36C24219B0008-0002004.pdf

December 29, 2016

David Doyle TRM Design & Planning, LLC 448 Delaware Avenue Buffalo, New York 14202

Re: Asbestos-Containing Materials, Lead-Based Paint and PCB Inspection Report Batavia VA Roof Replacement – Building 5

VA242-16-C-0068

222 Richmond Avenue Batavia, New York 14020

SET 2907

Dear Mr. Doyle:

Enclosed please find a copy of the Asbestos-Containing Materials, Lead-based Paint and PCB Inspection Report for Batavia VA Roof Replacement, located in Batavia, New York. Should you have any questions please do not hesitate to contact our office at 716.332.3134. Thank you for the opportunity to be of service to TRM Design & Planning, LLC.

Sincerely, Susanne Kelley President

Enclosures

Asbestos-Containing Materials, Lead-Based Paint, and PCB Inspection Report

OF THE:

Batavia VA Roof Replacement – Building 5

VA242-16-C-0068

222 Richmond Avenue Batavia, New York 14020

PREPARED BY:

PREPARED FOR:

TRM Design & Planning, LLC 448 Delaware Avenue

Buffalo, New York 14202

CONDITIONS AS OF:

November 9, 2016

Summary Tabulation

1. Introduction

2. Asbestos-Containing Materials Inspection

2.1 Methodology

2.2 Executive Summary

2.3A Confirmed Non-Asbestos Containing Materials 2.3B Summary Table of Asbestos-Containing Materials

2.4 Inspection Notes

3. Lead-Based Paint Inspection

3.1 Methodology

3.2 HUD/ EPA Standards

3.3A Summary Table of Lead-Based Painted/Coated Materials 3.3B Inspection Notes

3.4 OSHA Regulations

3.5 Disclosure Requirements

4. PCB Inspection

4.1 Methodology

4.2 Suspect PCB-Containing Materials

4.3 Summary Table of PCB-Containing Materials

Appendices

A General Conditions of Inspection B Certifications and Licenses C Chains of Custody and Laboratory Reports D Asbestos and PCB Sample Floor Plans E Summary Table of Confirmed Non-ACM Materials

1. Introduction

Sienna Environmental Technologies (Sienna) was retained by TRM Design & Planning, LLC to perform an inspection of Building 5 of the Batavia VA Medical Center, located at 222 Richmond Avenue in Batavia, New York to determine the presence of asbestos-containing materials, lead-based painted/coated materials and exterior PCB-contaminated caulks, glazings and sealants prior to work associated with the Batavia VA Roof Replacement project.

The inspection was conducted on November 9, 2016.

The scope of inspection work provided is as indicated in the proposal for Inspection Services dated October 17, 2016 and includes the following:

• Perform an inspection of the roofs of buildings 1 through 4 for asbestos-containing materials, lead-based paint, and PCB caulks which may be disturbed in the execution of the roof replacement.

Sienna’s scope of inspection work was altered from the original scope per the following direction from client:

• Perform an inspection for asbestos-containing materials, lead-based paint, and PCB caulks which may be disturbed in the execution of the roof replacement of buildings 5, 10, and 11.

• An inspection of building 3 was not performed.

• Inspection of flat built up roofs only, pitched slate roofs were excluded from client defined scope

• Client supplied samples were analyzed for slate roof components.

Sienna was charged with conducting the following tasks for this project:

1. Conducting an asbestos inspection in accordance with all applicable regulations,

2. Performing an inspection via X-Ray Florescence (XRF) for lead in accordance with all applicable regulations and guidelines,

3. Sampling exterior caulks, glazings and sealants for PCB contamination in accordance with all applicable regulations and guidelines, and

4. Providing a summary report of findings.

This report is generated for the exclusive use of the client and is not designed to serve as a specification for abatement. The owner is strongly encouraged to contract with a consultant having a current Asbestos Project Designer Certificate as issued by New York State Department of Labor for the preparation of contract specifications, work plans, and/or drawings prior to requesting bids for the abatement or removal of the materials identified in this report.

2. Asbestos-Containing Materials Inspection

2.1 Methodology

All asbestos inspection work performed by Sienna Environmental Technologies was conducted in accordance with applicable regulations including New York State Department of Labor standards 12 NYCRR Part 56, National Emission Standards for Hazardous Air Pollutants (NESHAPS), the Asbestos Hazard Emergency Response Act, and Occupational Safety and Health Administration regulations. All Sienna Environmental Technologies’ personnel assigned to conduct inspections have completed the Environmental Protection Agency (EPA) required training and New York State Department of Labor Division of Safety and Health certification program.

Based on the functional spaces and homogeneous areas (materials uniform in color or texture) identified by Sienna, samples of suspect materials were collected. Techniques used for sample collection were designed to minimize damage to suspected areas, reduce any potential for fiber release, and ensure the safety of the inspector and building occupants.

Samples were analyzed using Polarized Light Microscopy (PLM) in accordance with NYS DOH ELAP Item #198.1 or #198.6. For materials classified as non-friable organically bound materials (NOBs) that were analyzed as equal to or less than 1% asbestos by PLM, additional analysis was performed under Transmission Electron Microscopy (TEM) in accordance with NYS DOH ELAP Item #198.4. The results of this analysis confirmed whether or not a suspect material actually contained asbestos.

Although the report is a comprehensive analysis of the asbestos inspection work performed, it would be helpful to review all applicable federal, state and local rules, laws and regulations regarding the handling and treatment of asbestos-containing materials (ACM). The following is a list of suggested reading and information sources relating to asbestos:

• New York State Department of Labor Industrial Code Rule 56

• Occupational Safety and Health Administration

• Environmental Protection Agency Rule CFR 763.46 Asbestos Hazard Emergency Response

Act

• Environmental Protection Agency Rule 40 CFR, Chapter 61, Subpart M of the National

Emission Standards for Hazardous Air Pollutants (NESHAPS)

2.2 Executive Summary

The asbestos inspection included identification, sampling, analysis, and quantification of suspect materials that may be disturbed by the project. Copies of all laboratory analysis reports and chains of custody listing locations of sample collection are located in Appendix C.

2.3A Confirmed Non-Asbestos Containing Materials

These materials were sampled and analyzed by current EPA AHERA and ELAP protocols and were proven to contain less than 1% asbestos. Materials found to contain asbestos, but less than 1% asbestos are also listed by location(s) in which they exist in table 2.3B.

HAN Number Material Description Comments

MISCELLANEOUS (600s) 604 Counter Flashing Caulk Trace<1% Asbestos ROOFING (700s)

720 Felt Under Slate Trace<1% Asbestos Note 1

722A Elastomeric Coating N/A 722B Modified Cap N/A 722C Gypsum N/A 722D Isofoam N/A 722E Felt Moisture Barrier N/A

2.3B Summary Table of Asbestos-Containing Materials

The following table summarizes the Functional spaces that were included in the inspection for asbestos-containing materials and were verified or assumed to contain asbestos. Materials containing trace amounts (less than 1%) of asbestos are reported here for compliance with OSHA asbestos regulations. Refer to Appendix E for a table that summarizes the functional spaces that were included in the ACM visual inspections and the materials within the spaces found to contain no asbestos. Refer to sample location maps located in Appendix D for enumeration of functional spaces.

Functional Space ID/ Description

HAN Material Description ACM Approximate Quantity Condition Friability

R1-Roof *604 Counter Flashing Caulk Trace 30 LF I NF R2-Roof *720 Felt Under Slate Trace Note 1 I NF

Condition notes: I = Intact, D = Damaged, SD = Significantly Damaged

*The building component does not contain the requisite percentage of asbestos to be considered an asbestos containing material as defined by the USEPA or NYSDOL, but does contain asbestos and as such OSHA asbestos regulations apply.

2.4 Inspection Notes

Note 1 – Client provided this sample of material for laboratory analysis. Sienna did not quantify nor assess the condition of this material.

3. Lead-Based Paint Inspection

3.1 Methodology

Sienna Environmental Technologies used a spectrum analyzer to test painted or coated surfaces included in the scope of work. The analyzer measures the amount of lead in painted surfaces using X- Ray Fluorescence technology (XRF). The analyzer uses a radioactive source which locates lead atoms in painted surfaces and measures the concentration in milligrams per squared centimeter. If necessary, paint chip samples were also collected as part of this inspection. Representative surfaces/components were tested in a manner designed to adequately represent the different components, substrates, types of paint, construction and paint history. Various federal, state and local laws, rules, regulations and guidelines may be applicable to this project as it relates to Lead-Based Paint/coatings (LBP) including but not limited to:

1. Lead-Based Paint Renovation, Repair and Painting Regulation Rule (40 CFR Part 745.8 Subpart E (EPA))

2. Lead Safe Housing Rule (HUD 24 CFR Part 35)

3. Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (US

Department of Housing and Urban Development (HUD))

4. Occupational Safety and Health Administration (OSHA 29 CFR 1910 and 1926)

5. New York State Education Department (NYSED)

6. State of New York codes and laws

7. All local codes

8. All federal codes

9. US-DOT 49 CFR

The most recent edition of any relevant regulation, standard, document, or code shall be applicable to the work. Where conflict among the requirements exists, the most stringent requirements are generally applicable.

3.2 HUD/ EPA Standards

Certain HUD and EPA standards apply to “Lead-Based Paint” which is any paint or coating which contains lead at or above 1.0 mg/cm2 (via XRF), or 0.5 percent by weight (paint chip). Analysis indicated that the following components have a lead content equal to or greater than the HUD/EPA standard for Lead-Based Paint:

3.3A Summary Table of Lead-Based Painted/Coated Materials

Functional Space ID/ Description Material Description Approximate

Quantity Condition Positive or Homogeneous with Shot #

R1-Roof No LBP Coated Components

The presence of lead in surfaces that were analyzed as less than 0.5 percent lead by weight or in measurable amounts but less than 1.0 mg/cm2 is a consideration for the purposes of complying with OSHA regulations and are listed in Section 3.4. Refer to Section 3.4 for details.

3.3B Inspection Notes

No lead-based paint coated components were observed on the roof of Building 5 at the time of inspection.

3.4 OSHA Regulations

On May 4, 1993, OSHA promulgated the Lead Exposure in Construction Rule (29 CFR Part 1926.62).

This regulation applies to all construction activities involving potential lead exposures. This regulation applies when lead is present in any detectible amount and is not limited to HUD’s definition of Lead- Based Paint. Surface abrading and demolition activities may release lead from unpainted materials which contain lead such as glazed ceramic tile and porcelain, or enameled wall panels. Although these items do not meet HUD’s definition of Lead-Based Paint and need not be included in disclosure under the Lead Disclosure Rule (Refer to Section 3.5), they have been included for reference in 3.3 above.

3.5 Disclosure Requirements

If the subject property of this report is target housing, the owner has certain responsibilities under the Lead Disclosure Rule when the property is being sold or leased, or when a lease is being renewed with revisions. In general, lead disclosure is required in these circumstances, except that disclosure does not have to be made when the target housing is being leased if the inspection has found that it is Lead-Based Paint free.

Per 40 CFR Part 745 “Target Housing” is defined as: any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is less than 6 years of age resides or is expected to reside in such housing); or any 0-bedroom dwelling.

Results of this inspection must be provided to new lessees (tenants) and prospective buyers of this property under Federal law (24 CFR part 35 and 40 CFR part 745) before they become obligated under a lease or sales contract. The complete report must be provided by the owner to prospective buyers and it must be made available to prospective tenants and to renewing tenants if they have not been provided the information previously. The Inspector’s plain language summary of the report must be provided to the client (e.g., property owner or manager) when the complete report is provided. The landlord (lessor) or seller is also required to distribute an educational pamphlet approved by the U.S.

Environmental Protection Agency and include the Lead Warning Statement in the lease or sale contracts to ensure that parents have the information they need to protect their children from Lead- Based Paint hazards. Complete disclosure requires the landlord/sellers and renters/buyers (and their agents) to sign and date an acknowledgement that the required information and materials were provided and received. Also, prospective buyers must be provided the opportunity to have their own Lead-Based Paint inspection, lead hazard screen or risk assessment performed before the purchase agreement is signed; the standard period is 10 days, but this period may be changed or waived by agreement between the seller and prospective buyer. EPA regulations require the inspector to keep the inspection report for at least 3 years. (See Section IV of Chapter 7 of the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing for further details; see www.hud.gov/lead.)

http://www.hud.gov/lead

4. PCB Inspection

4.1 Methodology

Sienna Environmental Technologies identified suspect exterior PCB-containing caulk, glazing, or other sealant on building components that are included in the scope of work.

The inspection was performed in conformance with all applicable federal, state and local rules, laws, regulations and/or guidelines. All personnel assigned to conduct inspection wore personal protective equipment in accordance with standard OSHA protocols. The US EPA’s specified limit for PCB content/concentration is 50 ppm (parts per million) or 50 mg/kg (milligrams per kilogram) by weight.

The laboratory used for bulk sample analysis was approved by NYS ELAP and AIHA or NVLAP and performed laboratory analysis by EPA Method 8082.

The laboratory results are reported in mg/Kg (milligrams per kilogram) which equates to ppm (parts per million). Copies of all laboratory analysis reports and chains of custody listing locations of sample collection are located in Appendix C.

4.2 Suspect PCB-Containing Materials

The inspection revealed the following materials as suspect exterior PCB-containing caulking, glazing, or sealant materials:

HAN Number Description Results Above EPA Regulatory Limit (50 ppm)

MISCELLANEOUS (600s) 604 Counter Flashing Caulk No

4.3 Summary of PCB-contaminated Materials

Analysis indicates that all suspected PCB-containing materials have a PCB concentration less than the US EPA’s allowable limit of 50 mg/Kg

Appendix A General Conditions of Inspection

1. Sienna Environmental Technologies, LLC neither accepts nor implies any liability for the implementation of the recommendations found within this report.

2. This inspection was limited to areas accessible to the inspector. Sienna Environmental

Technologies, LLC neither accepts nor implies any liability for hazardous materials that may be present in other areas of the building.

3. The results of the laboratory analytical reports that may be contained herein are the product of the knowledge, experience and expertise of the laboratory retained to perform such services. Sienna Environmental Technologies neither accepts nor implies any liability for sample analysis reports compiled by others.

4. This report is based on the condition and contents present at the site on the day of the inspection.

Sienna Environmental Technologies, LLC is not liable for materials, chemicals or other substances of concern that may have been removed from the site, cleaned or disposed of prior to the inspection date or subsequent to that date.

5. An inspection for Asbestos-Containing Materials, Lead-Based Paint or PCB-Containing Materials relies heavily upon identification of homogeneous areas, with subsequent sampling and laboratory analysis determined by: the quantity of surfaces identified, generally accepted inspection protocols, regulatory requirements, and the inspector’s judgment. Specific sample locations are determined with the objective of selecting representative samples. As with any type of sampling, the possibility of obtaining a false positive or false negative does exist, is inherent in the sampling process, and can at times result from the uneven distribution of target analytes within the suspect material. The comprehensive inspection protocol developed and utilized by Sienna Environmental Technologies, LLC attempts to minimize the risk of a false positive or false negative result.

However, the client is advised that the risk of false positives or false negatives cannot be completely eliminated.

Appendix B Certifications and Licenses

Sienna Environmental Technologies, LLC

New York

This certification is valid from the date of issuance and expires November 20, 2018

Certification #

Issued On

August 21, 2015

NY-599-5

Lead, Heavy Metals, and Inorganics Branch

Michelle Price, Chief has fulfilled the requirements of the Toxic Substances Control Act (TSCA) Section 402, and has received certification to conduct lead-based paint activities pursuant to 40 CFR Part 745.226

New York State – Department of Labor Division of Safety and Health License and Certificate Unit State Campus, Building 12

Albany, NY 12240

ASBESTOS HANDLING LICENSE

Sienna Environmental Technologies LLC

350 Elmwood Avenue

Buffalo, NY 14222

FILE NUMBER: 00-1037

LICENSE NUMBER: 29432

LICENSE CLASS: RESTRICTED

DATE OF ISSUE: 02/03/2016

EXPIRATION DATE: 02/28/2017

Duly Authorized Representative – Susanne Kelley:

This license has been issued in accordance with applicable provisions of Article 30 of the Labor Law of New York State and of the New York State Codes, Rules and Regulations (12 NYCRR Part 56). It is subject to suspension or revocation for a (1) serious violation of state, federal or local laws with regard to the conduct of an asbestos project, or (2) demonstrated lack of responsibility in the conduct of any job involving asbestos or asbestos material.

This license is valid only for the contractor named above and this license or a photocopy must be prominently displayed at the asbestos project worksite. This license verifies that all persons employed by the licensee on an asbestos project in New York State have been issued an Asbestos Certificate, appropriate for the type of work they perform, by the New York State Department of Labor.

Eileen M. Franko, Director SH 432 (8/12) For the Commissioner of Labor

Appendix C Chains of Custody and Laboratory Reports

JPastore Rectangle

PCB Bulk Analysis Report

Sienna Environmental 11/11/2016

33-5983

11/18/2016

16-11-01748

7469 Whitepine Rd

Telephone: 800.347.4010

Richmond, VA 23237

Environmental Hazards Services, L.L.C.

Client:

Laboratory Results

Received Date:

Fax Number:

Reported Date:

Project/Test Address:

Client Number:

Report Number:

SET 2907; Batavia VA Hospital Roofs

350 Elmwood Avenue Buffalo, NY 14222-2204

716-332-3136

Lab Sample Number:

Client Sample Number:

Preparation Date:

Analysis Date:

16-11-01748-001

Aroclor 1016 (mg/kg)

Reporting Limit (mg/kg): Narrative ID:

Sample Matrix: Sample Weight (g):

11/17/2016 11/18/2016

Caulk

Aroclor 1221 (mg/kg)

Aroclor 1232 (mg/kg)

Aroclor 1242 (mg/kg)

Aroclor 1248 (mg/kg)

Aroclor 1260 (mg/kg)

Aroclor 1254 (mg/kg)

9.5 1.056

<9.5 <9.5 <9.5<9.5 <9.5<9.5<9.5

Lab Sample Number:

Client Sample Number:

Preparation Date:

Analysis Date:

16-11-01748-002

Aroclor 1016 (mg/kg)

Reporting Limit (mg/kg): Narrative ID:

Sample Matrix: Sample Weight (g):

11/17/2016 11/18/2016

Caulk

Aroclor 1221 (mg/kg)

Aroclor 1232 (mg/kg)

Aroclor 1242 (mg/kg)

Aroclor 1248 (mg/kg)

Aroclor 1260 (mg/kg)

Aroclor 1254 (mg/kg)

9.8 1.028

<9.8 <9.8 <9.8<9.8 <9.8<9.8<9.8

Page of 21

33-5983 16-11-01748 Project/Test Address:

Environmental Hazards Services, L.L.C Client Number: Report Number:

SET 2907; Batavia VA Hospital Roofs

Tasha Eaddy

QA/QC Clerk

Reviewed By Authorized Signatory:

Analysis Method: EPA SW846 8082A Preparation Method: EPA SW846 3540C

The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. All internal quality control requirements associated with the batch were met, unless otherwise noted. Results represent the analysis of samples submitted by the client. Unless otherwise noted, samples are reported without a dry weight correction. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the Environmental Hazards Service, L.L.C. Virginia Certification #460172 NY ELAP #11714.

Legend g = gram mg/kg = milligram per kilogram

Page of 22

Appendix D Asbestos and PCB Sample Floor Plans

Appendix E Summary Table of Confirmed Non-ACM Materials

Functional Space ID/ Description HAN Material Description

R1-Roof

722A Elastomeric Coating 722B Modified Cap 722C Gypsum 722D Isofoam 722E Felt Moisture Barrier