contaminations.

Refrigerants Refrigerators were identified may contain ozone depleting substances. An air conditioning unit was also present on the exterior west wall of the Fuels Management Lab (B3242). Ozone depleting substances (ODS) are regulated by the EPA and must be removed by certified technicians prior to equipment disposal. The refrigerators may be relocated by the owner. The air conditioner will be removed by this project.

E. REGULATORY CONSTRAINTS

1. Asbestos-Containing Materials

The Federal Occupational Safety and Health Administration (29 CFR 1926.1101) and the State of Alaska Department of Labor (8 AAC 61) have promulgated regulations requiring testing for airborne asbestos fibers; setting allowable exposure limits for workers potentially exposed to airborne asbestos fibers;

establishing contamination controls, work practices, and medical surveillance; and setting worker certification and protection requirements. These regulations apply to all workplace activities involving asbestos-containing materials.

The EPA regulations, 40 CFR 61, Subpart M of the National Emission Standards for Hazardous Air Pollutants (NESHAP), established procedures for handling ACM during removal and disposal. The

Eielson Fuels Management Lab Demolition Page 17 of 22

NESHAP regulations address three categories of ACM in a building being demolished:

1. Friable, or regulated ACM (RACM) which must be removed from a building before the building is demolished

2. Category I non-friable ACM (resilient flooring, asphalt roofing products, packing and gaskets)

3. Category II non-friable ACM (non-friable ACM other than Category I ACM).

If allowed by the disposal site, the EPA allows Category I and II non-friable ACM to remain in a building during demolition if: (1) Category I ACM is not in poor condition and is not friable and (2) the probability is low that Category II ACM will become crumbled, pulverized or reduced to powder during demolition. The condition of the ACM and method of demolition will generally determine if Category I and II non-friable ACM may be left in the building during demolition. This EPA standard also requires that no visible emissions be generated from the ACM during removal and transportation and does not allow intentional burning of any building containing ACM.

The EPA regulations require an owner (or the owner's contractor) to notify the EPA of asbestos removal operations and to establish responsibility for the removal, transportation, and disposal of asbestos-containing materials.

The disposal of asbestos waste is regulated by the EPA, the Alaska Department of Environmental Conservation, and the disposal site operator. Wastes being transported to the disposal site must be sealed in leak tight containers prior to disposal and must be accompanied by disposal permits and waste manifests.

2. Dusts with Asbestos

Settled and concealed dusts above ceilings, and at other areas that are not routinely cleaned (such as inside ducts and at roofs, etc.) are assumed to have measurable concentrations of asbestos. Based on sampling of similar settled and concealed dusts at similar buildings, those dusts are assumed to contain less than 1 percent asbestos. Normal settled and concealed dusts are distinct and treated differently from debris resulting from damaged asbestos-containing materials.

Background levels of asbestos in dusts for a particular location will depend on many factors, including whether or not asbestos occurs naturally in soils in the area.