S06-asbestos survey.pdf

Citadel Environmental Services, Inc. 400 North Tustin Ave., Suite 340, Santa Ana, CA 92705

Tel: (714) 547-4301 Fax: (714) 547-4647 www.citadelenvironmental.com

April 22, 2011

Chae Kim Asbestos Program Manager

VA SAN DIEGO MEDICAL CENTER

ENVIRONMENT, HEALTH & SAFETY

3350 La Jolla Village Drive San Diego, California 92161

Re: CITADEL Project No. 5137.1032.0 AHERA Re-Inspection Report VA San Diego Medical Center

Buildings #1, #2 3350 La Jolla Village Drive

San Diego, California 92161

Dear Mr. Kim:

Enclosed please find two (2) copies of Citadel Environmental Services, Inc.'s AHERA Re-Inspection Report for the above-referenced locations.

The inspection was conducted for Veterans Administration San Diego Healthcare System (VASDHS) in accordance with Citadel’s Proposal 5137.1032.P, dated August 26, 2010, and a mutually agreed upon scope of work.

If after your review you have any questions or require additional information, please do not hesitate to telephone me at (714) 547-4301.

Sincerely, CITADEL ENVIRONMENTAL SERVICES, INC.

Michelle Campbell Certified Asbestos Consultant Director, Building Sciences & Industrial Hygiene

Enclosure

Michelle Campbell

Digitally signed by Michelle Campbell DN: cn=Michelle Campbell, o=Citadel Environmental Services, Inc., ou, email=mcampbell@citadelenvironme ntal.com, c=US Date: 2011.04.25 16:22:11 -07'00'

CITADEL

ENVIRONMENTAL SERVICES, INC.

AHERA RE-INSPECTION REPORT

VETERANS ADMINISTRATION SAN DIEGO MEDICAL CENTER

BUILDINGS #1, #2

3350 LA JOLLA VILLAGE DRIVE

SAN DIEGO, CALIFORNIA 92161

VETERANS ADMINSTRATION SAN DIEGO HEALTHCARE SYSTEM

3350 LA JOLLA VILLAGE DRIVE

SAN DIEGO, CALIFORNIA 92161

An Employee-Owned Company

CITADEL PROJECT NUMBER: 5137.1032.0

DATE: APRIL 22, 2011

400 North Tustin Avenue, Suite 340, Santa Ana, California 92705 Phone: (714) 547-4301 Fax: (714) 547-4647 www.citadelenvironmental.com

Please consider the environment before printing this document

AHERA RE-INSPECTION REPORT

VETERANS ADMINISTRATION SAN DIEGO MEDICAL CENTER

BUILDINGS #1, #2

3350 LA JOLLA VILLAGE DRIVE

SAN DIEGO, CALIFORNIA 92161

EXECUTIVE SUMMARY i

1.0 INTRODUCTION 1

2.0 PROJECT DEFINITION AND BACKGROUND 2

3.0 BUILDING DESCRIPTION 3

4.0 SURVEY METHODOLOGIES 4

5.0 RE-INSPECTION 6

6.0 CONCLUSIONS AND RECOMMENDATIONS 11

GENERAL 11

ASBESTOS 12

7.0 RE-INSPECTION LIMITATIONS 14

8.0 SIGNATURES 15

TABLE OF CONTENTS

TABLES

Table 2 AHERA Categories Assessment Table 6 Summary of Recommended Response Actions

FIGURES

Figure 1 Site Plan Figure 5 Samples Location Building 1, Basement Floor Figure 6 Samples Location Building 1, 1st Floor Figure 7 Samples Location Building 1, 2nd Floor Figure 8 Samples Location Building 1, 3rd Floor Figure 9 Samples Location Building 1, 4th floor Figure 10 Samples Location Building 1, 5th Floor Figure 11 Samples Location Building 1, 6th floor Figure 12 Samples Location Building 1, Roof Level Figure 13 Samples Location Building 1, Penthouse and Room 8000 Figure 14 Samples Location Building 2, 1st Floor Figure 15 Samples Location Building 2, 2nd Floor and Tunnel Figure 16 Samples Location Building 2, Roof Level

Figure 47 Historic Sample Locations Building 1, First Floor Figure 48 Historic Sample Locations Building 1, Second Floor Figure 49 Historic Sample Locations Building 1, Fifth Floor Figure 50 Historic Sample Locations Building 1, Sixth Floor

Figure 51 AHERA Physical Assessment Categories, Building 1, Basement Floor Figure 52 AHERA Physical Assessment Categories, Building 1, First Floor Figure 53 AHERA Physical Assessment Categories, Building 1, Second Floor Figure 54 AHERA Physical Assessment Categories, Building 1, Third Floor Figure 55 AHERA Physical Assessment Categories, Building 1, Fourth Floor Figure 56 AHERA Physical Assessment Categories, Building 1, Fifth Floor Figure 57 AHERA Physical Assessment Categories, Building 1, Sixth Floor Figure 58 AHERA Physical Assessment Categories, Building 1, Penthouse and Room 8000 Figure 59 AHERA Physical Assessment Categories, Building 1, Roof Level Figure 60 AHERA Physical Assessment Categories, Building 2, First Floor Figure 61 AHERA Physical Assessment Categories, Building 2, Second Floor and Tunnel Figure 62 AHERA Physical Assessment Categories, Building 2, Roof Level

APPENDICES

A Project Team Certifications

TABLE OF CONTENTS

CITADEL Project No. 5137.1032.0 PRIVILEGED AND CONFIDENTIAL AHERA Re-Inspection Report VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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EXECUTIVE SUMMARY

Citadel Environmental Services, Inc. (Citadel) was contracted by the Veterans Administration San Diego Healthcare System (VASDHS) (the “Client”), to conduct an AHERA1 visual Re- Inspection (the “Re-Inspection”) of asbestos-containing materials (ACMs), asbestos-containing construction materials (ACCMs), and Assumed Asbestos-Containing Materials (AACMs), referred to herein collectively as the “ACMs”. The re-inspection was conducted in the Veterans Administration San Diego Medical Center (VASDMC), Buildings #1 and #2 (the “Buildings”). The re-inspection was conducted during the period of March 8th – April 1st, 2011, and excluded the interstitial spaces in Building #1 from the 1st through 6th floors.

Citadel conducted the Physical Assessment utilizing the seven (7) AHERA Physical Assessment Categories as outlined in Citadel’s 2010 Report2 and listed below:

AHERA Categories

1. Damaged or significantly damaged thermal system insulation (TSI)

2. Damaged friable surfacing ACM

3. Significantly damaged friable surfacing ACM

4. Damaged or significantly damaged friable miscellaneous ACM

5. ACM with potential for damage

6. ACM with potential for significant damage

7. Any remaining friable ACM or friable suspected ACM

Based upon the physical assessment results, Citadel has provided potential for damage and disturbance, and recommended response actions for each ACM, ACCM, and AACM.

Citadel also reviewed the response action recommendations in the Citadel’s 2010 Report, and has provided recommendations for the appropriate response actions for ACMS, ACCMs, and AACMs.

Drawings with bulk sample locations taken previously (Citadel’s 2010 Report) can be found on Figures 5 – 16 (excluding Building #1 interstitial spaces). Historic bulk sample locations can be found on Figures 47 – 50 (1st, 2nd, 5th and 6th Floors).

Recommended response actions, as well as the AHERA Assessment Categories, friability, material type, description and color, and analytical results of each ACM can be found in Table 2 – AHERA Categories Assessment.

In accordance with VASDHS policy, an AHERA inspection and additional bulk sampling of the First through Sixth Floors should be conducted in order to complete the inspection. Given that the floors are occupied as a heath care facility, thereby, limiting complete access to all suspect ACMs, a sampling strategy should be developed for the building that adequately identifies ACM, and also allows for continued use of the facility. Materials of particular concern are wall systems (e.g., wall sheetrock/joint compound and plaster), and flooring systems (e.g., vinyl floor coverings, carpet mastics/adhesive, and base coves and associated mastics/adhesives). These

1 Asbestos Hazard Emergency Response Act (AHERA), Public Law 99-519. AHERA mandated that US Environmental Protection Agency (EPA) develop regulations to respond to asbestos in schools. On October 20, 1987, EPA promulgated the Asbestos-Containing Materials in Schools Rule (AHERA), 40 CFR 763, Subpart E.

2 AHERA Re-Inspection Report, VA San Diego Medical Center, Buildings #1, #2, San Diego, California, dated April 30, 2010, by Citadel Environmental Services, Inc. (Citadel’s 2010 Report).

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

5137.1032.0_VASDHS_AHERA_Reinspection_Report_2011 | VA SAN DIEGO HEALTHCARE SYSTEM ii of iii materials have not been identified in sufficient detail by numbers of samples collected/analyzed to be able to complete an AHERA Inspection and Assessment of the building. The existing bulk sample data can be used as a starting point and built on provided that the data is verifiable (e.g., represents current building conditions).

The AHERA Summary of Physical Assessment Categories for the Buildings can be found on Figures 51 – 62.

Citadel recommends that the VASDHS implement the response actions indicated in Table 6 – Summary of Recommended Response Actions. More than one response action may be listed for a particular location. Under AHERA, the response action to be taken must be “sufficient to protect human health and the environment.” Once it is determined which response actions meet these criteria, the VASDHS may choose the action that is the “least burdensome”.

TABLE 6.0

SUMMARY OF RECOMMENDED RESPONSE ACTIONS

LOCATION O&M REPAIR ENCAPSULATION ENCLOSURE3 REMOVAL

01-01-B; Area “A”

– B191C, D, E, F

01-01-B; Area “B”

– B190B

01-01-B; Area “C”

– B201

01-01-B; Area “D”

– Loading Dock East

01-01-B; Area “E”

– Loading Dock West

01-01-B; B1000

01-01-B; B251- Jungle Room

01-01-B: Utility Tunnel To Building

01-01-B

3 Installation of airtight enclosures consisting of “hard lid” framed plaster or sheetrock ceilings in place of lay-in ceilings in conjunction with new or future renovation projects.

4 Previously a regulated area, where access was restricted to properly trained personnel wearing personal protective equipment (PPE). However, asbestos removal activities have since taken place and according to VASDHS personnel, all identified ACM in this area have been removed.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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LOCATION O&M REPAIR ENCAPSULATION ENCLOSURE5 REMOVAL

01-01 01-01; 1393 – Multipurpose Room

01-02

01-03

01-04

01-05

01-06

01-Penthouse, Room 8000

01-Roof

02-1st Floor

02-2nd Floor

02-Roof

Primary Response Action

Secondary Response Action

Third Choice

5 Installation of airtight enclosures consisting of “hard lid” framed plaster or sheetrock ceilings in place of lay-in ceilings in conjunction with new or future renovation projects.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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1.0 INTRODUCTION

Citadel Environmental Services, Inc. (Citadel) was contracted by the Veterans Administration San Diego Healthcare System (VASDHS) (the “Client”), to conduct an AHERA6 visual Re- Inspection (the “Re-Inspection”) of asbestos-containing materials (ACMs), asbestos-containing construction materials (ACCMs), and Assumed Asbestos-Containing Materials (AACMs), referred to herein collectively as the “ACMs”. The re-inspection was conducted in the Veterans Administration San Diego Medical Center (VASDMC), Buildings #1 and #2 (the “Buildings”), and excluded the interstitial spaces in Building #1 from the 1st through 6th floors.

The re-inspection was conducted by Citadel in accordance with VASDHS Policy as outlined in VA Handbook 7700.1, Paragraph 8.d, which states: “VA facilities shall control ACMs located at the facility in accordance with generally-accepted practices and OSHA and US Environmental Protection Agency (EPA) requirements and guidelines”. The handbook states further that: “1. An Asbestos Assessment. This assessment shall be performed and documented in accordance with EPA regulations published to implement AHERA that are appropriate for VA facilities where ACMs are located in the building.”

The re-inspection was conducted during the period of March 8th – April 1st, 2011, by Citadel representative Tim J. Mullen. Mr. Mullen is a California Certified Site Surveillance Technician (CSST #04-3546) and EPA-accredited Building Inspector. The re-inspection was conducted under the general supervision of Michelle Campbell, a California Certified Asbestos Consultant (CAC) (No. 09-4519), and EPA-accredited Building Inspector/Management Planner. The report was written by Ms. Campbell. Project team certifications can be found in Appendix A.

The re-inspection consisted of a Physical Assessment by the Building Inspector to determine the current condition and potential for disturbance of the ACMs. The Building Inspector/Management Planner then interpreted and evaluated the physical assessment data in order to determine the response action recommendations {e.g., Operations & Maintenance Program (O&M), Repair, Encapsulation, Enclosure, and Removal} for each ACM, ACCM and AACM. The re-inspection consisted of the following:

1. Known ACMs, ACCMs, and AACMs (Known ACMs) in the building as identified in Citadel’s previous AHERA Re-Inspection Report in 2010 (“Citadel’s 2010 Report”7);

2. Historic bulk sampling of ACMs and ACCMs (Historic ACMs) in the building identified in the Citadel’s 2010 Report; and

3. ACMs and ACCMs such as spray-on fireproofing, Thermal Systems Insulation (TSI) (pipe, fitting and duct insulation), wall systems (plaster, wall sheetrock/joint compound), and ceiling systems (lay-in ceiling panels with asbestos-containing spray-on fireproofing debris on the top side) by homogeneous area (Homogenous ACMs).

Citadel conducted the Physical Assessment utilizing the seven (7) AHERA Physical Assessment Categories as outlined in Citadel’s 2010 Report and listed below:

6 Asbestos Hazard Emergency Response Act (AHERA), Public Law 99-519. AHERA mandated that US Environmental Protection Agency (EPA) develop regulations to respond to asbestos in schools. On October 20, 1987, EPA promulgated the Asbestos-Containing Materials in Schools Rule (AHERA), 40 CFR 763, Subpart E.

7 AHERA Re-Inspection Report, VA San Diego Medical Center, Buildings #1, #2, San Diego, California, dated April 30, 2010, by Citadel Environmental Services, Inc. (Citadel’s 2010 Report).

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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AHERA Categories

1. Damaged or significantly damaged thermal system insulation (TSI)

2. Damaged friable surfacing ACM

3. Significantly damaged friable surfacing ACM

4. Damaged or significantly damaged friable miscellaneous ACM

5. ACM with potential for damage

6. ACM with potential for significant damage

7. Any remaining friable ACM or friable suspected ACM

Based upon the physical assessment results, Citadel has provided herein potential for damage and disturbance, and recommended response actions for each ACM, ACCM, and AACM.

Citadel also reviewed the response action recommendations in Citadel’s 2010 Report, and has provided herein recommendations for the appropriate response actions for ACMS, ACCMs, and AACMs.

ACMs, ACCMs, and AACMs were categorized as follows:

Thermal Systems Insulation (TSI): Pipe, fitting, duct insulation and associated Jackets.

Surfacing Materials (SM): Spray-on fireproofing on structural steel, spray-applied ceilings (“Popcorn” Ceilings), wall/ceiling plaster, and joint compound associated with wall sheetrock.

Miscellaneous Materials (MM): Vinyl floor tiles/sheeting and associated mastic, floor carpet mastic, lab countertops, fume hood liners (Transite™ Cement Board), wall sheetrock, lay-in ceiling panels, and roofing materials.

Assumed Asbestos-Containing Materials (AACM): Transite™ Cement Panels and Transite™ Cement Pipe.

2.0 PROJECT DEFINITION AND BACKGROUND

Asbestos has been determined to be a naturally occurring carcinogen once used in a wide variety of building products. Prior to 1979, asbestos was used extensively throughout the United States in a wide variety of buildings and building products such as insulation on piping and ductwork, wall and ceiling materials (e.g., sheetrock and plaster), surfacing materials on walls (e.g., textures) and ceilings (e.g., “popcorn”), flooring materials (e.g., tiles/vinyl sheet flooring and mastics and glues), roofing materials, and in structural support materials (e.g., fireproofing).

The presence of ACMs, ACCMs, and AACM within the buildings does not, in and of itself, pose a hazard to human health. In order for asbestos to be a health hazard, the asbestos must be disturbed in a way that causes the fibers to become airborne where that can be inhaled or swallowed.

ACMs, ACCMs and AACMs can be distinguished as friable or non-friable. Friable is a term that describes a material that can be crumbled or crushed to a powder when dry with ordinary hand pressure. Friable materials, therefore, are considered potentially more hazardous because of their ability to more easily release airborne asbestos fibers and cause exposure to building

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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5137.1032.0_VASDHS_AHERA_Reinspection_Report_2011| VA SAN DIEGO HEALTHCARE SYSTEM 3 of 15 occupants. Examples of friable ACMs include Thermal Systems Insulation (TSI) (e.g., pipe, fitting, duct, and tank insulation, spray-applied ceilings, lay-in ceiling panels, and spray-on fireproofing).

Non-friable materials (materials that can not be crumbled or crushed to a powder with ordinary hand pressure) are not hazardous unless they are cut, ground, sanded, or disturbed in a way that fibers can be released into the air. Examples of non-friable ACMs include packings, gaskets, vinyl floor tiles, roofing materials, and Transite™ cement products.

This re-inspection, in conjunction with the O&M and the O&M area baseline (ambient) air monitoring (performed as separate tasks) is designed to protect VASDHS employees, medical staff, vendors (contractors and sub-contractors), patients, tenants, and guests from quantifiable exposure to occupational asbestos respiratory hazards. Protection of VASDHS occupants from asbestos shall be achieved through a combination of measures including, but not limited to, education (training), periodic inspections of known ACMs, ACCMs, and AACM, implementation of appropriate response actions such as removal, enclosure, encapsulation, cleaning and operations and maintenance, adherence to certain policies and procedures, and compliance with all applicable Federal, state, and local laws and regulations.

3.0 BUILDING DESCRIPTION

The VASDMC Buildings #1 and #2 (Buildings) were reportedly constructed between 1968 and 1972, and occupy approximately 1,045,000 square feet within the VASDMC complex. Building #1 is a six-story medical facility, which includes a Penthouse and a Basement, and Interstitial Spaces above the suspended ceilings that houses building utilities such as electrical and communications systems, medical gases, and the HVAC mechanical systems. Building #2 is the two-story power plant for the VASDMC complex.

Building #1 is a concrete and steel frame truss structure insulated with asbestos containing spray-on fireproofing. The interior walls are constructed of sheetrock seamed together with joint compound, troweled-on plaster over welded wire mesh, and unfinished concrete. Wall ceramic tile is present in the Restrooms. Ceiling finishes include various types of mineral fiber-type lay-in ceiling panels, sheetrock seamed together with joint compound, troweled-on plaster over welded wire mesh, spray-applied acoustical finishes (“popcorn ceilings”), and unfinished concrete. Floor finishes include vinyl floor tile (VFT) and vinyl sheet flooring (VSF) adhered with latex adhesives and cutback mastics (FTM), carpeting adhered with latex adhesives, concrete, ceramic tiles, and stone/composite tiles. Vinyl baseboards adhered with latex adhesives are also present in select locations of the building. The exterior finish consists of stucco over welded wire mesh. Roof finishes include rolled felt field membranes and asbestos-containing mastic at penetrations.

Building #2 is a concrete and steel frame structure which houses the mechanical systems such as the boiler and chiller units which service the VASDMC complex. In Citadel’s 2010 Report, it indicates that asbestos-containing TSI has been removed from pipes, tanks and vessels in Building #2. As indicated in Citadel’s 2010 Report, verbal communication from VASDHS personnel has also confirmed that ACMs were removed from Building #2. Limited bulk sampling of accessible TSI (e.g., TSI not enclosed with metal jackets) was conducted by and asbestos was not detected in the bulk samples.

High pressure steam (HPS), condensate, and chilled water (CW) pipe systems were observed to originate in Building #2 at the entrance to the Utility Tunnel and are then routed through the

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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Utility Tunnel which connects to Building #1 into Room B251, “Jungle Room”. The HPS lines were previously insulated with pre-fabricated, asbestos-containing composition silicates wrapped with canvas jackets and metal jacketing. The associated fittings were packed with asbestos-containing mud” compounds wrapped with canvas jackets8. The HPS line had continued into Room B251 for approximately ten (10) linear feet and was then insulated with non-asbestos-containing fiberglass and canvas/foil jackets under metal jacketing. The condensate and CW lines and associated fittings in the Tunnel were insulated with fiberglass and canvas/foil jackets under metal jacketing.9 The CW lines at the entrance to the Utility Tunnel from Room B251 were insulated with pre-fabricated, asbestos-containing composition silicates wrapped with canvas jackets and metal jacketing. The associated fittings were previously packed with asbestos-containing “mud” compounds wrapped with canvas jackets. According to VASDHS personnel, asbestos abatement activities have since been conducted in the Utility Tunnel and Room B251, “Jungle Room”. Furthermore, all pipes in Room B251 were observed to have “asbestos-free” signs mounted on them. According to VASDHS personnel, all asbestos-containing pipes and associated fittings in the Utility Tunnel have been abated, and thus the Utility Tunnel is no longer considered a regulated area.

Heating, Ventilation, and Air Conditioning (HVAC) in Building #1 is provided by ducted supply and return air systems connected to the building mechanical systems located in the Interstitial Spaces above each floor. Access to the mechanical systems in the Interstitial Spaces is provided by steel catwalks suspended over the lay-in ceiling systems. HVAC ductwork seams are sealed with an asbestos-containing sealant. Plumbing systems observed in the Interstitial Spaces included Heating Hot Water Supply and Return (HHWS&R), and domestic hot and cold water (DHW/DCW), which are insulated with pre-fabricated, non-asbestos-containing fiberglass wrapped with canvas or foil jackets. The associated fittings are packed with asbestos-containing “mud” compounds wrapped with canvas jackets. Sanitary waste/vent and storm drain piping was observed to be uninsulated (black cast iron).

4.0 SURVEY METHODOLOGIES

EXISTING DOCUMENTATION REVIEW

Citadel began the re-inspection by first reviewing pre-existing documentation, which consisted of Citadel’s 2010 Report, and to-scale floor plans of the VASDMC, provided by the Client. The analytical data reviewed consisted of Known ACMs, Historic ACMs, and AACMs.

PHYSICAL ASSESSMENT

After Citadel completed the reviewed pre-existing documentation, a walk through was conducted and the buildings visually inspected to categorize ACMs by homogeneous areas (HAs). ACMs were grouped into AHERA homogeneous material categories (i.e., TSI, SM, and AACM). HAs consisted of groupings of those materials that have uniform appearances, textures, and installation dates. Citadel then performed a physical assessment by classifying ACMs into one of the following seven AHERA Physical Assessment Categories:

8 Project No. 664-09-929, Mechanical Room B241, (Jungle) & Tunnel Abatement Summary of Findings, Recommendations & Independent Government Estimate for Removal (Letter Report), Millennium Consulting Associates, March 2009.

9 Project No. 664-09-929, Mechanical Room B241, (Jungle) & Tunnel Abatement Amendment Letter Regarding Further Bulk Sampling for Asbestos, Millennium Consulting Associates, April 2009.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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1. Damaged or significantly damaged thermal system insulation (TSI) pipe, fitting, duct insulation.

2. Damaged friable surfacing ACM.

3. Significantly damage friable surfacing ACM.

4. Damaged or significantly damaged friable miscellaneous ACM.

5. ACM with a potential for damage.

6. ACM with a potential for significant damage.

7. Any remaining friable ACM or friable suspected ACM.

Physical Assessment Characteristics are defined as follows10:

Damaged Condition – Material with one or more of the following characteristics:

Crumbling, blistering, water damage, gouges, punctures, inadequate cohesion or adhesion of the material, missing jacketing, or other damage was observed over less than 25% of the materials if the damage is localized and less than 10% if the damage is evenly distributed; or accumulation of suspect powder, dust or debris below the material was observed.

Significantly Damaged Condition – Material with one or more of the following characteristics:

Crumbling, blistering, water damage, gouges, punctures, inadequate cohesion or adhesion of the material, missing jacketing, or other damage was observed over greater than 25% of the materials if the damage is localized and greater than 10% if evenly distributed; material is delaminating or showing adhesive failure; or accumulation of suspect powder, dust or debris below the material was observed.

Good Condition –

No or very limited visible damage or deterioration was observed.

POTENTIAL FOR DISTURBANCE CLASSIFICATIONS

POTENTIAL FOR

DISTURBANCE

FREQUENCY OF CONTACT INFLUENCE OFVIBRATION POTENTIAL FOR AIR EROSION

Potential for Significant Damage

ANY HIGH VALUE

Potential for Damage ANY MODERATE VALUE

Low Potential ALL LOW VALUES

Factors for determining the potential for disturbance:

10 Preamble to the AHERA Rule, Federal Register, October 30, 1987, p. 41830.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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Potential for Contact with the Material

High: Service workers work in the vicinity of the material more than once per week, or

The material is in a public area (e.g., hallway, corridor, auditorium) and accessible to building occupants.

Moderate: Service workers work in the vicinity of the material more than once per month to once per week, or

The material is in a room or office and accessible to the occupants.

Low: Service workers work in the vicinity of the material less than once per month, or

The material is visible but not within reach of building occupants.

All data collected during the re-inspection were recorded onto field forms and the data were then entered into the Microsoft Access database that was developed for the VASDHS and included in Citadel’s 2010 report. Photographs were taken at each assessment location and a file link was inserted into the respective record within the Microsoft Access database.

Samples that were collected previously are identified by a unique Sample Number (e.g., 0901), where “09” denotes the year (2009) and “01” denotes the sample number. Each bulk sample location was then identified by its Sample Grid Location (e.g., 01-06-INT-F,9.3”), where “01” denotes the Building, “06” denotes the Floor, INT denotes “Interstitial Space”, and “F,9.3” denotes the column grid location on the drawing. The grid consisted of an X and Y axis with number indicators in the X direction and letter indicators in the Y direction, creating a coordinate system.

5.0 PREVIOUS RESULTS

DEFINITION OF ASBESTOS-CONTAINING MATERIALS

The EPA's Asbestos NESHAPs and the San Diego Air Pollution Control District (SDAPCD), the local air pollution control district, define an asbestos-containing material as any material that contains a concentration of asbestos of greater than one percent (>1.0%) by area as determined by Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM). NESHAPs and SDAPCD Regulation XI further segregate asbestos-containing materials into Regulated Asbestos-Containing Materials (RACM), Category I Non-Friable Materials, and Category II Non- Friable Materials, which are defined as follows:

Regulated Asbestos-Containing Materials (RACM)/Asbestos-Containing Materials (ACM): Includes all friable asbestos materials, Category I Nonfriable ACM that have become friable or will become friable or has been or will be subjected to sanding, grinding, cutting or abrading, and Category II Nonfriable ACM that have a high probability of being crumbled, pulverized, or reduced to powder by the forces expected to act on the materials in the course of renovation or demolition.

Category I Nonfriable ACM: Includes asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than one percent

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

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5137.1032.0_VASDHS_AHERA_Reinspection_Report_2011| VA SAN DIEGO HEALTHCARE SYSTEM 7 of 15 asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, PLM.

Category II Nonfriable ACM: Includes any material, excluding Category I Nonfriable ACM containing more than one percent asbestos as determined using the method 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.

DEFINITION OF ASBESTOS-CONTAINING CONSTRUCTION MATERIALS

The California Department of Occupational Safety and Health (Cal/OSHA) further defines an asbestos-containing construction material (ACCM) as a material that contains greater than one-tenth of one percent (>0.1%) asbestos.

During previous re-inspections/surveys in the Buildings:

Asbestos was reported to be present in quantities of greater than one percent (>1.0%) in representative bulk samples of the following materials:

12” x 12” Vinyl Floor Tile, w/Mastic 12VFT3/FTM3

12” x 12” Vinyl Floor Tile, w/Mastic 12VFT4/FTM4

12” x 12” Vinyl Floor Tile, Green/White, Bottom Layer 12VFT5/FTM5

12” x 12” Vinyl Floor Tile, Brown w/Mastic 12VFT6/FTM6

12” x 12” Vinyl Floor Tile, Green 12VFT7

12” x 12” Vinyl Floor Tile, w/Mastic, Black 12VFT8/FTM8

12” x 12” Vinyl Floor Tile, w/Mastic 12VFT9/FTM9

Floor Carpet Mastic FCM1

Floor Carpet Mastic FCM2

Fume Hood Liner, Transite™ Cement Board, Gray MISC10

Wall panel, Transite™ Cement Board, Gray MISC11

Laboratory Countertop, Black MISC6

Pipe Jacket Insulation, 16" OD CHWS PJ/C3

Pipe Jacket Insulation, 16" OD Steam PJ/C4

Spray-On Fireproofing, White/Gray, Encasement on Beams SAF1

Spray-On Fireproofing, White/Gray, on Beams SAF2

Asbestos was reported to be present in quantities of less than one percent (<1.0%) (ACCM) in representative bulk samples of the following materials:

12” x 12” Vinyl Floor Tile, Yellow 12VFT13 12” x12” Vinyl Floor Tile, Brown w/Mastic 12VFT2/FTM2 Pipe Fitting Insulation, 10" OD Elbow PFI3 Pipe Fitting Insulation, 12" OD HP Steam PFI4

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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Pipe Jacket Insulation PJ/C6 Roof Penetration Mastic, Gray/Black RPM1 Wall Joint Compound, White WJC1 Wall Joint Compound, White WJC2 Wall Joint Compound, White WJC3 Wall Plaster, White WPF1 Wall Sheetrock, White WSR5

No detectable quantities of asbestos were reported (none detected) to be present in representative bulk samples of the following materials:

Plaster Brown Coat, Tan, Rough WPB1 Wall Joint Compound, White, a/w WSR3 WJC3 12” x 12” Ceiling Tile 1CT1

12” x 12” Vinyl Floor Tile, Blue, Top Layer 12VFT15

12” x 12” Vinyl Floor Tile, Granite Pattern 12VFT16

12” x 12” Vinyl Floor Tile, Brown 12VFT17

12” x 12” Vinyl Floor Tile, Beige, Bottom Layer 12VFT18

12” x 12” Vinyl Floor Tile, Green/Multi-Color 12VFT19

12” x 12” Vinyl Floor Tile 12VFT20

12” x 12” Vinyl Floor Tile, w/Mastic, Yellow 12VFT20/FTM7

12” x 12” Vinyl Floor Tile, White/Blue 12VFT21

12” x 12” Vinyl Floor Tile 12VFT22

12” x 12” Vinyl Floor Tile, Blue 12VFT23

12” x 12” Vinyl Floor Tile, White/Blue, w/Mastic 12VFT24/FTM14

12” x 12” Vinyl Floor Tile, Tan, w/Mastic 12VFT26/FTM15

12” x 12” Vinyl Floor Tile, Multi-Color 12VFT27

12” x 12” Vinyl Floor Tile, White/Black 12VFT28

12”x 12” Wall Tiles 12WT

18'x18', Vinyl Floor Tile, Blue 18VFT1

12” x 12”Ceiling Tile, White, w/Ceiling Tile Adhesive 1CT1, CTA1

12” x 12”Ceiling Tile, White 2CP1

2’ x 2’ Ceiling Panel, White 2CP2

2’ x 2’ Ceiling Panel, White 2CP3

2’ x 2’ Ceiling Panel, White 2CP4

2’ x 2’ Ceiling Panel, White 2CP5

2’ x 2’ Ceiling Panel, White 2CP6

2’ x 2’ Ceiling Panel, White 2CP7

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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2’ x 4’ Ceiling Panel, White 4CP1

2’ x 4’ Ceiling Panel, White 4CP3

2’ x 4’ Ceiling Panel, White 4CP4

2’ x 4’ Ceiling Panel, White 4CP5

2’ x 4’ Ceiling Panel, White 4CP6

2’ x 4’ Ceiling Panel, White 4CP7

Ceiling Tile Adhesive, Brown a/w 1CT1 CTA2

Cove Base Mastic FBM1

Cove Base Mastic, Brown FBM2

Cove Base Mastic FBM3

Cove Base Mastic FBM4

Cove Base Mastic FBM5

Cove Base Mastic FBM7

Cove Base Mastic FBM8

Floor Carpet Mastic FCM3

Mastic MISC12

Wall Material MISC13

Wallpaper Mastic, Brown MISC14

Material, White MISC15

Debris on counter MISC16

Vinyl Sheet Flooring, Gray MISC17

Dust on HVAC Return Air Vent MISC3

Laboratory Countertop, Black MISC5

Laboratory Countertop, Black MISC6

Laboratory Countertop, Black, New, MISC7

Countertop (black) MISC8

Debris on Wall Air Grill (above TSI) MISC9

Roof Field Membrane RFM1

Roof Field Membrane RFM2

Roof Penetration Mastic RPM2

Spray Applied Acoustical Ceiling, White SAC1

Epoxy Flooring VSF10

Vinyl Sheet Flooring VSF11

Vinyl Sheet Flooring, Black VSF12

Vinyl Sheet Flooring VSF13

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

5137.1032.0_VASDHS_AHERA_Reinspection_Report_2011| VA SAN DIEGO HEALTHCARE SYSTEM 10 of 15

Vinyl Sheet Flooring VSF14

Vinyl Sheet Flooring VSF15

Vinyl Sheet Flooring VSF16

Vinyl Sheet Flooring, Wood VSF17

Vinyl Sheet Flooring, Pink/Green VSF18

Vinyl Sheet Flooring, Green VSF19

Vinyl Sheet Flooring, Pink VSF3

Vinyl Sheet Flooring VSF4

Vinyl Sheet Flooring, w/Mastic VSF5, VSFM2

Vinyl Sheet Flooring, Wood, w/Mastic VSF6, VSFM3

Vinyl Sheet Flooring, Tan VSF7

Vinyl Sheet Flooring VSF8

Epoxy Flooring, Black VSF9

Wall Joint Compound, White WJC4

Wall Sheetrock, White WSR1

Wall Sheetrock, White WSR2

Wall Sheetrock, White WSR3

Wall Sheetrock, White WSR4

Wall Sheetrock, White/ Wall Joint Compound, White WSR6, WJC5

Pipe Insulation, 16" OD, CHWS SRI6

Pipe Insulation Jacket, 10" OD PJ/C7

Pipe Insulation Jacket PJ/C1

Pipe Insulation Jacket, 8" OD Condensate Return PJ/C8

Tank Insulation Jacket, Condensate Vent Tank TJ/C1

Tank Insulation, Condensate Vent Tank TI1

Pipe Insulation Jacket, 16" OD PJ/C9

Pipe Insulation, 1" OD SR17

Tank Insulation, Bottom Layer TI2

Tank Insulation, Top Layer TI3

Gasket, 12” OD HP Steam MISC10

Pipe Insulation Jacket, 12" OD HP Steam PJ/C10

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

5137.1032.0_VASDHS_AHERA_Reinspection_Report_2011| VA SAN DIEGO HEALTHCARE SYSTEM 11 of 15

ASSUMED ACMS/ACCMS

Transite™ Cement Panels, Operating Room Walls Transite™ Cement Panels, Fifth Floor, Adjacent to Elevators Transite™ Cement Panels, Behind Exterior Black Metal Panels Transite™ Cement Pipe, Sub-Surface Water Pipes

Drawings with bulk sample locations taken previously (Citadel’s 2010 Report) can be found on Figures 5 – 16 (excluding Building #1 interstitial spaces). Historic bulk sample locations can be found on Figures 47 – 50 (1st, 2nd, 5th and 6th Floors).

Recommended response actions, as well as the AHERA Assessment Categories, friability, material type, description and color, and analytical results of each previously-identified ACM can be found in Table 2 – AHERA Categories Assessment.

State worker protection laws, as set forth by the Cal/OSHA, define asbestos-containing construction materials (ACCMs) as those that contain greater >0.1% asbestos11 by weight.

Quantities of asbestos >0.1% were detected in the project area materials noted above; these materials are regulated ACCMs, and require removal by a DOSH-registered contractor.

6.0 CONCLUSIONS AND RECOMMENDATIONS

GENERAL

Citadel recommends that all identified and assumed ACMs be managed in place in accordance with the Client’s O & M addressing training, regulated area entrance/exit procedures, cleaning, maintenance, periodic inspections, demolition/renovation, and general operation procedures to minimize exposure to asbestos. A project specific “demolition level” survey should be performed prior to the disturbance of building materials that may be impacted by any proposed demolition/renovation.

Planning functions for any proposed demolition/renovation should take into account the following considerations. In accordance with the EPA’s NESHAPs 40 CFR Part 61, Subpart M, and San Diego Air Pollution Control District (SDAPCD Regulation XI), all Regulated Asbestos- Containing Materials (RACM)/ACMs, Category I Non-Friable and Category II Non-Friable ACMs that may become friable, must be removed prior to demolition and / or renovation activities. In addition to asbestos regulations that control the release of asbestos to the ambient environment, state worker protection laws are applicable. Federal and State OSHA regulations outline specific work practices for handling ACMs/ACCMs. ACMs/ACCMs should be removed by a DOSH registered asbestos abatement contractor

All contractors on the project site should be knowledgeable about the presence and proper handling of asbestos so that the risk of accidental exposure or contamination is minimized. In accordance with CFR 1926.1101, CCR 1529 and State of California Assembly Bills 3713 and 1564 (a.k.a., the Connelly Bills), VASDHS is required to transmit information concerning the location, condition, and quantity of known ACMs/ACCMs to those that may come into contact with the materials, including contract employees and/or tenants as outlined in the Client’s O&M Notification Requirements.

11Although Fed/OSHA changed their definition to 1.0% by area, Cal/OSHA remains, and is expected to remain, at 0.1% by weight.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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ASBESTOS

As recommended in Citadel’s 2010 report, a badge-type system should be implemented to limit access to the Interstitial Spaces by staff vendors, subcontractors, etc. assigned to work in the interstitial spaces who have prior authorization and meet certain pre-entry criteria such as training (e.g., regulated entry/exit procedures), medical exams (respiratory protection), and respirator fit tests, as specified in the O&M.

Due to previously-identified asbestos-containing spray-on fireproofing present on the structural steel and decking and asbestos-containing TSI in the Interstitial Spaces, which were previously identified in Citadel’s 2010 Report as having a high to medium risk for asbestos exposure, the VASDHS should consider the replacement of existing lay-in ceilings with airtight “hard lid” framed plaster or sheetrock ceilings (Enclosure) under the spray-on fireproofing, in conjunction with future renovation projects. Even though the lay-in ceilings are adequate in minimizing human exposure risk, as evidenced by the O&M air monitoring results1213, there is always the possibility of a breach in the lay-in ceilings due to maintenance or other activities in the Interstitial Space above, where materials, equipment , or persons can fall through the ceiling to the floor below.

The lay-in ceilings currently function only as a “barrier” between the interstitial spaces and occupied areas since they are not ‘airtight’ as defined by AHERA.

In accordance with VASDHS policy, an AHERA inspection and additional bulk sampling of the First through Sixth Floors should be conducted in order to complete the inspection. Given that the floors are occupied as a heath care facility, limiting complete access to all suspect ACMs, a sampling strategy should be developed for the building that adequately identifies ACM, and also allows for continued use of the facility. Materials of particular concern are wall systems (e.g., wall sheetrock/joint compound and plaster), and flooring systems (e.g., vinyl floor coverings, carpet mastics/adhesive, and base coves and associated mastics/adhesives). These materials have not been identified in sufficient detail by numbers of samples collected/analyzed to be able to complete an AHERA Inspection and Assessment of the building. The existing bulk sample data can be used as a starting point and built on provided that the data is verifiable (e.g., represents current building conditions).

The AHERA Summary of Physical Assessment Categories for the Buildings can be found on Figures 51 – 62.

Citadel recommends that the VASDHS implement the response actions indicated in Table 6 – Summary of Recommended Response Actions. More than one response action may be listed for a particular location. Under AHERA, the response action to be taken must be “sufficient to protect human health and the environment.” Once it is determined which response actions meet these criteria, the VASDHS may choose the action that is the “least burdensome”.

12 Asbestos Operations & Maintenance Plan Annual Air Monitoring Report, VA San Diego Medical Center, Buildings #1, #2, 3350 La Jolla Village Drive, San Diego, California 92161, dated May 4, 2010, by Citadel Environmental Services, Inc.

13 Asbestos fibers {Transmission Electron Microscopy (TEM) using NIOSH Method 7402 (PCM Equivalent)} were not detected in samples collected in occupied (Public or Patient Care) areas on 1st – 6th Floors.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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TABLE 6.0

SUMMARY OF RECOMMENDED RESPONSE ACTIONS

LOCATION O&M REPAIR ENCAPSULATION ENCLOSURE14 REMOVAL

01-01-B; Area “A”

– B191C, D, E, F

01-01-B; Area “B”

– B190B

01-01-B; Area “C”

– B201

01-01-B; Area “D”

– Loading Dock East

01-01-B; Area “E”

– Loading Dock West

01-01-B; B1000

01-01-B; B251- Jungle Room

01-01-B: Utility Tunnel To Building

01-01-B

01-01 01-01; 1393 – Multipurpose Room

01-02

01-03

01-04

01-05

01-06

01-Penthouse, Room 8000

14 Installation of airtight enclosures consisting of “hard lid” framed plaster or sheetrock ceilings in place of lay-in ceilings in conjunction with future renovation projects.

15 Previously a regulated area, where access was restricted to properly trained personnel wearing personal protective equipment (PPE). However, asbestos removal activities have since taken place and according to VASDHS personnel, all identified ACM in this area have been removed.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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LOCATION O&M REPAIR ENCAPSULATION ENCLOSURE16 REMOVAL

01-Roof

02-1st Floor

02-2nd Floor

02-Roof

Primary Response Action

Secondary Response Action

Third Choice

7.0 RE-INSPECTION LIMITATIONS

The re-inspection was limited to representative locations in the buildings. Accordingly, any materials which contain or are suspected to contain ACMs/ACCMs should not be modified, altered or disturbed in any way. Moving, drilling, cutting, sanding, abrading, or otherwise disturbing such materials (such as during remodeling, renovation or demolition), pose a health risk and should not be attempted by untrained or unlicensed personnel. These activities should only be done in accordance with all applicable health and safety standards, laws, rules, regulations and requirements. Only professionals licensed and qualified to handle, remove, abate and dispose of ACMs/ACCMs in accordance with all applicable requirements should handle such materials. Tenants and Employees are advised to notify the designated VASDHS representative immediately for guidance in determining the appropriate methods for maintenance, handling, removal, or disposal of known or suspect ACMs/ACCMs.

This report has been prepared by Citadel Environmental Services, Inc. exclusively for our Client and their Authorized Representatives. The information contained herein pertains only to accessible materials identified at the referenced property at the time of the performed in accordance with a mutually agreed upon scope of work. The findings and recommendations presented are based upon observations of present conditions, and may not necessarily indicate future conditions. Citadel Environmental Services, Inc. implies no warranty to the accuracy of information provided them by outside agents and transmitted herein. The information contained herein may not be used, disclosed, or copied without written permission of the Client.

16 Installation of airtight enclosures consisting of “hard lid” framed plaster or sheetrock ceilings in place of replacing lay-in ceilings in conjunction with new or future renovation projects.

VA San Diego Medical Center Buildings #1, #2 3350 La Jolla Village Drive, San Diego, Ca.

April 22, 2011

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8.0 SIGNATURES

Survey Performed by:

(See field documentation for signature)

Tim J. Mullen California Certified Site Surveillance Technician 04-3546

Report Prepared by:

Michelle L. Campbell, CMC California Certified Asbestos Consultant 09-4519

Nalinna Rasu California Certified Site Surveillance Technician 05-3753

Report Reviewed by:

Michelle L. Campbell, CMC California Certified Asbestos Consultant 09-4519

Michelle Campbell

Digitally signed by Michelle Campbell DN: cn=Michelle Campbell, o=Citadel Environmental Services, Inc., ou, email=mcampbell@citadelenvironmen tal.com, c=US Date: 2011.04.25 16:22:37 -07'00'

Michelle Campbell

Digitally signed by Michelle Campbell DN: cn=Michelle Campbell, o=Citadel Environmental Services, Inc., ou, email=mcampbell@citadelenvironme ntal.com, c=US Date: 2011.04.25 16:22:50 -07'00'

Nalinna Rasu

Digitally signed by Nalinna Rasu DN: cn=Nalinna Rasu, o=Citadel Environmental Services, Inc., ou, email=nrasu@citadelenvironmen tal.com, c=US Date: 2011.04.25 16:23:12 -07'00'