A.8.6_Am-0002_Specs_W912HV-17-B-0005.pdf

Hazardous Materials Inspection Report

FY 17 DoDEA MILCON Project PA00032 Replace Kadena Elementary School

Kadena Air Base, Okinawa, Japan

US Army Corps of Engineers, Japan Engineer District Contract No. W912HV-15-D-0008

ESC Project No. 1605

Revised February 22, 2017

Prepared For:

Woolpert –KZF JV 343 Fountains Parkway

Fairview Heights, IL 62208

Prepared By:

Am-0002

THIS PAGE IS INTENTIONALLY BLANK

HAZMAT Inspection Report i

CONTENTS

EXECUTIVE SUMMARY ............................................................................................................ i

ACRONYMS AND ABBREVIATIONS ..................................................................................... iv

1.0 INTRODUCTION

2.0 SITE OVERVIEW

2.1 Buildings 2415 A, B, C, D, E, J, O

2.2 Buildings 2415 F, G, H, I

2.3 Building 2415 K

2.4 Building 2415 M

2.5 Building 82415

2.6 Walkways

2.7 Other Facilities / Structures

3.0 REVIEW OF PREVIOUS REPORTS

4.0 ASBESTOS SURVEY

4.1 Suspect Asbestos-Containing Material

4.2 Asbestos Sampling Methods/Analysis

4.3 Asbestos-Containing Building material

5.0 LEAD-BASED PAINT

5.1 Suspect Lead-Based Paint

5.2 Lead-Based Paint Sampling Methods/Analysis

5.2.1 Lead-Containing Paint

5.2.2 LBP Paint as a GOJ Specially-Controlled Industrial Waste

6.0 POLYCHLORINATED BIPHENYLS

6.1 PCBs in Light Ballasts

6.2 PCB Oils in Transformers

7.0 OTHER POTENTIALLY HAZARDOUS BUILDING MATERIALS

7.1 Mercury

7.2 Radioactive Materials

7.3 Nickel-Cadmium Batteries

7.4 Refrigerants

7.5 Aboveground Storage Tanks (ASTs)

7.6 Underground Storage Tanks (USTs)

7.7 Transite Pipe

HAZMAT Inspection Report ii

8.0 GENERAL CONCLUSIONS AND RECOMMENDATIONS

9.0 LIMITATIONS

10.0 REFERENCES

TABLES

TABLE 1 SUMMARY OF SUSPECT ASBESTOS-CONTAINING MATERIALS

TABLE 2 CONSOLIDATED SUMMARY OF IDENTIFIED ACM MATERIALS

TABLE 3 SUMMARY OF SAMPLED SUSPECT LEAD-BASED PAINT

TABLE 4 SUSPECT PCB-CONTAINING LIGHT BALLASTS

TABLE 5 SUSPECT PCB-CONTAINING TRANSFORMERS

TABLE 6 SUSPECT MERCURY CONTAINING LIGHT BULBS

FIGURES

FIGURE 1: KADENA ELEMENTARY SCHOOL - SITE LOCATION MAP

FIGURE 2: KADENA ELEMENTARY SCHOOL EXITING FLOOR PLAN

APPENDICES

A ACM & LBP SAMPLING LOCATIONS

B ACM HOMOGENEOUS AREA LOCATION DRAWINGS

C ACM SAMPLING CHAINS-OF-CUSTODY & LABORATORY REPORTS

D LBP SAMPLING CHAINS-OF-CUSTODY & LABORATORY REPORTS

E PCB TRANSFORMER INFORMATION

F SITE CONDITIONS AND HAZARDOUS MATERIAL PHOTOGRAPHS

G PAST REPORTS

2012 AHERA ASBESTOS MANAGEMENT PLAN

2015 AHERA ASBESTOS MANAGEMENT PLAN

HAZMAT Investigation Report 1

ACRONYMS AND ABBREVIATIONS

ACBM Asbestos Containing Building Material ACM Asbestos Containing Material AHERA Asbestos Hazard Emergency Response Act AST Aboveground Storage Tank BLDG Building CFR Code of Federal Regulations cm Centimeter COC Chain of Custody DLA Defense Logistics Agency DODI Department of Defense Instruction EA Each EPA Environmental Protection Agency ESA Environmental Site Assessment ESC Environmental Science Corporation EST Environmental Support Team GOJ Government of Japan HAZMAT Hazardous Materials HID High Intensity Discharge HVAC Heating, Ventilation, & Air Conditioning HWAP Hazardous Waste Accumulation Point JEGS Japan Environmental Governing Standards KAB Kadena Air Base MAP Model Accreditation Program MATL Material mg/L Milligrams per liter N/A Not Applicable NESHAP National Emission Standard for Asbestos Ni-Cad Nickel-Cadmium NIST National Institute of Standards and Technologies NVLAP National Voluntary Laboratory Accreditation Program ODS Ozone Depleting Substance PCB Polychlorinated Biphenyl PLM Polarized Light Microscopy POL Petroleum, Oils, and Lubricants PPM Parts per million Rm Room ROTC Reserve Officer Training Corps SF Square Feet SM Square Meters TCLP Toxicity Characteristic Leaching Procedure TSI Thermal System Insulations US United States of America USFJ United States Forces Japan UST Underground Storage Tank

HAZMAT Investigation Report 2

1.0 INTRODUCTION

Environmental Science Corporation (ESC) conducted a hazardous material inspection for the existing Kadena Elementary School Educational Facility (Site) at Kadena Air Base, Okinawa, Japan. A review of existing documentation for previously identified hazardous materials was conducted and followed by visual inspection for suspect hazardous materials at the Site. For materials suspected as possible asbestos containing materials (ACM) and lead-based paint (LBP), bulk sampling was conducted from 10 to 12 December 2015 and 15 January 2016 for subsequent analysis at a qualified analytical laboratory.

The following tasks were conducted as part of the Hazardous Materials Survey:

Review of the US Government provided Asbestos Hazard Emergency Response Act (AHERA) report.

Field-verify the ACM identified in the report.

Conduct a supplemental hazardous materials survey, including additional sampling and analysis of suspect ACM and paint for lead content.

Identify hazardous building materials not included in the AHERA report provided, such as polychlorinated biphenyls (PCBs), mercury in fluorescent and high-intensity discharge (HID) light bulbs and/or thermostats, radioactive materials such as those found in smoke detectors, other regulated hazardous substances, and/or previously unidentified ACM or LBP.

2.0 SITE OVERVIEW

The objective of the inspection was to verify the location of hazardous materials in the 21 buildings and periphery structures or facilities planned for future demolition at the Site. Samples were mostly collected from the following areas through the 21 school buildings at Kadena Elementary School:

Plumbing/HVAC TSI- Various rooms Exterior walls Roof Other miscellaneous materials

The 21 school buildings surveyed are divided into the following wings: Buildings 2415 A, B, C, D, E, F, G, H, I, J, K, M, and O. The investigation also considered periphery structures and/or facilities as further described in Section 2.12 and Section 2.13 of this report. A site map showing the investigation boundary is provided as Figure 1, shown on the following page:

Investigated buildings present an atypical architectural/structural plan distribution with numerous wings and rooms added as the school expanded. Thus during the investigation these buildings were divided into four groups as described below in Section 2.1 based off of construction dates, building type, use, and materials present. It appears that interior and mechanical (such as heating, ventilation, and air conditioning) renovations were performed in recent years in the oldest portion of the school (Buildings 2415 A, B, C, D, E, J, and O). As a result, some finishing materials through the facilities vary and their conditions differ from one building to another. Facilities within the investigated Site were planned to be demolished in order to construct new Kadena Elementary School facilities, such as playgrounds, at the time of this supplemental hazardous materials survey.

HAZMAT Investigation Report 3

FIGURE 1: Kadena Elementary School - Site Location Map

HAZMAT Investigation Report 4

Figure 2 below shows the current floor plan of Kadena Elementary School as well as built dates for each building. This figure was provided by Woolpert and KZF Joint Venture to ESC prior to the investigation. Using this information, the wings were separated into the following groups:

2.1 BUILDINGS 2415 A, B, C, D, E, J, O

Buildings 2415 A, B, and O, as well as the central and eastern wing of 2415 C, central wing of 2415 D, and the eastern wing of 2415 J were all constructed in 1955 as the original school. The current use of these buildings includes offices, classrooms, restrooms, gymnasium, kitchen, maintenance areas, and storage rooms.

The remaining wings of Buildings 2415 C and D as well as 2415 E were built in 1960. These currently serve as classrooms, restrooms, and offices. As the building materials used in these additions appeared to be similar in type and condition as the original building, these additions were included in this grouping.

Classroom interiors seem to be in good condition. However, most of the exterior systems such as plumbing fixtures are in poor condition, especially in the mechanical room and janitor’s room.

There is one electrical transformer inside the building mechanical room. Two other pad transformers are located outdoors between Wings B and C.

2.2 BUILDINGS 2415 F, G, H, I

Buildings 2415 F, G, H, and I were built in 1971 and currently include classrooms, restrooms, storage areas, and the library. The interior of these buildings seem to be in good condition. The lighting system appears to have been upgraded, with an additional drop ceiling below the original ceiling. Some storage rooms and auxiliary areas seems not to have been updated, though the materials in these rooms seem to be in good condition.

2.3 BUILDING 2415 K

Building 2415 K was built in 1999 and currently serves as the Pre-Kindergarten program area.

There are classrooms, restrooms, and a kitchen in the building. Most materials seem to be in good condition though odors may suggest the presence of mold in the building, though not visually observed. There are also three pole transformers to the southwest of the building.

2.4 BUILDING 2415 M

Building 2415 M consists of two wings which were built in 2003. It is the kindergarten area and consists of classrooms, restrooms, and a small storage area. The building interior and exterior appear to be in good condition.

2.5 BUILDING 82415

Building 82415 is a small building south of the kitchen, which contains one transformer. The building date is unknown and whether it is in the scope of buildings to be demolished is unclear. It is in general disrepair with significant damage to the exterior.

HAZMAT Investigation Report 5

2.6 WALKWAYS

Covered walkways to connect each school building at the Kadena ES Site except building 2415 K.

However, most of these exterior walkways are concrete and used as hallways and are a part of the main school building. The only walkway considered separate was the metal awning connecting 2415 M to the main building. The paint is peeling, though the structure appears to be in good condition.

2.7 OTHER FACILITIES / STRUCTURES

Other structures include concrete structures such as electrical transformers, concrete enclosures, manholes, benches, signs, parking lot structures, playground equipment and other miscellaneous painted surfaces outside of any of the buildings under survey.

HAZMAT Investigation Report 6

FIGURE 2: Kadena Elementary School Exiting Floor Plan

HAZMAT Investigation Report 7

3.0 REVIEW OF PREVIOUS REPORTS

ESC reviewed the following reports prior to conducting the supplemental hazardous materials survey:

2012 AHERA Asbestos Management Plan, Kadena Elementary School prepared by ALPHA Facilities Solutions, LLC. (Alpha Facilities Solutions, 2012). The AHERA Management Plan was prepared to document the findings of the 2012 triennial AHERA and facility condition assessment inspection. Table 1 summarizes the Asbestos-containing building material (ACBM) previously identified at Kadena Elementary School. In addition to identifying assumed and confirmed ACM, the report also presented non-ACM materials (suspect materials that were sampled and determined to be less than 0.1 percent asbestos) and other materials (ACM that had been removed or could not be located). All Kadena Elementary School buildings are discussed in the plan, except Building 82415. Periphery facilities such as playgrounds, covered walkways, and parking structures are also not included.

ESC reviewed the 2015 AHERA Asbestos Management Plan, Kadena Elementary School prepared by ALPHA Facilities Solutions, LLC. (Alpha Facilities Solutions, 2015) in December 2016. The 2015 AHERA report did not identify any new ACM, which was not already identified in the 2012 report.

A summary of previously identified ACM & LBP in each of the existing Kadena Elementary School facilities are provided in the aforementioned historic reports and extracts from each report are included for reference in Appendix F of this report. A consolidated summary of all ACM identified (including materials identified as ACM in this supplementary survey) are included in Section 4.3, Table 2.

The Contractor shall be responsible for obtaining the full copies of the historical reports listed above from the Contracting Officer for use as reference prior to abatement or demolition work.

HAZMAT Investigation Report 8

4.0 ASBESTOS SURVEY

This supplemental asbestos survey and report were conducted in accordance with United States (U.S.) Environmental Protection Agency (EPA) guidance (40 CFR Part 763) and in accordance with the United States Forces Japan (USFJ) Japan Environmental Governing Standards (JEGS) (USFJ, 2012). Under the JEGS, ACM is defined as any material containing more than 0.1 percent asbestos by weight (this is more stringent criteria than observed in the United States). ACBM is defined in AHERA as surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other parts of a school building. The quantification of asbestos via Polarized Light Microscopy (PLM) was performed using EPA Method for the Determination of Asbestos in Bulk Building Materials (EPA, 1993).

This supplemental survey was conducted in anticipation of demolition of campus structures, which will comply with the EPA’s National Emission Standard for Asbestos (NESHAPs), contained in 40 Code of Federal Regulations (CFR) Chapter 61, Subpart M. NESHAPs requires identification of ACM prior to demolition of structures, including materials not surveyed for AHERA compliance

(e. g., exterior materials). The survey was conducted on Buildings 2415 A, B, C, D, E, F, G, H, I, J, K, M, and O, the covered walkways between the buildings, and playground areas at Kadena Elementary School and other minor periphery structures. As much as possible, sampling was conducted to minimize damage to the building and was patched to minimize creating a health hazard to inspectors or occupants.

4.1 SUSPECT ASBESTOS-CONTAINING MATERIAL

Suspect ACM is any material that is suspected of being asbestos-containing (based on appearance, usage, age of building, etc.) but has not been proven conclusively to be ACM (based on sampling, and analysis, documentation, building record, etc.), Homogeneous areas of suspect ACM were identified and samples were collected from each homogeneous area, in accordance with regulatory guidance and the professional judgment of a qualified EPA Model Accreditation Program (MAP) building inspector. For bulk sampling purposes, a homogeneous area is defined as an area that appears by composition, texture, and other characteristics to be uniform and applied during the same general time period. The sample locations are shown in the figures included in Appendix A.

Site and sample photographs are presented in the report photographs section in Appendix E.

Sampling forms, chains-of-custody (COCs), and analytical reports for asbestos samples are included in Appendix B. Samples were collected randomly from within the homogeneous area and delivered to Forensic Analytical Laboratories, Rancho Dominguez, CA under COC, for analysis by

PLM.

Table 2 summarizes the location, type, condition, and properties associated with the homogeneous areas of suspect ACM identified and sampled during the inspection. Analytical results greater than or equal to the JEGS regulatory limit of 0.1% and corresponding homogeneous material descriptions are highlighted in red. Where the asbestos bulk sample of the homogeneous material consisted of two or more distinct layers, the layer comprising the highest asbestos percentage is presented.

HAZMAT Investigation Report 9

Table 1 Summary of Suspect Asbestos-Containing Materials

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

Bldgs 2415 A, B, C, D, E, J

2415-S1 Interior White Paint on Concrete or Concrete Block

Nonfriable Surf Damaged High Low Low 2415C-2 2415-A-001 12/10/2015 ND

T103C 2415-A-002 12/10/2015 ND

D-8A 2415-A-003 12/10/2015 ND

D-4 2415-A-004 12/10/2015 1/14/2016

Trace*1 (0.06%)

E-6 2415-A-005 12/10/2015 ND

B-3 2415-A-006 12/10/2015 ND

A-6 2415-A-007 12/10/2015 ND

D-5 2415-A2-003 1/14/2016 2% chrysotile 2415-S2 1 x1 Green

Spotted Ceramic Floor Tile w/ White Grout

Nonfriable Misc Good High Low Low T102B 2415-A-008 12/10/2015 ND

T102C 2415-A-009 12/10/2015 ND

T104D 2415-A-010 12/10/2015 ND

2415-S3 4 x 4 White Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good High Low Low T102B 2415-A-011 12/10/2015 ND

T102E 2415-A-012 12/10/2015 ND

TB-3B, in B-3 2415-A-013 12/10/2015 ND

2415-S4 4 x 4 Turquoise Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good High Low Low T102C 2415-A-014 12/10/2015 ND

T104D 2415-A-015 12/10/2015 ND

T104J 2415-A-016 12/10/2015 ND

2415-S5 1 x1 Brown Spotted Ceramic Floor

Nonfriable Misc Good High Low Low T103C 2415-A-017 12/10/2015 ND

T101D 2415-A-018 12/10/2015 ND

HAZMAT Investigation Report 10

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

Tile w/ White Grout

T103D 2415-A-019 12/10/2015 ND

2415-S6 4 x 4 Pink Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good High Low Low T103C 2415-A-020 12/10/2015 ND

T101D 2415-A-021 12/10/2015 ND

T103D 2415-A-022 12/10/2015 ND

2415-S7 1 x1 Cream Ceramic Floor Tile w/ White Grout

Nonfriable Misc Good High Low Low

T102E 2415-A-023 12/10/2015 ND

2415-S8 1 x2 Brown Spotted Ceramic Floor Tile w/ White Grout

Nonfriable Misc Good High Low Low TB-3B, in B-3 2415-A-026 12/10/2015 ND

TB-3A, in B-3 2415-A-027 12/10/2015 ND

TA-6B 2415-A-028 12/10/2015 ND

2415-S9 Exterior Wall w/ Textured Paint Coating

Nonfriable Misc Good Mod Low High 2415 O2, north wall 2415-A-029 12/10/2015 ND

2415 O2, east wall 2415-A-030 12/10/2015 ND

2415 A8, north wall 2415-A-031 12/10/2015 ND

2415 B3, west wall 2415-A-032 12/10/2015 ND

2415 A2, north wall 2415-A-033 12/10/2015 ND

2415 J1, east wall 2415-A-034 12/10/2015 ND

2415 A1, south wall 2415-A-035 12/10/2015 ND

2415-S10 White Interior Paint in T104J

Friable Surf Significant Damage

Low Low Low

T104J 2415-A-036 12/10/2015 ND

2415-S11 Gray Roofing Material Over Walkways

Nonfriable Misc Good Low Low Low Roof of font walkway

2415-A-037 12/10/2015 ND

Roof of O Bldg walkway

2415-A-038 12/10/2015 ND

North end of central walkway

2415-A-039 12/10/2015 ND

HAZMAT Investigation Report 11

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

2415-S12

Asphaltic Roofing Material Over Main Building

Nonfriable Misc Damaged Low Low Low Roof of 2415 A2 (over A-8)

2415-A-040 12/10/2015 ND

Roof of 2415 B2 (Over TB-8)

2415-A-041 12/10/2015 ND

Roof of 2415 C2 (Over T104C)

2415-A-042 12/10/2015 12/30/2015

Trace*1

(<0.04%) Roof of 2415 D2

(Over D-8B)

2415-A-043 12/10/2015 ND

Roof of 2415 E2 (Over E-8)

2415-A-044 12/10/2015 ND

Bldgs 2415 F, G, H, I

2415F-S1 Exterior White Paint

Nonfriable Surf Good High Low Low 2415 I, north wall 2415F-A-001 12/12/2015 ND

2415 I, northwest corner 2415F-A-002 12/12/2015 ND

2415 I, west wall 2415F-A-003 12/12/2015 ND

2415 H, north wall 2415F-A-004 12/12/2015 ND

2415 H, west wall 2415F-A-005 12/12/2015 ND

2415 G, south wall 2415F-A-006 12/12/2015 ND

2415 G, north wall 2415F-A-007 12/12/2015 ND

2415F-S2 2 x 2 ft ACT w/ Pinholes, Upper Layer

Friable Misc Good Low Low Low 2415 I-3 2415F-A-008 12/12/2015 ND

2415 F-4 2415F-A-009 12/12/2015 ND

2415 G-3 2415F-A-010 12/12/2015 ND

2415F-S3 TCI Above Second Ceiling

Friable TCI Good Low Low Low 2415 I-3 2415F-A-011 12/12/2015 ND

2415 F-4 2415F-A-012 12/12/2015 ND

2415 G-3 2415F-A-013 12/12/2015 ND

2415F-S4 4 x4 White Nonfriable Misc Good High Low Low 2415 I-5C 2415F-A-014 12/12/2015 ND

HAZMAT Investigation Report 12

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

Ceramic Wall Tile w/ White Grout

2415 T102G 2415F-A-015 12/12/2015 ND

2415 T102F 2415F-A-016 12/12/2015 ND

2415F-S5 4 x4 Brown Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good High Low Low 2415 I-5C 2415F-A-017 12/12/2015 ND

2415 I-4B 2415F-A-018 12/12/2015 ND

2415 I-4B 2415F-A-019 12/12/2015 ND

2415F-S6 TSI Yellow Fiberglass w/ Silver Backing on Pipes

Friable TSI Good Low Low Low 2415 I-3 2415F-A-020 12/12/2015 ND

2415 M102I 2415F-A-021 12/12/2015 ND

2415 G-3 2415F-A-022 12/12/2015 ND

2415F-S7 TSI Yellow Fiberglass w/ White Backing on Pipes

Friable TSI Good Low Low Low 2415 I-7A 2415F-A-023 12/12/2015 ND

2415 I-7A 2415F-A-024 12/12/2015 ND

2415 M101G 2415F-A-025 12/12/2015 ND

2415F-S8 8 x 8 Beige Ceramic Floor Tile

Nonfriable Misc Good High Low Low T101I 2415F-A-026 12/12/2015 ND

T102G 2415F-A-027 12/12/2015 ND

2415F-S9 Asphaltic Roofing Material

Nonfriable Misc Damaged Low Low Low Roof of 2415 B3-1 (Over IC-B) 2415F-A-028 12/12/2015 ND

Roof of 2415 B3-1 (Over IC-A) 2415F-A-029 12/12/2015 ND

Roof of 2415 I (Over I-1) 2415F-A-030 12/12/2015 ND

Roof of 2415 H (Over H-3) 2415F-A-031 12/12/2015 ND

Roof of 2415 G

(G-7) 2415F-A-032 12/12/2015 ND

Bldg 2415 K

2415K-S1 Yellow TSI w/ Silver Paper Backing Above

Friable TSI Good Low Low Low 2415 K-1 2415K-A-001 12/12/2015 ND

2415 K-3 2415K-A-002 12/12/2015 ND

HAZMAT Investigation Report 13

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

Ceiling 2415 K-2 2415K-A-003 12/12/2015 ND

2415K-S2 4 x 4 White Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good High Low Low 2415 K-1 2415K-A-004 12/12/2015 ND

2415 K-2 2415K-A-005 12/12/2015 ND

2415 K-3 2415K-A-006 12/12/2015 ND

Bldg 2415 M

2415M-S1 4 x 4 Light Pink Ceramic Wall Tile w/ White Grout

Nonfriable Misc Good Moderate Low Low 2415 M-2A 2415M-A-001 12/10/2015 ND

2415 M-1A 2415M-A-002 12/10/2015 ND

2415 M-2 2415M-A-003 12/10/2015 ND

2415M-S2 1 x 1 Ceramic Floor Tile w/ White Grout

Nonfriable Misc Good High Low Low 2415 T102M 2415M-A-004 12/10/2015 ND

2415 T102M 2415M-A-005 12/10/2015 ND

2415 T101M 2415M-A-006 12/10/2015 ND

2415M-S3

Exterior White Paint

Nonfriable Surf Damaged Moderate Low Low 2415 M4-M9, east wall 2415M-A-007 12/10/2015 ND

2415 M4-M9, east wall

2415M-A-008 12/10/2015 ND

2415 M4-M9, north wall

2415M-A-009 12/10/2015 ND

2415 M4-M9, west wall

2415M-A-010 12/10/2015 ND

2415 M1-M3, north wall

2415M-A-011 12/10/2015 ND

2415 M1-M3, north wall

2415M-A-012 12/10/2015 ND

2415 M1-M3, east wall

2415M-A-013 12/10/2015 ND

HAZMAT Investigation Report 14

HA No.

Material

Description Friable/

Nonfriable Type Condition Contact Potential

Vibration Potential

Air Erosion Potential

Sample Locations Sample Information

ID

Analysis

Date Result

Bldg 82415

82415-S1 Exterior White Paint

Nonfriable Surf Damaged Moderate Low Low Transformer Bldg 82415 Exterior

82415-A-001 12/12/2015 ND

Transformer Bldg 82415 Exterior

82415-A-002 12/12/2015 ND

Transformer Bldg 82415 Exterior

82415-A-003 12/12/2015 ND

Notes:

HA No. – Homogeneous Area Number

*1 – A representative sample from the homogenous material resulting in “trace” asbestos was further analyzed by PLM EPA/600/R-93/116 1000-point count. The result of 1000 point count analysis is shown inside the parenthesis.

HAZMAT Investigation Report 15

4.2 ASBESTOS SAMPLING METHODS/ANALYSIS

The laboratory analyzed the bulk samples for asbestos content via PLM with EPA Method for the Determination of Asbestos in Bulk Building Materials (EPA, 1993). The figures included in Appendix A summarize the laboratory’s analyses of the samples, displaying sample locations, and the type and concentration of asbestos, if present. Where the asbestos bulk sample of the homogeneous material consisted of two or more distinct layers, the layer comprising the highest asbestos percentage is presented in the analytical results table. Laboratory analytical result reports and COC documents are included in Appendix B.

The JEGS define ACM as material that contains more than 0.1% asbestos (USFJ, 2012). Based on the asbestos bulk sample results, numerous additional homogeneous areas were identified and sampled during this supplemental survey were found to contain asbestos over regulatory limits.

In addition, a representative sample of each homogenous material found to contain “trace” levels of asbestos was additionally analyzed by using 1000-point counting, which has an analytical sensitivity exceeding the 0.1% regulatory JEGS regulatory level for asbestos content. Analytical results of the representative sample for each homogeneous area “set” are used to recommend management of that material as a whole. For any representative trace sample re-analyzed using 1000-point counting found ACM to exist below the JEGS regulatory limit of 0.1%, the associated homogenous material is considered to be non-ACM.

4.3 ASBESTOS-CONTAINING BUILDING MATERIAL

In summary, the following building materials, along with the previously identified material presented in Table 1, were assumed, reported, or confirmed to be ACM. Newly identified ACM resulting from the supplementary investigation are listed in red characters:

Table 2 Consolidated Summary of Identified ACM Materials

Mat No. Material Number and Description Locations Friability Condition Quantity

BLDG 2415 A, B, C, D, E, F, G, H, I, J, M, O

ESC-

INTERIOR WHITE PAINT ON

CONCRETE OR CONCRETE BLOCK

2415 A, B, C, D, E, O throughout

NO UNDAMAGED 6200 SF

007 CEMENT WALL PANEL, WHITE

PAINTED, WHITE CORE, ON UPPER

AND LOWER WINDOWS

H-4, J-4 NO UNDAMAGED 17 SF

011 RESILIENT FLOOR TILE, 9” X 9” CREAM F-1, F-2, F-3, F-4, F-

5, G-1, G-2, G-3, G-4, G-5, G-6, H-1, H-2, H-3, H-4, H-5, H-6, I- 1, I-2, I-3, I-4, I-5, I-6

NO UNDAMAGED 210 SF

021 RESILIENT FLOOR TILE, 9” X 9” BLACK J-4C NO UNDAMAGED 120 SF

046 ROPE GASKET, PAINTED SILVER M101J YES UNDAMAGED 2 EA

048 ROPE GASKET, WHITE, BOILER

GASKET

M101H YES UNDAMAGED 2 EA

HAZMAT Investigation Report 16

Mat No. Material Number and Description Locations Friability Condition Quantity

057 FLOOR ADHESIVE, BLACK, UNDER 9”

X 9” CREAM RESILIENT FLOOR TILE

F-1, F-2, F-3, F-4, F- 5, G-1, G-2, G-3, G-4, G-5, G-6, H-1, H-2, H-3, H-4, H-5, H-6, I- 1, I-2, I-3, I-4, I-5, I-6

NO UNDAMAGED 210 SF

066 THERMAL PIPE & FITTING

INSULATION, 4” DIAMETER, WHITE

PIPE CHASES YES UNDAMAGED 30 LF

070 FLOOR ADHESIVE, BLACK/YELLOW,

UNDER 1’ X 1’ BLUE RESILIENT FLOOR

TILE

J-4 NO UNDAMAGED 2728 SF

094 SHEET GASKET, GRAY, OBLONG

SHAPED, ON BOILER

M101J NO UNDAMAGED 1 EA

106 CEILING TILE ADHESIVE, BLACK,

UNDER 1’ X 1’ WHITE, PEGHOLE,

CEILING TILES

C101, J-4C, O-1A, O- 1B, O-2, O-3, O-4, O- 4A, O-4B, O-6, O-7, O-8A, O-8B

NO UNDAMAGED 4806 SF

128 FLOOR ADHESIVE, YELLOW, UNDER

BROWN RESILIENT FLOOR SHEETING

IC-B NO UNDAMAGED 584 SF

166 THERMAL FITTING INSULATION, 2” – 6”

DIAMETER, WHITE

ATTIC NO UNDAMAGED 2 EA

181 THERMAL FITTING INSULATION, 2” – 4”

DIAMETER, WHITE, HARD

C101, O-5, O-6, O-7, O-8A, O-8B

NO UNDAMAGED 63 EA

184 JOINT COMPOUND, YELLOW C102J, J-3A, J-3B, J-

NO UNDAMAGED 505 SF

188 THERMAL PIPE INSULATION, 2”

DIAMETER, WHITE PAPER

C101, O-5, O-6, O-7, O-8A, O-8B

NO UNDAMAGED 179 LF

193 COVE BASE ADHESIVE, GRAY, UNDER

4” BLACK RUBBER COVE BASE

F-1A, IC, IC-A, IC-B,

IC-C, IC-CA

NO UNDAMAGED 668 LF

210 COVE BASE ADHESIVE, GRAY, UNDER

4” BLACK RUBBER COVE BASE

I-1, I-2, I-3, I-4, I-5, I- 6, I-7

NO UNDAMAGED 770 LF

217 INTERIOR CAULK, WHITE, ON FOIL

PIPE JACKETS

M101F NO UNDAMAGED 10 LF

222 FLOOR ADHESIVE, YELLOW, UNDER

GRAY WITH WHITE STREAKS

RESILIENT FLOOR SHEETING

F-1, F-2, F-3, F-4 NO UNDAMAGED 2800 SF

228 INTERIOR CAULK, WHITE, ON

VARIOUS DIAMETER PIPE INSULATION

M101H NO UNDAMAGED 24 LF

233 COVE BASE ADHESIVE, YELLOW,

UNDER 4” BLACK RUBBER COVE BASE

I-4A, I-5A, I-5B NO UNDAMAGED 144 LF

234 SINK COATING, BLACK I-5B NO UNDAMAGED 1 EA

254 RESILIENT FLOOR SHEETING, LIGHT

CREAM WITH BROWN STREAKS

G-6 NO UNDAMAGED 896 SF

283 ASPHALTIC ROOFING MATERIAL,

GRAY, SINGLE PLY WITH FIBEROUS

MESH

ROOF NO DAMAGED 60,000 SF

284 WINDOW GLAZING, 3/4" THICK WHITE

PUTTY

EXTERIOR NO DAMAGED 100 LF

BLDG 2415K

212 SINK COATING, BLACK, TAR-LIKE K1, K2 NO UNDAMAGED 2 EA

HAZMAT Investigation Report 17

Mat No. Material Number and Description Locations Friability Condition Quantity

262 ASPHALTIC ROOFING MATERIAL,

BLACK, MODIFIRED BITUMEN

ROOF NO UNDAMAGED 2582 SF

HAZMAT Investigation Report 18

5.0 LEAD-BASED PAINT

This LBP survey and report were conducted in accordance with EPA guidance (40 CFR Part 745) and JEGS (DOD, 2012). LBP is defined as paint or other surface coatings that contain lead equal to or in excess of one milligram per square centimeter or more than 0.5 percent by weight. Lead-containing paint (LCP) is defined as paint or other surface coating that contain detectable amounts of lead, but at concentrations less than 0.5 percent by weight.

5.1 SUSPECT LEAD-BASED PAINT

Prior to sample collection, painted surfaces were categorized into distinct areas of homogeneity, substrate material, building material, distinct paint type, and apparent time of paint application. The sample locations are shown in Appendix A. Table 3 below summarizes suspect LBP sampled during the supplementary field investigation. The following paint samples confirmed to be LBP at the Kadena ES Site are shown in Table 3 in red text. LCP paint samples are shown in blue. Paints with no detectable amounts of lead are shown in black.

Table 3 Summary of Sampled Suspect Lead-Based Paint

Matl No. Color Substrate Condition Sample Location Sample ID Date Results

Bldgs 2415 A, B, C, D, E, J 2415‐1 White Concrete Good Exterior Wall 2415 C1 2415‐001 12/10/2015 <0.006%

2415‐2 Beige Concrete Good Exterior Wall 2415 C1 2415‐002 12/10/2015 0.051%

2415‐3 Blue Concrete Good Mural on Exterior West Wall 2415 C1

2415‐003 12/10/2015 0.009%

2415‐4 White Metal Damaged Exterior Electric Panel in 2415 C3

2415‐004 12/10/2015 <0.006%

2415‐5 White Concrete Damaged Wall of T102B in 2415 B

2415‐005 12/10/2015 <0.006%

2415‐6 Brown Wood Good Door in C‐2 in 2415 C2 2415‐006 12/10/2015 7.6%

2415‐7 White Concrete Good Wall in C‐2 in 2415 C2 2415‐007 12/10/2015 0.067%

2415‐8 White Metal Significant Damage

Pipe above walkway in 2415 O

2415‐008 12/10/2015 0.049%

2415‐9 Brown Metal Good Handrail to second floor in 2145 O

2415‐009 12/10/2015 0.009%

2415‐10 Gray Concrete Damaged Roof of 2415 B2 2415‐010 12/10/2015 0.086%

Bldg 2415 F, G, H, I 2415F‐1 White Concrete Damaged Exterior Wall 2415 I 2415F‐001 12/12/2015 <0.006%

2415F‐2 White Wallboar d/Concre te

Good Wall of I‐3 in 2415 I 2415F‐002 12/12/2015 0.035%

2415F‐3 Purple Over Blue

Metal/ Wood

Damaged Door and frame in I‐7 in 2415 I

2415F‐003 12/12/2015 0.49%

2415F‐4 White Metal Good Pipe in G‐3 in 2415 G 2415F‐004 12/12/2015 0.026%

HAZMAT Investigation Report 19

Matl No. Color Substrate Condition Sample Location Sample ID Date Results

Bldg 2415 K

2415K‐1 White Metal Significant Damage

Exterior Wall 2415 K 2415K‐001 12/12/2015 <0.006%

2415K‐2 White Metal Damaged Exterior Beam 2415 K 2415K‐002 12/12/2015 0.17%

2415K‐3 White Gypsum Good Wall in K3 in 2415K 2415K‐003 12/12/2015 <0.006%

2415K‐4 White Metal Good Pipe in K3 in 2415K 2415K‐004 12/12/2015 0.010%

Bldg 2415 M

2415M‐1 White Metal Good Exterior Column of 2415(M1‐M3)

2415M‐001 12/10/2015 <0.006%

2415M‐2 White Wall Board

Good Exterior Wall of 2415(M1‐M3)

2415M‐002 12/10/2015 <0.006%

2415M‐3 Brown Metal Damaged Handrail outside of 2415(M1‐M3)

2415M‐003 12/10/2015 0.54%

2415M‐4 Cream Gypsum Good Wall in M‐2 in 2415(M1‐M2)

2415M‐004 12/10/2015 0.006%

2415M‐5 Cream Metal Good Door Frame in M‐2 in 2415(M1‐M2)

2415M‐005 12/10/2015 3.6%

Bldg 82415 82415‐1 White Concrete Damaged Exterior Wall of 82415 82415‐001 12/12/2015 0.011%

82415‐2 Brown Concrete Good Exterior Wall of 82415 82415‐002 12/12/2015 0.47%

82415‐3 White Metal Damaged Exterior Vent of 82415 82415‐003 12/12/2015 0.003%

82415‐4 Brown over Green

Metal Significant Damage

Exterior Door of 82415 82415‐004 12/12/2015 2.8%

Playgrounds

PLAYGRO

UNDS‐1

Red Metal Good Kindergarten Playground, helicopter

PLAYGROUND

S‐001

12/10/2015 <0.006%

PLAYGRO

UNDS‐2

Yellow Metal Good Kindergarten Playground, phone

PLAYGROUND

S‐001

12/10/2015 <0.006%

PLAYGRO

UNDS‐3

Blue Metal Good Kindergarten Playground, sink

PLAYGROUND

S‐003

12/10/2015 <0.006%

PLAYGRO

UNDS‐4

Green Metal Damaged Main Playground, wave PLAYGROUND S‐004

12/10/2015 <0.006%

PLAYGRO

UNDS‐5

Black Metal Good Main Playground, main structure

PLAYGROUND

S‐005

12/10/2015 <0.006%

PLAYGRO

UNDS‐6

Beige Metal Damaged Main Playground, main structure

PLAYGROUND

S‐006

12/10/2015 <0.006%

Walkways WALK‐1 White Metal Significant

Damage Column from Exterior Walkway near 2415 K

WALKWAYS‐

12/10/2015 0.014%

Parking Areas

PARKING

‐1

Yellow Concrete Damaged Typical Curb PARKING‐001 12/12/2015 0.010%

PARKING

‐2

Yellow Asphalt Damaged Typical Line PARKING‐002 12/12/2015 0.016%

HAZMAT Investigation Report 20

Matl No. Color Substrate Condition Sample Location Sample ID Date Results

PARKING

‐3

White Asphalt Damaged Typical Line PARKING‐003 12/12/2015 0.008%

PARKING

‐4

Brown Metal Damaged Typical Fire Hydrant PARKING‐004 12/12/2015 <0.006%

PARKING

‐5

Brown Metal Damaged Typical Sign Pole PARKING‐005 12/12/2015 <0.02%

5.2 LEAD-BASED PAINT SAMPLING METHODS/ANALYSIS

Paint chip samples were collected in accordance with ASTM E1729-05, Standard Practice for Field Collection of Dried Paint Samples for Subsequent Lead Determination (ASTM, 2005). The samples were delivered to Forensic Analytical Laboratories, Hayward, CA under chain of custody for analysis by EPA Method 3050B/Method No. 7420, Atomic Absorption Spectroscopy (EPA, 1996). Laboratory reports are included in Appendix C, and shown in the Figures included in Appendix A.

5.2.1 Lead-Containing Paint

Lead-containing paint is paint containing detectable concentrations of lead, but not at sufficient concentration to be classified as LBP. EPA and JEGS define lead-based paint as paint that contains more than 0.5 percent lead by weight (40 CFR Part 745; USFJ, 2012). Based on the supplemental survey paint chip sample results, twenty-three (23) paint samples were identified at Kadena Elementary School had detectable concentrations of lead. Four (4) of the paint samples were determined to be lead-based paint out of a total thirty-nine (39) samples taken during the survey (Table 3).

5.2.2 LBP Paint as a GOJ Specially-Controlled Industrial Waste

It should be noted that GOJ regulatory limit for lead as a specially-controlled industrial waste is 0.3 milligrams per liter (mg/L) for waste sludge, acid, and alkali, as determined by toxicity characteristic leaching procedure (TCLP) laboratory analysis. Although TCLP testing was not part of the scope of this survey, it is recommended that TCLP analysis be performed on LCP-positive materials (particularly for those materials of high surface area) to determine whether the paint in question should be classified as a specially controlled industrial waste for disposal purposes.

HAZMAT Investigation Report 21

6.0 POLYCHLORINATED BIPHENYLS

Polychlorinated Biphenyls (PCBs) are synthetic chemicals that were manufactured for use in various industrial and commercial applications – including oil in electrical and hydraulic equipment, and plasticizers in paints, plastics and rubber products – because of their non-flammability, chemical stability, high boiling point, and electrical insulation properties. Until the late 1970s, PCBs were commonly used as insulators in electrical equipment because they have high tolerance to heat, do not burn easily, and are non-explosive. In 1979, the EPA banned the manufacture and sales of PCBs.

6.1 PCBS IN LIGHT BALLASTS

ESC visually inspected the light fixtures in offices, storage spaces, mechanical rooms, etc. for the presence of PCBs. The following table summarizes the estimated number of ballasts and light fixtures in each of the buildings and other structures associated with the Site:

Table 4 Suspect PCB-Containing Light Ballasts

Building / Facility

Type of Fixture

Est. Number of Fixtures

Est. Number of Ballasts

Est. Number of Bulbs

Notes

2415 A, B, C, D, E, J

Florescent 2000 2100 4000 Filament or HID

14 0 14 Exit sign lighting w/ battery pack

2415 F, G, H, I

Florescent 600 600 1200 Filament or HID

0 0 0 Exit sign lighting w/ battery pack

2415 K Florescent 50 50 100 Filament or HID

5 0 5 Exit sign lighting w/ battery pack

2415 M Florescent 350 350 650 Filament or HID

2 2 Exit sign lighting w/ battery pack

Notes:

Reported quantities represent estimates based on building drawings available at the time of survey. Quantities are rounded to the nearest 10 or 100 in cases where count could not be easily determined by visual observation alone.

Counts are given for estimate purposes only.

A representative number of light fixtures observed were dismantled to expose the ballasts for visual inspection. If the ballast was marked with a manufacturer's label of "NO PCB" or was a Japanese ballast manufactured after 2004 (year the regulatory definition for a PCB item in Japan was reduced to 0.5 mg/kg), the ballast was presumed to be PCB free. Ballasts without the "NO PCB" label or those manufactured before 2004 shall be presumed to contain PCBs and be handled accordingly by the demolition contractor.

PCB related wastes require additional processing and disposal through the Defense Logistics Agency (DLA) Disposition Services via the Kadena Air Base 718 CES/CEIE Environmental Department and shall not be disposed directly by the Contractor to an off-base facility. The Contractor shall contact the Kadena PCB Manager at 718 CES/CEIE at DSN (315) 634-5427 for coordination for turn-in of all ballasts (both PCB and non-PCB types).

HAZMAT Investigation Report 22

6.2 PCB OILS IN TRANSFORMERS

A total of 7 electrical transformer sites, 4 pad mount and 3 pole mount, were identified during interviews with facility managers and during consultation with the KAB Electrical Shop. From testing records available for the transformers known to exist at the Site all transformers contain no PCBs as of September 2009.

Table 5 Suspect PCB-Containing Transformers

ID Manufacturer Voltage Serial Number Condition PCB

Content Location

TV 2415 ABB 500 kVA 97A502479 Good ND, Sept 09 2415 Interior

SET 2415 ABB 500 kVA 96J030009 Good ND, Sept 09 Exterior

SET 2415A Cooper 300 kVA 0237014228 Good ND, Sept 09 Exterior

BP 2415 Cooper 25 kVA 981078896 Good ND, Sept 09 Pole

BP 2415A Cooper 25 kVA 981078893 Good ND, Sept 09 Pole

BP 2415B Cooper 25 kVA 981078894 Good ND, Sept 09 Pole

TH 113 Howard 100 kVA 1732751297 Unknown ND, Sept 09 82415

Most transformers were observed to have possible PCB contamination label affixed, though this does not confirm PCB contamination. No Non-PCB labels (R-temp fluid filled, Envirotemp fluid filled, <1 ppm PCB content, etc.) were observed affixed to any of the transformers, however, the presence of these labels does not prove the absence of PCB levels in accordance with local Japanese and/or JEGS regulations. The Japanese regulatory level for PCBs in oil was lowered to 0.5ppm in 2001 (JEGS also currently states a regulatory level of 0.5ppm). As a result of this change in regulation, equipment evaluated as PCB free in accordance with US manufacturer stickers may contain PCBs under current Japanese regulations. Unlike other hazardous wastes, PCB related wastes require additional processing and disposal through the DLA Disposition Services via 718 CES/CEIE and cannot be disposed directly by the Contractor to an off-base facility.

All electrical transformers and associated cables (i.e., paper insulated lead cable), shall be treated as possible PCB-containing materials and turned over the Kadena Base Electrical Shop at Building 1465. The Contractor shall contact the Kadena PCB Manager at 718 CES/CEIE at DSN (315) 634- 5427 for coordination for turn-in of transformers to Kadena Base Electrical (both PCB and non- PCB types). Photographic documentation for the transformers observed during the investigation can be referenced in Appendix E. KAB Electrical Shop related transformer oil analysis records are included in Appendix D.

HAZMAT Investigation Report 23

7.0 OTHER POTENTIALLY HAZARDOUS BUILDING MATERIALS

During the inspection, other potentially hazardous building materials were noted, including potential mercury-containing items, potential radioactive sources, nickel-cadmium or other batteries, aboveground storage tanks (ASTs) and underground storage tanks (USTs).

7.1 MERCURY

Mercury is a naturally occurring element that is present throughout the environment. Mercury is hazardous and requires special handling. In building, mercury is commonly found in thermometers, barometers, switches, thermostats, and fluorescent light bulbs.

Table 6 Suspect Mercury Containing Light Bulbs

Building / Facility

Type of Fixture Est.

Number of Fixtures

Est.

Number of

Bulbs

Notes

2415 A, B, C, D, E, J

Florescent 2000 4000 Filament or HID 14 14 Exit sign lighting w/ battery pack Thermostats/Switches 0 0

2415 F, G, H, I

Florescent 600 1200 Filament or HID 0 0 Exit sign lighting w/ battery pack Thermostats/Switches 0 0

2415 K Florescent 50 100 Filament or HID 5 5 Exit sign lighting w/ battery pack Thermostats/Switches 0 0

2415 M Florescent 350 650 Filament or HID 2 2 Exit sign lighting w/ battery pack Thermostats/Switches 0 0

Notes:

Reported quantities represent estimates based on building drawings available at the time of survey. Quantities are rounded to the nearest 10 or 100 in cases where count could not be easily determined by visual observation alone.

Counts are given for estimate purposes only. No thermostats or switches suspected to contain mercury were observed during this survey though this should be confirmed by the contractor for demolition.

As summarized in Table 6, it is estimated that about 3000 light fixtures containing around 6000 florescent light bulbs will be removed from Kadena Elementary School. The florescent light bulbs and HID lamps should be assumed to contain mercury unless proven otherwise, and should be removed, handled, and disposed accordingly.

Other potential mercury containing building materials were not observed in the buildings inspected at the Site, but could be present in electric switches and thermostats. Any equipment found to contain mercury should be properly handled and disposed of in accordance with JEGS and local waste handling regulations.

HAZMAT Investigation Report 24

7.2 RADIOACTIVE MATERIALS

Although not observed at buildings inspected at Kadena Elementary School, “exit” signs, especially glow-in-the-dark types, frequently contain tritium, the radioactive form of hydrogen. Smoke detectors also may use a small radioactive source, such as Americium-241, as a key component in detecting smoke particles. Therefore, smoke detectors and exit signs should be properly inspected, handled, and disposed of, to avoid damage and potential release of radioactive materials.

7.3 NICKEL-CADMIUM BATTERIES

Many exit signs and “emergency lighting” ballasts were observed to contain nickel-cadmium batteries. Nickel-cadmium batteries and/or other batteries associated with building equipment should be properly handled and disposed of in accordance with JEGS and local waste handling regulations. Section 6.1 Table 5 details lighting systems which were observed to contain Ni-Cad battery packs at Kadena Elementary School facilities.

7.4 REFRIGERANTS

No materials suspected to contained refrigerants with Ozone Depleting Substances (ODS) were observed during this investigation of Kadena Elementary School. The demolition contractor should confirm this before demolition.

7.5 ABOVEGROUND STORAGE TANKS (ASTS)

There were two (2) historic petroleum storage aboveground storage tanks (ASTs) at the Site. These were not observed during site investigations and during interviews with the facilities managers of Kadena Elementary School it was indicated that both were removed, though the removal dates are unknown. According to Kadena AB records, the tanks were a 3000 gal ACE double walled steel tank and a 1000 gal single wall steel tank. As there is no active boilers or generators at the school, therefore fuel storage tanks are assumed no longer present at this site. No other tanks, or records of existing tanks, were found during this investigation.

7.6 UNDERGROUND STORAGE TANKS (USTS)

There are no active or historic USTs on the Kadena Elementary School site.

7.7 TRANSITE PIPE

Although not observed at the site during the supplemental survey, transite piping, especially prevalent in underground sewer and storm drain utility pipelines, if encountered shall be presumed ACM unless verified non-ACM by a certified asbestos building inspector.

HAZMAT Investigation Report 25

8.0 GENERAL CONCLUSIONS AND RECOMMENDATIONS

Asbestos Containing Materials

Material assumed, reported, or confirmed to be ACM were found at Kadena Elementary School both during previous investigations and during this supplemental survey. Therefore, further action with respect to asbestos may be required if this material is to be disturbed or removed, and is required prior to renovation of the buildings. Should any building materials be encountered, which are suspected to contain asbestos and which were not accessible or evaluated in this survey, they must be assumed to contain asbestos, and handled appropriately, unless determined otherwise by a MAP-certified Asbestos Building Inspector. Any identified or presumed asbestos containing material shall be appropriately removed and disposed of in accordance with all applicable laws and regulations and in compliance with project specifications.

The following additional observations and notes were made at the conclusion of the supplementary hazardous materials survey for ACM materials:

A representative sample of each homogenous material found to contain “trace” levels of asbestos was additionally analyzed by using 1000-point counting, which has an analytical sensitivity exceeding the 0.1% regulatory JEGS regulatory level for asbestos content.

Analytical results of the representative sample for each homogeneous area “set” are used to recommend management of that material as a whole. For any representative trace sample re-analyzed using 1000-point counting found ACM to exist below the JEGS regulatory limit of 0.1%, the associated homogenous material is considered to be non-ACM.

When removing any part of a multi-layered flooring system (multiple mastic, resilient tile, sheeting components, etc.) which contains one or more layers of ACM, all flooring layers associated with that room or system will need to be removed and disposed of as ACM unless the Contractor can provide evidence that the ACM and non-ACM layer components can be separated without disturbance or agitation to the ACM positive flooring component.

Although not observed at the site during the supplemental survey, transite piping, especially prevalent in underground sewer and storm drain utility pipelines, if encountered shall be presumed ACM unless verified non-ACM by a certified asbestos building inspector.

Lead Containing Paint

LCP and LBP is present on and in the buildings at Kadena Elementary School. The condition of the paint ranged from poor to good. Worker and environmental protection precautions, including but not limited to proper training, engineering controls, and monitoring, is required if any lead-containing paint will be disturbed. Should any lead-based paint be found to be peeling or in otherwise poor condition, it should be properly removed. Surrounding areas, including exposed soil, must be protected during any activities that disturb paint with lead.

It is additionally recommended that materials identified with LCP or LBP coating be further tested in context of local hazardous waste regulation to evaluate disposal options for the painted building material off-installation. Specially-controlled waste criteria for lead concentration in demolition materials for disposal in Japan is 0.3 mg/L, tested by TCLP. If a material contains more than 0.3

HAZMAT Investigation Report 26 mg/L of lead content, it must undergo stricter handling and disposal requirements in accordance with the Japan Waste Management and Public Cleansing Law (GOJ, 1970, updated 2001).

Although TCLP testing was not part of the scope of this survey, it is recommended that TCLP analysis be performed on lead-positive materials to determine whether the paint in question can be disqualified as a specially-controlled industrial waste for disposal.

PCBs

PCBs are assumed to exist in any light ballast even those that contain a “NO PCB” label by a US manufacturer or is not Japanese ballast manufactured after 2004. PCB containing ballasts require additional coordination, processing and disposal through DLA Disposition Services and cannot be disposed directly at an off-base facility. Typically, all project ballasts need to be separated based on country of origin and turned into the 718 CES/CEIE Environmental Department.

In addition, all electrical transformers and associated cables shall be treated as PCB-containing materials until proven otherwise through an accepted testing program or adequate material data can be provided. Regardless, all transformers, whether PCB or non-PCB items, shall be turned into the Kadena Electric Shop at Building 1465 by the Contractor. The Contractor shall contact the Kadena PCB Manager at 718 CES/CEIE at DSN (315) 634-5427 for coordination for turn-in of transformers to Kadena Base Electrical at least 2 week prior to turn over.

Mercury

Florescent and HID light bulbs should be assumed to contain mercury unless proven otherwise, and should be removed, handled, and disposed in accordance with applicable local disposal laws and regulations.

Other potential mercury containing building materials were not observed in the buildings inspected at the Site, but could be present in electric switches and thermostats. Any equipment found to contain mercury should be removed, handled, and disposed in compliance with governing regulations.

Radioactive Materials / Nickel-Cadmium Batteries

Smoke detectors and exit signs at the Site should be properly inspected, handled, and disposed of, to avoid damage and potential release of radioactive materials. Many exit signs and “emergency” fluorescent tube lighting at Kadena Elementary School facilities contain Ni-Cad battery or other power supply that will require special handling and disposal.

HAZMAT Investigation Report 27

9.0…