36C24519B0006-0002004.pdf

ASBESTOS-CONTAINING MATERIALS SURVEY

BUILDING 500-GE

Martinsburg VA Medical Center

510 Butler Avenue Martinsburg, West Virginia 25405

Ms. Krista Bowen, Industrial Hygienist

BEC Project # WV15032

Fieldwork Conducted: July 15, 2016

Final Technical Report Date: February 9, 2017

Prepared by:

ENVIRONMENTAL SCIENCE, ENGINEERING & INDUSTRIAL HYGIENE SERVICES

ASBESTOS-CONTAINING MATERIALS SURVEY

BUILDING 500-GE

TABLE OF CONTENTS

SECTION I SITE DESCRIPTION 1.0

SECTION II ASBESTOS-CONTAINING MATERIALS SURVEY 1.0

SECTION III CONCLUSIONS & RECOMMENDATIONS 5.0

APPENDICES

APPENDIX A EMSL SAMPLE RESULTS & EMSL CHAIN OF CUSTODY

APPENDIX B SAMPLING LOG

APPENDIX C BEC STAFF QUALIFICATIONS

BOGGS ENVIRONMENTAL CONSULTANTS, INC.

Onsite Fieldwork Conducted By & Final Technical Report Reviewed By:

Colin T. Muir Environmental Specialist State of West Virginia US EPA AHERA Asbestos Inspector (#AI008813)

SECTION 1.0 SITE DESCRIPTION

Project Site: Building 500-GE

Requester Name: Ms. Krista Bowen, Industrial Hygienist

Requester Address: Department of Veteran Affairs

Subject Site Description & Scope of Work:

The subject site is Building 500-GE located on the campus at Martinsburg VA Medical Center at 510 Butler Avenue, Martinsburg West Virginia 25405, hereinafter referred to as the subject site.

BEC received authorization from Ms. Krista Bowen, Martinsburg VA Medical Center, Industrial Hygienist, to provide support services to update the existing asbestos-containing materials database developed by previous inspectors. Ms. Bowen requested the asbestos inspection to ensure compliance with United States Environmental Protection Agency’s (US EPA) and State of West Virginia regulations, prior to disturbance of building construction materials anticipated (scheduled) to occur during renovation activities and to update the inventory of asbestos-containing materials.

SECTION 2.0 ASBESTOS-CONTAINING MATERIAL SURVEY

BOGGS ENVIRONMENTAL CONSULTANTS, INC. (BEC) conducted an asbestos-containing building construction materials (ACBMs) re-inspection survey of the interior and exterior of the subject site to evaluate materials that were previously not sampled, collection and further evaluation of non-friable organically bound materials via Transmission Electron Microscopy (TEM), and updates of the existing locations and quantities of building construction materials. The asbestos inspection was conducted in accordance with the US EPA "Asbestos Hazard Emergency Response Act (AHERA) of 1986" (40 CFR Part 763) and the "Asbestos School Hazard Abatement Reauthorization Act (ASHARA) of 1992" (40 CFR Part 763, Appendix C-E, Model Accreditation Plan).

BEC staff member Mr. Colin Muir, a US EPA AHERA and State of West Virginia licensed asbestos inspector, conducted a preliminary field walk inspection for the purpose of developing an understanding of the previously sampled components and to identify any previously unidentified suspected asbestos-containing materials.

Subsequently, Mr. Muir collected multiple bulk samples of suspect ACBMs observed at the subject site on July 15, 2016.

FIELD SAMPLING

BEC advises, based upon current US EPA asbestos hazard control regulations, the minimum number of samples necessary to definitively determine the presence (or absence) of ACBMs is dependent on the nature and quantity of the suspect building construction material. Additionally, the US EPA has established a standardized schedule for bulk sample collection of suspect ACBMs based upon homogeneous areas.

BEC advises, based upon onsite visual inspection and bulk sampling activities, one (1) samples of the suspect ACBMs were collected and submitted to the analytical laboratory which upon laboratory analysis revealed a total of one (1) individual PLM/DS analyses were required. BEC advises, based upon US EPA asbestos analytical regulations, the laboratory analyst has the sole discretion/responsibility in determining whether the bulk sample is composed of one or multiple layers.

LABORATORY ANALYSIS

Pursuant to the field screen and bulk sample collection, BEC submitted the bulk samples to EMSL of Cinnaminson, New Jersey for asbestos content analysis. EMSL is accredited by the American Industrial Hygiene Association and the National Institute of Standards and Technology (NIST)-National Voluntary Laboratory Accreditation Program as proficient in the analysis of asbestos in bulk samples.

EMSL performed Polarized Light Microscopy with Dispersion Staining (PLM/DS) of the bulk samples in accordance with the “Method for the Determination of Asbestos in Bulk Building Materials” (US EPA. Method 600/R-93/116, July 1993).

BEC advises PLM/DS analysis revealed asbestos WAS NOT DETECTED in a number of the suspect ACBM bulk samples collected and submitted to EMSL. BEC provides the results of the PLM/DS analyses in Table A – Asbestos-Containing Material Testing Results:

TABLE A- ASBESTOS-CONTAINING MATERIAL TESTING RESULTS

HA# Sample # Material

Class.

Sampling Location

Building Construction Material

Asbestos (%)

62 500-GE-71516-1 M

GE-105A: Exhaust

Tunnel Wall Black residual wall mastic None Detected

See APPENDIX B – SAMPLING LOG for the comprehensive sampling log sheet complete with historical sampling data.

Upon receipt of PLM/DS laboratory data, EMSL was directed by Krista Bowen to conduct further analysis via “Gravimetric Reduction and Transmission Electron Microscopy” (ELAP 198.4) on one (1) non-friable organically-bound (NOB) suspect materials reported as none-detected by PLM.

The request for TEM analysis is based upon the understanding that small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. In addition, binding materials in certain building products can cause matrix interference, which may obscure underlying asbestos fibers from view and result in a false-negative analytical result. Therefore, PLM is not consistently reliable in detecting asbestos in NOB materials.

Quantitative transmission electron microscopy (TEM) is currently the only method that can definitively pronounce NOB materials as non-asbestos containing.

BEC advises TEM analysis revealed asbestos WAS DETECTED in any of the suspect NOB bulk samples submitted to EMSL. BEC provides the results of the NOB TEM analyses hereunder in Table B - Asbestos Survey NOB TEM Analytical Results.

TABLE B – ASBESTOS SURVEY - NOB TEM ANALYTICAL RESULTS

HA# Sample #

Class.

Sampling Location

Building Construction Material

Asbestos (%)

62 500-GE-71516-1 M

GE-105A: Exhaust

Tunnel Wall Black Residual Wall Mastic 0.33% Chrysotile

ASBESTOS SURVEY LIMITATIONS

The above limited inspection was characterized by close visual inspection of Building 500-GE, in accordance with US EPA regulations and generally accepted engineering work practices associated with the conduct of an asbestos survey. It is relevant to note, BEC did NOT conduct exploratory demolition to gain access to enclosed building conditions (e.g., wall cavities, pipe chases, HVAC ductwork shafts, ceiling plenums, etc.). Additionally, BEC sampling strategy was designed to include materials not previously sampled and non-organically bound materials which were not evaluated via TEM. As such, BEC assumes no responsibility that the historical information provided is accurate or complete.

BEC collected random bulk samples of suspect ACBMs. BEC has made every effort to identify all locations and types of asbestos-containing construction materials. BEC asbestos survey sampling strategy included multiple samples of the same materials chosen at random. However, BEC advises, due to the inconsistencies of manufacturer processes and contractor installation methods, materials of similar construction may contain varied quantities of asbestos.

Furthermore, BEC advises locating all asbestos-containing materials can only be definitively achieved by conducting exploratory demolition and sampling every section of pipe insulation, every fitting or valve covering, every square yard of fireproofing, and every square foot of other surface coating materials. Therefore, BEC makes no warranty, expressed or implied, that all asbestos has been found. Additionally, BEC recommends bulk sampling and analysis of all suspect ACBMs (not otherwise evaluated during this survey) encountered within a building area, prior to renovation or demolition.

SECTION 3.0 CONCLUSIONS AND RECOMMENDATIONS

CONCLUSIONS

1. BEC concludes, based upon onsite visual inspection, review of analytical data, and review of historical analytical data. US EPA-regulated ACBMs (defined as >1% asbestos content) were identified at the subject site and are listed in Table C – Asbestos-Containing Materials.

TABLE C: ASBESTOS-CONTAINING MATERIALS

Building Construction

Location

EPA

Regulated

OSHA

Regulated Estimated Quantity

Saddle Block GE-105 & GE-106 YES YES ~7 Each

Brown Metal Duct Seam Sealant

GE-105 YES YES ~6 SF

White Pipe Mastic

GE-100, GE-100A, GE-100C, GE-100D,

GE-100E, GE-101, GE-101A, GE-104, GE-

104A, GE-105, & GE-106

YES YES ~228 SF

2. BEC concludes, based upon review of US EPA and State of West Virginia law, specific regulations governing the disturbance, removal, and disposal of asbestos, DO APPLY to any work, of which is planned and/or can be reasonably anticipated to, result in the disturbance of the materials identified in the course of this inspection.

3. BEC concludes, based upon review of United States Occupational, Safety and Health Administration (Construction Industry-29 CFR 1926.1101 and General Industry-29 CFR 1910.1001) regulations governing non-occupational and occupational exposure to asbestos, DO APPLY to any renovation/demolition, housekeeping, maintenance and repair activities directly and/or indirectly impacting (disturbance/damage) the asbestos containing materials and trace containing materials.

SECTION 3.0 CONCLUSIONS AND RECOMMENDATIONS

CONCLUSIONS (continued)

4. BEC concludes, based upon onsite visual inspection and review of analytical data; US OSHA regulated (<1% asbestos) construction materials ARE PRESENT within the subject site, as listed in Table D – Summary of Trace ACBM

TABLE D: SUMMARY OF TRACE ACBMs

Building Construction

Location

EPA

Regulated

OSHA

Regulated Estimated Quantity

Black Residual Wall Mastic GE-105A NO YES ~520SF

RECOMMENDATIONS

1. BEC recommends should the renovation activities result in the discovery of additional suspect ACBMs, halting all work activities with subsequent bulk sample collection and analysis of discovered ACBMs, to determine asbestos content.

2. BEC recommends that all materials found to contain “Trace” amounts of asbestos be treated as asbestos-containing

APPENDIX A

EMSL SAMPLE RESULTS

EMSL CHAIN OF CUSTODY

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

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

VAMD78

041620022

613-C60024

Asbestos Survey

EMSL Order ID:

Customer ID:

Customer PO:

Project ID:

Attn:

Proj: 500-GE Asbestos Survey (Asbestos Survey)

Phone: (304) 263-3412

Fax: (304) 262-4881

Collected: 7/15/2016

Received: 7/21/2016

Analyzed: 8/03/2016

Krista Bowen

VA Medical Center

510 Butler Avenue

Martinsburg, WV 25405-9991

Summary Test Report for Asbestos Analysis of Bulk Material via EPA 600/R-93/116

Client Sample ID:

Sample Description:

Lab Sample ID: 041620022-0001500-6E-71516-1

GE105A: North wall/Black residual wall mastic

DateTEST Non-Fibrous Asbestos CommentColor Fibrous

Non-AsbestosAnalyzed

8/02/2016 20% 80%PLM Black None Detected

8/03/2016 0.0% 99.7% ChrysotileTEM Grav. Reduction Black 0.33%

Analyst(s):

TEM Grav. Reduction (1)Darrah Johnson-McDaniel

PLM (1)Dave Poitras

Benjamin Ellis, Laboratory Manager or Other Approved Signatory

Reviewed and approved by:

EMSL maintains liability limited to cost of analysis. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. This test report must not be used to claim product endorsement by NVLAP or any agency of the U.S.

Government. EMSL bears no responsibility for sample collection activities or analytical method limitations. The laboratory is not responsible for the accuracy of results when requested to physically separate and analyze layered samples. PLM alone is not consistently reliable in detecting asbestos in floor coverings and similar NOBs

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

Initial report from: 08/03/201613:42:39

Test Report:EPAMultiTests-7.32.2.D Printed: 8/03/2016 01:42PM Page 1 of 1

OrderID: 041620022

APPENDIX B

SAMPLING LOG

Building #:

Date: 7/15/2016

HA# Sample #

Lab initials/Chain of Custody #

Sample location

Material Description

General Material Category or substrate Notes

Bldg # Floor Wing Space # Location of Sample Asb. Type

Asb.

Content

62 500‐GE‐71516‐1 41620022 500 G E GE‐105A

GE‐105A: Exhaust

Tunnel Wall Black residual wall mastic Wall mastic Chrysotile 0.33% Via TEM

Lab Results

Sampling Log Sheet BEC Inspector: Collin Muir 500‐GE

APPENDIX C

BEC STAFF QUALIFICATIONS