HAZMAT MFR.pdf

STATE OF OHIO

ADJUTANT GENERAL’S DEPARTMENT

2825 West Dublin Granville Road

Columbus, Ohio 43235-2789

NGOH-IMR-ENV 29 August 2024

MEMORANDUM FOR RECORD

SUBJECT: Summary of Environmental Hazards and Management and Disposal Requirements for

Buildings Proposed for Demolition in FY24 at Camp James A. Garfield Joint Military Training Center

(CJAG), Portage and Trumbull Counties, Ohio

1. The following is a summary of environmental hazards identified for each of the buildings proposed to be demolished as part of the FY24 demolition project at CJAG. These results are based on prior demolition activities/experience, a Hazard Assessment completed in September 2018, January 2019, and July 2019 and asbestos surveys completed in 1991 and 2024. These reports are available upon request. Results from the Hazard Assessment and surveys must be thoroughly reviewed as part of the bidding process. All environmental hazards identified must be properly abated, containerized, labeled, managed, transported, and disposed or recycled by the contractor in accordance with Federal, State, and local regulations and OHARNG requirements.

2. Note that this project will generate asbestos waste and PCB bulk product waste which are managed under the Toxic Substances Control Act (TSCA) regulations. The project will also generate hazardous waste, which is managed under the Resource Conservation and Recovery Act (RCRA) and will cause the facility (CJAG) to operate as a Large-quantity Generator (LQG). Therefore, the contractor must have RCRA training and experience with managing hazardous waste in accordance with 40 CFR Part

262 and 265.12 and show proof of training/experience. The project will also generate asbestos waste which has been painted with lead based paint above the RCRA regulatory limit for lead.

3. All waste is to be properly labeled, stored, inspected, transported, and disposed of in accordance with

Federal, State, and local regulations and OHARNG requirements. All waste is to be containerized at the time the waste is generated. All waste containers must be inspected weekly using the OHARNG

Weekly Non-Hazardous & Hazardous Waste Inspection/Inventory Sheet. The following waste streams generated from OHARNG projects are to be managed as outlined below:

a. Asbestos-Containing Material (ACM) and asbestos waste will be managed in accordance with TSCA regulations and other applicable State and local regulations. Only licensed contractors approved and licensed through the Ohio EPA are permitted to conduct work at

CJAG.

b. Lead Painted Building Components with Toxicity Characteristic Leachate Procedure

(TCLP) results above 5 parts per million (ppm) will be managed as a D008 hazardous waste in accordance with RCRA regulations. RCRA waste is required to be transported and disposed of at a Defense Logistics Agency (DLA), Defense and Reutilization Organization

(DRMO) qualified transporter and facility. All painted metal must be recycled with the exception of metal painted with PCB paint. PCB-painted building components must be managed in accordance with TSCA regulations.

c. Metal is to be salvaged and sent to an appropriate recycling facility.

d. Fluorescent Bulbs will be managed as Universal Waste in accordance with Ohio

Administrative Code 3745-273 and the Ohio Environmental Protection Agency’s guidance document titled Managing Fluorescent Lamps.

e. Capacitors/ballasts which contain PCBs will be managed in accordance with TSCA regulations. Capacitors/ballasts labeled as “No PCBs” must be recycled.

f. Mercury-containing equipment/thermostats must be managed as Universal Waste in accordance with OAC 3745-273.

4. Water was identified in the basement and/or sumps of several buildings to be demolished as part of this project. Water must be managed and disposed of in accordance with this Memorandum for Record

(MFR).

The following is a summary of the environmental hazards for each building to be demolished:

1. Group 8 Area - Building 63-836 (25,208 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building 63-836 was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and found to contain the following ACMs: gasket, tar duct wrap (approximately 25 SF), tar felt

(approximately 692 SF), galbestos wall panel (approximately 8,864 SF), transite board (approximately

8,864 SF), roofing (25,200 SF), caulking. ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements. A tin clad fire door is located in the center of the building. During a prior demolition project at another Group 8 building (similar construction), the door was peeled open to check for asbestos and found to be solid wood. The contractor must verify if the fire door is solid wood or asbestos-containing prior to demolition and transport and dispose of it properly in accordance with local, State and Federal regulations.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces within the Group 8 buildings were sampled as part of prior building demolition activities and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood man and garage doors, wood fascia (not visible as the painted wood fascia is wrapped/covered). These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements. No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents: The contractor will be responsible to properly remove, transport, and dispose of any contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were observed.

These must be properly removed, containerized, labeled, inspected, transported and disposed in accordance with Federal, State, and local regulations.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported and disposed in accordance with local, State, and Federal regulations.

2. Group 8 Area - Building 63-837 (25,208 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building 63-837 was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and found to contain the following ACMs: gasket, tar duct wrap (approximately 25 LF), tar felt

(approximately 692 SF), galbestos wall panel (approximately 8,864 SF), transite board (approximately

8,864 SF), roofing (25,200 SF), caulking. ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements. A tin clad fire door is located in the center of the building. During a prior demolition project at another Group 8 building (similar construction), the door was peeled open to check for asbestos and found to be solid wood. The contractor must verify if the fire door is solid wood or asbestos-containing and properly transport and dispose of it in accordance with local, State and Federal regulations.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces within the Group 8 buildings were sampled as part of prior building demolition activities and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood man and garage doors, wood fascia (not visible as the painted wood fascia is wrapped/covered). These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements. No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents: The contractor will be responsible to properly remove, transport, and dispose of any contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were observed.

These must be properly removed, containerized, labeled, inspected, transported, and disposed in accordance with Federal, State, and local regulations.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with local, State and Federal regulations.

3. Group 8 Area - Building 63-850 (25,208 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Note this building is covered in a foam encapsulant. Building 63-850 was surveyed for asbestos-containing materials as part of a 1991 Asbestos Survey and found to contain the following

ACMs: gasket, tar duct wrap (approximately 25 LF), tar felt (approximately 692 SF), galbestos wall panel (approximately 8,864 SF – assumed to be under encapsulant), transite board (approximately 8,864

SF), roofing (25,200 SF), wiring (approximately 16 LF). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements. A tin clad fire door is located in the center of the building. During a prior demolition project at another Group 8 building (similar construction), the door was peeled open to check for asbestos and found to be solid wood. The contractor must verify if the fire door is solid wood or asbestos-containing and properly transport and dispose of it in accordance with local, State and Federal regulations.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces within the Group 8 buildings were sampled as part of prior building demolition activities and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood man and garage doors, wood fascia (not visible as the painted wood fascia is wrapped/covered). These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements. No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents: The contractor will be responsible to properly remove, transport, and dispose of any contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were observed.

These must be properly removed, containerized, labeled, inspected, transported, and disposed in accordance with Federal, State, and local regulations.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported and disposed in accordance with local, State, and Federal regulations.

4. Building 855 – Scale House (63 SF) and Scale:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building 855 was surveyed for asbestos-containing materials twice, once as part of a 1991

Asbestos Survey and again in 2024. The 1991 Asbestos Survey found the following ACMs: transite

(approximately 15 SF on east wall). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces of Building 855 were sampled in 2024 and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood door, wood siding, interior painted trim, interior painted wood and interior painted drywall. These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements.

PCBs were detected in the paint but were below regulatory limits.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. Therefore, all painted metal must be recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor will be responsible to properly remove, transport, and dispose of any contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were not observed in the building.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with local, State and Federal regulations.

-Painted Asbestos-Containing Materials - Painted building components at CJAG have historically been found to contain lead. Painted surfaces of Building 855 were sampled in 2024, specifically approximately 15 square feet of transite was painted and found to be above the regulatory limit for

TCLP Lead (5.0 ppm): This painted building components must be abated, containerized, labeled, inspected and disposed of as a mixed RCRA and TSCA waste. The waste must be transported and disposed of at a DLA DRMO approved transporter/facility.

5. George Road Treatment Plant - Building SD21 – Comminutor Building (850 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building SD21 was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and a September 2018 Hazard Assessment and found to contain the following ACMs: roofing

(approximately 850 SF), window glazing, and wire insulation (approximately 2 LF). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State, and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components were sampled during a September 2018 Hazard

Assessment. White-painted metal duct work was found to be above the regulatory limit for TCLP Lead

(5.0 ppm). State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. Lead paint was identified on metal building components during the survey. Non-PCB containing painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste. White-painted metal doors were sampled and found to be above the regulatory limit for PCBs

(50 ppm) (PCB sample result = 89 ppm, Total Lead result = 88 ppm). These must be properly removed before demolition and disposed as a PCB bulk product waste in accordance with Federal, State, and local regulations and OHARNG requirements. For PCB bulk product waste, the contractor must send a 15-day notification to the disposal facility prior to disposal in accordance with TSCA. Floor sweep was sampled and is nonhazardous.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with Federal, State, and local regulations.

-Basement or Sump Water: Water was identified and sampled in 2024. This water was determined to be below TSCA regulatory limits but is above the Maximum Contaminant Level for PCBs in drinking water. Therefore, the contractor must properly remove, containerize, transport and dispose of this water at a disposal facility off site as non-hazardous waste.

6. George Road Treatment Plant - Building SD21K (Chlorinator Building/Contact Tank):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building SD21K was surveyed for asbestos-containing materials as part of a September 2018

Hazard Assessment. No asbestos-containing materials were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components were sampled during a September 2018 Hazard

Assessment. Green-painted metal doors were found to be above the regulatory limit for TCLP Lead

(5.0 ppm). State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste. Floor sweep was sampled and found to be nonhazardous.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported and disposed in accordance with Federal, State, and local regulations.

7. George Road Treatment Plant - Building DM055 (Pump House):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building DM055 was surveyed for asbestos-containing materials as part of a September 2018

Hazard Assessment and the following ACMs were identified: roofing (approximately 110 SF) and window glazing (approximately 6 SF – assumed positive). ACMs must be properly abated, containerized, labeled, inspected, transported and disposed in a licensed asbestos landfill in accordance with Federal, State, and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components and floor sweep were sampled during a September 2018

Hazard Assessment. No building components or floor sweep were identified to contain Lead or PCBs above regulatory limits. State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint.

All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with Federal, State, and local regulations.

-Basement or Sump Water: Water was identified and sampled in 2024. This water was determined to be below TSCA regulatory limits but is above the Maximum Contaminant Level for PCBs in drinking water. The contractor must properly remove, containerize, transport and dispose of this water at a disposal facility off site as non-hazardous waste.

8. Sand Creek Treatment Plant - Building SD01 (562 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building SD01 was surveyed for asbestos-containing materials as part of a September 2018

Hazard Assessment and the following ACM was identified: roofing (approximately 500 SF). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State, and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components and floor sweep were sampled during a September 2018

Hazard Assessment. Yellow-painted metal rails were identified as having a lead result above the regulatory limit (5.0 ppm). No PCBs were identified above the regulatory limit. State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with Federal, State, and local regulations.

-Basement or Sump Water: Water was identified and sampled in 2024. This water was determined to be below TSCA regulatory limits but is above the Maximum Contaminant Level for PCBs in drinking water. The contractor must properly remove, containerize, transport and dispose of this water at a disposal facility off site as non-hazardous waste.

9. Sand Creek Treatment Plant - Building SD01A (176 SF):

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building SD01A was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and a September 2018 Hazard Assessment and the following ACMs were identified: roofing

(approximately 200 SF), wire insulation (approximately 2 LF), window glazing (approximately 6 SF).

ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State, and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components and floor sweep were sampled during a September 2018

Hazard Assessment. No Lead or PCB results were above regulatory limits. State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with Federal, State, and local regulations.

-Basement or Sump Water: Water was identified and sampled in 2024. This water was determined to be below TSCA regulatory limits but is above the Maximum Contaminant Level for PCBs in drinking water. The contractor must properly remove, containerize, transport and dispose of this water at a disposal facility off site as non-hazardous waste.

10. Sand Creek Treatment Plant - Building SD01L:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building SD01L was surveyed for asbestos-containing materials as part of a September 2018

Hazard Assessment. No asbestos-containing materials were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted components and floor sweep were sampled during a September 2018

Hazard Assessment. Lead was identified above the regulatory limit on green metal doors/frames. State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste. No

PCB results were above regulatory limits.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported, and disposed in accordance with Federal, State, and local regulations.

11. Block E Earth-covered Magazines – GE001:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Earth-covered magazines were comprehensively surveyed for asbestos in a Hazard

Assessment dated January 2019. Several magazines from each block were surveyed and results were associated to other structures in those blocks as construction of earth-covered magazines was completed at the same time using standard construction plans. No asbestos-containing materials were identified.

GE001 is a black powder magazine and is of a different construction type but built during the same timeframe. A visual inspection was completed for suspect ACM and none were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. PCBs (in paint) were sampled as part of a previous magazine demolition projects. No PCBs above regulatory limits were identified. Lead was identified above the regulatory limit as part of previous sampling for demolition projects on green metal doors/frames. State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

12. Block E Earth-covered Magazines – GE002:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Earth-covered magazines were comprehensively surveyed for asbestos in a Hazard

Assessment dated January 2019. Several magazines from each block were surveyed and results were associated to other structures in those blocks as construction of earth-covered magazines was completed at the same time using standard construction plans. No asbestos-containing materials were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. PCBs (in paint) were sampled as part of a previous demolition project of earth-covered magazines. No PCBs above regulatory limits were identified. Lead was identified above the regulatory limit as part of previous sampling for demolition projects on green metal doors/frames.

State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

13. Block E Earth-covered Magazines – GE003:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Earth-covered magazines were comprehensively surveyed for asbestos in a Hazard

Assessment dated January 2019. Several magazines from each block were surveyed and results were associated to other structures in those blocks as construction of earth-covered magazines was completed at the same time using standard construction plans. No asbestos-containing materials were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. PCBs (in paint) were sampled as part of a previous demolition project of earth-covered magazines. No PCBs above regulatory limits were identified. Lead was identified above the regulatory limit as part of previous sampling for demolition projects on green metal doors/frames.

State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

14. Group 1 Earth-covered Magazines – B0002:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Earth-covered magazines were comprehensively surveyed for asbestos in a Hazard

Assessment dated January 2019. Several magazines from each block were surveyed and results were associated to other structures in those blocks as construction of earth-covered magazines was completed at the same time using standard construction plans. No asbestos-containing materials were identified.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. PCBs (in paint) were sampled as part of a previous demolition project of earth-covered magazines. No PCBs above regulatory limits were identified. Lead was identified above the regulatory limit as part of previous sampling for demolition projects on green metal doors/frames.

State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

15. Building 71-848:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Note half of this building burned down in a fire and is no longer present. Building 71-848 was surveyed for asbestos-containing materials as part of a 1991 Asbestos Survey and found to contain the following ACMs: galbestos wall panel (approximately 3,810 SF), transite board (approximately 3,810

SF), roofing (12,600 SF), caulking, stored corrugated asbestos panels (approximately 100 SF). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces within the Group 8 buildings were sampled as part of prior building demolition activities and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood man and garage doors, wood fascia (not visible as the painted wood fascia is wrapped/covered). These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements. No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents: The contractor will be responsible to properly remove, transport, and dispose of any contents in the building in accordance with applicable local, State and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were observed.

These must be properly removed, containerized, labeled, inspected, transported, and disposed in accordance with Federal, State, and local regulations.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported and disposed in accordance with local, State, and Federal regulations.

16. Building 71-849:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building 71-849 was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and found to contain the following ACMs: tape/joint compound (approximately 204 SF), beige

12x12 floor tile (approximately 36 SF), galbestos wall panel (approximately 8,864 SF), transite board

(approximately 8.864 SF), roofing (25,200 SF), caulking, window glazing (approximately 350 SF), fire door, fibrous rope gasket (approximately 12 SF per explosion proof light fixture). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces within the Group 8 buildings were sampled as part of a July

2019 Hazard Assessment and prior building demolition activities and the following materials were found to be above the regulatory limit for TCLP Lead (5.0 ppm): All exterior wood trim, wood man and garage doors, wood fascia (not visible as the painted wood fascia is wrapped/covered). These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements.

No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: Fluorescent bulbs and ballasts/capacitors were observed.

These must be properly removed, containerized, labeled, inspected, transported, and disposed in accordance with Federal, State, and local regulations.

-Mercury-containing equipment/thermostats: Mercury-containing thermostats/switches were observed in the building. All mercury-containing equipment must be properly removed, containerized, transported and disposed in accordance with local, State, and Federal regulations.

17. Building T2502:

-Asbestos-Containing Materials (ACM): Buildings at CJAG have historically been found to contain asbestos. Building T2502 was surveyed for asbestos-containing materials as part of a 1991 Asbestos

Survey and a September 2018 Hazard Assessment and found to contain the following ACMs: tan/beige linoleum (approximately 200 SF), transite siding and vapor barrier (approximately 2000 SF), galbestos roofing (approximately 203 SF), door caulking (approximately 21 LF), window glazing (approximately

50 SF). ACMs must be properly abated, containerized, labeled, inspected, transported, and disposed in a licensed asbestos landfill in accordance with Federal, State and local regulations and OHARNG requirements.

-Painted building components: Painted building components at CJAG have historically been found to contain lead and/or PCBs. Painted surfaces were sampled as part of a September 2018 Hazard

Assessment and the following materials were found to be above the regulatory limit for TCLP Lead

(5.0 ppm): all exterior wood trim. These painted building components must be removed before demolition and managed as a separate waste stream. They must be removed, containerized, labeled, inspected, transported and disposed of as hazardous waste in accordance with Federal, State, and local regulations and OHARNG requirements. No PCBs above the regulatory limit were identified.

-Metal: State of Ohio regulations indicate that if the demolition debris is some form of metal, such as steel structural components, lead pipes, or electrical components, they may be recycled as scrap metal without regulation under the hazardous waste rules, even if coated with lead-based paint. All painted metal must be removed prior to demolition and recycled as scrap metal to avoid disposal as hazardous waste.

-Building contents - The contractor must properly remove, transport, and dispose of any remaining contents in the building in accordance with applicable local, State, and Federal regulations.

-Fluorescent lights bulbs, ballasts, capacitors: No fluorescent bulbs or ballasts/capacitors were observed.

-Mercury-containing equipment/thermostats: No mercury-containing thermostats/switches were observed in the building.

This Memorandum for Record was prepared by Ms. Kathryn S. Tait, OHARNG Environmental Specialist

3. Ms. Tait can be contacted at (614)336-6136 or kathryn.s.tait.nfg@army.mil.

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KATHRYN S. TAIT

OHARNG Environmental Specialist 3 mailto:kathryn.s.tait.nfg@mail.mil