Houston_ACM Survey_Final_10.10.2018.pdf

AHERA ASBESTOS SURVEY REPORT

HOUSTON NATIONAL CEMETERY

BUILDINGS 2501 AND 3006

1621 ALDINE WESTERN ROAD

HOUSTON, TEXAS 77039

VACANT BUILDINGS DUE DILIGENCE

ZONE 1

DEPARTMENT OF VETERANS AFFAIRS

PREPARED BY:

TTL ASSOCIATES, INC.

1915 NORTH 12th STREET

TOLEDO, OHIO 43604

(419) 324-2222

(419) 241-1808 FAX

October 2018

Department of Veterans Affairs October 2018 TTL Project No. 1637601 Page i

October 5, 2018 TTL Project No. 1637601

AHERA Inspection Report Houston National Cemetery

Buildings 2501 and 3006 1621 Aldine Western Road

Houston, TX 77039

TTL Associates, Inc. (TTL), a Service-Disabled Veteran-Owned Small Business (SDVOSB), under contract to Concourse Federal Group (Concourse), performed non-destructive United States Environmental Protection Agency (U.S. EPA) Asbestos Hazard Emergency Response Act (AHERA) surveys at the Houston National Cemetery, on April 18, 2018. The AHERA surveys were conducted for two specific Houston NCA buildings – Buildings 2501 and 3006 - and the full AHERA survey report is enclosed. As documented in the report and based on the asbestos sampling results, asbestos containing material (ACM) was identified in both buildings (i.e., 2501, 3006). TTL’s estimated asbestos abatement costs for the buildings are as follows:

NCA Building Abatement Cost 2501 $13,736.00 3006 $1,554.20

Additional survey activities are required by the U.S. EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) regulations. A survey to thoroughly inspect each of the buildings should be conducted to identify materials that were potentially hidden or inaccessible during the AHERA asbestos inspection. The U.S. EPA NESHAP asbestos regulations (40CFR Part 61, Subpart M) require the removal of all regulated asbestos-containing materials (RACM) from a facility being demolished or renovated prior to beginning any activity that might damage or disturb the material.

TTL appreciates the opportunity to provide Concourse, the VA Office of Asset Enterprise Management (OAEM) and the Houston NCA with our environmental consulting and testing services and we look forward to working with you in the future. Should you have any questions concerning this report, please contact Ms. Sara Vogelpohl at (419) 214-5090.

Sincerely, TTL Associates, Inc.

Sara Vogelpohl, CIH Veronica Allen, P.E., PMP Manager, Asbestos and Hazardous Materials Services Manager, Federal Services

Attachments

TTL Project No. 1637601 Page i

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

2.0 ASBESTOS SURVEY RESULTS

2.1 Project Purpose and Objective

2.2 Inspection

2.3 Inspection Results

3.0 CONCLUSIONS/RECOMMENDATIONS

4.0 LIMITATIONS

5.0 ATTACHMENTS

ATTACHMENTS

ATTACHMENT A: Asbestos Inspector Certification ATTACHMENT B AHERA Asbestos Survey Summary Tables ATTACHMENT C: Asbestos Analytical Reports ATTACHMENT D: Photo Log of ACM ATTACHMENT E: Cost Estimates for Asbestos Abatement

TTL Project No. 1637601 Page 1

1.0 EXECUTIVE SUMMARY

TTL Associates, Inc. (TTL) conducted non-destructive United States Environmental Protection Agency (U.S.

EPA) Asbestos Hazard Emergency Response Act (AHERA) surveys on April 18, 2018, at the Houston National Cemetery, located at 2002 Holcombe Boulevard in Houston, Texas. As directed by Concourse and VA’s Office of Asset Enterprise Management (OAEM), the AHERA survey was conducted for two specific NCA buildings – Buildings 2501 and 3006.

This survey was non-destructive and was conducted in accessible areas only. The surveys thus did not identify materials hidden inside walls or above hard ceilings, in accordance with the AHERA regulation.

Suspected asbestos containing materials (ACM) were identified in both buildings (i.e., 2501, 3006).

In the two buildings where suspect ACM was identified (i.e., 2501, 3006), a total of eight homogenous sampling areas (HSA) were identified, from which a total from which a total of fourteen samples were collected and twenty sample layers analyzed.

The following tables list the identified or assumed ACM and the condition of the material according to AHERA Regulations.

Building 2501

HSA

Number Material Description Condition

(as defined in AHERA Regulations) Quantity

HSA 01 Vinyl Sheet Flooring 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 200 SF

HSA 02 Drywall and Joint Compound 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 3700 SF

HSA 03 Vinyl Sheet Flooring 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 75 SF

HSA 04 Transite Siding Shingles 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 1500 SF

SF = square feet ACBM = asbestos containing building material

Building 3006

(as defined in AHERA Regulations)

Quantity

HSA 01 Transite Siding Shingles 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 380 SF

SF = square feet ACBM = asbestos containing building material

For each building where ACM is identified, AHERA regulations require an operations and maintenance (O&M) plan. The O&M plan must be written and implemented, and include employee training and material surveillance. The following two NCA buildings require an O&M plan:

TTL Project No. 1637601 Page 2

• Building 2501 and

• Building 3006

The VA proposed disposition of two NCA buildings (i.e. 2501, 3006) is demolition and reuse, respectively.

If the disposition is demolition or renovation, additional inspection activities are required by the U.S.

EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) regulations. The U.S. EPA NESHAP asbestos regulations (40 CFR Part 61, Subpart M) require the removal of all regulated asbestos-containing materials (RACM) from a facility being demolished or renovated prior to beginning any activity that might damage or disturb the material.

The estimated asbestos abatement cost for each of the two NCA buildings containing ACM is as follows:

NCA Building Abatement Cost 2501 $13,736.00 3006 $1,554.20

TTL Project No. 1637601 Page 3

2.0 ASBESTOS SURVEY RESULTS

OAEM seeks to determine disposal methods and reuse alternatives for certain VA vacant buildings inventory through a Vacant Buildings Reduction Initiative. VA requires due diligence support services involving the preparation of reports related to the environmental conditions of the buildings. As part of the due diligence activities, TTL has conducted this AHERA survey for two specific NCA buildings (i.e. 2501, 3006).

The purpose of the AHERA regulation is to protect building occupants and custodial and maintenance personnel from exposure to asbestos by visually inspecting buildings for friable and non-friable materials and to sample such materials to determine asbestos content. The U.S. EPA defines ACM as a material that contains greater than one-percent (1%) asbestos by visual estimation or weight.

The surveys were non-destructive and conducted in accessible areas only. The surveys thus did not identify materials hidden inside walls or above hard ceilings, in accordance with the AHERA regulation.

At the NCA, the proposed disposition of each building surveyed is as follows:

• Building 2501: Demolition

• Building 3006: Undetermined

A description of the two buildings is as follows:

Building No.

Building Use Building Size (square feet) Description

2501 Residential Structure 1,237 One-story vacant residential structure

3006 Agricultural Shed 320 One-story shed

2.1 Project Purpose and Objective

The objective of this project was to collect the environmental due diligence data necessary to support the VA’s Vacant Buildings Reduction Initiative.

TTL conducted the surveys in accessible areas of the interior areas of the site buildings to determine the presence of ACM. The asbestos survey included the identification of suspect materials and the definition of HSA, assessment of the condition of each material, estimation of approximate quantity of the suspect ACM, and collection and analysis of bulk samples from each identified HSA. An HSA is defined as a material that exhibited similar physical characteristics (e.g., texture, surface color, and appearance) and was applied or installed at the same time (if known) as observed by the inspector utilizing professional judgment and experience.

Suspect ACM samples were collected using a coring device or other means, as appropriate to collect a cross section of the suspect material. The samples were placed into clean and unused sealable bags marked with unique sample identification numbers. The samples of suspect ACM were transported to EMSL Analytical, Inc. (EMSL) for analysis by polarized light microscopy (PLM), in accordance with U.S. EPA Method 600/R-93/116 and National Voluntary Laboratory Accreditation Program (NVLAP) guidelines. The

TTL Project No. 1637601 Page 4

EPA/600/R-93/116 “Method for the Determination of Asbestos in Bulk Building Materials” requires that all multiple, distinct layers must be analyzed individually. Sample analysis results are provided for each distinct layer of each sample submitted to EMSL’s laboratory. EMSL is accredited by the NVLAP, which is administered by the National Institute of Standards and Technology (NIST). The laboratory accreditation number is included in the attached analytical report.

2.2 Inspection

The AHERA survey was completed by an Asbestos Inspector certified by the Texas Department of State Health Service. Mr. Jeffrey Lanan (Certificate number 105724) conducted non-destructive AHERA survey of the accessible interior areas of the buildings (i.e. 2501, 3006). A copy of Mr. Lanan’s State of Texas certification is included in Attachment A.

2.3 Inspection Results

Suspect ACM were identified for the two NCA buildings (i.e., 2501, 3006). A total of eight HSA were identified in accessible areas of Buildings 2501 and 3006, from which a total of fourteen samples were collected and twenty sample layers analyzed.

The following materials were identified as ACM as defined by the U.S. EPA:

(as defined in AHERA Regulations) Quantity

HSA 01 Vinyl Sheet Flooring 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 200 SF

HSA 02 Drywall and Joint Compound 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 3700 SF

HSA 03 Vinyl Sheet Flooring 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 75 SF

HSA 04 Transite Siding Shingles 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 1500 SF

SF = square feet ACBM = asbestos containing building material

Building 3006

(as defined in AHERA Regulations)

Quantity

HSA 01 Transite Siding Shingles 7: ACBM any remaining Friable ACBM or Friable Suspected ACBM 380 SF

SF = square feet ACBM = asbestos containing building material

Attachment B contains the AHERA Asbestos Summary Tables that list the materials identified and the laboratory analytical results. Attachment C contains copies of the laboratory analytical reports while Attachment D contains a photo log of identified ACM.

TTL Project No. 1637601 Page 5

3.0 CONCLUSIONS/RECOMMENDATIONS

ACM was identified in two NCA buildings (i.e., 2501, 3006).

For both of these NCA buildings, AHERA regulations require an ACM O&M plan. The ACM O&M plan must be written and implemented, and include employee training and material surveillance. The following two NCA buildings require an ACM O&M plan:

• Building 2501, and

• Building 3006.

The VA proposed disposition of these two NCA buildings (i.e., 2501, 3006) is demolition. If the disposition is demolition or renovation, additional inspection activities are required by the U.S. EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) regulations. The U.S. EPA NESHAP asbestos regulations require the removal of all regulated asbestos-containing materials (RACM) from a facility being demolished or renovated prior to beginning any activity that might damage or disturb the material.

The estimated asbestos abatement costs for each of the NCA buildings containing ACM are as follows:

NCA Building Abatement Cost 2501 $13,736.00 3006 $1,554.20

A budgetary cost estimate, including a detailed price breakdown, for asbestos abatement for each building is located in Attachment E. TTL utilized the 2018 RS Mean values to determine the cost estimate.

TTL Project No. 1637601 Page 6

4.0 LIMITATIONS

TTL has made reasonable efforts to identify and quantify suspect ACM based upon the standard of care in the environmental industry existing at the time of the survey. This survey only summarizes the potential presence and estimated quantities of visually observed ACM in accessible areas. ACM inside walls, above hard ceilings, etc. was not inspected during this survey. Exterior areas are outside the scope of AHERA surveys.

If a given material is not described in this survey or cannot be identified as a non-suspect material, the material should be assumed to contain asbestos until sampling and analysis can be accomplished. If demolition is implemented, or renovation is planned, additional survey activities are required by the U.S.

EPA NESHAP regulations.

The information contained in this report was based upon specific parameters and regulations in force at the time of the survey. TTL accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, nor does this report represent an instrument of regulatory compliance or an asbestos abatement specification.

TTL Project No. 1637601 Page 7

5.0 ATTACHMENTS

See attached Appendices to reference the following:

• ATTACHMENT A: Asbestos Inspector Certification

• ATTACHMENT B: AHERA Asbestos Survey Summary Tables

• ATTACHMENT C: Asbestos Analytical Reports

• ATTACHMENT D: Photo Log of ACM

• ATTACHMENT E: Cost Estimates for Asbestos Abatement

ATTACHMENT A

ASBESTOS INSPECTOR CERTIFICATION

ATTACHMENT B

AHERA ASBESTOS SURVEY SUMMARY TABLES

Homogeneous Sampling Areas

Houston National Cemetery 1621 Aldine Western Road

Houston, Texas

TTL Project No. 16170.02 1 of 1

HSA # Material Description Friability Functional Area Quantity Units Sample Number Sample Results Condition 01 Vinyl Sheet Flooring NF Kitchen 200 SF 01-01, 02, 03 Positive 7

Total 200 SF

02 Drywall & Joint Compound NF Walls and Ceiling, Throughout 3,700 SF 02-01, 02, 03 Positive 7

Total 3,700 SF

03 Vinyl Sheet Flooring NF Bathroom 75 SF 03-01, 02, 03 Positive 7

Total 75 SF

04 Transite Siding Shingles NF Exterior 1,500 SF 04-01 Positive 7

Total 1,500 SF

05 Siding Felt NF Exterior, Beneath Siding 1,500 SF 05-01 Negative 7

Total 1,500 SF

06 Window Caulk NF Exterior Windows 13 Each 06-01 Negative 7

Total 13 Each

AHERA Condition 1-Damaged or Significatly Damaged TSI 2-Damaged Friable Surfacing 3-Significantly Damaged Firable Surfacing 4-Damaged or Significantly Damaged Friable Miscallaneous ACMB 5-ACBM with Potential for Damage 6-ACBM with Potential for Significatly Damage 7-Any Remaining Friable ACBM for Friable Suspect ACBM

Homogeneous Sampling Areas Building 3006 - Storage Shed Houston National Cemetery 1621 Aldine Western Road

Houston, Texas

TTL Project No. 16170.02 1 of 1

HSA # Material Description Friability Functional Area Quantity Units Sample Number Sample Results Condition

01 Transite Siding Shingles NF Exterior 380 SF 01-01 Positive 7

Total 380

02 Window Caulk NF Exterior Window 1 each 02-01 Negative 7

Total 1

AHERA Condition 1 Damaged or significantly damaged thermal system insulation ACM 2 Damaged friable surfacing ACM 3 Signifcantly damaged friable surfacing ACM 4 Damaged or significantly damaged friable miscellaneous ACM 5 ACBM with potential for damage 6 ACBM with potential for significant damage 7 Any remaining friable ACBM or friable suspect ACBM

ATTACHMENT C

ASBESTOS ANALYTICAL REPORTS

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041814410EMSL Order:

Customer ID: TTL63

Customer PO: 012520

Project ID:

Attention: Phone:Sara Vogelpohl (419) 698-6397

Fax:TTL Associates, Inc. (419) 321-6252

Received Date:1915 North 12th Street 05/14/2018 9:10 AM

Analysis Date:Toledo, OH 43604 05/15/2018

Collected Date: 04/18/2018

Project: 1637606 / Dept. of Veterans Affairs / Houston, TX

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

01-01

041814410-0001

15% ChrysotileNon-fibrous (Other)85%Gray

Fibrous

Homogeneous

Houston - Shed

02-01

041814410-0002

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Houston - Shed

Analyst(s)

Daniel Fricker (2) Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial report from: 05/15/2018 11:43:38

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 5/15/2018 11:43 AM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041814462EMSL Order:

Customer ID: TTL63

Customer PO: 012520

Project ID:

Attention: Phone:Sara Vogelpohl (419) 698-6397

Fax:TTL Associates, Inc. (419) 321-6252

Received Date:1915 North 12th Street 05/14/2018 9:10 AM

Analysis Date:Toledo, OH 43604 05/15/2018 - 05/16/2018

Collected Date: 04/18/2018

Project: 16376.06 / Dept of Veterans Affairs, Houston, TX

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

01-01

041814462-0001

8% ChrysotileNon-fibrous (Other)67%Cellulose

Glass

15%

10%

White

Fibrous

Homogeneous

Houston - Building

01-02

041814462-0002

10% ChrysotileNon-fibrous (Other)80%Cellulose10%White

Fibrous

Homogeneous

Houston - Building

01-03

041814462-0003

10% ChrysotileNon-fibrous (Other)65%Cellulose

Glass

15%

10%

White

Fibrous

Homogeneous

Houston - Building

02-01-Drywall

041814462-0004

None DetectedNon-fibrous (Other)85%Cellulose15%White

Fibrous

Homogeneous

Houston - Building

02-01-Joint Compound

041814462-0004A

2% ChrysotileNon-fibrous (Other)98%White

Non-Fibrous

Homogeneous

Houston - Building

02-02-Drywall

041814462-0005

None DetectedNon-fibrous (Other)85%Cellulose15%White

Fibrous

Homogeneous

Houston - Building

02-02-Joint Compound

041814462-0005A

2% ChrysotileNon-fibrous (Other)98%White

Non-Fibrous

Homogeneous

Houston - Building

02-03-Drywall

041814462-0006

None DetectedNon-fibrous (Other)85%Cellulose15%White

Fibrous

Homogeneous

Houston - Building

02-03-Joint Compound

041814462-0006A

2% ChrysotileNon-fibrous (Other)98%White

Non-Fibrous

Homogeneous

Houston - Building

03-01-Sheet Flooring

041814462-0007

12% ChrysotileNon-fibrous (Other)78%Cellulose10%Tan

Fibrous

Homogeneous

Houston - Building

03-01-Mastic

041814462-0007A

<1% ChrysotileNon-fibrous (Other)100%Brown

Non-Fibrous

Homogeneous

Houston - Building

Possible contamination from sheet flooring

03-02-Sheet Flooring

041814462-0008

10% ChrysotileNon-fibrous (Other)80%Cellulose10%Tan

Fibrous

Homogeneous

Houston - Building

03-02-Mastic

041814462-0008A

<1% ChrysotileNon-fibrous (Other)100%Brown

Non-Fibrous

Homogeneous

Houston - Building

Possible contamination from sheet flooring

03-03-Sheet Flooring

041814462-0009

10% ChrysotileNon-fibrous (Other)80%Cellulose10%Tan

Fibrous

Homogeneous

Houston - Building

03-03-Mastic

041814462-0009A

<1% ChrysotileNon-fibrous (Other)100%Brown

Non-Fibrous

Homogeneous

Houston - Building

Possible contamination from sheet flooring

Initial report from: 05/16/2018 06:42:51

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 5/16/2018 6:42 AM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041814462EMSL Order:

Customer ID: TTL63

Customer PO: 012520

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

04-01

041814462-0010

15% ChrysotileNon-fibrous (Other)85%Gray

Fibrous

Homogeneous

Houston - Building

05-01

041814462-0011

None DetectedNon-fibrous (Other)50%Cellulose50%Black

Fibrous

Homogeneous

Houston - Building

06-01

041814462-0012

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Houston - Building

Analyst(s)

Gregory Barry (10)

Nancy Stalter (8)

Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial report from: 05/16/2018 06:42:51

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 5/16/2018 6:42 AM

ATTACHMENT D

PHOTO LOG OF ACM

Houston National Cemetery, Houston, Texas June 2018 TTL Project No. 1637601 Page 1

Photo No. 1: Drywall and Joint Compound (HSA 02)

Photo No. 2: Vinyl Sheet Flooring (HSA 01)

Houston National Cemetery, Houston, Texas June 2018 TTL Project No. 1637601 Page 2

Photo No. 3: Transite Siding Shingles (HSA 04)

Building 1370

Photo No. 4: Transite Siding Shingles (HSA 01)

ATTACHMENT E

COST ESTIMATES FOR ASBESTOS ABATEMENT

Building 2501 Quantity Units Rate Estimate

Vinyl Sheet Flooring 200 SF 2.48$ 496.00$ Drywall and Joint Compound 3,700 SF 1.87$ 6,919.00$ Vinyl Sheet Flooring 75 SF 2.48$ 186.00$ Transite Siding Shingles 1,500 SF 4.09$ 6,135.00$

Total 13,736.00$

Building 3006 Quantity Units Rate Estimate

Transite Siding Shingles 380 SF 4.09$ 1,554.20$ Total 1,554.20$

SF = Square Feet

Cost estimate based on 2018 RS Means values

COST ESTIMATES FOR ASBESTOS ABATEMENT