S65C_Final_ACM_LBP_Haz_Survey_Report_082614.pdf

Final Asbestos-Containing Materials Survey, Lead-Based Paint Survey, and Hazardous Components Inventory

Lock S65C Property Okeechobee County, Florida

CTO Number: W912EP-11-D-0008 Delivery Order: 0011

PREPARED FOR:

US ARMY CORPS OF ENGINEERS

DEPARTMENT OF THE ARMY

JACKSONVILLE DISTRICT

701 SAN MARCO BOULEVARD

JACKSONVILLE, FLORIDA 32207

PREPARED BY:

AEROSTAR SES LLC

11181 ST. JOHNS INDUSTRIAL PARKWAY NORTH

JACKSONVILLE, FLORIDA 32246

Aerostar Project # M3010.0015.0011.07

August 2014

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

This is to certify that the Final Report for the Asbestos-Containing Materials (ACM) Survey, Lead-Based Paint (LBP) Survey, and Hazardous Components Inventory of the Lock S65C Property located in Okeechobee County, Florida, has been examined by the undersigned.

DATE August 26, 2014 SIGNATURE:

Miles Eckert Project Scientist AHERA Asbestos Building Inspector Certification No. 7ME0830120AIR0002 Lead-Based Paint Risk Assessor Certification No. FL-R-124717-1

DATE August 26, 2014 SIGNATURE:

John H. Hubbard Senior Project Manager

DATE August 12, 2013 SIGNATURE:

Paul M. Fitch Licensed Asbestos Consultant License No. AX64

Lock S65C Property, Okeechobee County, Florida August 26, 2014 Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page i

TABLE OF CONTENTS

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

1.0 EXECUTIVE SUMMARY

1.1 Site Name

1.2 Name and Certificate of Inspector(s)

1.3 Site Description and Activities

1.4 Findings and Results

1.4.1 Asbestos Survey

1.4.2 Lead-Based Paint Survey

1.4.3 Hazardous Component Inventory

2.0 INTRODUCTION

3.0 REGULATORY SUMMARY

3.1 Asbestos

3.1.1 Environmental Protection Agency

3.1.2 Occupational Safety and Health Administration

3.1.3 Florida

3.2 Lead

3.2.1 EPA

3.2.2 Occupational Safety and Health Administration

3.2.3 Department of Housing and Urban Development

3.3 Hazardous Components

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

4.2 Lead-Based Paint Survey

4.3 Hazardous Component Inventory

5.0 RESULTS

5.1 Asbestos Survey Results

5.2 Lead-Based Paint Survey Results

5.3 Hazardous Component Inventory Results

6.0 CONCLUSIONS AND RECOMMENDATIONS

6.1 Asbestos-Containing Materials

6.2 Lead-Based Paint

6.3 Hazardous Component Inventory

TABLES

TABLE 1 Summary of Asbestos Survey TABLE 2 Summary of XRF Survey TABLE 3 Paint Chip Sample Results TABLE 4 Summary of Hazardous Components Survey

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page ii

FIGURES

FIGURE 1 Homogeneous Area Sample Locations – Tender House FIGURE 2 Homogeneous Area Sample Locations – Gate Buildings FIGURE 3 XRF and Paint Chip Sample Locations – Tender House FIGURE 4 XRF Sample Locations – Gate Buildings FIGURE 5 XRF and Paint Chip Sample Locations – Lock FIGURE 6 Homogeneous Area and XRF Sample Locations – Spillway & Monitor Well

APPENDICES

APPENDIX A Certifications APPENDIX B Notice of Demolition or Asbestos Renovation APPENDIX C Laboratory Analytical Results APPENDIX D Photographic Documentation

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 1

1.0 EXECUTIVE SUMMARY

1.1 Site Name

Tender House and Gate Buildings S65C Property Lorida, Okeechobee County, Florida Contract No: W912EP-11-D-0008; Task Order No: 0011

1.2 Name and Certificate of Inspector(s)

Miles Eckert Tracy Gonzo Project Scientist Project Scientist AHERA Asbestos Building Inspector AHERA Asbestos Building Inspector Certification No. 7ME0830120AIR0002 Certification No. 7ME08301201AIR0003 Lead-Based Paint Risk Assessor Lead-Based Paint Risk Assessor Certification No. FL-R-124717-1 Certification No. FL-R-15761-2

1.3 Site Description and Activities

From March 25 to 27 and on August 7, 2013, Aerostar SES LLC (Aerostar) conducted an Asbestos-Containing Materials (ACM) Survey, a Lead-Based Paint (LBP) Survey, and a Hazardous Components Inventory at the Lock S65C Property located in Okeechobee County, Florida. The site consists of a lock, a spill way, a Tender House, a Pump House, a Radio Antenna, monitor wells, and four small Gate Buildings. The area of the surveys included all accessible areas throughout the exteriors and interiors of each structure. The site is scheduled for demolition.

1.4 Findings and Results

The following table summarizes the findings of the surveys and identifies material requiring special handling:

Building/Structure Friable

ACM*

Non-friable

Category I

ACM*

Non-friable

Category

II ACM*

Material Containing

<1% Asbestos*

LBP

Hazardous

Components/Special Waste**

Tender House YES YES NO YES NO† YES

Pump House NO NO NO NO NO† NO

Gate Buildings 1 &

NO YES YES NO NO† YES

Gate Buildings 3 &

NO NO NO NO NO† NO

Radio Antenna NO NO NO NO NO NO

Monitor Wells NO NO YES NO NO YES

Spillway NO NO YES NO YES YES

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 2

Building/Structure Friable

ACM*

Non-friable

Category I

ACM*

Non-friable

Category

II ACM*

Material Containing

<1% Asbestos*

LBP

Hazardous

Components/Special Waste**

Gates NO NO NO NO NO† YES

* Material must be handled in accordance with OSHA Standard 29 CFR 1926.1101 and/or NESHAPs † Lead concentrations were detected < 1.0 mg/cm2 or 0.5% wt.

** Materials must be handled in accordance with 40 CFR 273 or 40 CFR 761

1.4.1 Asbestos Survey

A visual reconnaissance of suspect ACMs was performed in all accessible areas throughout the buildings and structures located at the site. A total of 20 homogeneous areas were identified.

Six homogeneous areas sampled within the structures were found to contain greater than 1% asbestos by Polarized Light Microscopy (PLM) or the Point Count Method. Asbestos was detected greater than 1% in asphalt shingle mastic, roof flashing, ceiling texture, and floor tile mastic within the Tender House; window glazing within Gate Buildings 1 & 2; and 9” x 9” vinyl floor tile in Gate Building 2. One homogeneous area sampled was found to contain less than 1% asbestos by the Point Count Method. Joint compound located in the Tender House was found to contain less than 1% asbestos. Four identified homogeneous area were not sampled. The generator vibration damper located in Gate Building 1; gaskets on the monitor well with a telemetry system located southwest of the spillway; electrical components located throughout the Gate and Spillway operation equipment; and the Stilling Well pipe located in Gate Building 2 were not sampled and are assumed to contain asbestos until sampled for analysis. No asbestos was detected in the remaining nine homogeneous areas.

1.4.2 Lead-Based Paint Survey

A LBP survey was performed throughout the buildings and structures using a Niton XLp 302A series X-Ray Fluorescence (XRF) portable spectrum analyzer, serial number 23358. Two of the 227 XRF sample locations exhibited lead concentrations equal to or greater than 1.0 milligram per square centimeter (mg/cm2). Lead concentrations less than 1.0 mg/cm2 were detected in 85 of 227 XRF sample locations.

Aerostar collected four paint chip samples from coating systems for laboratory analysis. Three of the four paint chip samples were found to contain detectable lead concentrations less than 0.5 percent by weight (% wt.). One of the four paint chip samples was found to contain no detectable lead concentration.

1.4.3 Hazardous Component Inventory

Aerostar inspected for and quantified components throughout each building and structure to evaluate for the presence of hazardous materials or materials requiring special handling.

Light fixtures were dismantled to determine if lighting ballast labeling included information regarding PCB content, if the ballasts contained PCBs, and to determine if bulbs contained

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 3 mercury. Two types of ballasts were identified labeled “No PCBs”. Two types of fluorescent lamps were identified which contain trace amounts of elemental mercury. Twenty-one Compact Fluorescent Self-Ballasted light bulbs were identified. Eight High-Intensity Discharge lights and six nautical lights were identified.

Heating, ventilation, and air conditioning (HVAC) system components were inspected and associated thermostats were dismantled inspected to determine if they contained mercury. One thermostat was identified containing a mercury switch. Three Air Conditioners were identified that contain Freon or similar coolant.

An underground propane tank was identified on the site containing an unknown amount of propane.

Two monitor wells and a radio antenna were inspected for hazardous materials. No hazardous materials were observed.

Multiple containers of commercial products were observed at the site. Products included household cleaners, various pesticides, automotive products, petroleum based lubricants and cleaners, fuel containers, and water softener pellets.

Five hydraulic pumps and one generator were identified in the Gate Buildings and the Spillway Hydraulic Room all containing fluids and lubricants. A portion of the equipment was labeled identifying the fluids and/or lubricants as “Bio-Friendly”.

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2.0 INTRODUCTION

From March 25 to 27 and on August 7, 2013, Aerostar conducted an ACM Survey, LBP Survey, and Hazardous Components Inventory of the buildings and structures at the Lock S65C Property located in Okeechobee County, Florida. The site consists of a lock, a spill way, a Tender House, a Pump House, a Radio Antenna, monitor wells, and four small Gate Buildings. The area of the surveys included all accessible areas throughout the exteriors and interiors of each structure. The site is scheduled to undergo demolition. Aerostar is a Licensed Asbestos Business Organization, recognized by the Florida Department of Business and Professional Regulation (DBPR), Asbestos Licensing Unit, License Number ZA455. Aerostar is certified by the Environmental Protection Agency (EPA), Pesticides and Toxic Substances Branch, to conduct lead-based paint activities in the State of Florida, Certification Number FL-1654-3. The ACM inspections were performed by Asbestos Hazard Emergency Response Act (AHERA)-certified Asbestos Inspectors under the direction of a DBPR-Licensed Asbestos Consultant (LAC). The LBP surveys were conducted by EPA-certified lead-based paint Risk Assessors. Copies of our certifications are included in Appendix A.

3.0 REGULATORY SUMMARY

3.1 Asbestos

3.1.1 Environmental Protection Agency

The EPA has published a list of hazardous air pollutants and promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations. Since asbestos presents a significant risk to human health as a result of air emissions from one or more source categories, it is therefore considered a hazardous air pollutant. The Asbestos NESHAP Regulation (40 CFR 61, Subpart M) addresses milling, manufacturing and fabricating operations, demolition and renovation activities, waste disposal issues, active and inactive waste disposal sites and asbestos conversion processes.

Friable ACM is defined by the Asbestos NESHAP Regulations as any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure (Sec. 61.141).

Non-friable ACM is any material containing greater than 1% asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure (Sec. 61.141).

EPA also defines two categories of non-friable ACM: Category I and Category II non-friable

ACM.

Category I non-friable ACM is any asbestos-containing packing, gasket, mastic, resilient floor covering or asphalt roofing product which contains greater than 1% asbestos as

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 5 determined using PLM according to the method specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141).

Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing greater than 1% asbestos as determined using PLM according to the methods specified in Appendix E, Subpart E, 40 CFR Part 763 (Sec. 61.141), that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos-Containing Material (RACM) is: (a) friable ACM, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

Category I non-friable ACM must be inspected and tested for friability if it is in poor condition prior to demolition to determine whether or not it is subject to NESHAP. If the ACM is friable, it must be handled in accordance with NESHAP. Asbestos-containing packings, gaskets, resilient floor coverings and asphalt roofing materials must be removed prior to demolition only if they are in poor condition and are friable.

NESHAP further requires that if a facility is demolished by intentional burning, all of the facility's ACM, including Category I and II non-friable ACM, must be removed prior to burning (Sec. 61.145(c)(10)).

If Category I or Category II non-friable ACM is to be sanded, ground, cut, or abraded, the material is considered RACM and the owner or operator must abide by the following (Sec.

61.145(c)(1)):

(i) Adequately wet the material during the sanding, grinding, cutting or abrading operations;

(ii) Comply with the requirements of 61.145(c)(3)(i) if wetting would unavoidably damage equipment or present a safety hazard; and

(iii) Handle asbestos material produced by the sanding, grinding, cutting, or abrading, as asbestos-containing waste material subject to the waste handling and collection provisions of Section 61.150.

Except for the following, Section 61.145(c) of the Asbestos NESHAP regulation requires that each owner or operator of a demolition or renovation activity involving RACM remove all such material from a facility being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

ACM need not be removed before demolition or renovation if it:

(i) Is a Category I non-friable ACM that has not become friable;

(ii) Is on a facility component that is encased in concrete or other similarly hard material and is adequately wet whenever exposed during demolition or renovation;

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 6

(iii) Was not accessible for testing and therefore was not discovered until after demolition or renovation began and, as a result of the demolition or renovation, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at all times until disposed of; or

(iv) Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition or renovation.

3.1.2 Occupational Safety and Health Administration

The Occupational Safety and Health Administration (OSHA) regulates asbestos exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where asbestos is present;

Removal or encapsulation of materials containing asbestos;

Construction, alteration, repair, maintenance, or renovation of structures, substrates, or portions thereof, that contain asbestos;

Installation of products containing asbestos;

Asbestos spill/emergency cleanup; and Transportation, disposal, storage, containment of and housekeeping activities involving asbestos or products containing asbestos, on the site or location at which construction activities are performed.

The OSHA Standard 29 CFR 1926.1101 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to asbestos. The OSHA standard does not apply to asbestos-containing asphalt roof coatings, cements and mastics.

3.1.3 Florida

Florida Statutes 469.004 and 469.005 require licensure of asbestos consultants and contractors by the DBPR.

Florida Statute 553.79 requires that the Florida Department of Environmental Protection (FDEP) be notified in writing before a local building permit is granted for any building demolition or renovation which would disturb asbestos material. A copy of the FDEP permit is included as Appendix B.

3.2 Lead

3.2.1 EPA

EPA’s 2008 Lead-Based Paint Renovation, Repair and Painting (RRP) Rule (as amended in 2010 and 2011), aims to protect the public from lead-based paint hazards associated with renovation, repair and painting activities. Under the rule, beginning April 22, 2010, firms performing renovation, repair and painting projects that disturb lead-based paint in homes, child care

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 7 facilities, and kindergartens built before 1978 must be EPA- or state-certified and must use certified renovators who follow specific work practices to prevent lead contamination. This includes in-house maintenance staff and many types of outside contractors.

3.2.2 Occupational Safety and Health Administration

OSHA regulates lead exposure during all construction work including, but not limited to, the following:

Demolition or salvage of structures where lead or materials containing lead are present;

Removal or encapsulation of materials containing lead;

New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead;

Installation of products containing lead;

Lead contamination/emergency cleanup;

Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed, and Maintenance operations associated with the construction activities.

The OSHA Standard 29 CFR 1926.62 requires the use of engineering controls, work practices, and personal protective equipment to reduce or eliminate employee exposure to lead.

3.2.3 Department of Housing and Urban Development

According to the Department of Housing and Urban Development (HUD) guidelines 20 CFR Part 35, lead-based paint is defined as paint containing a lead concentration greater than or equal to 0.5 % wt by laboratory analysis or 1.0 mg/cm2 of lead by XRF. HUD’s definition of LBP cannot be used to determine safe working conditions under OSHA. OSHA’s Lead in Construction Standard, 29 CFR 1926.62, was intended to apply to any detectable concentration of lead in paint by laboratory analysis. OSHA’s only accepted methodology for determining an employee’s exposure to airborne lead contaminants is through personal air monitoring. Any paint with detectable concentrations of lead, by XRF or laboratory analysis that is subjected to cutting, abrading, welding, scraping, and/or sanding, must be handled in accordance with 29 CFR 1926.62, to prevent employee exposure.

3.3 Hazardous Components

Equipment found to contain mercury, such as switches or bulbs must be handled in accordance with 40 CFR Part 273. Materials found to contain PCBs, such as ballasts, must be handled in accordance with 40 CFR Part 761.

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 8

4.0 METHODS OF INVESTIGATION

4.1 Asbestos Survey

Sampling protocols set forth by the EPA under 40 CFR 763.86 were followed during the inspection. The asbestos survey was performed by observing, touching, and sampling accessible suspect building materials throughout the building. The purpose of this survey was to locate and identify suspect ACMs, to quantify the material, and to separate it into unique areas for further assessment. The condition and location of representative suspect materials were defined throughout the building.

Bulk asbestos sampling procedures utilized for the collection of suspect ACMs first required the establishment of a homogeneous sampling area. A homogeneous sampling area is defined as an area of material of the same type (texture and color) which was applied during the same general time period. Each individual sampling area was then examined and representative samples of suspect materials were collected. The U.S. EPA has published guidelines and recommendations pertaining to surveying and sampling for friable ACMs. The guidelines were followed during the survey where appropriate. U.S. EPA publications and current regulations mainly address friable materials, such as surface finishes and structural fireproofing. The samples were analyzed by PLM with dispersion staining according to EPA Method 600/R-93/116. The PLM test is an EPA-approved analytical method for asbestos identification. Bulk samples were collected by an AHERA-certified Asbestos Inspector, and analyzed by a laboratory that maintains accreditation through the National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of bulk samples by PLM. The test uses the unique optical properties of mineral forms in the samples to specifically identify the various asbestos types.

Where distinct layers were present, bulk samples were collected to represent each individual layer of the suspect material. Mastic and/or other adhesive substances were included when possible. At the time of sample collection, the inspector noted material type, approximate amount, sampling locations, and condition of the materials.

Samples were labeled with a unique alphanumeric identification system (S65C-T/G-HA-yy-zz).

The first set of characters (S65C) indicates the identification assigned to the property. The second set of characters (T/G) indicates the building where samples were collected (T for Tender House or G for Gate Buildings). If no T or G was assigned, the material was identified on an outlying structure. The third set of characters (HA) indicates the samples were sampled from a homogeneous area for asbestos analysis. The fourth set of characters (yy) indicates the homogeneous area designation assigned by the asbestos inspector. The fifth set of characters

(zz) is the individual sample identification number. Where distinct layers were separated, a letter (A, B, C) was assigned for each additional layer analyzed by the laboratory.

The surface area of the samples was adequately wetted prior to sample collection. All necessary precautions were taken to prevent visible emissions, air-borne fiber release, and debris, and to protect the facility occupants from exposure. Samples were submitted in independent sealed containers to EMSL Analytical, Inc. (EMSL), 5125 Adanson Street, Suite 900, Orlando, Florida, for laboratory analysis according to EPA Method 600/R-93/116.

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4.2 Lead-Based Paint Survey

The LBP inspection was performed using Niton XLp 302A series XRF portable spectrum analyzer, serial number 23358. The Niton XLp 302A series XRF uses a Cadmium-109 radioactive source. The source undergoes a radioactive decay, in a two-step process, that releases x-rays and gamma rays with enough energy to cause both K-shell and L-shell fluorescence. During this process, if the primary x-ray emitted by the XRF has sufficient energy, electrons are ejected from the inner shells of the lead atoms, creating vacancies that cause an unstable condition for the atoms. As the atoms return to their stable condition, electrons from the outer shells are transferred to the inner shells releasing energy. The Niton XLp 302A series XRF uses dual detectors to read the K-shell and L-shell energy spectrums that are produced.

XRF sampling results were obtained from each sampling area within the buildings. The sampling locations were determined by the color of paint, substrate, and location within the building. The sampling locations are identified by room number or description, source, substrate, feature, condition of paint, and color. The site was arbitrarily designated as follows:

“A” northeast at the Tender House and Gate Buildings and northwest at the Spillway; and “B”, “C”, and “D” proceeding clockwise in relation to side “A”. The XRF sample results are reported in mg/cm2. Calibration checks were performed immediately before, after, and every four hours during the LBP survey to ensure the sample results were within the tolerance limits of the instrument’s Performance Characteristic Sheet.

Two paint chip samples were collected from the coating systems on the exterior of the Tender House and two paint chip samples were collected from coating systems associated with the gates.

The samples contained all layers of paint, including the bottom layer, to the substrate. Each sample was labeled with a unique alphanumeric identification system. The first set of characters (S65C) indicates the identification assigned to the property. The second set of characters (T/G) indicates the building where samples were collected (T for Tender House or G for Gate Buildings) or with “XRF” if collected from the gates. The third set of characters indicates the corresponding XRF sample number. Samples were submitted to EMSL for analysis by Flame Atomic Absorption Spectroscopy (Flame AAS), EPA analytical method SW 846-3050B/7000B.

Laboratory analysis consisted of digestion of the sample using acid, then heating, filtering, and analyzing the digested sample by atomic absorption-direct aspiration.

4.3 Hazardous Component Inventory

Aerostar inspected for and quantified components throughout each building and structure to evaluate for the presence of hazardous materials or materials requiring special handling. A portion of identified light fixtures were dismantled and inspected for labels stating “No PCBs”.

Fluorescent and High Intensity Discharge (HID) lighting lamps were inspected for manufacturer labeling. Heating Ventilation and Air Conditioner (HVAC) system components and switches were inspected for the presence of coolant or mercury. Each area was inspected for storage containers or equipment which may contain hazardous materials including, but not limited to electrical transformers, various electric motors, telephone and electrical equipment, compressed gases, paints, oils, cleaning supplies, consumer electronics, and stored batteries. Material Safety Data Sheets developed by the manufacturer were reviewed to provide information on hazardous material content of identified components.

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 10

5.0 RESULTS

5.1 Asbestos Survey Results

From March 25 to 27 and on August 7, 2013, Mr. Miles Eckert and Ms. Tracy Gonzo, AHERA-certified Asbestos Inspectors, conducted asbestos surveys of the structures to identify the locations, quantities, and conditions of suspect ACMs. Aerostar performed an asbestos demolition survey of all areas throughout the buildings. A total of 20 homogeneous areas were identified. The identified homogeneous materials included:

Tender House

Asphalt Shingles (2 types) Mastic Associated with Asphalt Shingles Flashing Drywall Joint Compound Tape Ceiling Texture 12” x 12” Vinyl Floor Tile (VFT) Mastic Associated with 12” x 12” VFT Window Caulking

Gate Buildings

Window Glazing 9” x 9” VFT Mastic Associated with 9” x 9” VFT Vibration Damper Electrical System Components Stilling Well Pipe

Spillway and Monitor Wells

Expansion Joint Gaskets

A total of 45 samples were collected from 16 of the 20 identified homogeneous areas and submitted to EMSL for analysis by PLM. Following receipt of the results of the PLM analysis, six samples collected from two homogeneous areas were re-analzyed by the EPA Point Count Method (EPA 600/R-93/116 and/or 600-M4-82-020) to further evaluate asbestos content.

Analytical results of the samples revealed that 6 of the 20 homogeneous areas identified were found to contain greater than 1% asbestos by PLM or Point Count method and are as follows:

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 11

Material Description

Homogeneous Area ID

Location Approximate

Amount Asbestos Type

Analysis

NESHAP

Category

Mastic Associated With Asphalt

Shingles

S65-T-HA-1A

Throughout the Roof of the Tender House

2,100 SF

Chrysotile

5% PLM NF Cat. I

Flashing S65C-T-HA-2 Roof Penetrations of the Tender House

2 SF

Chrysotile 5%

PLM NF Cat. I

Ceiling Texture S65C-T-HA-5

Throughout All Rooms except the Bathroom of the Tender House

960 SF

Chrysotile

1.25-1.75% Point Count RACM

Mastic Associated With 12” x 12”

Vinyl Floor Tile - Beige

S65C-T-HA-6

Throughout All Rooms except the Bathroom of the Tender House

910 SF Chrysotile 3% PLM NF Cat. I

Window Glazing S65C-G-HA-1 Interior Windows in Gate Buildings 1 & 2

192 LF (16

Windows

4’x2’) Chrysotile 2% PLM NF Cat. II

9” x 9” Vinyl Floor Tile - Gray

S65C-G-HA-2

Bathroom of Gate

Maintenance Building

27 SF Chrysotile 5% PLM NF Cat. I

Four homogeneous areas were identified and are assumed to contain asbestos until sampled is as follows:

Material Description

Homogeneous Area ID

Location Approximate

Amount Asbestos Type %

NESHAP

Category

Vibration Damper S65C-G-HA-3 Generator within Gate

Building 1 1 Damper Assumed NF Cat. II

Gaskets S65C-3

Monitor Well with Telemetry System in the southeastern portion of the property

4 Gaskets Assumed NF Cat. II

Electrical System Components

S65C- Operational Equipment

Throughout the Spillway and Gate Lock System

2,000 LF Assumed NF Cat. II

Stilling Well Pipe S65C-5 Gate Building 2 15” Diameter and 3 LF High

Assumed NF Cat. II

Three samples of joint compound located throughout the interior walls and ceilings of the Tender House (homogeneous sample area S65C-T-HA-4) were also analyzed by the EPA Point Count Method to further assess and quantify the asbestos content of this material. The results of this method indicated that the material contains 0.50% - 1.00% Chrysotile asbestos.

Asbestos sample results are summarized in Table 1. Sample locations are depicted on Figures 1, 2, and 6. Consultant, inspector, and laboratory credentials are provided in Appendix A. A copy of the laboratory analytical results and appropriate Chain of Custody Records are included in Appendix C. Photographic Documentation is included as Appendix D.

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5.2 Lead-Based Paint Survey Results

Based on the Department of Housing and Urban Development (HUD) guidelines, a laboratory analysis of a paint chip sample equal to or greater than 0.5 percent lead by weight (% wt), or an XRF sample equal to or greater than 1.0 mg/cm2 is the action level at which the paint is considered to be LBP. XRF sample readings (Pbc ± Pbc Error) are reported as lead concentration (Pbc) in mg/cm2 plus or minus the statistical deviation (Pbc Error) that allows for 95% confidence. To determine the XRF sample result to be positive or negative, the XRF sample readings (Pbc ± Pbc Error) were reported as a 95% confidence interval compared to the HUD action-level (1.0 mg/cm2). Two of the XRF sample results exhibited lead concentrations greater than 1.0 mg/cm2:

Gray concrete door frame in the Spillway hydraulic room White concrete door frame in the Spillway hydraulic room

Concentrations of lead below the level which HUD defines as LBP were detected in the following building components:

Tender House

Beige brick threshold and window sill on the exterior Beige cinderblock walls in the Laundry Room and on the exterior Beige drywall walls in Bedrooms 1, 2, and 3 Beige wood ceiling in the Laundry Room, Carport, and on the exterior Beige wood crown molding and wall in the Carport Beige wood door jamb and shelf in the Laundry Room Beige wood gable siding on the exterior Beige wood soffit on the exterior Blue brick windowsills on the exterior Blue wood column, crown molding, and trim on the exterior Blue wood door casings in the Carport Beige wood door casing in the Pump House Blue wood door jamb and trim in the Pump House Gray concrete floor in the Carport Red cinderblock wall of the Pump House Red wood wall in the Laundry Room White drywall ceilings in the Kitchen and Dining Room White drywall walls in the Bathroom, and Kitchen White wood baseboards in the Dining Room and Bedroom 2 White wood crown molding and door of the Porch White wood door casings in the Living Room, Kitchen, and Bedroom 3 White wood door jambs in the Hall and Bedroom 2 White wood shelf in the Bathroom White wood wall on the Porch

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 13

Gate Buildings

Gray concrete floors of Buildings 1, 2, 3, and 4 White cinder block walls on the exterior of Buildings 1, 2, 3, and 4 Yellow concrete bollard on the exterior of Building 2

Gates

Gray metal top of the Gate

Spillway

Gray metal boxes on the top of the Spillway Gray concrete walls in the Hydraulic Room White concrete walls in the Hydraulic Room Red concrete wall in the Hydraulic Room White concrete ceiling in the Hydraulic Room Yellow concrete sign on the road

Four paint chip samples were collected from coating systems at the site. Sample S65C-T-13 was collected from the beige wood gable siding on the exterior of the Tender House, sample S65C-T- 42 was collected from the blue wood crown molding on the exterior of the Tender House, sample S65C-XRF-9 was collected from the yellow concrete bollards around the Gates, and sample S65C-XRF-15 was collected from the gray metal top of the Gates. Analytical results of the paint chip samples indicated lead concentrations less than the level considered to be LBP by the HUD guidelines of 0.5% wt. Paint chip sample S65C-T-13 contained a lead concentration of 0.24% wt., sample S65C-T-42 contained a lead concentration of 0.34% wt., sample S65C-XRF-9 contained a lead concentration of <0.10% wt., and sample S65C-XRF-15 contained a lead concentration of 0.012% wt.

XRF sample results are provided in Table 2. Paint chip sample results are provided in Table 3 along with the corresponding XRF sample results. XRF and Paint Chip Sample locations are depicted on Figures 3 through 6. Consultant, inspector, and laboratory credentials are provided in Appendix A. A copy of the laboratory analytical results and appropriate Chain of Custody Records are included in Appendix B.

5.3 Hazardous Component Inventory Results

Aerostar inspected for and quantified components throughout each building and structure to evaluate for the presence of hazardous materials or materials requiring special handling. The following components were identified:

Aerostar observed five light fixtures and found 2 types of light ballast within the Tender House and Gate Buildings which were labeled “No PCBs”.

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 14

Aerostar observed five light fixtures and found 2 types of fluorescent lamps within the Tender House and Gate Buildings. According to the manufacturer, the lamps contain trace amounts of elemental mercury.

Aerostar observed five 4-bulb light fixtures and one 1-bulb light fixture at the site containing Compact Fluorescent Self-Ballasted light bulbs. According to the manufacturer, the bulbs contain trace amounts of elemental mercury.

The Tender house has central and window HVAC systems; both were active and contained Freon or similar coolant. Building 2 has a window A/C that contains Freon or similar coolant.

Aerostar identified one HVAC system thermostat within the Tender House which contained a mercury switch.

Multiple containers of commercial products were observed throughout the site. Products include household cleaners, various pesticides, automotive products, petroleum based lubricants and cleaners, fuel containers, and water softener pellets.

Aerostar identified hinges, cables, mechanical devices at the Spillway and Gates which contain hydraulic oil or similar lubrications. A portion of the systems were labeled as containing biodegradable environmentally friendly lubricants.

Hand rails and cleats located on the Spillway and within the Lock were galvanized with no paint.

The radio antenna was galvanized with no paint. No hazardous materials were observed at the radio antenna.

The monitor well with a telemetry system on the southeast corner of the Spillway had four flanges with gaskets. No hazardous materials were observed.

No hazardous materials were observed at the monitor well on the northwest corner of the property beyond the Spillway.

A propane Underground Storage Tank (UST) was observed on the site. No labeling was observed to indicate tank size. According to Ms. Fran Hettinger (Lock Operator) the tank is maintained and refilled by “Glades Gas”. Five abandon wells were observed in the vicinity of the propane tank.

A Westinghouse Control Center, Model 4THC 81237-1 CG7, was observed in Building 2 manufactured in 1964. Additional unlabeled electrical equipment was observed at the site. Electrical equipment was energized. The equipment may contain asbestos components and other hazardous electrical components.

A Cumins Onan Genset Generator (Model No. 65GGHB, Serial No. E980739483) was located in Gate Building 1. The generator was operated using the propane UST. The generator contains unknown types of cooling fluids and lubricants.

Five hydraulic pumps were located in each of the Gate Buildings 1 through 4 and the hydraulic room at the east end of the Stillway. All five hydraulic pumps have unknown types of lubricants.

A water shut-off valve was located on the northwest bank.

Hydraulic fluid used in multiple components had labels that stated to fill only with a biodegradable or non toxic hydraulic fluid.

A 12 volt lead-acid battery, Model Car Quest Part No. 27-70, was observed in Gate

Building 1.

A 12 volt lead-acid battery, Model Power Sonic No. PS-12400NB was observed in the

Spillway Hydraulic Room.

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 15

Hazardous components survey findings are provided in Table 4. Photographic Documentation is included as Appendix D.

6.0 CONCLUSIONS AND RECOMMENDATIONS

Aerostar has completed ACM and LBP Surveys and a Hazardous Components Inventory of the Lock S65C Property located in Okeechobee County, Florida.

The following table summarizes the findings of the surveys and identifies material requiring special handling:

Building/Structure Friable

ACM*

Non-friable

Category I

ACM*

Non-friable

Category

II ACM*

Material Containing

<1% Asbestos*

LBP

Hazardous

Components/Special Waste**

Tender House YES YES NO YES NO† YES

Pump House NO NO NO NO NO† NO

Gate Buildings 1 &

NO YES YES NO NO† YES

Gate Buildings 3 &

NO NO NO NO NO† NO

Radio Antenna NO NO NO NO NO NO

Monitor Wells NO NO YES NO NO YES

Spillway NO NO YES NO YES YES

Gates NO NO NO NO NO† YES

* Material must be handled in accordance with OSHA Standard 29 CFR 1926.1101 and/or NESHAPs † Lead concentrations were detected < 1.0 mg/cm2 or 0.5% wt.

** Materials must be handled in accordance with 40 CFR 273 or 40 CFR 761

6.1 Asbestos-Containing Materials

Twenty homogeneous areas were identified during the asbestos survey. Four identified homogeneous areas were not sampled. A total of 45 samples were collected from 16 identified homogeneous areas and submitted for PLM analysis. Six samples were re-analyzed by the EPA Point Count Method. Analytical results of the samples revealed that 6 homogeneous areas sampled contained greater than 1% asbestos by PLM or the Point Count Method, which include asphalt shingle mastic, flashing, ceiling texture, VFT, and VFT mastic. Four homogeneous areas were not sampled and are assumed to contain asbestos until sampled for analysis, which include a vibration damper, gaskets, electrical system components, and a stiller pipe. One homogeneous area sampled contained less than 1% asbestos by the Point Count Method, which includes joint compound. No asbestos was detected in the remaining nine homogeneous areas.

Floor tile, mastics, gaskets, and flashing are NESHAP Category I non-friable ACMs. NESHAP Category I non-friable ACMs are not required to be removed prior to demolition or renovation of the building, provided that wet-demolition practices are implemented and resulting debris from the structure is properly transported to a landfill permitted for disposal of ACM. If NESHAP

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 16

Category I non-friable ACMs are in poor condition or become friable during demolition, the material must be treated as a RACM and be removed by a licensed asbestos abatement contractor and disposed of at a class one landfill prior to renovation, remodeling, or demolition of the building.

Vibration dampers, electrical system components, and pipe are NESHAP Category II non-friable ACMs. NESHAP Category II non-friable ACMs must be removed by a licensed asbestos abatement contractor following OSHA Class II work activities and disposed of at a class one landfill prior to renovation, remodeling, or demolition of the building.

Joint compound found to contain less than 1% asbestos by the Point Count Method is not categorized by the NESHAP regulation; however, precautions must be taken when handling the material to prevent worker exposure to asbestos in accordance with OSHA standards. OSHA requires that single layer sampling be conducted for multilayered materials such as wallboard.

The removal of wallboard systems that contain asbestos is covered by the standard as a Class II operation. The material should be removed in accordance with 29 CFR 1926.1101 and can be disposed of as Construction and Demolition (C&D) debris.

Ceiling texture is a RACM. RACMs must be removed by a licensed asbestos abatement contractor following OSHA Class I work activities and disposed of at a class one landfill prior to renovation, remodeling or demolition of the building.

Due to the presence of ACM, OSHA’s Asbestos Standard for the Construction Industry (29 CFR 1926.1101) must be followed. Any renovation, remodeling, or demolition of ACMs must be handled by a DBPR Licensed Asbestos Contractor under Florida Administrative Code (F.A.C.)

Title XXXII Chapter 469.

In accordance with the OSHA Asbestos Standard for the Construction Industry (29 CFR 1926.1101), demolition of a building with ACM left in place falls under the definition of removal of installed ACM. The removal of installed ACM is either Class I or Class II asbestos work, and all applicable requirements of this standard apply. Whether such demolition is Class I asbestos work or Class II asbestos work is determined by the type of ACM left in place. If any asbestos-containing thermal system insulation or surfacing material is left installed in the building, then the work being performed is Class I asbestos work. If the ACM left installed in the building does not include any thermal system insulation or surfacing material, then the work being performed is Class II asbestos work.

Suspect ACMs encountered during demolition activities that are not identified in this survey should be assumed to contain asbestos or be sampled by an AHERA-certified inspector and analyzed by an accredited laboratory.

6.2 Lead-Based Paint

HUD guidelines state that paint containing a lead concentration greater than or equal to 0.5 % wt by laboratory analysis or 1.0 mg/cm2 of lead by XRF is defined as LBP. Two of the XRF sample results exhibited concentrations of lead equal to or greater than 1.0 mg/cm2. Four paint chip samples were collected from coatings which exhibited a concentration of lead less than 1.0

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 17 mg/cm2 by XRF and submitted for laboratory analysis. Paint chip sample results showed that the four paint chip samples contained lead concentrations less than 0.5 % wt. Based on the XRF and laboratory analytical results, two coatings within the buildings are defined as LBP by HUD definition. The two colors (gray and white) are on the Spillway Hydraulic Room door frame.

The door frame should be removed and disposed or recycled prior to demolition.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 85 XRF sample locations.

Analytical results revealed detectable concentrations of lead below 0.5% wt in three paint chip samples collected. Aerostar recommends the use of Lead-Safe Work Practices and implementation of administrative and engineering controls when conducting activities which disturb paints or coatings with any concentrations of lead to prevent worker exposure or environmental impacts.

Based on OSHA’s Lead in Construction Standard, worker protection controls must be implemented for coatings with any detectable concentrations of lead. HUD’s definition of LBP cannot be used to determine safe working conditions under OSHA. OSHA’s Lead in Construction Standard, 29 CFR 1926.62, was intended to apply to any detectable concentration of lead in paint by laboratory analysis. OSHA’s only accepted methodology for determining an employee’s exposure to airborne lead contaminants is through personal air monitoring. Any paint with detectable concentrations of lead, by XRF or laboratory analysis, that is subjected to cutting, abrading, welding, scraping, and/or sanding, must be handled in accordance with 29 CFR 1926.62, to prevent employee exposure.

6.3 Hazardous Component Inventory

Identified hazardous materials/components or materials requiring special handling included fluorescent lights and light fixtures with several types of PCB and non-PCB ballasts batteries, central and window HVAC systems, and storage of containers or equipment which may contain hazardous materials including, but not limited to various electric motors, electrical equipment, compressed gases, paint, oil, household and industrial cleaning supplies, consumer electronics, and stored batteries.

Ballasts and electrical system components that are identified as containing no PCBs should be handled and disposed of in accordance with 40 CFR 261 or recycled.

According to the manufacturer MSDS, the fluorescent lamps and bulbs, if broken, may result in some exposure to the phosphor powder dust and to a small amount of elemental mercury vapor.

The fluorescent and compact fluorescent lamps should be disposed of in accordance to Standards for Universal Waste Management, 40 CFR Part 273.5 or taken to an appropriate recycling facility that accepts lamps and bulbs.

Mercury containing thermostats requires disposal as hazardous material or can be delivered to a metal recycler who accepts mercury.

HVAC coolants and propane should be reclaimed by licensed contractors familiar with the handling of these materials.

Final ACM Survey, LBP Survey, and Hazardous Components Inventory Aerostar Project Number M3010.0015.0011.07 Page 18

Lubricants should be reclaimed and recycled.

Lead-acid batteries should be taken to a proper disposal facility.

All metals should be taken to a scrap yard for recycling.

Suspect lead-, mercury-, and PCB-containing components encountered during renovation/demolition activities that are not identified in this survey should be assumed to contain hazardous material and disposed of in accordance to federal, state, and local regulations.

Multiple containers of commercial products were observed at the site. Products include household cleaners, various pesticides, automotive products, petroleum based lubricants and cleaners, fuel containers, and water softener pellets. Products should be disposed of in accordance with manufacturer’s recommendations.

TABLES

TABLE 1

Summary of Asbestos Survey

Lock S65C Property Okeechobee County, Florida

Homogeneous Sample ID

Material Description Location Approximate Amount Number of

Samples Collected

Asbestos Type %

NESHAP

Category

Condition

S65C-T-HA-1-1,

S65C-T-HA-1-2,

S65C-T-HA-1-3

Asphalt Shingles Throughout Roof on the Tender House 2,100 SF 3 ND - Good

S65C-T-HA-1-2A

Mastic Associated with

Asphalt Shingles Throughout Roof on the Tender House 2,100 SF 1 5% Chrysotile NF Cat. I Good

S65C-T-HA-1-2B Asphalt Shingles - Gray Throughout Roof on the Tender House 2,100 SF 1 ND - Good

S65C-T-HA-2-1,

S65C-T-HA-2-2,

S65C-T-HA-2-3

Flashing Roof Penetrations on the Tender House 2 SF 3 5% Chrysotile NF Cat. I Good

S65C-T-HA-3-1,

S65C-T-HA-3-2,

S65C-T-HA-3-3,

S65C-T-HA-3-4,

S65C-T-HA-3-5

Drywall Throughout Interior

Walls and Ceilings of the Tender House

4,050 SF 5 ND - Good

S65C-T-HA-4-1,

S65C-T-HA-4-2,

S65C-T-HA-4-3

Joint Compound Throughout Interior

Walls and Ceilings of the Tender House

405 SF 3

2% Chrysotile by

PLM, 0.50% -

1.00% Chrysotile by Point Count

- Good

S65C-T-HA-4-1A,

S65C-T-HA-4-2A

Tape Throughout Interior

Walls and Ceilings of the Tender House

405 SF 2 ND - Good

S65C-T-HA-5-1,

S65C-T-HA-5-2,

S65C-T-HA-5-3

Ceiling Texture Throughout Ceilings of the Tender House

960 SF 3

3% Chrysotile by

PLM, 1.25% -

1.75% Chrysotile by Point Count

RACM Good

NF Cat. I - Non-Friable Category I ACM ND - None Detected NF Cat. II - Non-Friable Category II ACM SF - Square Feet RACM - Regulated Asbestos Containing Material LF - Linear Feet Page 1 of 3

Lock S65C Property Okeechobee County, Florida

Homogeneous Sample ID

Material Description Location Approximate Amount Number of

Samples Collected

Asbestos Type %

NESHAP

Category

Condition

S65C-T-HA-6-1,

S65C-T-HA-6-2,

S65C-T-HA-6-3

12" x 12" Vinyl Floor Tile (VFT) - Beige

Thro…