W912QR24B0010_CERTFinal_Enviro_Survey-0001.pdf

Solicitation For

REPAIR HVAC AHU’S 1,2,4,&5 AND

CHILLERS 88 CG B 10271

WRIGHT-PATTERSON AFB. OH

P2: 499504

Design-Bid-Build

Specifications - Enviro Survey

05 August 2024

W912QR24B0010

Corrected Final Design

29 August 2024

W912QR24B0010-0001

Certified Final Design

ARIMS: 200A

Disposition: Maintain for 15yrs after construction

W912QR24B0010_CERTFinal_Enviro_Survey-0001

Hazardous Building Material Survey Report

Wright Patterson Air Force Base Repair HVAC AHUS 1, 2, 4, 5 and Exterior Chillers

Facility 10271 Project Number: ZHTV 1600020

Submitted By:

Nichole Lashley, CHMM Certified Asbestos Hazard Evaluation Specialist #ES34071

Certified Hazardous Materials Manager (#24829) and

Malea Casey Certified Asbestos Hazard Evaluation Specialist #ES545334

Submitted To:

Kevin Lanning, Jr., P.E.

Kevin.J.Lanning@usace.army.mil

P.O. Box 0059 Louisville, KY 40201-0059

January 11, 2022

4555 Lake Forest Drive, Suite 650, Blue Ash, OH 45242 Phone: 937-271-1226 www.ascgroup.net i | P a g e

TABLE OF CONTENTS

LIST OF ACRONYMS .................................................................................................................. iii

1.0 EXECUTIVE SUMMARY

1.1 Asbestos Containing Material (ACM) Overview

1.2 Lead Overview

1.3 Hazardous Building Materials Overview

1.4 Mold

2.0 INTRODUCTION

2.1 Assumptions

3.0 REGULATIONS

3.1 Environmental Protection Agency (EPA)

3.1.1 Asbestos National Emissions Standard Hazardous Air Pollutant (NESHAP)

3.1.2 Universal Wastes (UWs)

3.2 American Society for Testing and Materials (ASTM) Standards

3.3 Occupational Safety and Health Administration (OSHA)

3.3.1 Asbestos

3.3.2 Lead-based paint (LBP)

4.0 ASBESTOS SAMPLING AND RESULTS

4.1 Confirmed Asbestos Containing Materials (ACMs)

4.2 Assumed Asbestos Containing Materials (ACMs)

4.3 Non- Asbestos Containing Materials (NACMs)

5.0 ACM CONCLUSIONS

5.1 Assumed ACM Gaskets Associated with Flanges and Valves

5.2 Assumed ACM Vibration Cloth

6.0 ENVIRONMENTAL LEAD AND LEAD-BASED PAINT CONCLUSIONS

7.0 HAZARDOUS BUILDING MATERIALS

7.1 Mercury-Containing Thermostats

7.2 Mold

7.3 Water Softening Chemicals

7.4 Ozone Depleting Refrigerants

7.5 Refrigerant Oil

8.0 RECOMMENDATIONS

8.1 Asbestos

8.2 Lead-based paint

8.3 Other Hazards

9.0 REPORT RELIANCE

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APPENDICES

A: Assessor’s Certifications and Lab Accreditations B: Sample Location Diagrams C: Tables

Table 1: Building Materials Bulk Sampled Table 2: Non-ACM

D: Laboratory Certificates of Analysis and Chains of Custody E: Inventory of ACM and Hazardous Building Materials F: Photograph Documentation G: Asbestos Material Location Diagrams H: Hazardous Building Material Locations I: Safety Data Sheets iii | P a g e

LIST OF ACRONYMS

ACM Asbestos Containing Material(s) AHU Air Handling Unit(s)

Assessor(s) Nichole Lashley, CHMM Malea Casey

ASTM American Society for Testing and Materials ASC/Auxano ASC Group Inc./Auxano Environmental LLC.

CFR Code of Federal Regulations CFCs Chlorofluorocarbon DL Detection Limit EPA Environmental Protection Agency FL Fluorescent Lamps

HVAC

HW

Heating Ventilation Air Conditioning Hazardous Waste

IATL International Asbestos Testing Laboratories LBP Lead-Based Paint LED Light-Emitting Diode MCE Mercury-Containing Equipment MG/CM Milligrams Per Square Centimeter MSDS Material Safety Data Sheets NESHAP National Emissions Standard for Hazardous Air Pollutants NVLAP National Voluntary Laboratory Accreditation Program OAC Ohio Administrative Code OSHA Occupational Safety and Health Administration PACM Presumed Asbestos Containing Material(s) PCB Polychlorinated Biphenyls PEL Permissible Exposure Level PLM Polarized Light Microscopy RACM Regulated Asbestos Containing Material(s) SOW Statement of Work TCLP Toxicity Characteristics Leaching Procedure UW Universal Waste(s) UWR Universal Waste Rule USEPA United States Environmental Protection Agency WPAFB Wright Patterson Air Force Base

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FACILITY 10271

CONSTRUCTION SECTION ASBESTOS, LEAD-BASED PAINT AND

HAZARDOUS BUILDING MATERIAL SURVEY REPORT

WRIGHT PATTERSON AIR FORCE BASE

ZHTV 1600020, REPAIR HVAC AHUS 1, 2, 4, 5 AND EXTERIOR CHILLERS

1.0 EXECUTIVE SUMMARY

This project involves Facility 10271 in Area A at Wright Patterson Air Force Base that was built in the late-1950s with the cooling towers installed in 1993. This project includes replacing Air Handling Units (AHUs) 1, 2, 4, and 5 as well as demolishing the existing exterior chillers and relocating them to a new location. The work includes related pumps, piping, insulation, valves, power supply, controls, cooling tower basin and modifications to structural supports as necessary. This report contains the findings of ASC/Auxano investigation in preparation for the replacement of AHU 1, 2, 4, 5 and exterior Chillers.

1.1 ASBESTOS CONTAINING MATERIAL (ACM) OVERVIEW

The Environmental Protection Agency (EPA) defines a homogeneous area as a surfacing material, thermal system insulation, or miscellaneous material that is uniform in color and texture. The use or application of the homogeneous area is also used to identify suspect Asbestos Containing Materials (ACMs). The EPA and the Occupational Health and Safety Administration (OSHA) define ACM as any material that contains more than one percent (by weight) of asbestos (>1 percent). Only one sample from a homogeneous area with an asbestos concentration >1 percent is required to collectively identify that material as an ACM.

The EPA additionally categorizes ACM as follows:

Category I non-friable ACM – asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than one percent asbestos as determined using Polarized Light Microscopy (PLM).

Category II non-friable ACM – any material, excluding Category I non-friable ACM, containing more than one percent asbestos as determined using the PLM method that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated asbestos-containing material (RACM) – (a) Friable asbestos material, (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 regulated by this subpart.

Potential asbestos exposure in construction is regulated when construction, alteration, repair, maintenance, renovation or demolition of structures, substrates, or portions thereof contain asbestos (29 CFR 1926.1101 (a)(3)).

On December 16 and 21, 2021, Nichole Lashley and Malea Casey, Ohio Environmental Protection Agency (OEPA) Certified Asbestos Hazard Evaluation Specialists (#ES34071 and #ES545334, 2 | P a g e respectively), conducted an Asbestos ASTM E2356-14 for Pre-Construction Survey at Wright Patterson Air Force Base (WPAFB), Ohio 45433 for the replacement of AHU 1, 2, 4, 5 and the exterior Chillers at Facility 10271. The following list summarizes the ACM determined to be present (Note: Functional space designations were declared by the assessor and may not represent actual user functional space declarations. Reference Appendix E and G for Asbestos Material Location Diagrams as they relate to ACMs within the functional spaces identified by the assessor):

• Category II assumed ACM Vibration Cloth associated with AHUs – 1st Floor Mechanical Room, Catwalk above 1st Floor Mechanical Room, and 2nd Floor Mechanical Room ~55 ft²

• Category I assumed ACM Gaskets associated with Flanges and Valves – Cooling Towers, 1st Floor Mechanical Room, Pump Room, and 2nd Floor Mechanical Room ~144 ft²

Appendix F contains photographic documentation representative of the materials found within the building. Additionally, removal of any ACM will need to comply with OSHA and WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

1.2 LEAD OVERVIEW

Contractors impacting or disturbing painted substrates would need to comply with the OSHA Lead in Construction Standard, 29 CFR 1926.62. The OSHA Permissible Exposure Limit (PEL) for airborne lead exposure concentrations has been established to be 50 micrograms per cubic meter and the OSHA Action Level has been established to be 30 micrograms per cubic meter. All contractors will be required to perform personal exposure monitoring when disturbing any existing painted substrates and components and compare sample results to the OSHA regulatory threshold levels and conduct work practices accordingly. The construction debris must adhere to the WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

1.3 HAZARDOUS BUILDING MATERIALS OVERVIEW

The following hazardous materials were reported by ASC/Auxano to be within or on the exterior of Facility 10271:

• Compressed Freon Refrigerant (~70 pounds [lbs])

• Mineral Oil associated w/ Trane Cooling Unit (~200 gallon [gal])

• Mercury Thermometers (3 each)

• Non-Mercury Thermostats (5 each)

• Sodium hypochlorite (200 gal)

• Microcontrol 15N (20 gal)

• CL-2150 (20 gal)

• CL-5556 Chemtreat (20 gal)

Removal and disposal of these items will need to follow WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements), unless they will be re-used as part of this project.

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1.4 MOLD

On December 16, 2021, Ms. Lashley collected one bulk biotape sample to determine the levels of surface mold present on the chiller. The sample was submitted it to iATL, Mount Laurel, NJ to be analyzed for mold utilizing bioaerosol fungal contact plate.

Standard Chain-Of-Custody procedures were followed. The sample was labeled accurately and completely to match all information on the completed Chain-Of-Custody, including sample ID, sample time, date, type of analysis, project and samplers’ name, and location.

Sample Number Sample Location Mold-form Identified Concentration

Mold #1 Underside of Chiller #2 Cladosporium low

The results indicated that Cladosporium of low concentration was present on the underside of Chiller #2. Cladosporium growths appear green, brown, or black. This mold was observed on the exterior of the cooling tower. The contractor removing the mold should be made aware of the hazard. Additionally, the main concern would be mold inside of the building. As long as the cooling tower is replaced and the system cleaned with a biocide, this should not be an issue.

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2.0 INTRODUCTION

On December 16 and 21, 2021, Nichole Lashley and Malea Casey, Ohio Environmental Protection Agency (OEPA) Certified Asbestos Hazard Evaluation Specialists (#ES34071 and #ES545334, respectively), conducted an Asbestos American Society for Testing and Materials (ASTM) E2356- 14 for Pre-Construction Survey at Wright Patterson Air Force Base (WPAFB), Ohio 45433 for the replacement of AHUs 1, 2, 4, 5 and exterior Chillers at Facility 10271. The assessors’ certifications and lab accreditations are included in Appendix A.

The intent of this assessment effort was to identify all types, locations, and corresponding conditions of all ACM, Polychlorinated biphenyls (PCBs), and other Hazardous Materials that are anticipated to be impacted or disturbed because of the project. The hazardous materials assessment was conducted in accordance with applicable EPA regulations. The asbestos assessment was completed in accordance with the National Emissions Standard Hazardous Air Pollutants (NESHAPs) and (ASTM E2356-14 Standard Practice for Comprehensive Building Asbestos Surveys. The ASTM outlines practices for three (3) types of ACM surveys: Baseline Surveys, Project Design Surveys, and Pre-Construction Surveys. The objectives established for each of these survey types differs based upon the significance and use intended for the survey. Based upon ASC/Auxano’s interpretation of the ASTM E2356-14 Standard, the survey that was performed for this assessment effort would be classified, in part, as both a Project Design Survey and Pre- Construction Survey.

Prior to the assessment, ASC/Auxano staff were provided with a set of existing floor plans by KZF Design which were utilized by the assessor to identify the limits of the scope of work for the renovation, as well as to assist in determining building materials/components that are anticipated to be demolished/removed as part of this project.

2.1 ASSUMPTIONS

The initial time of construction of Facility 10271 was the late-1950s, with the cooling towers installed in 1993. It was ASC/Auxano's understanding that various renovations have occurred to the building. The following assumptions were made by the assessors as part of this assessment effort:

All Presumed Asbestos Containing Material (PACM) were treated and sampled as separate homogenous areas since the dates of installation, maintenance, and change-out schedules were not known.

Quantities of ACM are related to the anticipated impact or disturbance related to this project.

Possible ACM in inaccessible areas that were not visible (e.g. wall cavities, inside mechanical equipment, etc.) was not assessed.

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3.0 REGULATIONS

3.1 ENVIRONMENTAL PROTECTION AGENCY (EPA)

3.1.1 Asbestos National Emissions Standard Hazardous Air Pollutant (NESHAP)

In the 1970s, the United States Environmental Protection Agency (USEPA) Clean Air Act implemented regulations which banned and phased out various asbestos products including, but not limited to, spray-applied fireproofing and thermal systems insulation products. Pursuant to the Clean Air Act of 1970, the USEPA established the asbestos NESHAP, which has since been revised and updated in 1990. The intent of NESHAP is to minimize the release of asbestos fibers during activities involving handling of asbestos and specifies work practices to be followed during renovation, demolition, or other abatement activities when friable asbestos is involved.

The following EPA terminology and corresponding definitions are relative to ACM that have been identified within the demolition areas:

RACM – any friable ACM containing more than one percent asbestos as determined using PLM according to the method specified in Appendix A, Subpart F, 40 Code of Federal Regulations (CFR) Part 763 (Sec. 61.141).

Category I non-friable ACM – any asbestos-containing gasket, resilient floor covering or asphalt roofing product that contains more than one percent asbestos as determined using PLM according to the method specified in Appendix A, Subpart F, 40 CFR Part 763 (Sec. 61.141).

Category II non-friable ACM – Any material, excluding Category I non-friable ACM, containing more than one percent asbestos as determined by the methods specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

The OEPA asbestos program licenses and certifies companies directly involved with the asbestos abatement industry. The program regulates asbestos abatement contractors, supervisors, workers, building inspector/management planners, and air monitoring technicians. In addition, OEPA conducts random asbestos abatement project audits and reviews asbestos contractor licenses, certifications, medical, fit testing, and the asbestos abatement project.

The OEPA notification of demolition and renovation form is required for:

Every demolition of a facility, regardless of whether asbestos is involved. This includes all structures that will be intentionally burned for fire training purposes.

A renovation when the amount of RACM stripped, removed, dislodged, cut, drilled, or similarly disturbed exceeds 260 linear feet (lf) on pipes or 160 square feet (ft²) on other facility components or 35 cubic feet ( ft3) of facility components.

An abatement when the activity involves the removal, renovation, enclosure, repair or encapsulation of friable ACM in an amount greater than 50 lf on pipes or 50 ft² on other facility components.

State regulations for Asbestos Hazard Abatement Contractors, Specialists, and other professionals are included in Chapter 3745-22 of the Ohio Administrative Code (OAC). Additionally, WPAFB

6 | P a g e standard specification section 01 35 43 (General Environmental Protection Requirements) needs to be followed during the project.

3.1.2 Universal Wastes (UWs)

ASC/Auxano performed a visual inspection of existing building equipment for the presence of other hazardous materials and Universal Wastes (UWs) [pursuant to 40 CFR 273.9, and 40 CFR 260.10]. The survey was limited to above grade only and did not include a soil or subsurface investigation. Materials evaluated as part of this inspection included: PCB containing units such as lighting ballasts and PCB-containing electrical units (i.e., electrical transformers); lead-containing units such as car batteries or emergency exit sign batteries; fluorescent lighting tubes;

mercury-containing units such as light switches and thermostats; refrigerants, halon, and other Chlorofluorocarbons (CFCs) such as fire extinguishing systems and Freon® used in association with building drinking fountains; heavy metals as may be found in cooling tower water treatment systems; solvents, paints, fuel (storage tanks), lubricants, and other associated maintenance and cleaning products; radioactive materials that may be contained in units such as smoke detectors, emergency exit signs, or medical equipment; office materials, supplies, and equipment such as computer monitors and printing supplies, and miscellaneous materials such as unlabeled materials or substances of concern.

UWs are specific hazardous waste streams that a generator can choose to manage in an alternative manner in place of the more complex hazardous waste requirements. The Universal Waste Rules (UWR) are intended to promote recycling as well as proper disposal by easing certain regulatory requirements. Ohio’s UWRs are in OAC Chapter 3745-273.

If the material such as PCBs cannot meet the UW specific waste stream it must be disposed of a Hazardous Waste (HW). Disposal requirements for WPAFB are found in the standard specification sections 01 35 43 (General Environmental Protection Requirements).

3.2 AMERICAN SOCIETY FOR TESTING AND MATERIALS (ASTM) STANDARDS

The ACM assessment also utilized ASTM E2356-14 Standard Practice for Comprehensive Building Asbestos Surveys. The ASTM outlines practices for three (3) types of ACM surveys:

Baseline Surveys, Project Design Surveys, and Pre-Construction Surveys. The objectives established for each of these survey types differs based upon the significance and use intended for the survey. Based upon ASC/Auxano’s interpretation of the ASTM E2356-14 Standard, the survey that was performed for this assessment effort would be classified, in part, as both a Project Design Survey and Pre-Construction Survey.

3.3 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA)

3.3.1 Asbestos

OSHA has been involved with controlling work exposure to asbestos since 1971. The 29 CFR

1926.1101 Construction Industry Standard for Asbestos was introduced in 1994. Provisions covered in this standard include asbestos worker protection for those involved with disturbing asbestos, protection of those employees working around asbestos, exposure assessments, periodic monitoring, medical surveillance, work procedures, respiratory protection, personal protective equipment, hazard communication, housekeeping, recordkeeping, and competent person

7 | P a g e responsibilities. Note that OSHA regulates building materials containing any percentage or amount of asbestos, including all materials less than one percent asbestos. Additionally, WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements) needs to be followed during the project.

3.3.2 Lead-based paint (LBP)

OSHA’s definition of a Lead-Based Paint (LBP) includes all paints, varnishes, stains, lacquers, or coatings containing any concentration of lead greater than zero percent. All contractors impacting existing LBP coated surfaces need to comply with the OSHA Lead in Construction Standard (29 CFR 1926.62). The OSHA PEL for airborne lead exposure concentrations has been established to be 50 micrograms per cubic meter and the OSHA Action Level has been established to be 30 micrograms per cubic meter. All contractors will be required to perform personal exposure monitoring when disturbing any existing painted substrates and components and compare sample results to the OSHA regulatory threshold levels and conduct work practices accordingly. This standard has been developed to protect workers from potential exposures to lead. Additionally, WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements) needs to be followed during the project.

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4.0 ASBESTOS SAMPLING AND RESULTS

Rooms, functional spaces, and components were assessed and surveyed for the presence of ACM.

Bulk samples of suspect ACM were collected to confirm or deny the presence of asbestos. All samples were placed into clean sealed bags and identified with a unique sample number. Sampling tools were decontaminated between each sampling episode. Seventy (70) bulk samples (including all layers) of twenty-eight (28) homogeneous areas were collected by an OEPA Licensed Asbestos Hazard Evaluation Specialist in accordance with current EPA (40 CFR 61, Subpart M) and OSHA 29 CFR 1926.1101 requirements and sampling protocol. Appendix B contains Sample Location Diagrams. Samples of suspect building materials collected as part of this assessment effort are included within Appendix C – Table 1: Building Materials Bulk Sampled.

4.1 CONFIRMED ASBESTOS CONTAINING MATERIALS (ACMS)

Bulk samples collected for this assessment were analyzed via International Asbestos Testing Laboratories (IATL) accredited National Voluntary Laboratory Accreditation Program (NVLAP) laboratory using PLM Method EPA 600 R-93/116, 1993.

There were no positive analysis results for asbestos associated with these sampling efforts.

Corresponding Lab Chain of Custodies and Certificates of Analysis are included within Appendix D.

4.2 ASSUMED ASBESTOS CONTAINING MATERIALS (ACMS)

Various building materials were assumed as ACM as part of this assessment effort. These building materials were assumed to contain ACM based upon one or more of the following factors: lack of accessibility to sample, or if the area was un-safe (worker protection) to sample. The following list represents the assumed ACM within the renovation areas for this project:

• Category II assumed ACM Vibration Cloth associated with AHUs – 1st Floor Mechanical Room, Catwalk above 1st Floor Mechanical Room, and 2nd Floor Mechanical Room ~55 ft²

• Category I assumed ACM Gaskets associated with Flanges and Valves – Cooling Towers, 1st Floor Mechanical Room, Pump Room, and 2nd Floor Mechanical Room ~144 ft²

This material was assumed to be ACM since bulk sampling this material would require the dismantlement of equipment to access them successfully. Reference Appendix E - Inventory of ACM, which includes the locations, quantities, conditions, and corresponding NESHAP categories of these materials throughout the facility.

4.3 NON- ASBESTOS CONTAINING MATERIALS (NACMS)

Building materials that were bulk sampled and reported by the laboratory to contain no asbestos content are inventoried within Appendix C – Table 2: Non-Asbestos Containing Materials.

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5.0 ACM CONCLUSIONS

The following conclusions represent the assessor’s professional judgment regarding the existing ACM anticipated to be impacted or disturbed as a result of this renovation project. Reference Appendix B- Bulk Sample Location Diagram and Appendix E – Photographs for information regarding sampling.

5.1 ASSUMED ACM GASKETS ASSOCIATED WITH FLANGES AND VALVES

Category I non-friable ACM Gaskets associated with Flanges and Valves were assumed to be present within Facility 10271. These components were located on the water piping systems related to the Air Handling Units (AHUs) and Cooling Towers. Approximately 144 ft² of gaskets were assumed to contain ACM, since bulk sampling these materials would require the dismantlement of flanges and valves to access successfully. Each gasket would need to be treated as a separate homogenous area and sampled accordingly to prove that the materials contain no asbestos content, especially since the gasket installation date(s), change out, and maintenance schedules were not known. The condition of the ACM gaskets was unknown since they were encased within metal.

Due to the minimal cost impact, the abatement of the ACM gaskets would have on the overall project cost, the assessor recommends that the gaskets are removed and disposed of as ACM by an Ohio Licensed Asbestos Abatement Contractor prior to commencement of demolition. Bulk sampling each of the gaskets for asbestos would not be realistically obtainable in the assessor’s professional judgment, based upon the quantity of gaskets related to the variety of different building systems and perceived unknown maintenance change-out schedules.

5.2 ASSUMED ACM VIBRATION CLOTH

Approximately 55 ft² of Category II non-friable Vibration Cloth associated with AHUs in the 1st Floor Mechanical Room, Catwalk above the Mechanical Room, and 2nd Floor Mechanical Room was assumed to contain ACM, since bulk sampling this material would require the dismantlement of equipment to access them successfully. Each cloth would need to be treated as a separate homogenous area and sampled accordingly to prove that the materials contain no asbestos content, especially since the installation date(s), change out, and maintenance schedules were not known.

ASC/Auxano recommends the vibration cloth remain as an assumed ACM and be removed and disposed of by on Ohio Licensed Asbestos Abatement Contractor prior to any impact or disturbance via demolition work practices.

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6.0 ENVIRONMENTAL LEAD AND LEAD-BASED PAINT CONCLUSIONS

Contractors impacting or disturbing painted substrates that would require grinding, sanding, scraping, abrasive blasting, welding, cutting and/or torch burning would need to comply with the OSHA Lead in Construction Standard, 29 CFR 1926.62. The OSHA PEL for airborne lead exposure concentrations has been established to be 50 micrograms per cubic meter and the OSHA Action Level has been established to be 30 micrograms per cubic meter. All contractors will be required to perform personal exposure monitoring when disturbing any existing painted substrates and components and compare sample results to the OSHA regulatory threshold levels and conduct work practices accordingly. The construction debris must adhere to the WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

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7.0 HAZARDOUS BUILDING MATERIALS

7.1 MERCURY-CONTAINING THERMOSTATS

This category includes mercury-containing thermostats that fail the Toxicity Characteristic Leaching Procedure (TCLP). The TCLP is a procedure used to determine whether a waste exhibits the hazardous waste characteristic for toxicity. Mercury-containing thermostats are temperature control devices that contain metallic mercury in an ampule attached to a bimetal sensing element, and mercury-containing ampules removed from temperature control devices in compliance with the UWR and disposed of in accordance with WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements) prior to demolition.

During the site visit, 5 non-mercury thermostats and 3 mercury-containing thermometers were identified. A location map can be found in Appendix H and quantities per room are reported in Appendix E.

7.2 MOLD

On December 16, 2021, Ms. Lashley collected one bulk biotape sample to determine the levels of surface mold present on the cooling towers. The sample was submitted it to iATL, Mount Laurel, NJ to be analyzed for mold utilizing bioaerosol fungal contact plate.

Standard Chain-Of-Custody procedures were followed. The sample was labeled accurately and completely to match all information on the completed Chain-Of-Custody, including sample ID, sample time, date, type of analysis, project and samplers’ name, and location.

The results indicated that Cladosporium mold was found on the exterior cooling towers at Facility 10271. Cladosporium growths appear green, brown or black. This mold was observed on the exterior of the cooling tower. The contractor removing the mold should be made aware of the hazard. Additionally, the main concern would be mold inside of the building. As long as the cooling tower is replaced and the system cleaned with a biocide, this should not be an issue.

7.3 WATER SOFTENING CHEMICALS

Chemicals present in a water softener system can include sulfuric acid, benzotriazole, methylisothiazolinone, sodium hypochlorite. Sulfuric acid is a highly corrosive strong acid that can be dangerous to human health (skin contact as well as inhalation) to handle.

Methylisothiazolinone and sodium hypochlorite have also been linked to lung toxicity and should be handled with care.

Water softeners also contains chemicals meant to form insoluble precipitates with other chemicals in the water, thus eliminating them from the filtered water. These are a concern as the chemicals present in the water softener are highly corrosive in nature. If in contact with metals, they can leach electrons from the metal piping leading to corrosion and decrease of integrity of the metal.

The following chemicals, observed in the Pump Room, are utilized to soften the water from the cooling tower:

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Sodium hypochlorinate (200 gal) Microcontrol 15N (20 gal) CL-2150 (20 gal) CL-5556 Chemtreat (20 gal) Hypochlorite solution 12-15% (55 gal)

A location map can be found in Appendix H, quantities per area are reported in Appendix E, SDS can be found in Appendix I. These materials will need to be properly disposed of within State and Federal regulations prior to removal/renovation activities.

7.4 OZONE DEPLETING REFRIGERANTS

A CFC is an organic compound that contains only carbon, chlorine, and fluorine, produced as a volatile derivative of methane, ethane, and propane. They are also commonly known by the DuPont brand name Freon. The most common representative is dichlorodifluoromethane (R-12 or Freon-12). Many CFCs have been widely used as refrigerants, propellants (in aerosol applications), and solvents. Because CFCs contribute to ozone depletion in the upper atmosphere, the manufacture of such compounds has been phased out under the Montreal Protocol, and they are being replaced with other products.

During the site visit, 1 ozone refrigerant tank, containing an estimated 70 lbs of compressed freon, was discovered within a Trane Cooling Unit that was in the renovation space. This tank will need to be properly removed and disposed of in accordance with State and Federal regulations.

7.5 REFRIGERANT OIL

Refrigeration systems depend on two main types of lubricant: synthetic and mineral oil. Synthetic oil is a longer lasting solution, but mineral oil is more commonly used in industrial applications, like air conditioning units for large spaces. The exact formulation of oil for a specific compressor depends on the size and power requirements of the compressor. Oil viscosity, which measures the resistance of the lubricant to various factors such as heat and pressure, is the main factor in determining the formulation of lubricant to be used in a compressor.

A 200 gallon Tank of Refrigerant Oil was observed on a Trane Cooling Unit in the 1st Floor Mechanical Room. Quantities per room are reported in Appendix E. Removal and disposal of these items will need to follow WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

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8.0 RECOMMENDATIONS

8.1 ASBESTOS

“Regulated asbestos-containing material” means:

(a) Friable asbestos material;

(b) Category I non-friable asbestos-containing material that has become friable;

(c) Category I non-friable asbestos-containing material that will be or has been subjected to sanding, grinding, cutting, or abrading; or

(d) Category II non-friable asbestos-containing material 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 during demolition or renovation operations regulated by OAC chapter 3745- 20-01.

The OEPA notification of demolition and renovation form is required for:

Every demolition of a facility, regardless of whether asbestos is involved. This includes all structures that will be intentionally burned for fire training purposes.

A renovation when the amount of RACM stripped, removed, dislodged, cut, drilled, or similarly disturbed exceeds 260 lf on pipes or 160 ft² on other facility components or 35 ft3 of facility components.

An abatement when the activity involves the removal, renovation, enclosure, repair or encapsulation of friable ACM in an amount greater than 50 lf on pipes or 50 ft² on other facility components.

State regulations for Asbestos Hazard Abatement Contractors, Specialists, and other professionals are included in Chapter 3745-22 of the OAC. Additionally, WPAFB standard specification section 01 35 43 (General Environmental Protection Requirements) needs to be followed during the project.

8.2 LEAD-BASED PAINT

All contractors impacting or disturbing painted substrates that would require grinding/sanding/scraping of existing paint would need to comply with the OSHA Lead in Construction Standard, 29 CFR 1926.62. The OSHA PEL for airborne lead exposure concentrations has been established to be 50 micrograms per cubic meter and the OSHA Action Level has been established to be 30 micrograms per cubic meter. All contractors will be required to perform personal exposure monitoring when disturbing any existing painted substrates and components and compare sample results to the OSHA regulatory threshold levels and conduct work practices accordingly. The construction debris must adhere to the WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

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8.3 OTHER HAZARDS

The contractor will be responsible for the complete removal, recycling and/or disposal of Hazardous Building Materials. Removal and disposal of these items will need to follow WPAFB standard specification sections 01 35 43 (General Environmental Protection Requirements).

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9.0 REPORT RELIANCE

This document was prepared for the use of WPAFB and KZF Design and can be relied upon by WPAFB and KZF Design as the end user of this report. ASC/Auxano assures that the scope of the investigation and contents included within the report are in conformance with accepted requirements and follow the generally accepted standards and practices of environmental consultants. The statements contained in the report are true and accurate to the best of our knowledge.

Sincerely, Nichole Lashley Senior Environmental Scientist ASC/Auxano

16 | P a g e

APPENDICES

A: Assessor’s Certifications and Lab Accreditations B: Sample Location Diagrams C: Table 1: Building Materials Bulk Sampled

Table 2: Non-ACM D: Laboratory Certificates of Analysis and Chains of Custody E: Inventory of ACM and Hazardous Building Materials F: Photograph Documentation G: Asbestos Material Location Diagrams H: Hazardous Building Material Locations I: Safety Data Sheets

FACILITY 20033

A: ASSESSOR’S CERTIFICATIONS AND LAB ACCREDITATIONS

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R hio Mike DeWlne, Governor epa.ohio.gov • (614) 644-3020 • (6 ES34071 8/3,22 h

Ohio Environmental Protection Agency

Jon Husted, Lt. Governor Laurie A. Stevenson, Director

7/6/2021

Nichole Lashley 4222 Lantana Dr.

Lebanon, OH 45036

RE: Evaluation Specialist Certification Number: ES34071 Expiration Date: 8/3/2022

Dear Nichole Lashley:

This letter and enclosed certification card approves your request to be cenif1ea as an asbestos Evaluation Specialist. You must present your card upon request at anY. projectsitewhile performing duties. Copies of cards are not acceptable as proof of cert1ficat1on.

Thiscertification mar be revoked by the Director of the Ohio Environmental Protection Agency (EPA) forviolation o any of the requirements of 3745-22 or 3745-20 of the Ohio Administrative Code.

If youhave any questions, please contact the Asbestos Program at 614-644-0226 or by email at asbestoslicensinq@epa.oh1o.gov.

Sincerely, Joshua S. Koch Manager, Business Operations Support Section Ohio EPA - Division of Air Pollution Control

- State ofOh10-

Env1ronmental Protection Agency Asbestos Program

Hazard Evaluation Specialist Nichole E Lashley

Lebanon OH 45036

50 West Town Street· Suite 700 • P.O. Box 10, Certification Number ExpirationDate hio Mike DeWlne, Governor epa.ohio.!:t-----------.------.---,-----

Environmental Protection Agency

Jon Husted, Lt. Governor Laurie A. Stevenson, Director

7/6/2021

Malea Casey 10579 Thornview Drive Cincinnati, OH 45241

RE: Evaluation Specialist Certification Number: ES545334 Expiration Date: 6/30/2022

Dear Malea Casey:

This letter and enclosed certification card approves your request to be certified as an asbestos Evaluation Specialist. You must present your card upon request at anY. project site while performing duties. Copies of cards are not acceptable as proof of certIficat1on.

This certification may be revoked by the Director of the Ohio Environmental Protection Agency (EPA) for violation of any of the requirements of 3745-22 or 3745-20 of the Ohio Administrative Code.

If you have any questions, please contact the Asbestos Program at 614-644-0226 or by email at asbestoslicensinq@epa.oh1o.gov.

Sincerely, Joshua S. Koch Manager, Business Operations Support Section Ohio EPA - Division of Air Pollution Control

Environmental Protection Agency

Asbestos Hazard Evaluation Specialist Malea Casey

10579 Thornview Drive Cincinnati OH 45241

Certification Number Expiration Date 50 West Town Street • ES545334 6/30/22

DOB: 6124197

Asbestos Program

September 30, 2019

Laboratory TD: 100188 Frank Ehrenfeld Tnternational Asbestos Testing Laboratories (TATL) 9000 Commerce Parkway, Suite B.

Mt. Laurel, NJ 08054

Dear Mr. Ehrenfeld:

Congratulations! The ATHA Laboratory Accreditation Programs (ATHA-LAP), LLC's Analytical Accreditation Board (AAB) has approved Tnternational Asbestos Testing Laboratories (TATL) as an accredited Tndustrial Hygiene, Environmental Lead, and Environmental Microbiology laboratory.

Accreditation documentation includes the THLAP, ELLAP, and EMLAP accreditation certificate, scope of accreditation document and a copy of the current ATHA-LAP, LLC license agreement (if your completed agreement is not on file at ATHA-LAP, LLC). The accreditation symbol has been designed for use by all ATHA-LAP, LLC accredited laboratories. Tf your laboratory chooses to use the symbol in its advertising the laboratory's accreditation, you must complete and return the ATHA-LAP, LLC license agreement to a Laboratory Accreditation Specialist.

Once submitted, an electronic copy of the accreditation symbol will be sent to you.

Laboratory accreditation shall be maintained by continued compliance with THLAP, ELLAP, and EMLAP requirements (see Policy Modules 2B, 2C, 2D, and 6), which includes proficient participation in ATHA-LAP, LLC approved proficiency testing, demonstration of competency, or round robin program as indicated on the ATHA-LAP "Approved PT and Round Robin" webpage, its associated Scope/PT table, and as required in Policy Module 6, for all Fields of Testing (FoTs) for which the laboratory is accredited. An accredited laboratory that wishes to expand into a new FoT must submit an updated accreditation application to ATHA-LAP, LLC for review by the AAB.

Any changes in ownership, laboratory location, personnel, FoTs/Methods, or significant procedural changes shall be reported to ATHA-LAP, LLC in writing within twenty (20) business days of the change.

The accreditation certificate is the property of ATHA-LAP, LLC and must be returned to us should your laboratory withdraw or be removed from the THLAP, ELLAP, and EMLAP.

Again, congratulations. Tf you have any questions, please contact Drake McGregor, Laboratory Accreditation Specialist, at (703) 846-0739.

Sincerely, Cheryl O. Morton Managing Director

AIHA Laboratory Accreditation Programs, LLC

3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042 USA main +1 703-846-0736 fax +1 703-207-8558

Twitter: @AIHA_LAP_LLC R4 01/24/2018

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ATHA Laboratory Accreditation Programs, LLC

SCOPE OF ACCREDTTATTON

International Asbestos Testing Laboratories (IATL) Laboratory TD: 100188 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054 Tssue Date: 09/30/2019

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

Industrial Hygiene Laboratory Accreditation Program (IHLAP)

Initial Accreditation Date: 03/01/1991

IHLAP Scope Category

Field of Testing (FoT) (FoTs cover all relevant TH matrices)

Technology sub-type/ Detector

Published Reference Method/Title of In-house Method

Method Description or Analyte

(for internal methods only)

Spectrometry Core

Atomic Absorption FAA NTOSH 7082

X-ray Diffraction (XRD) NTOSH 7500

Asbestos/Fiber Microscopy Core

Polarized Light Microscopy (PLM)

EPA 600/R-93/116

Phase Contrast Microscopy (PCM)

NTOSH 7400

Transmission Electron Microscopy (TEM)

NTOSH 7402

A complete listing of currently accredited Tndustrial Hygiene laboratories is available on the ATHA-LAP, LLC website at:

http://www.aihaaccreditedlabs.org

Effective: 04/10/2015 100188_Scope_THLAP_2019_09_30

International Asbestos Testing Laboratories (IATL) 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054

Laboratory TD: 100188 Tssue Date: 09/30/2019

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

The EPA recognizes the ATHA-LAP, LLC ELLAP program as meeting the requirements of the National Lead Laboratory Accreditation Program (NLLAP) established under Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 and includes paint, soil and dust wipe analysis. Air and composited wipes analyses are not included as part of the NLLAP.

Environmental Lead Laboratory Accreditation Program (ELLAP)

Initial Accreditation Date: 01/20/1997

Field of Testing (FoT) Technology sub-type/ Detector Method Method Description

(for internal methods only)

Paint ASTM D3335-85a

Soil

EPA SW-846 3050B

EPA SW-846 7000B

Settled Dust by Wipe

EPA SW-846 3050B

EPA SW-846 7000B

Airborne Dust NTOSH 7082

A complete listing of currently accredited Environmental Lead laboratories is available on the ATHA-LAP, LLC website at:

http://www.aihaaccreditedlabs.org

Effective: 10/14/2016 Scope_ELLAP_R7

International Asbestos Testing Laboratories (IATL) 9000 Commerce Parkway, Suite B, Mt. Laurel, NJ 08054

Laboratory TD: 100188 Tssue Date: 09/30/2019

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

Environmental Microbiology Laboratory Accreditation Program (EMLAP)

Initial Accreditation Date: 12/01/2013

EMLAP Category Field of Testing (FoT) Method Method Description

(for internal methods only)

Fungal

Air - Direct Examination ASTM D7391-09

Bulk - Direct Examination ASTM D7391-09

Surface - Direct Examination ASTM D7391-09

A complete listing of currently accredited Environmental Microbiology laboratories is available on the ATHA-LAP, LLC website at: http://www.aihaaccreditedlabs.org

Effective: 03/12/2013 100188_Scope_EMLAP_2019_09_30

[;\,(n) National Voluntary 141 OF CQ«,, 'w'LSLA:'iJ: Laboratory Accreditation Program 1q8_"I"'=• ---,,' "'

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SCOPE OF ACCREDITATION TO ISO/IEC 17025:2017

International Asbestos Testing Laboratories 9000 Commerce Parkway

Suite B Mt. Laurel, NJ 08054

Mr. Frank E. Ehrenfeld lJ1 Phone: 856-231-9449 Fax: 856-231-9818

Email: frankebrenfeld@iatl.com http://www.iatl.com

ASBESTOS FIBER ANALYSIS NVLAP LAB CODE 101165-0

Bulk Asbestos Analysis

Code 18/A0I

18/A03

Description EPA•· 40 C'.FR Appendix E to Subpart E of Part 763, Interim Method of the Detennination of Asbestos in Bulk Insulation Samples

EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials

Airborne Asbestos Analysis

Code 18/A02

Description U.S. EPA's "InterimTransmission Electron Microscopy Analytical Methods-Mandatory and Nonmandatory-and Mandatory Section to Determine Completion of ResponseActions"asfound in 40 CFR, Part 763, Subpart E, Appendix A.

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C: TABLES

TABLE 1: BUILDING MATERIALS BULK SAMPLED

TABLE 2: NON-ACM

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