Draft_Hazmat_Studies_Fort_Jackson.pdf

DRAFT HAZMAT STUDIES FORT JACKSON

ASBESTOS AND LEAD-BASED PAINT ASSESSMENT

BUILDINGS 1877, 2100, 2270, 2280, 4350, & 5385, FORT JACKSON

COLUMBIA, RICHLAND COUNTY, SOUTH CAROLINA

CONTRACT NUMBER: W912HN-14-D-0003-DW01

TASK ORDER: DW01

Prepared For:

Dawson Technical, LLC

1 Meadowlands Plaza, Suite 200 East Rutherford, New Jersey 07073

And

United States Army Corps of Engineers Charleston District

69A Hagood Avenue Charleston, South Carolina 29403

Prepared By:

Aerostar SES LLC 11181 St. Johns Industrial Parkway North

Jacksonville, Florida 32246

(904) 565-2820

August 24, 2015

DRAFT

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

This is to certify that the Draft Report for the HazMat Study Fort Jackson, Asbestos and Lead- Based Paint Assessments of Six Buildings, located at Fort Jackson, Columbia, Richland County, South Carolina, has been examined by the undersigned.

DATE August 24, 2015 SIGNATURE:

Mark Hamblin Aerostar SES LLC Project Scientist Asbestos Building Inspector Certification No. BI-01362 Lead-Based Paint Risk Assessor Certification No. SC-I-I146815-1

John H. Hubbard Aerostar SES LLC Senior Project Manager

Paul M. Fitch Aerostar SES LLC Project Engineer South Carolina Registered Engineer Certification No. 26699

Michelle Caruso Dawson Technical, LLC Program Manager

Lemuel Campbell Dawson Technical, LLC Project Manager

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page i

TABLE OF CONTENTS

SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

1.0 EXECUTIVE SUMMARY .............................................................................................. 1-1

1.1 Site Name ................................................................................................................. 1-1

1.2 Name and Certificate of Inspector(s) ....................................................................... 1-1

1.3 Site Description and Activities ................................................................................. 1-1

1.4 Findings and Results ................................................................................................ 1-1

1.4.1 Asbestos Survey .......................................................................................... 1-2

1.4.2 Lead-Based Paint Survey ............................................................................ 1-3

2.0 INTRODUCTION............................................................................................................. 2-1

3.0 REGULATORY SUMMARY.......................................................................................... 3-1

3.1 Asbestos .................................................................................................................... 3-1

3.1.1 Environmental Protection Agency .............................................................. 3-1

3.1.2 Occupational Safety and Health Administration ........................................ 3-2

3.1.3 State of South Carolina ............................................................................... 3-3

3.2 Lead-Based Paint ...................................................................................................... 3-3

3.2.1 Occupational Safety and Health Administration ...................................... 3-13

3.2.2 U. S. Department of Housing and Urban Development ........................... 3-14

4.0 METHODS OF INVESTIGATION ................................................................................ 4-1

4.1 Asbestos Survey ....................................................................................................... 4-1

4.2 Lead-Based Paint Survey ......................................................................................... 4-2

5.0 BUILDING 1877 ............................................................................................................... 5-1

5.1 Asbestos Survey Results .......................................................................................... 5-1

5.2 Lead-Based Paint Survey Results ............................................................................. 5-3

5.3 Conclusions and Recommendations ......................................................................... 5-5

5.3.1 Asbestos-Containing Materials ................................................................... 5-5

5.3.2 Lead-Based Paint ........................................................................................ 5-7

TABLES

Table 5-1 Summary of Asbestos Survey Table 5-2 Summary of XRF Survey

FIGURES

Figure 5-1 Homogeneous Area Sample Locations - First Floor Figure 5-2 Homogeneous Area Sample Locations - Second Floor Figure 5-3 Homogeneous Area Sample Locations - Third Floor and Roof Figure 5-4 Asbestos-Containing Material Locations - First Floor Figure 5-5 Asbestos-Containing Material Locations - Second Floor

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page ii

Figure 5-6 Asbestos-Containing Material Locations - Third Floor Figure 5-7 XRF Sample Locations - First Floor Figure 5-8 XRF and Paint Chip Sample Locations - Second Floor Figure 5-9 XRF Sample Locations - Third Floor

PHOTOGRAPHIC DOCUMENTATION

6.0 BUILDING 2100 ............................................................................................................... 6-1

6.1 Asbestos Survey Results .......................................................................................... 6-1

6.2 Lead-Based Paint Survey Results ............................................................................. 6-2

6.3 Conclusions and Recommendations ......................................................................... 6-3

6.3.1 Asbestos-Containing Materials ................................................................... 6-3

6.3.2 Lead-Based Paint ........................................................................................ 6-3

TABLES

Table 6-1 Summary of Asbestos Survey Table 6-2 Summary of XRF Survey

FIGURES

Figure 6-1 Homogeneous Area Sample Locations - First Floor Figure 6-2 Homogeneous Area Sample Locations - Second Floor Figure 6-3 Asbestos-Containing Material Locations - First Floor Figure 6-4 Asbestos-Containing Material Locations - Second Floor Figure 6-5 XRF and Paint Chip Sample Locations - First Floor Figure 6-6 XRF Sample Locations - Second Floor

PHOTOGRAPHIC DOCUMENTATION

7.0 BUILDING 2270 ............................................................................................................... 7-1

7.1 Asbestos Survey Results .......................................................................................... 7-1

7.2 Lead-Based Paint Survey Results ............................................................................. 7-2

7.3 Conclusions and Recommendations ......................................................................... 7-3

7.3.1 Asbestos-Containing Materials ................................................................... 7-3

7.3.2 Lead-Based Paint ........................................................................................ 7-4

TABLES

Table 7-1 Summary of Asbestos Survey Table 7-2 Summary of XRF Survey

FIGURES

Figure 7-1 Homogeneous Area Sample Locations Figure 7-2 Asbestos-Containing Material Locations Figure 7-3 XRF Sample Locations

PHOTOGRAPHIC DOCUMENTATION

8.0 BUILDING 2280 ............................................................................................................... 8-1

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page iii

8.1 Asbestos Survey Results .......................................................................................... 8-1

8.2 Lead-Based Paint Survey Results ............................................................................. 8-2

8.3 Conclusions and Recommendations ......................................................................... 8-5

8.3.1 Asbestos-Containing Materials ................................................................... 8-5

8.3.2 Lead-Based Paint ........................................................................................ 8-6

TABLES

Table 8-1 Summary of Asbestos Survey Table 8-2 Summary of XRF Survey

FIGURES

Figure 8-1 Homogeneous Area Sample Locations Figure 8-2 Asbestos-Containing Material Locations Figure 8-3 XRF and Paint Chip Sample Locations

PHOTOGRAPHIC DOCUMENTATION

9.0 BUILDING 4350 ............................................................................................................... 9-1

9.1 Asbestos Survey Results .......................................................................................... 9-1

9.2 Lead-Based Paint Survey Results ............................................................................. 9-2

9.3 Conclusions and Recommendations ......................................................................... 9-2

9.3.1 Asbestos-Containing Materials ................................................................... 9-3

9.3.2 Lead-Based Paint ........................................................................................ 9-4

TABLES

Table 9-1 Summary of Asbestos Survey Table 9-2 Summary of XRF Survey

FIGURES

Figure 9-1 Homogeneous Area Sample Locations Figure 9-2 Asbestos-Containing Material Locations Figure 9-2 XRF Sample Locations

PHOTOGRAPHIC DOCUMENTATION

10.0 BUILDING 5385 ............................................................................................................. 10-1

10.1 Asbestos Survey Results ........................................................................................ 10-1

10.2 Lead-Based Paint Survey Results ........................................................................... 10-3

10.3 Conclusions and Recommendations ....................................................................... 10-4

10.3.1 Asbestos-Containing Materials ................................................................. 10-4

10.3.2 Lead-Based Paint ...................................................................................... 10-6

TABLES

Table 10-1 Summary of Asbestos Survey Table 10-2 Summary of XRF Survey

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page iv

FIGURES

Figure 10-1 Homogeneous Area Sample Locations - First Floor Figure 10-2 Homogeneous Area Sample Locations - Second Floor Figure 10-3 Homogeneous Area Sample Location - Third Floor and Roof Figure 10-4 Asbestos-Containing Material Locations - First Floor Figure 10-5 Asbestos-Containing Material Locations - Second Floor Figure 10-6 Asbestos-Containing Material Locations - Third Floor Figure 10-7 XRF and Paint Chip Sample Locations - First Floor Figure 10-8 XRF Sample Locations - Second Floor Figure 10-9 XRF Sample Locations

PHOTOGRAPHIC DOCUMENTATION

APPENDICES

APPENDIX A Certifications APPENDIX B DAWSON Daily Reports APPENDIX C Laboratory Analytical Results

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 1-1

1.0 EXECUTIVE SUMMARY

1.1 Site Name

Six Buildings, Fort Jackson Columbia, Richland County, South Carolina Contract No: W912HN-14-D-0003 Task Order No: DW01

1.2 Name and Certificate of Inspector

Mark Hamblin Asbestos Building Inspector Asbestos Certification No. BI-01362 Lead-Based Paint Risk Assessor Lead Certification No. SC-I-I146815-1

1.3 Site Description and Activities

In July 2015, Aerostar SES LLC (Aerostar) conducted Asbestos-Containing Materials (ACM) and Lead-Based Paint (LBP) Surveys throughout Buildings 1877, 2100, 2270, 2280, 4350, and 5385, located at Fort Jackson, Columbia, Richland County, South Carolina. The surveys included all accessible areas throughout the buildings’ exteriors and interiors. The buildings are scheduled for renovation. Dawson Technical, LLC (DAWSON) provided oversight and coordination of the survey activities. The following table summarizes the buildings, provided square footage, and building use in which the ACM and LBP surveys were conducted.

1.4 Findings and Results

The following table summarizes the findings throughout the buildings and identifies material requiring special handling:

Building Friable ACM Non-friable Category I

ACM

Non-friable Category II

ACM

Material Containing

<1% Asbestos

LBP

≥1.0 mg/cm2

1877 No Yes* Yes* Yes** Yes†

2100 No Yes* Yes* No Yes†

2270 No Yes* Yes* No Yes†

2280 Yes* Yes* Yes* No Yes†

4350 No Yes* Yes* No Yes†

5385 Yes* Yes* Yes* Yes** Yes†

* Materials must be handled in accordance with 40 CFR 61 Subpart M and 29 CFR 1926.1101 ** Material must be handled in accordance with OSHA Standard 29 CFR 1926.1101 † Lead concentrations were also detected <1.0 mg/cm2 or <0.5 % wt. which must be handled in accordance with

OSHA Standard 29 CFR 1926.62

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 1-2

1.4.1 Asbestos Survey

A visual reconnaissance of suspect ACMs was performed in all accessible areas throughout the buildings. A summary of findings is outlined below.

Summary of ACM Survey

Building Square Footage

(SF)

Number of Homogenous

Areas

Number of PLM Samples

Number of NOB Samples Verified with

TEM

Number of Homogenous Areas with >

1% ACM

Number of Homogenous Areas with <

1% ACM

Number of Homogenous

Areas Assumed to be ACM

1877 56,396 34 113 15 8 1 4 2100 54,758 21 85 14 0 0 2 2270 13,280 23 91 13 4 0 1 2280 5,077 24 73 7 10 0 2 4350 6,867 19 71 12 2 0 2 5385 9,839 26 97 11 7 1 2

TOTALS 146,217 147 530 72 31 2 13

NOB Non-Friable Organically Bound PLM Polarizing Light Microscopy TEM Transmission Electron Microscopy

Building 1877

A total of 34 homogeneous areas were identified in Building 1877, thirty (30) of which were sampled. Four (4) homogeneous areas were not sampled and are assumed to contain asbestos until sampled, which included gaskets, fire doors, shower pan membrane, and vinyl sheet floor. Eight

(8) of the thirty (30) homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis, which included window caulk, pipe stop, vinyl floor tile (VFT), mastics, and tar and felt paper. One (1) homogeneous area was found to contain less than 1% asbestos by PLM or the point count method, which includes skim coat.

Building 2100

A total of 21 homogeneous areas were identified in Building 2100. Nineteen (19) of which were sampled. Two (2) homogeneous areas were not sampled and are assumed to contain asbestos until sampled, which included fire doors and gaskets. None of the 19 homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis.

Building 2270

A total of 23 homogeneous areas were identified in Building 2270, twenty-two (22) of which were sampled. One (1) homogeneous area was not sampled and is assumed to contain asbestos until sampled, which included fire doors. Four (4) of the 22 homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis, which included mastics. No asbestos was detected in the remaining 18 homogeneous areas.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 1-3

Building 2280

A total of 24 homogeneous areas were identified in Building 2280, twenty-two (22) of which were sampled. Two (2) homogeneous areas were not sampled and are assumed to contain asbestos until sampled, which included fire doors and gaskets. Ten (10) of the 22 homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis, which included mastics, caulk, skim coat, thermal system insulation (TSI) elbows, window glaze, joint compound, VFT, and flashing. No asbestos was detected in the remaining 12 homogeneous areas.

Building 4350

A total of 19 homogeneous areas were identified in Building 4350, seventeen (17) of which were sampled. Two (2) homogeneous areas were not sampled and are assumed to contain asbestos until sampled, which included fire doors and gaskets. Two (2) of the 17 homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis, which included mastic and door caulk. No asbestos was detected in the remaining 15 homogeneous areas

Building 5385

A total of 26 homogeneous areas were identified in Building 5385, twenty-four (24) of which were sampled. Two (2) homogeneous areas were not sampled and are assumed to contain asbestos until sampled, which included gaskets and fire doors. Seven (7) of the 24 homogeneous areas sampled throughout the building were found to contain greater than 1% asbestos by PLM analysis or the point count method, which included VFTs, mastics, skim coat texture, joint compound, and felt.

One (1) homogeneous area was found to contain less than 1% asbestos, which includes TSI wrap and mastic. No asbestos was detected in the remaining 16 homogeneous areas.

1.4.2 Lead-Based Paint Survey

A LBP survey was performed throughout the building using Niton XLp 302A series X-Ray Fluorescence (XRF) portable spectrum analyzers, serial numbers 23358 and 23952. A summary of findings is as follows:

Building 1877

Lead concentrations equal to or greater than 1.0 milligrams per centimeter squared (mg/cm2) were found in 31 XRF sample locations. Metal risers, metal rails, metal I-beams, cider block walls, and a metal ladder exhibited lead concentrations greater than 1.0 mg/cm2.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 118 XRF sample locations.

Metal conduits, multiple types of vinyl cove base, cinder block walls, vinyl floors, metal door casings, a metal beam, metal posts, tile walls, metal doors, a stair tread, metal rails, metal HVACs, a brick wall, a door casing, drywall walls, a wood door casing, a metal riser, a metal I-beam, and a cinder block door casing exhibited detectable lead concentrations less than 1.0 mg/cm2.

Aerostar collected two paint chip samples from select paints and coatings for laboratory analysis by Flame Atomic Absorption Spectroscopy (Flame AAS). The two paint chip samples collected

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 1-4 from the white cinder block wall and the black stairwell railing were found to contain lead greater than 0.5% wt.

Building 2100

A lead concentration equal to or greater than 1.0 mg/cm2 was found in one XRF sample location, which includes a metal I-beam.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 33 XRF sample locations.

Cinder block walls, a concrete ceiling, a concrete tread, a drywall ceiling, a drywall wall, metal bay doors, a metal bay door track, metal beams, a metal door casing, a metal I-beam, a metal post, metal rails, and metal risers exhibited detectable lead concentrations less than 1.0 mg/cm2.

Aerostar collected one paint chip sample from select paints and coatings for laboratory analysis by Flame AAS. The paint chip sample collected from the brown metal I-beam on the loading dock was found to contain lead less than 0.5% wt.

Building 2270

Lead concentrations equal to or greater than 1.0 mg/cm2 were found in 27 XRF sample locations.

Concrete walls, metal beams, metal ceilings, metal door, metal door frames, metal I-beams, a metal ladder, metal posts, and metal soffits exhibited lead concentrations greater than 1.0 mg/cm2.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 19 XRF sample locations.

Wood baseboards, a concrete crawlspace grate, a metal door, metal downspouts, a metal pipe, metal rails, a concrete wall, drywall walls, a metal window casing, and metal window frames exhibited detectable lead concentrations less than 1.0 mg/cm2.

Building 2280

Lead concentrations equal to or greater than 1.0 mg/cm2 were found in 43 XRF sample locations.

A concrete loading dock, a concrete riser, a concrete tread, metal doors, metal door casings, metal loading docks, metal rails, a metal roof, a metal service window, metal treads, metal window casings, and a wood door exhibited lead concentrations greater than 1.0 mg/cm2.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 69 XRF sample locations.

Cinder block walls, a concrete beam, concrete ceilings, concrete loading docks, concrete treads, drywall ceilings, a drywall wall, metal beams, metal doors, metal door casings, metal drains, metal HVACs, a metal pipe, metal rails, metal service windows, a metal window cage, a stone window sill, a wood chair rail, wood doors, and a wood door casing exhibited detectable lead concentrations less than 1.0 mg/cm2.

Aerostar collected one paint chip sample from select paints and coatings for laboratory analysis by Flame AAS. The paint chip sample collected from the silver concrete loading dock on the exterior of the building was found to contain lead less than 0.010% wt.

Building 4350

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 1-5

Lead concentrations equal to or greater than 1.0 mg/cm2 were found in nine XRF sample locations.

Metal beams, metal door frames, and metal downspouts exhibited lead concentrations greater than

1.0 mg/cm2.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 20 XRF sample locations.

Metal beams, a metal door casing, metal door frames, cinder block walls, drywall walls, and a metal window casing exhibited detectable lead concentrations less than 1.0 mg/cm2.

Building 5385

Lead concentrations equal to or greater than 1.0 mg/cm2 were found in 14 XRF sample locations.

A metal gutter, metal I-beams, a metal ladder, metal rails, metal risers, and a metal window frame exhibited lead concentrations greater than 1.0 mg/cm2.

Detectable concentrations of lead below 1.0 mg/cm2 were found in 52 XRF sample locations.

Wood balusters, wood baseboards, a metal beam, a metal cabinet, a drywall ceiling, wood chair rails, metal conduits, multiple types of vinyl cove base, wood crown moldings, metal doors, metal door casings, a metal door frame, metal rails, a metal roof hatch, metal stalls, metal under treads, cinder block walls, and drywall walls exhibited detectable lead concentrations less than 1.0 mg/cm2.

Aerostar collected one paint chip sample from select paints and coatings for laboratory analysis by Flame AAS. The paint chip sample collected from the black metal window casing in Room 105 was found to contain lead less than 0.05% wt.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 2-1

2.0 INTRODUCTION

From July 27 to 31, 2015, Aerostar conducted ACM and LBP Surveys for Buildings 1877, 2100, 2270, 2280, 4350, and 5385, located at Fort Jackson, Columbia, Richland County, South Carolina.

The area of the surveys included all accessible areas throughout the buildings’ exteriors and interiors. The buildings are scheduled for renovation. The asbestos survey activities were conducted by a South Carolina Department of Health and Environmental Control (SC-DHEC)-accredited individual. Aerostar is certified by the United States Environmental Protection Agency (EPA), Pesticides and Toxic Substances Branch, to conduct lead-based paint activities in the State of South Carolina, Certification Number SC-1654-5. The asbestos and lead-based paint surveys were performed by Mr. Mark Hamblin, an Asbestos Hazard Emergency Response Act (AHERA)-certified Asbestos Inspector accredited by SC-DHEC, accreditation Number BI-01362; and an EPA-certified lead-based paint Risk Assessor, Certificate Number SC-I-I146815-1. Copies of personnel and firm certifications are included in Appendix A. Dawson Technical, LLC (DAWSON) provided oversight and coordination of the survey activities. Copies of Daily Reports provided by DAWSON are included in Appendix B.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 3-1

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 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.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 3-2

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;

(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

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 3-3

• 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 State of South Carolina

According to SC-DHEC Regulation 61-86.1, Section IV.A, asbestos consultants, contractors, and inspectors must be licensed by the SC-DHEC.

SC-DHEC Regulation 61-86.1, Section X, requires that SC-DHEC be notified of any asbestos abatement activity, renovation or operations and maintenance (O&M) activity affecting asbestos-containing building materials (ACBM), or any demolition in facilities or public buildings.

According to SC-DHEC Regulation 61-86.1, Section VI.D.2, negative results for non-friable organically bound (NOB) materials should be verified with at least one TEM analysis in accordance with the American Society for Testing Building Materials (ASTM) Standard E2356 standard practice for comprehensive building asbestos surveys.

3.2 Lead-Based Paint

3.2.1 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 is present;

• Removal or encapsulation of materials containing lead;

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

• Installation of products containing lead;

• Lead spill/emergency cleanup; and

• Transportation, disposal, storage, containment of and housekeeping activities involving products containing lead, on the site or location at which construction activities are performed.

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.

3.2.2 U.S. Department of Housing and Urban Development

According to the U.S. 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

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 3-4 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.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 4-1

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 buildings. 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 buildings.

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 accredited by SC-DHEC, 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. In accordance with SC-DHEC Regulation 61-86.1, Section VI.D.2, negative results for Non-friable Organically Bound (NOB) materials were verified by Transmission Electron Microscopy (TEM) analysis in accordance with ASTM E2356.

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 (xxxx-yy-zz). The first set of characters (xxxx) indicates the building number assigned by the facility. The second set of numbers (yy) indicates the homogeneous area designation assigned by the asbestos inspector. The third set of numbers (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), 200 Route 130 North, Cinnaminson, New Jersey;

and 2500 Gateway Centre Boulevard, Suite 600, Morrisville, North Carolina, for laboratory analysis according to EPA Method 600/R-93/116.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 4-2

4.2 Lead-Based Paint Survey

The LBP inspection was performed using Niton XLp 302A series XRF portable spectrum analyzers, serial numbers 23358 and 23952. 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 throughout the buildings. The sampling locations were determined by the color of paint, substrate, and location throughout the buildings. The sampling locations are identified by room number or description, source, substrate, feature, condition of paint, and color. Building 1877 was arbitrarily designated as follows: “A” northeast; and “B”, “C”, and “D” proceeding clockwise in relation to side “A”. Building 4350 was arbitrarily designated as follows: “A” southeast; and “B”, “C”, and “D” proceeding clockwise in relation to side “A”. Buildings 2100 and 5385 were arbitrarily designated as follows: “A” west;

and “B”, “C”, and “D” proceeding clockwise in relation to side “A”. Buildings 2270 and 2280 were arbitrarily designated as follows: “A” northwest; 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.

Paint chip samples were collected if deemed necessary from paints and coatings of representative substrates. The sampling locations were determined by the color of paint, substrate, and location throughout the buildings. The sampling locations were labeled with the corresponding XRF reading number. Paint chip samples included all layers of paint to the substrate material. Samples were submitted to EMSL Cinnaminson, New Jersey, a laboratory which maintains accreditation through the Environmental Lead Laboratory Accreditation Program (ELLAP) for analysis by Flame AAS.

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 5-1

5.0 BUILDING 1877

5.1 Asbestos Survey Results

An AHERA-certified Asbestos Inspector, conducted an asbestos survey of Building 1877 to identify the locations, quantities, and conditions of ACMs. Aerostar performed the asbestos survey throughout all areas of the building’s exterior and interior. A total of 34 homogeneous areas were identified. The homogeneous areas identified included:

• Window Caulk

• Expansion Joint

• Pipe Stop

• Caulk/Putty

• 12”x12” VFT (3 types)

• Mastic associated with 12”x12” VFT (3 types)

• 2’x4’ Ceiling Tile (2 types)

• 4” Cove Base

• Mastic associated with 4” Cove Base

• Mastic

• Skim Coat

• Fiberglass and Foil TSI Mastic (2 types)

• Caulk

• Heating, Ventilation, and Air Conditioning (HVAC) Mastic (2 types)

• Built-Up Tar and Gravel Roof

• Tar and Felt Paper

• Tar

• Cove Base

• Mastic associated with Cove Base

• Gypsum Wallboard

• Joint Compound

• TSI Elbow

• TSI

• Gaskets

• Fire Doors

• Shower Pan Membrane

• Vinyl Sheet Floor

A total of 113 samples were collected and submitted to EMSL for analysis by PLM or TEM.

Analytical results of the samples revealed that eight of the 30 homogeneous areas sampled were found to contain greater than 1% asbestos by PLM. One homogeneous area was found to contain less than 1% asbestos by the point count method. A summary of materials found to contain asbestos are as follows:

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 5-2

Material Description

Homogeneous Area ID Location Approximate

Amount Asbestos Type

% Analysis NESHAP Category

Brown Window Caulk 1877-1 Surrounding Exterior

Windows 1,800 SF 3% Chrysotile PLM NF Cat. II

Tan and Yellow Pipe Stop 1877-3

Surrounding HVAC Condensate Drain Pipe on Building

Exterior

20 SF 2% Chrysotile PLM NF Cat. I

Tan with White and Beige Streaks

12”x12” VFT 1877-5 Throughout Interior of Building 41,000 SF 5% Chrysotile PLM NF Cat. I

Black Mastic associated with Tan with White and Beige Streaks 12”x12” VFT

1877-5A Throughout Interior of Building 41,000 SF 8% Chrysotile PLM NF Cat. I

Tan Mastic 1877-9 Dryer Vent Ducts in

Halls of First and Second Floors

20 SF 2% Chrysotile PLM NF Cat. I

White Skim Coat 1877-10 Ceiling in Storage, Closets, and Laundry

1,000 SF

<1% Chrysotile /

0.5% Chrysotile

PLM / EPA

Point Count

N/A

Black Mastic associated with White 12”x12”

VFT

1877-14A

First Floor Male Laundry Room, First Floor Supply Room, Female Bay

#8

60 SF 5-8%

Chrysotile PLM NF Cat. I

Tar and Felt Paper 1877-16

Roof under Metal Roof – Surrounding Roof Hatch Access and Flashing

1,000 SF 5-8%

Chrysotile PLM NF Cat. I

Black Mastic associated with

Light Tan 12”x12” VFT

1877-21A Third Floor Hallway 150 SF 3-5%

Chrysotile PLM NF Cat. I

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

Material Description

Homogeneous Area ID Location Approximate

Amount Asbestos Type % NESHAP Category

Gaskets 1877-26

Water System – throughout Building, Mechanical Room – First Floor

50 SF Assumed NF Cat. I

Fire Doors 1877-27 Throughout Building

840 SF (40

Doors ~ 21 SF each)

Assumed NF Cat. II

Shower Pan Membrane 1877-28 Under Ceramic Tile in

All Shower Areas 4,700 SF Assumed NF Cat. II

Vinyl Sheet Floor 1877-29 Shower Areas 4,700 SF Assumed NF Cat. I

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 5-3

In accordance with SC-DHEC Regulation 61-86.1, Section VI.D.2, negative results for NOB materials were verified by TEM analysis. Laboratory analysis indicated that none of the 15 NOB materials with no asbestos detected by PLM were found to contain greater than 1% asbestos by

TEM.

Asbestos sample results are summarized in Table 5-1. Sample locations are depicted on Figures 5-1, 5-2, and 5-3, and ACM locations are shown on Figures 5-4, 5-5, and 5-6. Photographic Documentation is included at the end of Section 5.0. 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.

5.2 Lead-Based Paint Survey Results

Based on the HUD guidelines, an XRF sample equal to or greater than 1.0 mg/cm2 of lead by XRF or 0.5% wt. by laboratory analysis 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 HUD’s definition of LBP (1.0 mg/cm2). 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.

The following building components exhibited XRF sample results containing lead concentrations greater than or equal to 1.0 mg/cm2:

• Black metal risers on the stairwells on the first, second, and third floors

• Black metal rails on the stairwells on the first and third floors

• Black cinder block walls in the laundry room on the second floor

• Black metal I-beams in the 1st/2nd PLT Male Bay South on the second floor; in the supply and conference rooms on the third floor; and in the 4th PLT Female Bay (southwest) on the first floor

• A blue metal I-beam in the 4th PLT Female Bay (southwest) on the first floor

• A brown metal ladder in the maintenance room on the third floor

• Maroon metal I-beams in the 4th PLT Male Bay South on the first floor and the day room on the second floor

• White metal I-beams in the day room and 1st/2nd PLT Male Bay North on the second floor;

in Classrooms #2, #4, #5, #7, #12, and #09L, and the Commanding Sergeant’s and testing rooms on the third floor; and in the 4th PLT Female Bay (northwest) on the first and second floors

Additionally, detectable concentrations of lead below the level which HUD defines as LBP (1.0 mg/cm2) were recorded in the following building components:

• Black metal conduit in the orderly room on the first floor and office on the third floor

Buildings 1877, 2100, 2270, 2280, 4350, & 5385, Fort Jackson, Columbia, Richland County, South Carolina August 24, 2015 Draft HazMat Studies Fort Jackson, Asbestos and LBP Assessments, Contract Number: W912HN-14-D-0003, Task Order DW01 Page 5-4

• Multiple types of black vinyl cove base in the orderly room, 4th PLT Male Bay South, hallway, supply room, and laundry room on the first floor; in the hallway and laundry room on the second floor; and in the office (southeast) on the third floor

• Black vinyl floors in the orderly room on the first floor and on the stair on the second floor

• Black metal door casings in the orderly room, laundry room, 4th PLT Male Bay North, 4th

PLT Female Bay (southwest), stairwell, and 4th PLT Female Bay (northwest) on the first floor; the hallways, storage, and 1st/2nd PLT Male Bay North and South on the second floor;

and the hallway, laundry, conference room, and 1st Sergeant room on the third floor

• Black cinder block walls in the CDR’s office, laundry rooms, and stair on the first floor;

the 1st/2nd PLT Male Bay North, laundry room, and 4th PLT Female Bay (northwest) on the second floor; and the hallways, latrine, and Commanding Sergeant room on the third floor

• A black metal post in the 4th PLT Male Bay North on the first floor

• Black metal doors in the 4th PLT Male Bay North, supply room, 4th PLT Female Bay

(southwest), hallway, and 4th PLT Female Bay (northwest) on the first floor; in the hallways, 1st/2nd PLT Male Bay North and South, and 4th PLT Female Bay (southwest) on the second floor; and in the maintenance room and hallway on the third floor

• A black tread on the side stairwell on the first floor

• Black metal rails on the stairwells on the second floor

• A black metal HVAC in the day room on the second floor and 4th PLT Female Bay

(southwest) on the first floor

• A black brick wall in the day room on the second floor

• Black tile walls in the latrine on the third floor

• A black wood door casing in the office (southeast) on the third floor

• A black metal riser on the stairwell on the third floor

• Black metal rails on the exterior

• Brown metal door casings in Office #10 on the third floor, Drill SGTS Dressing Room on the second floor, and the supply room on the first floor

• A maroon metal beam in the hallway on the first floor

• A maroon drywall wall in the latrine on the third floor

• Yellow cinder block walls in the hallways on the third floor; and 4th PLT Female Bay

(southwest) and hallway on the second floor

• A yellow drywall wall in the hallway on the third floor

• A yellow cinder block…