Camp Buckner - RTA Specifications Appendix 1.2 Hazmat Report.pdf

LIMITED HAZARDOUS MATERIALS SURVEY

CAMP BUCKNER REVITALIZATION

USMA MILITARY RESERVATION

HIGHLAND MILLS, NY

Contract #: W912-DS-18-AE-0007 Task Order #: W912-DS-19-F00XX

Prepared for:

JACOBS / EwingCole, A Joint Venture 9191 South Jamaica Street

Englewood, CO 80112

Submitted by:

6401 Golden Triangle Drive, Suite 304 Greenbelt, MD 20770

Telephone: (202) 832-1433

December 26, 2019

Architect-Engineering Services in Support of the Camp Buckner Revitalization United States Military Academy West Point Military Reservation, Highland Mills, NY

Hazardous Materials Survey Task Order W912DS19F00XX

Contract Solicitation W912DS‐18‐AE‐0007

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Table of Contents

EXECUTIVE SUMMARY ............................................................................................... iii

ACRONYMS .................................................................................................................. vi

1.0 INTRODUCTION

2.0 ASBESTOS INSPECTION REPORT

2.1 SURVEY METHODOLOGY

2.2 ANALYTICAL PROCEDURES

2.3 INACCESSIBLE AND LIMITED-ACCESS SPACES

2.4 SURVEY LIMITATIONS

2.5 ASBESTOS INSPECTION RESULTS

2.6 ASBESTOS CONCLUSIONS

2.7 ASBESTOS RECOMMENDATIONS

3.0 LEAD-BASED PAINT INSPECTION

3.1 LBP INSPECTION METHODOLOGY

3.2 LBP INSPECTION DATA

3.3 LBP INSPECTION RESULTS

3.4 LBP CONCLUSIONS AND RECOMMENDATIONS

4.0 MOLD INSPECTION REPORT

4.1 METHODOLOGY

4.2 MOLD RESULTS AND INTERPRETATION

4.3 MOLD REMEDIATION RECOMMENDATIONS

6.0 POLYCHLORINATED BIPHENYL (PCB) REPORT

6.1 METHODOLOGY

6.2 PCB RESULTS AND INTERPRETATION

6.3 PCB CONCLUSIONS AND RECOMMENDATIONS

7.0 UNIVERSAL WASTES

8.0 FIRE DETECTION SYSTEMS AND FIRE EXTINGUISHERS

9.0 SELF-LUMINOUS EXIT SIGNS

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11.0 DISCLAIMER

ATTACHMENTS:

ATTACHMENT 1 – ASBESTOS ANALYTICAL RESULTS

ATTACHMENT 2 – SUMMARY OF MATERIALS SAMPLED FOR ASBESTOS

ATTACHMENT 3 – DRAWINGS OF BULK ASBESTOS SAMPLE LOCATIONS

ATTACHMENT 4 – LBP RESULTS-XRF RAW DATA

ATTACHMENT 5 – LBP RESULTS-PAINT CHIP ANALYSIS

ATTACHMENT 6 – DETAILS OF LEAD CONTAINING COMPONENTS

ATTACHMENT 7 – LABORATORY MOLD RESULTS AND FIELD NOTES

ATTACHMENT 8 – MOLD PHOTOS TAKEN NOVEMBER 13-14, 2019

ATTACHMENT 9 – PCB RESULTS

ATTACHMENT 10 – INSPECTOR CERTIFICATIONS/LICENSES

ATTACHMENT 11 – LABORATORY LICENSE(S)

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EXECUTIVE SUMMARY

The United States Army Corps of Engineers, New York, retained Jacobs/Ewing Cole, A Joint Venture (JV) to provide Architect-Engineering Services in support of the Camp Buckner Revitalization. The Joint Venture retained Global Consulting, Inc. (GCI) to perform the hazardous materials survey of randomly-selected barracks slated for future renovation phases at Camp Buckner (the Facility) located on the United States Military Academy’s Military Reservation located in Highland Mills, New York, 10930.

The barracks were built in phases between the years of 1943 and the 1960s. GCI was provided information that Phase 1 (1600 Buildings) were constructed in 1972, whereas Phases 2-4 (1500 Buildings) were built in 1965/pre-1965. Each barrack is approximately 2,400 SF in size. The barracks are occupied approximately six weeks per year by Freshman Cadets (approximately 40 cadets/barrack). Each single level barracks consists of an elevated concrete slab, an original bathroom, a more recently created restroom designed for female cadets, and in some instances, an Arms Room. The roofs consisted of different materials (corrugated metal, shingles, etc.) With the exception of a few Arms Rooms, all barracks were made accessible for inspection. Roofing components were excluded from the survey as roofers were not present to repair the penetrations. Any membranes, sealants, flashing, etc, may contain asbestos, and the roofs should be assumed to be asbestos-containing.

Two buildings per renovation phase (1-4) were selected at random. This report documents the inspection of randomly-selected barracks of the Facility, conducted between the dates of November 13 and 14, 2019, by licensed, certified, and experienced inspectors for the following hazardous materials: asbestos-containing material (ACM), lead-based paint (LBP), mold, polychlorinated biphenyls (PCBs), and other potentially hazardous materials.

Asbestos:

The purpose of the asbestos survey was to identify the locations and quantities of asbestos-containing materials (ACM - materials with an asbestos content greater than

1%) that may be impacted by renovation/demolition activities.

Bulk samples of suspect ACMs were collected by GCI’s EPA-accredited, New York-licensed Asbestos Hazard Emergency Response Act (AHERA) Inspector, Mr. Gary E.

Wyrwa (NYSDOL Cert# 90-03929). Samples were submitted to AmeriSci Richmond, in Midlothian, Virginia, a New York State Department of Health-certified laboratory for analysis of asbestos content.

The following materials were positively-identified as ACM by laboratory analysis:

• Exterior vapor barrier of Building 1516 (approx. quantity: 320 linear feet (LF))

• Exterior caulk of Building 1516 (approx. quantity: 300 LF)

• Exterior silver paint from the roof of Building 1516, 1503, and 1520 (unknown quantity)

• Exterior gray caulk of Building 1520 (approx. quantity: 300 LF)

• Exterior cloth vapor barrier of Building 1520 (approx. quantity: 320 LF)

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The following building materials were not sampled (or were not fully sampled) due to sampling limitations and/or out of concern that sampling may compromise the integrity of the substrate/structure, and are Presumed Asbestos-Containing Materials (PACM):

• Roofing materials (excluded from the survey)

• Possible mastic patties behind the mirrors in restrooms

• Possible pipe insulation inside pipe chases of restrooms

All asbestos-containing materials with the potential to be impacted by the renovation should be abated in accordance with all applicable federal, state, and local regulations.

The abatement shall be conducted in accordance with New York State Industrial Code Rule (ICR) 56. Project design specifications should include removal and disposal of all identified ACMs that are anticipated to be impacted by the proposed project.

If additional suspect materials are identified during demolition/renovation that will be disturbed by the proposed work, and they have not been analyzed for asbestos content, these materials should be protected from disturbance until further investigated, sampled, and analyzed.

Lead-Based Paint:

GCI’s Lead Risk Assessor assessed the Facility for the presence of Lead-Based Paint (LBP) materials between the dates of November 13 and 14, 2019, using an X-Ray Fluorescence (XRF) Analyzer.

Lead-based paint (LBP) is defined by New York Local Law #1 as painted surfaces that contain greater than 1.0 mg/cm2 of lead. Components/Paints with greater than 0.009% lead by weight are Lead-Containing Paint (LCP). Inconclusive XRF readings were followed up with a paint chip sample submitted to a laboratory for analysis to confirm the result.

The following materials were found to contain LBP by XRF detection:

• Structural columns and beams in the 1500 buildings

• Slop sinks in men’s rooms in both 1500 & 1600 buildings

• Yellow toilet doors/partitions in women’s rooms in both 1500 & 1600 buildings

• Yellow paint on exterior step/stairs in both 1500 & 1600 buildings

• Gray paint on gate door in arms room of Building 1612

Many materials were found to contain LCP by XRF detection and/or paint chip analysis.

These materials are described in Section 3.3 LBP Inspection Results.

When components with LBP or LCP are disturbed during renovation/demolition, they should be managed in accordance with applicable Federal, state, and local regulations.

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Mold

GCI’s New York State-licensed mold inspector, Mr. Michael Vollo, License # MA00871 conducted a mold inspection of the Facility. GCI found evidence of apparent microbial growth in the cadet showers.

Air testing was conducted in areas where apparent microbial growth was identified. Mold spores were detected in concentrations greater than that of outdoor ambient samples.

This can likely be attributed to cold weather conditions and a lack of moisture at the time of the inspection. Areas with visible apparent microbial growth should be remediated and repaired in accordance with New York state laws and U.S. Army guidelines.

Polychlorinated Biphenyls (PCBs)

The EPA and NYS DEC considers a material to be PCB-containing if it contains equal to or greater than 50 parts per million (ppm) of PCBs. Laboratory analysis (Method 8082) by ALS Laboratory Group in Salt Lake City, Utah, confirmed that none of the three bulk window caulk samples contained detectable concentrations of PCBs.

GCI noted approximately 17 light fixtures in each barrack. There is an elevated potential that PCB-containing light ballasts are present in those fixtures based on the age and type of fixtures observed.

Universal Wastes

Fluorescent lightbulbs may contain mercury and should be managed as Universal Waste.

General Universal Wastes include batteries, pesticides, mercury-containing equipment and lamps. GCI noted approximately 34 lightbulbs in each barrack.

Fire Detection Systems and Fire Extinguishers

Smoke detectors, fire extinguishers, and/or fire alarms of varying ages were noted during GCI’s inspection.

Self-Luminous EXIT Signs

Approximately three to four EXIT signs were noted in each barrack during GCI’s inspection.

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ACRONYMS

ACGIH American Conference of Governmental Industrial Hygienists

ACM Asbestos-Containing Material

AHERA Asbestos Hazard Emergency Response Act

ASTM American Society for Testing and Materials

CFR Code of Federal Regulations

ELAP Environmental Laboratory Accreditation Program

EPA Environmental Protection Agency

FDNY Fire Department of New York

HUD U.S. Department of Housing and Urban Development

ICR Industrial Code Rule (New York)

JV Joint Venture

LBP Lead-Based Paint

LCP Lead-Containing Paint

NFPA National Fire Protection Association

NIOSH National Institute of Occupational Safety and Health

NESHAP National Emission Standards for Hazardous Air Pollutants

NOB Non-Friable Organically Bound Material

NRC U.S. Nuclear Regulatory Commission

NYSDEC New York State Department of Environmental Conservation

NYSDOL New York State Department of Labor

OSHA Occupational Safety & Health Administration

PPM Parts Per Million

PCM Phase Contrast Microscopy

PCS Performance Characteristic Sheet

PLM Polarized Light Microscopy

PCB Polychlorinated Biphenyl

PACM Presumed Asbestos-Containing Material

RACM Regulated Asbestos-Containing Material

RCRA Resource Conservation and Recovery Act (RCRA)

SDS Safety Data Sheet

TCLP Toxic Characteristic Leaching Procedure

TG Technical Guidelines (ARMY)

TEM Transmission Electron Microscopy

TSCA Toxic Substances Control Act

TSI Thermal System Insulation

UW Universal Waste

UWR Universal Waste Rule

XRF X-Ray Fluorescence

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1.0 INTRODUCTION

The United States Army Corps of Engineers, New York, retained Jacobs/Ewing Cole, A Joint Venture (JV) to provide Architect-Engineering Services in support of the Camp Buckner Revitalization. The Joint Venture retained Global Consulting, Inc. (GCI) to perform the hazardous materials survey of randomly-selected barracks slated for future demolition at Camp Buckner (the Facility) located on the United States Military Academy’s Military Reservation located in Highland Mills, New York, 10930. The mutual goal of the contractor and the government is to achieve a quality product, safely, within the expected timeframe and budget.

The purpose of the survey was to identify the location and quantity of asbestos-containing materials (ACM), lead-based paint (LBP), mold, polychlorinated biphenyls (PCBs), and other hazardous and regulated wastes that may be impacted by renovation/demolition activities.

The scope of work for the survey consisted of the following tasks:

1. Review of record plans for identified and suspect ACM and LBP that may be impacted by the scope of work;

2. Conduct a visual inspection of the project area to identify potential location(s) of hazardous materials that may be affected by the scope of work.

3. Collect bulk samples of suspect ACMs; Assess building components for LBP using an Olympus Vanta C Series XRF Analyzer; Investigate for mold growth by collecting swabs of microbial growth (where present) and air samples; Collect bulk samples of suspect PCB-containing materials; and Inventory other visible hazardous and regulated materials.

4. Submit the suspect ACM bulk samples to a certified laboratory for Polarized

Light Microscopy (PLM) and/or Transmission Electron Microscopy (TEM) -where applicable; Download the Olympus Vanta C-Series XRF Analyzer results;

Submit the mold swabs and air samples to a certified laboratory for analysis.;

Submit the suspect PCB-containing samples to a certified laboratory for analysis.

5. Prepare a report summarizing data, collection techniques, analysis procedures, location and quantity of hazardous materials.

6. Provide basic recommendations for asbestos, lead, and mold regarding safe handling and disposal.

2.0 ASBESTOS INSPECTION REPORT

GCI inspected interior & exterior (excluding the roof) spaces within the selected buildings in West Point’s Camp Buckner for the presence of suspect ACM between the dates of November 13 and 14, 2019. The site survey was completed by EPA-accredited Asbestos Hazard Emergency Response Act (AHERA) and New York State Department of Labor (NYSDOL)-certified asbestos inspector, Mr. Mr. Gary E. Wyrwa (NYSDOL Cert# 90- 03929. A copy of Mr. Wyrwa’s asbestos license is included in Attachment 10.

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The analytical results of this asbestos inspection are presented in Attachment 1 and the sampling locations are presented on the drawings in Attachment 3. The Environmental Protection Agency (EPA) and the State of New York are the authorities that regulate activities related to asbestos-containing materials (ACMs) within the State of New York.

The EPA regulations cover four asbestos activities; (1) removal, repair, or encapsulation of ACM, (2) approval of asbestos training providers, (3) regulation of persons accredited to perform asbestos-related activities, and (4) asbestos in schools. The EPA regulates the enforcement of the National Emission Standards for Hazardous Air Pollutants (NESHAP), and enforcement of the asbestos notification regulations.

2.1 SURVEY METHODOLOGY

The asbestos survey was divided into two distinct phases: pre-inspection planning and the inspection for ACM.

2.1.1 PRE-INSPECTION PLANNING

The pre-inspection planning phase includes reviewing previous inspection reports, management plans, and abatement reports, if available. The JV provided GCI with information regarding the planned use of the property. GCI planned an inspection strategy and coordinated the inspection work with the JV and Facility personnel. It was determined that this survey should include all accessible portions of the structures to ensure that intended demolition can be conducted in an efficient and safe manner compliant with applicable Federal, state, and local regulations.

2.1.2 FIELD INSPECTION

The inspection was conducted on an area-by-area basis as determined in the planning phase. GCI’S asbestos inspector identified materials considered to be suspect ACM according to AHERA protocols, unless otherwise specified.

As defined by AHERA, suspect ACM include the following building material types:

❑ Surfacing materials (e.g.: spray-applied or troweled-on fire proofing, plaster, etc.)

❑ Thermal System Insulation (TSI) (e.g.: Pipe insulation, boiler lagging, tank insulation, and duct insulation, etc.)

❑ Miscellaneous materials (e.g.: ceiling tiles, floor tiles & mastic, gaskets, fire doors, roofing systems, etc.)

Suspect materials that were homogeneous in nature (i.e., uniform in color and texture, installation date) were identified, touched to determine friability, and sampled by removing a small piece. Extreme care was taken to avoid potential fiber release during the inspection/sampling process. Before sample collection, a fine mist of water was typically applied to the sample site. Samples were collected using sharpened core samplers and/or razor knives, where necessary, and immediately placed in labeled containers and sealed.

Any dust generated was wet-wiped to minimize the potential for fiber release.

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Samples were collected in a randomly-distributed manner in accordance with AHERA provisions (40 CFR 763.86). The location, condition, and quantity of each homogeneous material were recorded in the inspector’s log.

Several materials should be assumed asbestos-containing based on the age of the structure, and/or out of concern that sampling may compromise the integrity of the material, component, or system.

The following building materials were not sampled (or were not entirely sampled) due to sampling limitations and are presumed asbestos-containing materials (PACM):

• Possible pipe insulation inside pipe chases in restrooms

• Roofing materials (excluded from the survey)

The accessible suspect materials with the potential to be impacted by the renovation/ demolition activities were inspected, assessed, and sampled where possible.

2.2 ANALYTICAL PROCEDURES

The samples of suspect ACMs were packaged and delivered under strict chain of custody procedures to AmeriSci Richmond in Midlothian, Virginia. This laboratory is accredited by the New York State Department of Health (NY Lab ID# 10984). Laboratory accreditation documentation is provided in Attachment 11.

The Occupational Health and Safety Administration (OSHA) and the State of New York define an ACM as any material containing greater than 1% asbestos.

In accordance with New York Environmental Laboratory Accreditation Program (ELAP) protocol, samples in a homogeneous group were analyzed until either the entire group was analyzed (all the results are negative) or a positive result was obtained by Polarized Light Microscopy (PLM). Bulk sample analysis is accomplished by using a polarized light microscope equipped with dispersion staining. This method of analysis involves the staining of a suspect material in a solution of known refractive index and the subjection to illumination by polarized light. The resulting color display enables mineral identification.

When a positive result occurs in a sample set for a homogeneous material, the remaining samples in the group are not analyzed.

Samples of non-friable organically bound (NOB) materials (i.e., mastics, caulks, etc.)

found to be negative for asbestos by PLM analysis were re-analyzed by Transmission Electron Microscopy (TEM) until first positive or all samples were found to be negative.

Laboratory analytical results are provided as Attachment 1. A summary of field data including the sample designations, gross descriptions, and analytical results, including photos, are provided as Attachment 2.

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2.3 INACCESSIBLE AND LIMITED-ACCESS SPACES

Every reasonable attempt was made to locate ACM, and to identify those ACM as Thermal System Insulation (TSI), surfacing material, or “other” miscellaneous materials.

Inaccessible areas could be addressed only through extrapolation of conditions in accessible building spaces. Areas that were inaccessible, or where the survey was limited to visual observation only, are identified in this report’s narrative. Hatches were investigated as feasible; some were sealed closed. Such inaccessible areas might include but are not limited to the those listed in Table 1: Description of Inaccessible Locations.

Table 1: Description of Inaccessible Locations

❑ Within walls Inside the drywall/metal partition walls, ❑ Enclosed pipe chases ❑ Chases behind sinks/toilets/showers in restrooms

❑ Above solid ceilings Ceilings without access hatches

❑ Elevated Spaces Areas above a standard eight-foot ladder’s reach

Limited access areas (i.e. beneath fixed walls, under wall-to-wall carpeting, or above fixed ceilings with small access hatches) were investigated as feasible, and, as a result, conclusions regarding the presence or absence of asbestos might be of limited accuracy.

2.4 SURVEY LIMITATIONS

All other suspect materials uncovered during renovation/demolition activities not identified within this report should be assumed asbestos-containing until bulk sampling and laboratory analysis confirm otherwise.

Roofing components were excluded from the scope of work as roofers were not present to patch holes. Roofs were not sampled (with the exception of silver roofing paint that had dripped from the roof down the side of the barrack(s)). The silver paint is asbestos-containing. All other roofing materials should be considered presumed asbestos-containing materials (PACM) and should be treated as ACM until sampling and laboratory analysis determine the asbestos content.

Due to survey limitations, not all barracks on the reservation were assessed for suspect materials. GCI’s Asbestos Inspector collected samples from two barracks of each of the four renovation phases at random (Barracks 1611, 1612, 1509, 1523, 1516, 1520, 1508 and 1503.)

2.5 ASBESTOS INSPECTION RESULTS

A total of 180 bulk samples were collected from 60 homogeneous materials. Laboratory analytical data and chain of custody documentation of all bulk samples are provided as Attachment 1. A description of these materials and laboratory analytical results are

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December 26, 2019 Jacobs / EwingCole, A Joint Venture (JV) P a g e | 5 summarized in a table provided as Attachment 2. Sampling locations and positively-identified ACMs are illustrated on Drawings presented in Attachment 3.

Positively-identified asbestos-containing materials (ACM) and laboratory analytical results from the analysis of the samples are summarized in Table 2.

Table 2: Description of Positively-Identified ACM

Description Sample # Location Asbestos Content

Photograph

PHASE 3

Exterior Vapor

Barrier (Homogeneous area #32)

B1516-1114-B94 Building 1516/

Exterior 6.2% - 6.7% Chrysotile

B1516-1114-B95

Building 1516/ Exterior

Not Analyzed/ Positive Stop

B1516-1114-B96

Not Analyzed/ Positive Stop

PHASE 3

Exterior Caulk

(Homogeneous area #33)

B1516-1114-B97

4.0% - 5.9%

B1516-1114-B98

Not Analyzed/

B1516-1114-B99

Not Analyzed/ Positive Stop

PHASE 3

Exterior Silver Paint (Homogeneous area #34)

B1516-1114-B100

2.6% - 4.1%

B1516-1114-B101

Not Analyzed/

B1516-1114-B102

Not Analyzed/ Positive Stop

PHASE 3

Exterior Grey Caulk (Homogeneous area #39)

B1520-1114-B115 Building 1520/

8.8% Chrysotile

B1520-1114-B116 Building 1520/

Exterior Not Analyzed/

Positive Stop

B1520-1114-B117 Building 1520/

Exterior Not Analyzed/

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Table 2: Description of Positively-Identified ACM

Description Sample # Location Asbestos Content

Photograph

PHASE 3

Cloth Vapor Barrier (Homogeneous area #42)

B1520-1114-B124

7.8% Chrysotile

B1520-1114-B125

Exterior Not Analyzed/

Positive Stop

B1520-1114-B126 Building 1520/

Exterior Not Analyzed/

Positive Stop

PHASE 3

Exterior Silver Paint (Homogeneous area #44)

B1520-1114-B130 Building 1520/

4.6% Chrysotile

B1520-1114-B131

Exterior Not Analyzed/

Positive Stop

B1520-1114-B132 Building 1520/

Exterior Not Analyzed/

Positive Stop

PHASE 2

Exterior Silver Paint (Homogeneous area #58)

B1503-1114-B173 Building 1503/

4.4% Chrysotile

B1503-1114-B174 Building 1503/

Exterior Not Analyzed/

Positive Stop

B1503-1114-B175 Building 1503/

Exterior Not Analyzed/

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Materials found to contain trace concentrations of asbestos (less than one percent (<1%)) and laboratory analytical results are summarized in Table 3.

Table 3: Description of Materials with Trace Asbestos (<1%)

Description Sample # Location Asbestos Content

Photograph

PHASE 1

Exterior Caulk

(Homogeneous area #06)

B1611-1113-B16 Building 1611/

Exterior Anthophyllite

Trace

B1611-1113-B17 Building 1611/

Exterior Anthophyllite

Trace

B1611-1113-B18 Building 1611/

Exterior Anthophyllite

Trace

PHASE 3

Outer Wrap on

Fiberglass (Homogeneous area #30)

B1516-1114-B88 Building 1516/

Various Locations

B1516-1114-B89

Various Locations None Detected

B1516-1114-B90 Building 1516/

Various Locations None Detected

Phase 3 Interior Yellow

Paint (Homogeneous area #43)

B1520-1114-B127 Building 1520/

Throughout None Detected

B1520-1114-B128

Throughout None Detected

B1520-1114-B129 Building 1520/

Throughout

The following building materials were not sampled (or were not entirely sampled) due to sampling limitations and are presumed asbestos-containing materials (PACM):

• Possible pipe insulation inside pipe chases in restrooms

• Roofing materials (excluded from the survey)

2.6 ASBESTOS CONCLUSIONS

Regulated asbestos-containing material (RACM) is defined as friable asbestos-containing material or non-friable asbestos-containing material (ACM) that will be, or has been, subjected to sanding, grinding, cutting, or abrading or has crumbled, pulverized, or

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December 26, 2019 Jacobs / EwingCole, A Joint Venture (JV) P a g e | 8 reduced to powder during demolition or renovation operations. Both presumed and positively-identified ACM should be treated as RACM.

RACM with the potential to be impacted by the renovation/demolition should be abated in accordance with all applicable federal, state and local regulations. The abatement shall be conducted in accordance with New York State ICR 56. Project design specifications should include removal and disposal of all assumed and positively-identified ACMs anticipated to be impacted by the proposed project.

Materials presented in Table 2 and in the list of PACM are RACM. Wherever these materials are found, they shall be removed in accordance with state and federal regulations.

Materials presented in Table 3 are materials with trace concentrations of asbestos (less than one percent (<1%) asbestos). Work practice requirements and prohibitions as stated in the Construction Asbestos Standard, 29 CFR 1926.1101, must be observed regardless of the exposure levels and of the percentage of asbestos in the materials.

Many materials sampled were non-detect for asbestos, and, therefore, those materials are not considered as ACM. General safety and health standards in construction may be used for their removal, demolition, and disposal.

As indicated in the survey limitations, physical bulk sampling was limited to Barracks 1611, 1612, 1509, 1523, 1516, 1520, 1508 and 1503. GCI opened ceiling hatches as feasible, but was limited to visual observation only. Based on the visual inspection conducted in additional Camp Buckner barracks, GCI’s Asbestos Inspector made the determination that all the barracks of Phase 1 (1600 Buildings) and Phases 2-4 (1500 Buildings) were homogeneous in construction. The positive ACM results of our survey should be extrapolated to all barracks. The following asbestos assumptions should made of all barracks on the reservation:

• Any material that is homogeneous to the positively-identified asbestos-containing materials shall be considered an asbestos-containing material.

• Any material that is homogeneous with another type of material (material that was non-detect for asbestos or material with trace asbestos), may not be considered as such. Until further bulk sampling is performed, these materials are considered PACM and should be treated as ACM. (See note.)

Note: Without assessing and sampling each barrack, federal asbestos regulations prohibit an AHERA Asbestos Inspector from extrapolating non-asbestos-containing data to other buildings. Bulk sampling and laboratory analysis are the only means by which a material may be declared non-detect.

If additional suspect materials are identified during renovation/demolition that will be disturbed by the proposed work, and have not been tested to determine asbestos content, these materials, should be protected from impact until further investigated or treated as

PACM.

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All quantities must be field-verified by a licensed asbestos abatement contractor(s) prior to demolition or renovation.

2.7 ASBESTOS RECOMMENDATIONS

1. The abatement contractor shall note the project work involves asbestos removal.

The contractor performing the asbestos removal shall be a licensed New York

State Abatement Contractor. The persons performing the asbestos removal shall by New York State-certified asbestos handlers and shall comply with all applicable local, state, and federal laws, rules, and regulations as per https://www.health.ny.gov/environmental/indoors/asbestos/laws.htm

2. The abatement contractor shall verify the location of asbestos-containing materials, and any asbestos debris and/or contaminated materials that may be near the asbestos-containing materials. Removal of any asbestos-contaminated debris shall be a part of the asbestos project and be performed by certified persons.

3. It is the abatement contractor’s responsibility to remove the asbestos-containing materials present on this project in accordance with New York State ICR 56

Regulations relative to a large-scale asbestos project.

4. Before the abatement meeting, the abatement contractor is required to submit to the Owner the following information:

1) A valid asbestos handling license;

2) Insurance coverage documentation;

3) Emergency Contact Numbers;

4) Asbestos Waste Hauler Documentation and copy of New York State

Department of Environmental Conservation (NYSDEC) Part 364 permit;

5) Name of EPA approved landfill as well as copies of all permits;

6) Copies of NYSDOL Handlers and Supervisor certificates;

7) Copies of all current respirator fit tests and medical exam certifications;

8) NYSDOL, EPA Local (if applicable) notifications. Notifications must be in place a minimum of 10 days prior to the start of the job;

9) Detailed project schedule (asbestos abatement) including all phases

(mobilization, prep, removal, clearance.)

3.0 LEAD-BASED PAINT INSPECTION REPORT

The Facility was assessed for the presence of lead-based paint (LBP) materials between the dates of November 13 and 14, 2019. The survey was conducted by GCI’s Lead Risk Assessor, Mr. Sameera Meegoda (EPA Certification #107953, DC License DC19-9473), and the results are presented in Section 3.3 LBP Inspection Results. Certifications and licensure are provided in Attachment 10.

https://www.health.ny.gov/environmental/indoors/asbestos/laws.htm

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3.1 LBP INSPECTION METHODOLOGY

Testing for LBP was conducted using an Olympus Vanta C-Series X-Ray Fluorescence (XRF) Analyzer (serial number 804122); hereto referred to as XRF. Prior to XRF analysis, the instrument was calibrated against reference standards of known lead concentrations.

Doors, door frames, windows, window frames, window sills, walls, ceilings, pipes, and other miscellaneous painted surfaces and building materials were screened for LBP.

The XRF detects lead in the field by reading fluorescence emanating from a painted surface when exposed to small amounts of radiation. XRF readings are in milligrams per square centimeter (mg/cm2), a mass per area unit. Prior to testing, the composition of the test building substrate (e.g., wood, metal, etc.) was determined by the lead inspector, and subsequently logged into the XRF analyzer. The XRF automatically performs a substrate correction to ensure that this factor does not result in false negative readings.

Lead-based paint is defined by the State of New York as any paint, varnish, shellac, or other coating that contains lead greater than 1.0 mg/cm2 as measured by XRF analysis. Lead-containing paint (LCP) is defined by EPA as any components /paints with greater than 0.009% lead by weight (90 parts per million).

At the end of each sampling session, a calibration re-check is performed to ensure that the instrument has maintained accuracy and precision during the measurement period.

The instrument is also calibrated each time it is turned off, or on, and typically at four (4) hour intervals during the workday for the same reasons. The use of the XRF was in general accordance with the Performance Characteristic Sheet (PCS) methodology for the specific instrument. XRF instrument calibration checks were performed according to the PCS.

In addition to testing with an XRF, when results were inconclusive, paint chip samples were collected in accordance with New York and EPA regulations. Paint chip samples were analyzed by AMA Analytical at Lanham, MD.

3.2 LBP INSPECTION DATA

The XRF data was downloaded directly to a computer to generate a report detailing the date/time, materials sampled, location, substrate and lead content. The annotated and raw XRF data is presented in Attachment 4. Paint chip analytical results are presented in Attachment 5

3.3 LBP INSPECTION RESULTS

Most of the structures tested were found to be below the standard that indicates they are LBP according to the New York Department of Health.

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The components found to contain LBP are summarized in Table 4.

Table 4: Description of Lead-Based Paint Surfaces

Description/Location Assessment Photo

Structural Steel Columns and Beams

Max. detected concentration

66.5 mg/cm2

Condition Intact

Location 1500 buildings

Slop Sinks in Men’s Rooms

Max. detected

24.9 mg/cm2

Location Both 1500 & 1600 buildings

Yellow Toilet Doors/Partitions in Women’s Rooms

Max. detected

3.6 mg/cm2

Both 1500 & 1600 buildings

Yellow Paint on Exterior Step/Stairs

Max. detected

4.5 mg/cm2

Condition Deteriorated

Both 1500 & 1600 buildings

Gray Paint on Gate Door in Arms Room

Max. detected

1.8 mg/cm2

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Table 4: Description of Lead-Based Paint Surfaces

Description/Location Assessment Photo

Condition Deteriorated

Location Building 1612

The following materials were found to contain LCP by XRF detection:

• Structural columns and beams in 1600 buildings

• Beige paint on walls (cinderblocks, drywall, and concrete wall base) in both 1500 & 1600 buildings

• Beige paint on metal walls and ceilings in both 1500 & 1600 buildings

• Beige paint on metal pipes (water lines & drain) in both 1500 & 1600 buildings

• Gray paint on metal doors in 1600 buildings

• Gray paint on metal door frames in 1600 buildings

• Light gray paint on corrugated metal walls

• White ceramic walls in both 1500 & 1600 buildings

• White paint on metal/drywall pipe chases behind sinks in Women’s Rooms in both 1500 & 1600 buildings

• Silver, black, orange and red paints on exterior hand rails in both 1500 & 1600 buildings

• Gray paint on concrete floors in Building 1612

• Gray paint on exterior wooden trim at the bottom of the wall in Building 1509

• Skirting wall tiles in Men’s Shower Rooms in 1600 buildings

• Gray/White paint on metal door frame (Exit/Entrance) in both 1500 & 1600 buildings

• Silver paint from the roof found on the exterior metal walls of Building 1516

Brief assessments, including photos, of LCP components are provided as Attachment 6.

3.4 LBP CONCLUSIONS AND RECOMMENDATIONS

Prior to demolition, the LBP materials should be characterized, sampled and managed in accordance with American Society for Testing and Materials (ASTM) E-1908. If the waste stream passes the EPA Landfill criteria as determined by the Toxic Characteristic Leaching Procedure (TCLP), it may be disposed of as normal construction waste in a facility licensed to accept the materials. LBP materials on metal substrates should be recycled as metal scrap in accordance with Federal, state and local regulations. The contractor shall remove the materials as a whole component to the greatest extent possible and shall properly characterize each waste stream for disposal. In addition, all

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December 26, 2019 Jacobs / EwingCole, A Joint Venture (JV) P a g e | 13 federal standards pertaining to lead-containing paint under General Industry (29 CFR 1910), Construction (29 CFR 1926), and Agriculture (29 CFR 1928) should be followed.

OSHA defines lead-containing paint as any paint that contains a detectable amount of lead. It is possible that the paint tested has trace amounts of lead at concentrations lower than the limit of detection of the instrument. Therefore, OSHA in Construction should be followed during demolition for painted surfaces containing less than 1.0 mg/cm2 of lead paint.

Contractors must be trained and accredited through the New York Department of Health and be employed by a lead firm licensed by the state of New York when a permit is needed.

Lead paint contractors include those who work on residential, public, and commercial buildings as well as the maintenance work required in rental housing; structural steel projects, such as bridges, water tanks, and industrial structures; and conduct lead paint inspections. Abatement supervisors and workers must be trained in accordance with New York state laws. If lead paint-containing components are not to be abated, lead safe construction practices should be followed.

Unlike asbestos, there are no state or federal requirements to remove lead-containing building components prior to demolition. In addition, the requirements of Title 40 Chapter 1, Subchapter R, and Part 745 for Target Housing does not apply to military barracks. Army guidelines should be followed concerning the removal of LBP from military residences. The lead survey performed within the Camp Buckner targeted major building components that might impact future worker protection associated with salvage or other demolition activities. It is not intended to be used for a USEPA-HUD risk assessment or for the classification of demolition debris. The contractor is responsible for verifying all building components for lead prior to any salvage activities and following all OSHA requirements associated with the removal of lead. The demolition debris must be classified by Toxicity Characteristic Leaching Procedure (TCLP) analysis.

As indicated in the survey limitations, physical bulk sampling was limited to Barracks 1611, 1612, 1509, 1523, 1516, 1520, 1508 and 1503. Based on the visual inspection conducted in additional Camp Buckner barracks, GCI’s Lead Inspector made the determination that all the barracks of Phase 1 and Phases 2-4 were homogeneous in construction. The following lead paint assumptions should made for all barracks on the reservation:

• Any paints/components that are homogeneous with identified LBP or LCP should be considered as such.

• Any additional paints/components identified during renovation/demolition that will be disturbed by the proposed work may require additional testing for further verification.

4.0 MOLD INSPECTION REPORT

Mold inspections are regulated by the New York Department of Labor. A mold inspection of the accessible spaces in Barracks 1611, 1612, 1509, 1523, 1516, 1520, 1508 and 1503, was conducted between the dates of November 13 and 14, 2019, by GCI’s New York State-licensed mold inspector, Mr. Michael Vollo, License # MA00871. His license may be

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December 26, 2019 Jacobs / EwingCole, A Joint Venture (JV) P a g e | 14 found in Attachment 10. The survey was conducted in accordance with New York regulations.

4.1 METHODOLOGY

The inspection included a visual inspection as well as swab and air sampling. Air sampling was conducted using a Buck BioAire™ pump and Air-O-Cell® Cassettes. Air samples were collected in rooms (showers) that had apparent visible microbial growth. Ambient air samples were collected outside of the barracks. Air and swab samples were submitted under strict chain of custody to Hayes Microbial of Midlothian, Virginia, for analysis via direct identification analysis.

4.2 MOLD RESULTS AND INTERPRETATION

Swab samples collected from several buildings at Camp Buckner were analyzed as containing low levels of Aspergillus/Penicillium, Chaetomium, Myxomycetes, and Cladiosporium. The concentration of these mold types was likely low due to the extremely cold weather conditions at the time of sampling, combined with limited activity (water source) in the showers since the summer months.

Non-viable air samples collected in the showers of several barracks detected elevated levels of mold in relation to the ambient samples. Ambient mold concentrations were likely low due to cold ambient conditions at the time of sampling. Analysis detected concentrations of Cladiosporium at a much higher concentration than background ambient air samples. However, Cladiosporium was detected as the dominant mold species in ambient background air samples as well. Non-viable air samples also detected Aspergillus/Penicillium, Chaetomium, and Myxomycetes. All mold species detected on the swab samples of the shower walls were also detected on the non-viable air samples.

Ideally, indoor concentrations of mold should be less than ambient concentrations with no visible apparent microbial growth present. The majority of results for the inside samples collected during the survey were less than the ambient (outdoor) concentration results of mold spores. The barracks are not heated and have not had any “shower activity” since the summer months. With high levels of mold detected in the indoor shower air samples, it can be concluded that significant mold growth does exist on the shower walls. Future samples collected during spring and summer months, may indicate much higher concentrations of mold and different dominate species.

Complete mold laboratory analysis reports and photographs may be found in Attachments 7 and 8, respectively.

4.3 MOLD REMEDIATION RECOMMENDATIONS

GCI found visible mold growth in the showers and detected mold in the air. Mold can remain dormant and begin to grow once moisture is reintroduced. Areas with apparent visible microbial growth, or with signs of active or previous water damage, should be treated and repaired accordingly. Areas with significant levels of apparent visible microbial growth should be abated in accordance with New York law.

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GCI has the following recommendations for the remediation of apparent visible microbial growth and water damage on components that are to remain after renovation:

• Visible mold should be removed from all building materials and the area should be treated with a biocide.

• Any sections of the sheetrock ceiling containing visible mold or water damage should be removed.

• Impacted plaster walls should be dried utilizing dehumidifiers; plaster and other materials that have been wet for over 48 hours, and are in poor condition, should be replaced.

Remediation should be performed in accordance with New York state law and the appropriate EPA and Army Technical Guidelines (TG 277).

5.0 POLYCHLORINATED BIPHENYL (PCB) REPORT

The Toxic Substances Control Act (TSCA) of 1976 authorized the U.S. Environmental Protection Agency (EPA) to control substances that were determined to cause unreasonable risk to public health or the environment. In 1979, the U.S. EPA banned the manufacture of new products containing PCBs and developed regulatory requirements for the storage, labeling, use, and disposal of materials containing PCBs at levels above the regulatory thresholds. In addition, the regulations under TSCA specify allowed or authorized uses of PCBs in certain situations. If a material or item is not specifically listed, it is considered unauthorized. The U.S. EPA considers building materials containing PCBs, including caulk, with PCB concentration exceeding 50 ppm to be a regulated material that requires specific abatement requirements and worker protection considerations.

5.1 METHODOLOGY

The inspection included a visual inspection as well as bulk sampling. Three bulk samples were submitted under strict chain of custody to ALS Laboratory Group of Holland, Michigan. EPA Method 8082 was used to determine the concentrations of various Aroclors using dual capillary columns with electron capture detectors. Aroclor is a PCB mixture produced from approximately 1930 to 1979; it is one of the most commonly known trade names for PCB mixtures. There are many types of Aroclors, and each has a distinguishing suffix number that indicates the degree of chlorination.

5.2 PCB RESULTS AND INTERPRETATION

The EPA considers a material to be PCB-containing if it contains equal to or greater than 50 parts per million (ppm) of PCBs. Laboratory analysis confirmed that none of the three samples contained detectable concentrations of PCBs. Laboratory results are presented in Attachment 9.

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Table 5: Concentrations of PCBs Noted in Caulking Samples summarizes the laboratory’s findings.

Table 5: Concentrations of PCBs Noted in Caulking Samples

Suspect Material Location PCB (Yes or No)

Gray Caulk B1516; under metal exterior walls No

Gray Caulk B1520; under metal exterior walls No

White Caulk B1520; around concrete footings No

GCI observed approximately 17 light fixtures in each barrack that are equipped with two ballasts per fixture. There is an elevated potential that PCB-containing light ballasts are present in light fixtures throughout the Facility.

5.3 PCB CONCLUSIONS AND RECOMMENDATIONS

Should fluorescent-light ballasts that are not specifically marked “non-PCB containing” ballasts be encountered during renovation, they should be managed and disposed of in accordance with Toxic Substances Control Act (TSCA) Storage and Disposal Requirements for Fluorescent Light Ballasts.

6.0 UNIVERSAL WASTES

EPA's Universal Waste (UW) regulations are promulgated in 40 CFR 273. This regulation sets hazardous waste management standards for federally designated "universal wastes," which include:

• Batteries

• Pesticides

• Mercury-containing equipment and

• Bulbs (lamps)

The regulations are alternate standards for the handling of UW. In contrast to the requirements found in 40 CFR 260 through 272, UW should be segregated and disposed of every 90 days, and in accordance with Federal, state, and local regulations. Disposal and management of such bulbs is regulated by the Resource Conservation and Recovery Act (RCRA) Universal Waste Rule (UWR) and should be handed in accordance with this rule. All future identified UW should be properly packaged and disposed of in accordance with Universal Waste rules.

GCI noted approximately 17 light fixtures in each barrack, therefore, as many as 34 fluorescent light bulbs containing mercury may be present. Any spent fluorescent bulbs stored at the site should be considered waste unless they are specifically identified as a new product stored onsite pending use. Disposal and management of spent bulbs is http://www.epa.gov/waste/hazard/wastetypes/universal/batteries.htm http://www.epa.gov/waste/hazard/wastetypes/universal/pesticides.htm http://www.epa.gov/waste/hazard/wastetypes/universal/mce.htm http://www.epa.gov/waste/hazard/wastetypes/universal/lamps/index.htm

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December 26, 2019 Jacobs / EwingCole, A Joint Venture (JV) P a g e | 17 regulated by the Resource Conservation and Recovery Act (RCRA) Universal Waste Rule (UWR) and should be handled and disposed of in accordance with this rule.

7.0 FIRE DETECTION SYSTEMS AND FIRE EXTINGUISHERS

Smoke detectors and/or fire alarms of unknown ages were noted during GCI’s inspection.

Ionization smoke detectors, if present, may use a small amount of radioactive material, americium-241, to detect smoke. Some very early smoke detectors were made using Radium-226 instead of americium-241. These older smoke detectors were available for use in industrial or commercial facilities. There is no health threat from ionization smoke detectors as long as the detector is not tampered with, burned and it is used as directed.

The fire extinguishers and any halon-type portable fire extinguishers (if found in the building) should be decommissioned in accordance with National Fire Protection Association (NFPA) 10 and 12A (Standard for Portable Fire Extinguishers, Standard on Halon 1301 Fire Extinguishing Systems). Removal and recycling of Halon 1211 from fire extinguishers shall be done only using a listed halon closed recovery system and trained technicians.

Old fire extinguishers that are not dry chemical or carbon dioxide may contain carbon tetrachloride, a known carcinogen. Contact a local Fire Department of New York (FDNY) -certified fire extinguisher retailer to request that they dispose of or recycle the fire extinguishers.

8.0 SELF-LUMINOUS EXIT SIGNS

Approximately three to four EXIT signs per barrack were noted during GCI’s inspection.

Self-luminous EXIT signs containing the radioactive gas, tritium, were widely used in a variety of facilities across the United States at one time. While the United States Department of Defense’s Unified Facilities Criteria specifically prohibits tritium exit signs in military facilities, given the age of the Facility, signs containing this gas may be present.

Intact tritium EXIT signs pose little or no threat to public health and safety and do not constitute a security risk. However, the NRC requires proper accounting and disposal of all radioactive materials.