W912HN-23-B-3000 BECC319022_RAFB_Bldg_125_HMA_Report_200715 .pdf

JULY 15, 2020

REPORT OF LIMITED SCOPE

HAZARDOUS MATERIALS

ASSESSMENT FOR

Robins Air Force Base-Building 125 Renovations Building 125-Robins AFB

Warner Robins, Georgia 31098 BBECC Project Number: 319022

PREPARED FOR:

Mason and Hanger

C/O Warren Foy 300 W. Vine Street

Lexington, Kentucky 40507

GEOTECHNICAL, MATERIALS, AND ENVIRONMENTAL ENGINEERS

360 Industrial Lane, Birmingham, AL 35211 - (205) 941-1119 - www.beccinc.com

WWarner Robins AFB-Bldg 125 Renovations Robins AFB-Bldg 125, Warner Robins, GA

BECC Project #319022

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TABLE OF CONTENTS

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Table of Contents

SECTION 1: SUMMARY OF FINDINGS & CONCLUSIONS

SECTION 2: INTRODUCTION

2.1 Project Authorization

2.1.1 User Reliance

2.2 Purpose

2.3 Detailed Scope of Services

SECTION 3: LIMITATIONS, TERMS & CONDITIONS

3.1 Significant Assumptions

3.2 Exceptions & Limitations of Assessment

3.3 Terms & Conditions of Assessment

3.3.1 ACM Assessment Terms & Conditions

3.3.2 LBP Assessment Terms & Conditions

3.3.3 Metallic Analyte Wipe Tests

SECTION 4: PROJECT DESCRIPTION

SECTION 5: METALLIC ANALYTES

5.1 Inspection

5.1.1 Procedure

5.1.2 Laboratory

5.2 Findings & Conclusions

SECTION 6: ASBESTOS CONTAINING MATERIAL

6.1 Definitions

6.2 ACM Classifications

6.3 Notifications

6.4 Inspection

6.4.1 Procedure

6.4.2 Laboratory

6.5 Findings & Conclusions

SECTION 7: LEAD-BASED PAINT (LBP)

7.1 Definitions

7.2 Inspection

7.2.1 Procedure

7.2.2 Laboratory

7.3 Findings & Conclusions

SECTION 8: PROFESSIONAL SIGNATURES

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SECTION 9: HAZARD ASSESSMENT FACTORS

9.1 Metallic Analytes

9.1.1 Exposure Control & Monitoring Plan

9.1.2 Respiratory Protection & Personal Protective Equipment (PPE) Plan

9.1.3 Employee Training & Hygiene Practices

9.1.4 Site Control

9.2 Asbestos-Containing Materials (ACM)

9.3 Lead-Based Paint (LBP)

SECTION 10: CLOSING

List of Appendices

APPENDIX A – Maps

APPENDIX B – Environmental Laboratory Reports

APPENDIX C – Chain of Custody (COC)

APPENDIX D – Industrial Hygienist Report

APPENDIX E – Credentials

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REPORT

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SECTION 1: SUMMARY OF FINDINGS & CONCLUSIONS

The purpose of this assessment was to identify and sample suspect hazardous materials and perform laboratory analysis to confirm or deny the existence of such materials as asbestos fibers in building materials planned for disturbance and elevated lead concentrations on painted surfaces. This assessment also included wipe testing dust on flat surfaces for suspected contaminants including Resource Conservation and Recovery Act (RCRA) heavy metals arsenic, cadmium, chromium, lead, selenium, and silver, as well as other metals beryllium, nickel, and zinc.

Portions of this survey and assessment was performed pursuant of the USEPA 40 CFR Part 61 NESHAP and Part 763 AHERA/ASHARA guidelines.

The areas inspected in Building 125 consist of the second floor conference room and adjacent machine shop.

The work summarized in this report consists of a Limited Scope Hazardous Material Assessment of the interior of the building, analytical testing of suspect Asbestos Containing Materials (ACM), summaries of inspection findings, and recommendations for abatement/cleaning if necessary. The Asbestos Building Inspection was conducted in general conformance with NESHAP but limited to areas planned for disturbance during renovation. Lead-Based Paint and Metallic Analyte assessment was conducted to include renovation areas where applicable.

Suspect ACM materials observed were limited to pipe insulation (TSI) and cementitious board on the machine shop walls. This assessment concluded ACM was encountered (cementitious wall board) in the renovation areas as determined by the procedures and limitations described in the report.

This assessment concluded no paint sample classified as lead-based (Total Lead content greater than 0.5%). Lead was detected in samples as 0.05%. Samples were not tested for leachable properties by TCLP due to low lead content.

This assessment concluded metallic analytes were present in dust samples on the roof truss system, including

Cadmium (Cd), Chromium (Cr), Lead (Pb), Nickel (Ni), Zinc (Zn), and Copper (Cu).

NOTE: This report is limited in scope such that the assessment was restricted to areas planned for disturbance during renovation activities. Therefore, this HMA excludes assessment of building waste streams and material storage and use. The asbestos survey does not satisfy a “thorough” inspection as required by NESHAP and therefore does not fully comply with NESHAP regulations.

If any suspect materials not accessible during the inspection are uncovered during renovation, work should be halted immediately and BECC should be contacted to observe and or test the uncovered material. Work should not resume until the samples have been analyzed and the contractor has been advised on how to proceed.

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SECTION 2: INTRODUCTION

2.1 Project Authorization

BECC performed a limited in scope Hazardous Material Assessment (HMA) on Building 125 located on Robins Air Force Base (AFB) in Warner Robins, Georgia. The assessment included wipe testing of flat surfaces located on roof trusses and beams, an asbestos-containing material (ACM) survey on suspect materials planned for disturbance during renovation pursuant of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) and Asbestos Hazard Emergency Response Act (AHERA)/Asbestos School Hazard Abatement Reauthorization Act (ASHARA), and a lead-based paint (LBP) survey of painted surfaces of the roof structure.

This survey was conducted in accordance with BECC proposal number Q1-19125 dated August 28, 2019.

Sampling for asbestos performed as part of this work was conducted under NESHAP and AHERA/ASHARA guidelines, where feasible, as well applicable state and federal regulatory agencies. The HMA survey may not be exhaustive in scope nor does it guarantee a risk free site. Some limitations may apply depending on conditions of the facilities subject to inspection. Depending on the extent of sampling possible, additional testing may be required.

2.1.1 User Reliance

The resulting report is provided for the sole use of Mason and Hanger, Their Affiliates and Subsidiaries, Their Successors, Assigns and Grantees. Use of this report is subject to the Terms and Conditions including the Limitation of Liability as stated in BECC proposal number Q1-19125 dated August 28, 2019. Use by any third parties will be at such party’s sole risk except when granted under written permission by BECC. Any such authorized use or reliance by third parties will be subject to the same Agreement, under which the work was conducted for Mason and Hanger.

2.2 Purpose

An HMA was requested for renovation areas of Building 125 of Robins AFB located in Warner Robins, Georgia.

The areas to be renovated and were inspected include the existing machine shop and 2nd level conference room.

Laboratory samples were collected according to each predetermined zone as designated on the maps in AAppendix A – Maps. Wipe tests were performed to collect dust samples along the roof beams and trusses for evaluation of hazardous metal generated during operations performed within the building. Paint scrapings were also collected where possible from the roof decking or the truss system to evaluate a possible impact to the waste stream from removing the existing paint. The ACM inspection was performed for the purpose of compliance with State and Federal EPA regulations involving renovation of commercial properties as directed under the National Emission Standards for Hazardous Air Pollutants (NESHAP).

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2.3 Detailed Scope of Services

The scope of services provided by BECC consisted of 5 major elements:

Walk Through Inspection - BECC conducted a thorough walk-through of the facility(ies) to identify suspect materials that may require testing and defined by operations in each zone and homogeneous materials.

Categorize each suspect material and associate with each zone or space and homogeneous material, including material condition.

Collect Samples - BECC collected samples from each zone or space of suspect material.

Photographs - BECC obtained photographs of sample locations, where possible, depicting conditions and identifying characteristics of the samples taken.

Evaluation and Report – Deliver samples to a NIST registered laboratory to perform analysis of metallic analytes by SW846 6010B, Toxicity Characteristic Leaching Procedure (TCLP) by SW846 1311/6010B, bulk sample of building materials using Polarized Light Microscopy (PLM), pursuant to EPA 600/M4-82-020 to determine the presence of asbestos fibers, and Total Lead analysis via Inductive Coupled Plasma (ICP) Atomic Emission Spectrophotometry with Ultrasonic Nebulizer using EPA Method 6010. This report was generated to discuss the impact, if any, of these materials under state or federal regulations, including NESHAP and AHERA/ASHARA guidelines related to the proposed work at the facility.

SECTION 3: LIMITATIONS, TERMS & CONDITIONS

3.1 Significant Assumptions

Parts of the conclusions reached in this assessment may be based on the presumption materials encountered were ACM. OSHA allows for the use of Presumed Asbestos Containing Materials (PACM) for certain materials in buildings constructed no later than 1980 in lieu of testing where sampling may be difficult or undesirable (i.e.

non-destructive sampling only). This practice may be used where the guidelines of NESHAP cannot be fully satisfied. For projects that must strictly follow NESHAP guidelines, further testing may be necessary and may be conducted at the time of renovation under the strict supervision of a certified trained asbestos inspector or industrial hygienist.

Wipe and LBP samples were taken in a distributed random method and results are interpolated based on the pre-determined zones noted on the maps in AAppendix A – Maps.

3.2 Exceptions & Limitations of Assessment

Areas of the building assessed for suspect contaminants/materials, and sampled in this assessment, are limited to areas impacted by the planned renovations with exception of LBP and metallic analyte wipe tests. The renovation areas inspected in Building 125 consist of existing machine shop and 2nd level conference room. LBP and metallic analyte wipe tests are representative of the whole interior high surfaces of the machine shop.

Future conditions of materials could change subject to unforeseeable site activity or facility use. This assessment may not be exhaustive in scope nor does it guarantee a risk free site. This assessment represents the professional judgment and conclusions of the certified and trained asbestos inspector performing the assessment. No conclusions are intended nor implied beyond those stated.

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This survey and evaluation was performed for the exclusive use of MMason and Hanger, for the specific application to the subject project. BECC notes that this assessment was limited to the collection of suspect materials from readily accessible locations of the facility within the defined workspaces for renovation.

Laboratory analysis for ACM samples utilized PLM for asbestos samples. Point Counting was not utilized for this project.

This HMA is limited in scope due to the assessment restricted to areas on renovation or planned areas of disturbance. Hazardous material use and storage as well as waste streams were not considered in this assessment. The ACM assessment was limited to planned areas of disturbance as previously defined and does not fully comply with NESHAP regulations.

3.3 Terms & Conditions of Assessment

The results, findings, observations and recommendations expressed in this report are based only on conditions that were observed during BECC's inspection of the site on March 16-18, 2020. Although care has been taken by BECC in compiling and checking the information contained in this report to verify that it is current and accurate, BECC disclaims any and all liability for any errors, omissions or inaccuracies in such information and data and for any consequences arising from such omissions or inaccuracies. The recommendations provided in this report do not constitute legal and/or medical advice. It is further understood that BECC makes no representations or warranties of any kind, including but not limited to, the warranties of fitness for a particular purpose of merchantability nor are such representations or warranties to be implied with respect to the data furnished, and BECC assumes no responsibility with respect to customers, its employees, client's or customers' use thereof.

BECC, their representative and this report make no representation and/or assumptions as to past conditions or future occurrences at this site. The information provided herein applies only to the subject property as it existed during BECC's site visit. Should this site's use and/or conditions change, information, observations and recommendations found herein would no longer apply. This report is intended to be used in its entirety. No excerpts may be taken to be representative of the findings of this assessment. BECC shall not be liable for any special, consequential and/or exemplary damages resulting, in whole or in part, from the customer's use of the data provided.

3.3.1 ACM Assessment Terms & Conditions

It should be noted that this assessment is only intended for the purpose of identifying suspect building materials that may contain asbestos fibers using a limited sampling program. This assessment, due to its scope and nature is typically not sufficient to estimate costs of abatement or to obtain construction permits for inaccessible structures or spaces not included within the scope of work. This is because not all areas are generally accessible and areas that are hidden, inaccessible or covered by other construction may not be exposed until the work begins. Further, the assessment includes sampling of homogeneous areas and not specific sampling at each individual location that there may be interest in due to renovation/demolition activities.

3.3.2 LBP Assessment Terms & Conditions

It should be noted that this assessment is only intended for the purpose of identifying suspect painted surfaces that may contain elevated lead concentrations using a limited sampling program. This assessment, due to its scope and nature is typically not sufficient to estimate costs of abatement or to obtain construction permits for inaccessible structures or spaces not included within the scope of work.

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3.3.3 Metallic Analyte Wipe Tests

While wipe samples present data regarding the presence or absence of each contaminant in a 100 square centimeter area, this data cannot be directly compared to an “Occupational Exposure Limit, such as the OSHA Permissible Exposure Limit (PEL), ACGIH Threshold Limit Value (TLV), or NIOSH Recommended Exposure Limit

(REL).

SECTION 4: PROJECT DESCRIPTION

On March 17, 2020, Mr. Jeremy Mitchell, a certified Asbestos Inspector, Mr. Jeffery Dennis, a certified Industrial Hygienist, and Mr. Trey Robinson conducted a visual assessment and sampling of suspect materials in the subject building and spaces. The spaces assessed included the 2nd floor conference room and machine shop area, as well as the renovation area as described in Section 2.2. These spaces are anticipated to be disturbed during planned renovation activities. It should be expected that some suspect materials may be encountered during renovation that were not sampled during this assessment, such as in limited access spaces. All work should cease, and the material must be evaluated by certified personnel before work shall proceed.

The project also included geotechnical and environmental subsurface exploration of subsurface soils. This exploration involved coring the existing slab in 2 locations and sampling soils for strength, consistency, environmental impacts, and classification.

SECTION 5: METALLIC ANALYTES

Jeffery Dennis (certified hygienist) of DENNSCO performed wipe sampling to determine the presence/absence of the following heavy metals in the dust on roof truss systems and a Hazard Assessment, including the following:

Total Arsenic (As) Total Beryllium (Be) Total Cadmium (Cd) Total Chromium (Cr) Total Copper (Cu) Total Lead (Pb) Total Nickel (Ni) Total Selenium (Se) Total Silver (Ag) Total Zinc (Zn)

5.1 Inspection

5.1.1 Procedure

Wipe sampling was performed using a 100-centimeter template and single use wipes. Each sample was documented, and a sample designation was assigned. Each sample was submitted to an accredited analytical laboratory for analysis.

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5.1.2 Laboratory

The Wipe Samples were analyzed for heavy metals content by SW846 EPA Method 6010B. The results are presented on the laboratory reports as μg/cm2.

The analytical laboratory used, Sutherland Environmental, Inc., is accredited by the National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program. The laboratory analytical reports can be found in AAppendix B – Environmental Laboratory Reports and the inspection chain of custody forms can be found in AAppendix C – Chain of Custody (COC).

5.2 Findings & Conclusions

This assessment data has confirmed the presence of the following heavy metal contaminants on high surfaces inside Building #125 machine shop:

Table 5.2 Building 125 – Total Metals

SAMPLE # MATERIAL & LOCATION ANALYTES DETECTED

B125-W1-Duct Dust Cd, Cr, Pb, Ni, Zn, & Cu

B125-W2-LF Dust Cd, Cr, Pb, Ni, Zn, & Cu

B125-W3-CR1 Dust Cd, Cr, Pb, Ni, Zn, & Cu

B125-W4-PI1 Dust Cd, Cr, Pb, Ni, Zn, & Cu

B125-W5-CR2 Dust Cd, Cr, Pb, Ni, Zn, & Cu

The Industrial Hygienist report can be found in AAppendix D – Industrial Hygienist Report.

SECTION 6: ASBESTOS CONTAINING MATERIAL

6.1 Definitions

Demolition is defined as the removal of any structural member of a building. Renovations are limited to the removal and addition of non-structural members or materials.

ACM is defined as any material which contains more than one percent (1%) asbestos by area, as determined by the method specified in Appendix A of Subpart F, 40 CFR Part 763. ACM is generally found in some common building materials such as: drop-in ceiling tile, hard plaster, floor tile, sheet vinyl flooring, joint compound, insulation, heating system insulation, window and door caulking, window glazing, hardboard siding, and a variety of roofing materials.

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In order to be considered a Regulated Asbestos Containing Material (RACM), the material shall be either friable (any material which, when dry, can be crumbled, pulverized, or reduced to powder by either hand pressure or mechanical forces reasonably expected to act on the material) or have a reasonable probability of becoming friable in the course of ordinary or anticipated use of the building containing the material or during the course of demolition or renovation operations. RACM can also be non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading. Activities which involve friable asbestos, such as demolition or renovation, are regulated by the US EPA, the Georgia Environmental Protection Department (GEPD) and the US Occupational Safety and Health Administration (OSHA).

Non-friable ACM may not be regulated because it does not pose a potential respiratory hazard. Non-friable ACM which will become friable during a renovation or a demolition is regulated.

6.2 ACM Classifications

RACM - Regulated ACM means (a) Friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable 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 regulated by 40 CFR Part 61, Subpart M. Plaster, joint compound, and Transite are examples of Category II friable ACM. RACM totaling over 3 square feet, 3 linear feet, or a total of more than 0.75 cubic feet must be removed by a certified contractor prior to renovation or demolition.

Category I - Category I ACM includes non-friable materials that can be maintained in non-friable condition during the renovation or demolition by not performing certain activities. Roofing, for example, can become friable by being subjected to such activities as cutting, grinding, and abrading; and resilient floor covering can become friable by being subjected to sanding, beadblasting, or pulverization into small pieces and/or powder. Unless these materials are acted upon by one of these methods, it is considered non-friable and is not subject to the NESHAP regulation. Category I ACM need not be removed prior to demolition unless it is in very poor condition.

Category II - Category II ACM includes all other non-friable material not included in Category I that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

6.3 Notifications

Notification of demolition or renovation of a facility must be sent to GEPD ten (10) working days prior to the activity. With demolition or renovation projects involving the removal of greater than or equal to 10 linear feet, 10 square feet, or a total of 10 cubic feet of ACM, GEPD must be notified ten (10) working days prior to the activity.

Demolition of a facility with less than 10 linear feet, 10 square feet, or a total of 10 cubic feet of ACM (including facilities with no asbestos) must notify GEPD ten (10) working days prior to demolition.

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6.4 Inspection

6.4.1 Procedure

Suspect ACM was placed in homogeneous sampling areas. A homogeneous area contains material that is uniform in texture, appearance, installed at the same time, and is unlikely to contain more than one type or formulation of material. A total of three samples were collected that were suspect ACM to determine the actual composition of the material by laboratory analysis. These samples were collected from Thermal System Insulation (TSI) suspended from the roof deck of the building.

Walls, ceilings, and floors were inspected to assess the presence of “hidden” areas and materials that could have been concealed by past renovations. Heating systems and water heating systems were inspected for suspect ACM.

All bulk samples were recorded on a chain of custody and a diagram. Photographs were taken by Mr. Jeffery Dennis where possible. Photographs were generally restricted during the inspection so not all suspect materials may have been documented in the photographs.

6.4.2 Laboratory

The Bulk Samples were analyzed for asbestos content by Polarized Light Microscopy (PLM). The results are given in percent (%) asbestos. If the results are between 1 and 10%, then the inspector can order that a more exacting quantitative method be completed for that sample. This method is called a Point-Count analysis.

The Point-Count analysis is ordered particularly when the asbestos percentage is low, and it involves a Category II substance. The difference between no abatement action required (less than 1%) and costly abatement usually hinges on the Point-Count results.

The analytical laboratory used, EMC Labs, Inc., is accredited by the National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program. The laboratory analytical reports can be found in AAppendix B – Environmental Laboratory Reports and the inspection chain of custody forms can be found in AAppendix C – Chain of Custody (COC).

6.5 Findings & Conclusions

Based on materials assessed in the planned renovation disturbance areas, only TSI on suspended pipes and the cementitious board along the partition wall between the machine shop and hanger was regarded as suspect ACM.

The following table represents the laboratory results of the bulk samples obtained under the scope of this assessment.

Table 6.5 Building 125

SAMPLE # MATERIAL SAMPLED LOCATION FRIABLE % ASBESTOS

B125-TSI-1 Thermal Insulation Hanging pipes N/A ND

B125-TSI-2 Cementitious Wall Board Partition wall between hanger and machine shop Yes 12

ND – Non Detect There is RACM cementitious board on the machine shop walls. No Category I or Category II ACM was present in sampled material from Building 125.

Other samples observed and assesses were not found to be suspect ACM.

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SECTION 7: LEAD-BASED PAINT (LBP)

7.1 Definitions

Demolition is defined as the removal of any structural member of a building. Renovations are limited to the removal and addition of non-structural members or materials.

Two different factors were used to evaluate for lead based paint: OSHA and the EPA. OSHA and the EPA do not have quantitative definitions for lead based paint. As an alternative, the US Department of Housing and Urban Development (HUD) was considered. The HUD threshold stipulates that lead based paint is defined as surface coatings with lead equal to or greater than 1.0 mg/cm2 or 0.5 percent by weight. The Georgia Environmental Protection Department (GEPD) has established as 5 parts per million (ppm) threshold (based on TCLP) to determine if paint containing lead should be classified as hazardous waste.

7.2 Inspection

7.2.1 Procedure

A visual inspection was performed of painted surfaces included in the planned disturbance areas of the renovation and the interior roof deck and truss system of the building. Before collecting samples, distinct testing combinations were identified. A testing combination is made up of a room equivalent, a building component, and a substrate. Paint color is not included as part of a testing combination. Samples were collected of each testing combination identified.

BECC’s visual inspection of identified at 1 homogeneously painted surface as the interior roof deck and truss system. Most walls were painted with a similar paint with some variations; however, the adhesion property of the paint limited sampling to detached areas of the roof deck. A total of seven samples were collected from the roof deck: 2 TCLP and 5 Total Lead samples.

7.2.2 Laboratory

Paint chip samples were collected into individual containers and transported to the laboratory for analysis.

All samples can be individually identified with a sample number that directly corresponds to sample numbers listed on the Sample Logs and Chain of Custody in Appendix C of this report. Samples were analyzed for Total Lead content by Inductive Coupled Plasma (ICP) Atomic Emission Spectrophotometry with Ultrasonic Nebulizer using EPA Method 6010 and Toxicity Characteristic Leaching Procedure (TCLP) by SW846 1311/6010B. Samples were digested according to EPA method 3050 (modified). The laboratory analytical reports can be found in AAppendix B – Environmental Laboratory Reports and the inspection chain of custody forms can be found in AAppendix C – Chain of Custody (COC).

7.3 Findings & Conclusions

A summary of paint chip analysis is listed in the following tables. No paint sampled qualified as a lead-containing material (based on 0.5% by weight). Based on lead content of the paint sampled, the lead content based TCLP will not exceeded the GEPD TCLP definition of hazardous lead waste of 5 ppm. A detailed log of samples is available in Appendix B.

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Table 7.3

Building 125 – Total Lead

SAMPLE # MATERIAL SAMPLED LOCATION PPM

(mg/Kg) % Pb by Weight

B125-P1 Paint Machine Shop 525 0.0525

SECTION 8: PROFESSIONAL SIGNATURES

CERTIFICATION: The Environmental Professional certifies and agrees that:

1. The Environmental Professional has no present or contemplated future interest in the property being inspected;

and neither the employment to make the inspection, nor the compensation for it, is contingent upon the outcome of the inspection.

2. The Environmental Professional has no personal interest in or bias with respect to the subject matter of the inspection or the participants in connection with it. The findings of the Report are not based in whole or in part upon the race, color, or national origin of the past, current or prospective owners or occupants of the property inspected, or upon the race, color or national origin of the past, current and/or future owners or occupants of the properties in the vicinity of the property inspected.

3. The Environmental Professional has personally inspected the property. To the best of the Inspector’s knowledge and belief, all statements and information in this report are true and correct, and the Environmental Professional has not knowingly withheld any significant information.

4. All contingent and limiting conditions are contained herein (imposed by the terms of the assignment or by the undersigned affecting the analyses, opinions, and conclusions contained in the report).

5. This report has been made in general conformity with United States Environmental Protection Agency’s (EPA) National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations, and the Indiana Department of Environmental Management’s (IDEM) regulations.

6. All conclusions and opinions concerning the property being assessed that are set forth in the Inspection Report were prepared by the Environmental Professional whose signature appears on the report. No change of any item in the Inspection Report shall be made by anyone other than the Environmental Professional, and the Environmental Professional shall have no responsibility for any unauthorized change.

The Asbestos Building Inspection and Lead-Based Paint Assessment described herein was conducted by Mr.

Jeremy Mitchell, certified Asbestos Inspector (The Environmental Institute Certification #17862) of BECC. BECC's work consisted solely of the activities described in the original report and is subject to the Limitations, Terms & Conditions constraints provided therein.

Jeremy Mitchell Asbestos Inspector TEI Cert #17862 Expiration Date 3/9/2021

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The Hazard Assessment Factors for metallic analytes (including LBP) described herein was conducted with by Mr.

Jeffery Dennis, certified Industrial Hygienist, of Dennsco. Dennsco's work consisted solely of the activities described in the original report and is subject to the Limitations, Terms & Conditions constraints provided therein.

SECTION 9: HAZARD ASSESSMENT FACTORS

9.1 Metallic Analytes

During the “Cleaning/Paint Removal Stage” of this renovation project the workers removing the current paint and the heavy metal contaminants present on the surfaces shall be protected from exposure. Occupational Exposure Limits are based upon 8-hour Time Weighted Averages for personnel air monitoring samples and are expressed as such, i.e., the Lead (Pb) OSHA PEL is currently 50 ug/cubic meter of air over an 8-Hour TWA.

The wipe data serves as a portion of the “Initial Determination” of the presence of the heavy metal contaminants discussed in Section 5 of this report. During the cleaning/removal phase of this renovation project, the following recommendations are provided to protect workers from exposure and to comply with all applicable OSHA Regulations regarding heavy metal exposure. These recommendations should be included in all correspondence with potential contractors and should be accounted for in each bid package and operational plan.

9.1.1 Exposure Control & Monitoring Plan

A Heavy Metals Exposure Control Plan will be required to be developed and implemented throughout the cleaning/removal process. Industrial Hygiene Exposure Monitoring should be performed during the initial cleaning/ removal work. Personnel air monitoring samples should be collected and analyzed in accordance with OSHA Regulations and NIOSH Analytical Methods. Results of the initial air monitoring should be compared to the applicable OSHA PELs. Additional monitoring and frequency of additional monitoring will be dependent upon the results of the initial personnel air monitoring. Workers shall be protected from heavy metal exposure by means of Personal protective Equipment (PPE), Respiratory Protective Equipment, Skin Protective Equipment, and Eye Protective Equipment until the results of the initial air monitoring event are known. Upon receipt of the initial air monitoring results protective measures may then be modified to meet the requirements based upon actual exposure levels.

9.1.2 Respiratory Protection & Personal Protective Equipment (PPE) Plan A detailed Respiratory Protection Plan will be required to be developed and implemented throughout the cleaning/removal process. A detailed PPE Plan will be required to be developed and implemented throughout the cleaning/removal process.

9.1.3 Employee Training & Hygiene Practices

Employee Training in the hazards of the heavy metals present, protective methods, work practices, and PPE will be required to be developed, performed, and documented prior to the start of work. Protocols for hygiene related issues scubas personnel change areas, hand-washing facilities, shower facilities, work practices, eating and drinking prohibitions, and PPE will be required to be developed and implemented throughout the cleaning/removal process. A medical surveillance program will be required to be developed and implemented throughout the cleaning/removal process.

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9.1.4 Site Control

Appropriate signage in and around all work areas will be required to be developed and implemented throughout the cleaning/removal process. Appropriate ventilation will be required to be developed and implemented to reduce employee and environmental exposure and cross contamination of adjacent work areas during all phases of this process.

A Waste Control Plan to include work practices with regards to the collection, documentation, transportation, and disposal of all heavy metal contaminated waste products will be required to be developed and implemented throughout the cleaning/removal process. The waste control program shall meet all Environmental Protection Agency (EPA) Federal and State regulations and Resource Conservation and Recovery Act (RCRA) regulations.

9.2 Asbestos-Containing Materials (ACM)

Friability is a hazard assessment classification used each time suspect ACM was sampled. The term friable means that the material can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Materials classified as non-friable may be reclassified as friable if the material is damaged. Friable ACM has been determined by the EPA and OSHA (termed intact and non-intact) to be more "Hazardous" than non-friable ACM, because friable ACM can be made airborne more readily than non-friable ACM. In assessing the fiber release potential, only current conditions of all ACM identified were noted.

Only materials made accessible within each building or structure was evaluated. Materials that were hidden and/or not accessible were not evaluated as part of this survey. If materials suspected of containing asbestos are found that were not accessible during this survey, they should be analyzed for asbestos content. Materials visibly identified as non-asbestos (fiberglass, foam rubber, wood, etc.) were not sampled.

9.3 Lead-Based Paint (LBP)

Two different factors were used to evaluate for lead based paint: OSHA and the EPA. OSHA and the EPA do not have quantitative definitions for lead based paint. As an alternative, the US Department of Housing and Urban Development (HUD) was considered. The HUD threshold stipulates that lead based paint is defined as surface coatings with lead equal to or greater than 1.0 mg/cm2 or 0.5 percent by weight. HUD also publishes a document about lead evaluation and control, titled “Guidelines for the Evaluation and Control of lead-Based Paint Hazards in Housing” found at https://www.hud.gov/program_offices/healthy_homes/lbp/hudguidelines. Chapter 13 of this documents describes proper encapsulation methods for abatement by encapsulation.

Should lead-containing materials be identified, the Environmental Protection Agency (EPA) rules require that lead-based paint material be classified as hazardous if the Toxicity Characteristic Leaching Procedure (TCLP) reads more than 5 parts per million in lead. Building material debris generally passes the TCLP and therefore is usually not considered hazardous.

Report for Limited Scope Hazardous Material Assessment July 15, 2020 Page 18 of 18

The OSHA Lead in Construction Standard (OSHA - 1926.62) stipulates that a lead-based paint assessment be performed on any suspect materials prior to renovation/demolition. All of OSHA rules pertaining to lead-based paint deal with worker exposure levels or the concentration of lead in the air. An Action Level of 30 g/m3 (micrograms of airborne lead dust per cubic meter of air in an 8 hour period) will trigger periodic exposure monitoring, biological monitoring and training during the course of the renovation/demolition work. If an Exposure Limit of 50 g/m3 is reached then work practice controls, respiratory protection, protective clothing, hygiene facilities and signs may be required.

SECTION 10: CLOSING

We appreciate the opportunity to work with you on this project. If you have any questions or we may be of further services to you, please call us.

Jeremy Mitchell, P.E. Martin T. Burford, P.E.

Technical Service Division Manager President

APPENDIX A

Robins AFB Building 125 Renova on Environmental Sample Loca on Map

LOCATION: Robins Air Force Base, Building 125, Warner Robins, GA BECC Project No.: 319022

MAP SCALE:

N/A

Building #7

Bu ild in g

#2

Bu ild in g

#5

B125-P1

B125-TSI-2

B125-TSI-1

P O

V

MED

ACC

MED

ACC

MED

ACC

MED

ACC

DP

HAND

SINK

SALAD

BARDELI

SERVICE

STAND-UP

COOLER

W/C

SERVICE

W/C

SERVICE

W/C

SERVICE

ICE

CREAM

C O

O

LE

R C

O O

LE

R

C O

O

LE

R

P D

TO

BA

C C

O

C H

EC

K

O U

T

R E

G

ISTER

FO

U

N

TA

IN

N

A C

H O

H O

T D

O G

CHIPS/SNACKS

C O

FF

EE

T

EA

THIS AREA WILL

INCLUDE THE

FOLLOWING:

DRY STORAGE, WALK

IN COOLER,

PREP, WASH,

ELECTRICAL, COMM

AND JANITOR ROOMS.

C.F.

15X22

OFFICE

15X15

OFFICE

15X15 C.F.

15X22

OFFICE

15X15

OFFICE

15X15C.F.

15X24

MEC. ROOM

17X19

COMM.

ROOM

8X19

NEW OFFICE SPACE & RESTROOMS FOR 124 EMPLOYEES

ABOVE B125 PROPOSED BREAK AREA 14,900 SF.

APPENDIX B

EMC LABS, INC.

EMC LABS, INC.

APPENDIX C

APPENDIX D

www.dennsco.com Phone: 205.960.0679 Phone: 205.940.3224

Fax: 205.225.6122

June 5, 2020

Mr. Jeremy Mitchell, PE Registered Professional Engineer Technical Services Division Manager

BECC

360 Industrial Lane Birmingham, AL 35211

Subject: Robbins Air Force Base Project Building #125 Industrial Hygiene Report

Mr. Mitchell:

Thank you for the opportunity to be of service to BECC in support of the current Robbins Air Force Base Project. This report outlines the industrial hygiene monitoring activities performed March 17, 2020.

Method

DENNSCO was asked to perform wipe sampling to determine the presence/absence of the following heavy metals:

• Total Arsenic (As)

• Total Beryllium (Be)

• Total Cadmium (Cd)

• Total Chromium (Cr)

• Total Copper (Cu)

• Total Lead (Pb)

• Total Nickel (Ni)

• Total Selenium (Se)

• Total Silver (Ag)

• Total Zinc (Zn)

Wipe sampling was performed using a 100 centimeter template and single use wipes. Each sample was documented and a sample designation was assigned. Each sample was submitted to an accredited analytical laboratory for analysis.

Results

The following sample documentation is provided in this report:

• Sampling Map - Building #125

• Analytical Chain of Custody Documentation

• Analytical Report

Discussion of Analytical Results

The following Wipe Sample Analytical Results determine the presence/absence of each parameter tested. All results are presented in micrograms/100 cm2 (ug/100 cm2).

BDL = Below Detection Limit. Detection Limit, as reported by the analytical laboratory is equal to below 0.0050 ug/ cm2.

Hazard Assessment

During the “Cleaning/Paint Removal Stage” of this renovation project the workers removing the current paint and the heavy metal contaminants present on the painted surfaces shall be protected from exposure. While this monitoring of paint wipe samples presents data regarding the presence or absence of each contaminant in a 100 square centimeter area, this data can not be directly compared to an “Occupational Exposure Limit, such as the OSHA Permissible Exposure Limit (PEL), ACGIH Threshold Limit Value (TLV), or NIOSH Recommended Exposure Limit (REL).

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Phone: 205.940.3224

Fax: 205.225.6122

Occupational Exposure Limits are based upon 8-hour Time Weighted Averages for personnel air monitoring samples and are expressed as such, i.s., the Lead (Pb) OSHA PEL is currently 50 ug/cubic meter of air over an 8-Hour TWA.

However, this monitoring data has confirmed the presence of the following heavy metal contaminants on the painted surfaces inside Building #125:

• Total Cadmium (Cd) - Range - 0.022 - 1.5 ug/100 cm2

• Total Chromium (Cr) - Range - 0.070 - 9.1 ug/100 cm2

• Toal Lead (Pb) - Range - 0.26 - 7.3 ug/100 cm2

• Total Nickel (Ni) - Range - 0.055 - 1.1 ug/100 cm2

• Total Zinc (zn) - Range - 2.1 - 23 ug/100 cm2

• Total Copper (Cu) - Range - 0.43 - 5.2 ug/100 cm2

This data serves as a portion of the “Initial Determination” of the presence of these heavy metal contaminants.

During the cleaning/removal phase of this renovation project, the following recommendations are provided to protect workers from exposure and to comply with all applicable OSHA Regulations regarding heavy metal exposure. These recommendations should be included in all correspondence with potential contractors and should be accounted for in each bid package and operational plan.

Exposure Control Plan - A Heavy Metals Exposure Control Plan will be required to be developed and implemented throughout the cleaning/removal process.

Exposure Monitoring - Industrial Hygiene Exposure Monitoring should be performed during the initial cleaning/ removal work. Personnel air monitoring samples should be collected and analyzed in accordance with OSHA Regulations and NIOSH Analytical Methods. Results of the initial air monitoring should be compared to the applicable OSHA PELs. Additional monitoring and frequency of additional monitoring will be dependent upon the results of the initial personnel air monitoring. Workers shall be protected from heavy metal exposure by means of Personal protective Equipment (PPE), Respiratory Protective Equipment, Skin Protective Equipment, and Eye Protective Equipment until the results of the initial air monitoring event are known. Upon receipt of the initial air monitoring results protective measures may then be modified to meet the requirements based upon actual exposure levels.

Respiratory Protection - A detailed Respiratory Protection Plan will be required to be developed and implemented throughout the cleaning/removal process.

Personal Protective Equipment (PPE) Plan - A detailed PPE Plan will be required to be developed and implemented throughout the cleaning/removal process.

Employee Training - Employee Training in the hazards of the heavy metals present, protective methods, work practices, and and PPE will be required to be developed, performed, and documented prior to the start of work.

Hygiene Areas and Practices - Protocols for hygiene related issues scubas personnel change areas, hand-washing facilities, shower facilities, work practices, eating and drinking prohibitions, and PPE will be required to be developed and implemented throughout the cleaning/removal process.

Medical Surveillance Program - A medical surveillance program will be required to be developed and implemented throughout the cleaning/removal process.

Signage - Appropriate signage in and around all work ares will be required to be developed and implemented throughout the cleaning/removal process.

Ventilation - Appropriate ventilation will be required to be developed and implemented to reduce employee and environmental exposure and cross contamination of adjacent work ares during all phases of this process.

Waste Control - A Waste Control Plan to include work practices with regard to the collection, documentation, transportation, and disposal of all heavy metal contaminated waste products will be required to be developed and implemented throughout the cleaning/removal process. The waste control program shall meet all Environmental Protection Agency (EPA) Federal and State regulations and Resource Conservation and Recovery Act (RCRA) regulations.

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Phone: 205.940.3224

Fax: 205.225.6122

Attachments

The following Project Documentation is attached for reference:

• Building #140 Sample Map

• Analytical Chain of Custody Documentation

• Analytical Reports

Parameter/ Sample ID

B125-W1- Duct B125-W2-LF B125-W3-

CR1 B125-W4-PI1 B125-W5-

CR2

Total Aresenic BDL BDL BDL BDL BDL

Total Barium BDL BDL BDL BDL BDL

Total Cadmium 0.022 1.5 0.075 0.033 0.050

Total Chromium 0.070 9.1 0.38 0.24 0.27

Total Lead 0.26 7.3 0.53 0.55 0.53

Total Mercury BDL BDL BDL BDL BDL

Total Selenium BDL BDL BDL BDL BDL

Total Silver BDL BDL BDL BDL BDL

Total Nickel 0.055 1.1 0.12 0.060 0.15

Total Zinc 10 23 2.1 4.5 2.4

Total Copper 0.54 5.2 0.43 0.78 0.55

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Phone: 205.940.3224

Fax: 205.225.6122

Conclusion

Thank you once again for this opportunity to be of service. please do not hesitate to contact DENNSCO should questions arise or should additional information be required.

Respectfully Submitted, Jeffery K. Dennis, MS, CSP, ASP, CIT, CHMM, CSSM, WSO-CSE President Cheif Operating Officer Managing Partner

DENNSCO

C - 205-960-9679 E - jdennis@dennsco.com W - www.dennsco.com

Attachments: As Outlined Above

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