512-23-154 - Appendix - HAZMAT.pdf

Asbestos & Lead Survey & Analysis Report (Boiler Rooms)

Loch Raven Veteran’s Affairs Medical Center Baltimore, Maryland

Prepared for:

Above Group Inc.

305 East Drive, Suite H

Melbourne, Florida 32904 Prepared by:

March 15, 2024

8626 Tesoro Dr., Suite 810 ● San Antonio, TX 78217 ● (210) 930 2834 ● www.atei97.com Texas Registered Engineering Firm F-8920, Geoscience Firm 50647, and Architecture Firm BR 1889

March 15, 2024 Mr. Stephen Kizim, PE, HFDP, EBCP Senior Mechanical Engineer/Project Manager Above Group, Inc.

305 East Drive, Suite H Melbourne, FL 32904

Re: Boiler Rooms Asbestos & Lead Survey Loch Raven Veteran’s Affairs Medical Center 3901 The Alameda Baltimore, MD 21218 Alpha Terra Project No. S230518-636

Mr. Kizim:

On November 13th thru 16th, 2023 Alpha Terra Engineering, Inc. (Alpha Terra) conducted an Asbestos and Lead Survey in connection with project “512-23-154 Loch Raven Construct Consolidated Boiler Spaces (Design)” to construct consolidated boiler rooms, spaces, or a single new boiler plant building, to feed either the entire campus or the entire campus minus Building 1 at the Loch Raven VAMC to identify, to the extent feasible, regulated building materials/components associated with the boiler rooms located in Buildings 1, 2, 4, 5, 6, and 7 of the Loch Raven Veterans Administration Medical Center (Loch Raven VAMC) in Baltimore, MD. The regulated building materials/components that the onsite asbestos and lead survey attempted to identify include:

• Asbestos-containing materials associated with various building materials.

• Lead-containing coatings or substrates found in paints, shellacs, caulks, and glazing.

The surveys performed comply with all applicable local state and federal regulations. The asbestos inspection, bulk sampling, and analytical procedures were performed in general accordance with the Environmental Protection Agency’s (EPA) interpretations, and guidelines of the Asbestos Hazard Emergency Response Act (AHERA). The lead paint inspection was performed in general accordance with the Occupational Safety & Health Administration (OSHA) Lead in Construction to identify any amount of lead in paint and the Housing and Urban Development (HUD) to identify lead-based paint. This document is not meant to be used as a hazardous materials (HAZMAT) specification for asbestos abatement or lead-containing paint remediation. Any reliance on this report by a third party is at such party’s sole risk.

Loch Raven VAMC – Boiler Rooms Asbestos & Lead Survey Loch Raven Construct Consolidated Boiler Spaces 3901 The Alameda, Baltimore, MD Alpha Terra Project # S230726-678 ii | P a g eAbove Group, Inc.

Alpha Terra appreciates the opportunity to provide this service to Above Group, Inc. If you have any questions regarding the following survey, please contact the undersigned at (210) 930-2843.

Sincerely, Alpha Terra Engineering, Inc.

Dan B. Ross Earl McIntosh, Jr.

Environmental Project Manager Senior Vice President EPA Accredited Asbestos Inspector Senior Asbestos Certified Consultant EPA Accredited Lead Risk Assessor emcintosh@atei97.com dross@atei97.com mailto:emcintosh@atei97.com mailto:dross@atei97.com

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ALPHA TERRA ENGINEERING, INC.

TABLE OF CONTENTS

TABLE OF CONTENTS ............................................................................................................... i ACRONYMS AND ABBREVIATIONS ......................................................................................... ii

1.0 EXECUTIVE SUMMERY

2.0 INTRODUCTION

2.1 Property Description

2.2 Scope of Work

2.3 Survey History

3.0 FIELD ACTIVITIES

3.1 Site Visit

3.2 Visual Assessment

3.3 Physical Assessment

3.4 Sample Collection

3.5 Asbestos Sample Methodology and Analysis

3.6 Lead Paint Sample Methodology and Analysis

4.0 REGULATORY OVERVIEW

4.1 Asbestos

4.2 Lead Paint

5.0 FINDINGS AND GUIDANCE

6.0 GENERAL COMMENTS

APPENDICES

I. Bulk Sample Collection Summary II. Laboratory Analytical Report for Bulk Samples III. Bulk Sample Location Maps IV. XRF Analytical Report V. Licenses and Certifications VI. XRF Performance Characteristic Sheet VII. Site Photographs

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ACRONYMS AND ABBREVIATIONS

ACBM Asbestos Containing Building Materials ACM Asbestos Containing Materials AHERA Asbestos Hazard Emergency Response Act AL Action Level CAA Clean Air Act CFC Chlorofluorocarbons CFR Code of Federal Regulations CFT Ceramic Floor Tile CMU Concrete Masonry Unit CWT Ceramic Wall Tile EPA Environmental Protection Agency HAZMAT Hazardous Material Hg Mercury HID High Intensity Discharge HUD Housing and Urban Development HVAC Heating Ventilation and Airconditioning LBP Lead-Based Paint LCP Lead-Containing Paint LF Linear Feet mg/cm2 Milligrams per square centimeter mg/m3 Milligrams per cubic meter NIST National Institute of Standards and Technology OSHA Occupational Health and Safety Administration NESHAP National Emissions Standard for Hazardous Air Pollutants Ni-Cd Nickel-cadmium PCB Polychlorinated Biphenyl PCS Performance Calibration Sheet PEL permissible exposure limit PLM Polarized Light Microscopy PPM Parts Per Million RACM Regulated Asbestos-Containing Materials RCRA Resource Conservation and Recovery Act RTU Roof Top Units SACT Suspended Acoustical Ceiling Tiles

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SF Square Feet SRM Standard Reference Material SSLA Small Sealed Lead-Acid TCLP Toxicity Characteristic Leaching Procedure TPO Thermo-plastic Polyolefin TSCA Toxic Substances Control Act TWA Time-Weighted Average ug/m3 Micrograms per cubic meter VFT Vinyl Floor Tile XRF X-Ray Fluorescence

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1.0 EXECUTIVE SUMMERY

Alpha Terra Engineering, Inc. (Alpha Terra) has completed the Asbestos and Lead Survey of the boiler rooms in Buildings 1, 2, 4, 5, 6, and 7 at the Loch Raven Veterans Administration Medical Center (Loch Raven VAMC) located at 3901 The Alameda, Baltimore, MD 21218. Field reconnaissance was performed by Mr. Dan B. Ross, Environmental Project Manager accompanied by Matthew Wilmott, Environmental Technician, with Alpha Terra between November 13th through 16th, 2023. This report documents the inspection methodologies applied during the Asbestos and Lead Survey, which includes the sampling and testing of suspect asbestos-containing materials (ACM) and testing paints, coatings, or substrates associated with the window units for the presence of lead (Pb).

The Asbestos and Lead Survey performed complies with all applicable local state and federal regulations. The asbestos inspection, bulk sampling, and analytical procedures were performed in general accordance with the EPA interpretations, and guidelines of AHERA. The lead paint inspection was performed in general accordance with EPA/HUD guidelines to identify lead-based paint (LBP) and OSHA Lead in Construction (OSHA) standard to identify any lead-containing paint (LCP) or coatings that contain lead. This document is not meant to be used as a hazardous materials (HAZMAT) specification for abatement. Any reliance on this report by a third party is at such party’s sole risk.

This summary is presented solely for introductory purposes, and the information contained in this section should be used only in conjunction with the full text of this report.

Findings:

• Asbestos – No asbestos-containing materials were identified.

• Lead – No lead-containing paints or coatings were identified.

Opinions:

Response action requirements will vary depending on the scope of any renovation or demolition activities. Although every reasonable effort was made by Alpha Terra to identify, sample, and analyze suspect materials for the presence of asbestos-containing materials and lead-containing paint, Above Group, Inc. should consider the potential of regulated building materials that may still exist within the boiler rooms survey that were not observed during this survey. If previously unknown suspect materials are encountered, Above Group, Inc. should take appropriate actions to have the suspect materials sampled and tested before continuing renovation or demolition activities. Additionally, Above Group, Inc. should ensure that all persons performing abatement and/or renovation activities at this site are appropriately licensed by the Maryland Department of the Environment (MDE) and the City of Baltimore (if applicable).

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2.0 INTRODUCTION

2.1 Property Description

Loch Raven VAMC buildings 1, 2, 4, 5, 6, and 7 are slab-on-grade brick and mortar structures constructed in the 1950’s. The boiler rooms associated with these structures are ground level windowless enclosed rooms that provide heat and hot water service to the buildings to which they are attached.

2.2 Scope of Work

The purpose of this Asbestos and Lead Survey was to identify, to the extent feasible, regulated materials including ACM, LBP, and lead-containing coatings associated with boilers and water and steam lines connected to the boilers within the boiler rooms located in buildings 1, 2, 4, 5, 6, and 7 on the Loch Raven VAMC campus. These substances may require removal prior to commencing renovation or demolition activities.

Asbestos: The Maryland Department of the Environment (MDE) handles asbestos concerns in Maryland. The MDE regulates asbestos-related activities in the State of Maryland. The MDE requires that a certified asbestos entity conduct an asbestos survey which conforms to accepted industry standards such as the protocol specified in 40 CFR Part 763.85, commonly referred to as the AHERA that applies to schools. Other factors are taken into consideration when determining the best method to determine the location, extent, and condition of ACMs in a non-school building.

EPA regulation 40 CFR 61, Subpart M, NESHAP, prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP, which is enforced by the MDE, requires that prior to the commencement of demolition or renovation, that the facility or part of the facility affected be thoroughly inspected for the presence of both Friable (Regulated Asbestos-Containing Building Materials), and Non-Friable (Category I & II Asbestos- Containing Materials). The OSHA has promulgated a worker protection standard for the disturbance of asbestos during renovation and demolition projects.

Lead-Based Paint: The HUD guidelines consider a lead in paint or other surface coatings content equal to or greater than 1.0 mg/cm2 or 0.5% by weight or 5,000 ppm to be the level at which the coating is considered “lead-based”, and at which point a potential hazard exists.

Lead-Containing Coatings: OSHA considers paint or coatings containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work. Employers of construction workers are responsible for developing and implementing a worker protection program. At a minimum, the employer should develop and implement a worker protection program for employees exposed to lead-containing paints and coatings to prevent exposures from exceeding the permissible exposure limit (PEL).

OSHA recognizes that HUD and EPA find XRF analyzers acceptable for analyzing lead in paint at their clearance level of 1.0 mg/cm2. They also recognize that some instruments can measure accurately at lower levels. However, please be aware that while XRF analyzers may be an acceptable method of analysis for meeting HUD/EPA requirements, OSHA's concerns are different from those of HUD and EPA

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OSHA does not consider any method that relies solely on the analysis of bulk materials or surface content of lead (or other toxic material) to be acceptable for safely predicting employee exposure to airborne contaminants. Without air monitoring results or without the benefit of historical or objective data (including air sampling which clearly demonstrates that the employee cannot be exposed above the action level during any process, operation, or activity) the analysis of bulk or surface samples cannot be used to determine employee airborne exposure.

2.3 Survey History

Above Group, Inc. furnished utility plans, elevations, and details (Dated: July 14, 2023, and October 10, 2023) and existing condition boiler room photos dated July 23, 2023, as reference documentation pertaining to the boiler rooms identified in buildings 1, 2, 4, 5, 6, and 7. No previous asbestos or lead survey reports were provided pertaining to the boiler rooms and associated water and steam pipes.

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3.0 FIELD ACTIVITIES

3.1 Site Visit

From November 13 through November 16, 2023, Alpha Terra personnel performed the Asbestos and Lead Survey at the Loch Raven VAMC to locate and identify asbestos-containing building materials, and lead-containing coatings associated with the boiler rooms identified in buildings 1, 2, 4, 5, 6, and 7 that may require special handling and/or disposal during any future demolition or construction activities. The Asbestos and Lead Survey and analysis report were conducted by:

• Mr. Dan B. Ross – EPA Accredited Asbestos Inspector & Lead Risk Assessor

• Mr. Earl McIntosh – Senior Document Reviewer, Senior Asbestos Certified

Consultant Copies of the relevant certifications are provided in the appendices. This report includes inspection findings and presents the laboratory analytical results from samples collected from the building (including roof). The asbestos survey was conducted in general accordance with the sample collection protocols established in the EPA regulations (40 CFR 763 - The Asbestos Hazard Emergency Response Act (AHERA)). The lead in coatings testing and evaluation was conducted in general accordance with the EPA/HUD guidelines and OHSA standards (29 CFR

1926.62 – Lead in Construction).

3.2 Visual Assessment

Accessible areas of the site, which included most areas of the building interior (excluding the crawl space and roof), were visually observed to identify homogeneous areas, collect samples of suspect asbestos-containing materials, analyze painted and coated components to determine the presence of lead-based paint and lead-containing coatings. Building materials identified as concrete, glass, wood, masonry, metal, or rubber were not considered suspect ACM.

3.3 Physical Assessment

Asbestos - a physical assessment of each accessible homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

Lead - a physical assessment of painted and or coated surfaces was conducted to assess its condition and define associated component before testing select painted surfaces for the presence of LBP and coatings that contain lead using an XRF instrument. Painted or coated surfaces were assessed to be in “intact” or “deteriorating” condition depending on degree of cracking, flaking, chipping and or peeling.

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3.4 Sample Collection

Bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Random samples of suspect materials were collected in each homogeneous area.

The sample team members collected bulk samples using wet methods as applicable to reduce the potential for fiber release. Samples were placed in resealable containers and labeled with unique sample numbers using an indelible marker. Suspect ACM samples collected from the subject property include:

• A total of twenty-seven (27) bulk samples were collected from nine (9) homogeneous areas of suspect ACM.

A summary of suspect bulk samples collected for analysis during the survey is included in Appendix I.

3.5 Asbestos Sample Methodology and Analysis

Bulk suspect asbestos samples were submitted under chain-of-custody to Crisp Analytical Laboratories LLC of Carrollton, Texas. Crisp Analytical Laboratories LLC is accredited under the National Voluntary Laboratory Accreditation Program for analysis by PLM with dispersion staining techniques per EPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/RC-93-116). The percentage of asbestos, where applicable, was determined by microscopy visual estimation. Crisp Analytical Labs is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 200349-0). Reports of laboratory analysis of all suspect asbestos samples collected, and sample chain-of-custody documentation are included in Appendix III.

3.6 Lead Paint Sample Methodology and Analysis

Painted surfaces were tested for the presence of lead using a SciAps X-550 XRF instrument.

XRF testing did not indicate any of the tested painted surfaces as “inconclusive.” Therefore, no bulk paint chip samples of suspect lead-containing paint materials were collected during the survey.

A SciAps X-550 XRF instrument was used to determine whether surface coatings contained lead-based paint (LBP). The building was evaluated to identify different testing combinations present. For the purposes of this survey and in the absence of published guidelines for testing commercial buildings, Alpha Terra generally observed HUD Guidelines for determining the presence of lead in coated surfaces, such as paints, shellacs, glazing, etc.; per these guidelines, individual tests are to be classified as part of a group based on the testing combination (i.e., room equivalent, component, and substrate). Substrates are classified as brick, masonry, concrete, drywall, metal, plaster, or wood. A component is defined as an item, such as doors, windows, walls, etc. When using testing combinations, results are classified by summing the individual component test results of positive, negative, or inconclusive.

For more detailed information, including testing location, component, color, and substrate, refer to the XRF analytical report contained in Appendix V.

No materials were assumed to be LCP or LBP. Any inaccessible areas (i.e., above suspended ceilings, behind equipment, etc.) found to have coated surfaces different than those referred to the LCP summary listed in Appendix IV should be tested when access permits or should be assumed to be positive for LCP or LBP.

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XRF Instrumentation

The SciAps X-550 XRF instrument (Device Serial No. 00722; Date of Manufacture: July 2022) was used in the testing for LBP for this project. During the inspection, the standard set by EPA, and HUD of 1.0 mg/cm2 was followed to determine the components that contained LBP.

The calibration of the SciAps X-550 XRF instrument was performed in accordance with the Performance Characteristic Sheet (PCS). The SciAps X-550 XRF instrument was calibrated using the paint film nearest 1.0 mg/cm2 in the NIST SRM.

Using protocols provided by HUD and the instrument manufacturer and in accordance with the NIST reference standard, calibration checks are performed at least twice daily, once prior to the inspection and once immediately after the inspection and every four (4) hours in-between. If for any reason the SciAps X-550 XRF instrument is not maintaining a consistent calibration reading within the manufacturer’s supplied standards for their PCS, manufacturer’s recommendations are used to bring the instrument into calibration. If the instrument cannot be brought back into calibration, the instrument will be returned to the manufacturer for repair and/or recalibration.

The PCS is located in Appendix VII.

An XRF reading at or above the standard of 1.0 mg/cm2 for lead is considered positive for the presence of LBP; however, a reading above 0.0 mg/cm2 and below 1.0 mg/cm2 for lead is considered LCP and not considered LBP, disturbance of the lead-containing material could create harmful conditions if proper precautions are not taken during activities that aggressively disturb these paint combinations.

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4.0 REGULATORY OVERVIEW

4.1 Asbestos

The MDE which requires any asbestos-related activity to be performed by an individual licensed by the State of Maryland, through the MDE. An asbestos related activity consists of the disturbance (whether intentional or unintentional), removal, encapsulation, or enclosure of asbestos, including preparations or final clearance, the performance of asbestos surveys, the development of management plans and response actions, asbestos project design, the collection or analysis of asbestos samples, monitoring for airborne asbestos, bidding for a contract for any of these activities, or any other activity required to be licensed under MDE.

Abatement of ACM or regulated asbestos-containing materials (RACM) must be performed by a State of Maryland licensed asbestos abatement contractor. In addition, third party air monitoring must be conducted during the abatement activities.

The asbestos NESHAP (40 CFR Part 61 Subpart M) regulates asbestos fiber emission and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under NESHAP, building materials found to contain, or assumed to contain, asbestos is classified as Category I non-friable or Category II non-friable asbestos-containing materials. Friable ACM are those materials that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Category II non-friable ACM includes packing, gaskets, resilient floor coverings and asphalt roofing products containing more than 1% asbestos. Category II non-friable asbestos containing building materials are any materials other than Category I materials that contain more than 1% asbestos.

Category I friable ACM and/or Category II non-friable ACM in poor condition that has become friable, or which will be subject to drilling, sanding, grinding, cutting, or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered RACM and must be removed prior to renovation or demolition activities.

The MDE and NESHAP require that written notification be submitted before beginning renovation or demolition projects which include the disturbance of any regulated ACM (RACM) or presumed ACM (PACM) in a building or facility, or before the demolition of a building or facility, even when no asbestos is present. This written notification must be provided to the TDSHS at least ten (10) working days prior to the commencement of asbestos abatement or demolition activities. Removal of RACM or PACM, must be conducted by a State of Texas licensed asbestos contractor. In addition, third party air monitoring must be performed during abatement activities.

The OSHA Asbestos standard for the construction industry (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc).

The OSHA standard classifies construction and maintenance activities which could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work. States that administer their own federally approved state OSHA programs may require other precautions.

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4.2 Lead Paint

Under the state of Maryland law, lead paint abatement is "a set of measures designed to eliminate or reduce lead-based paint hazards." Anyone who provides a lead paint abatement service shall be accredited by the MDE. An accredited contractor must follow procedures covered in State regulations. Anyone who removes lead paint, or who conducts any other maintenance or home improvement activity which creates a hazard by disturbing lead paint, should follow the safe practices which are included in these regulations. Regulatory agencies (HUD, MDE) have defined LBP as a paint or other surface coating that contain lead concentrations equal to or greater than 1.0 mg/cm2, 5,000 ppm, or more than 0.5% by weight for buildings that meet the definition of target housing.

OSHA does not define the amount of lead in paint that constitutes LBP. The lead standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions. The OSHA lead standard for construction (29 Code of Federal Regulations [CFR] 1926.62) applies to construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. Under this standard, construction includes, but is not limited to, the following:

• Demolition or salvage of structures where lead or materials containing lead are present,

• Removal or encapsulation of materials containing lead,

• New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead,

• Installation of products containing lead,

• Lead contamination/emergency clean-up,

• Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed, and

• Maintenance operations associated with construction activities described above.

Employers must be assured that no employee will be exposed to lead at concentrations greater than the permissible exposure limit (PEL) of 50 ug/m3 as an 8-hour TWA. The OSHA standard also establishes an action level (AL) of 30 ug/m3, which if exceeded, triggers certain requirements, including periodic exposure monitoring and medical monitoring. The standard requires initial monitoring to evaluate employee exposure. If results are below the AL, no further action is required. If results exceed the AL, exposure monitoring must be repeated every six (6) months, a medical surveillance program must be instituted, and employees must be provided with training about lead. If results exceed the PEL, additional requirements are triggered.

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5.0 FINDINGS AND GUIDANCE

Asbestos

Alpha Terra has completed the asbestos confirmation survey for the Loch Raven VAMC boiler replacement and consolidation project. The following is a summary of findings and estimate of associated square feet (SF) and linear feet (LF), if applicable:

None of the suspect building materials sampled were found to contain asbestos within the scope of this survey.

It should be noted that suspect materials not identified during this survey may exist within the building. Should suspect materials other than those which were identified during this survey be uncovered prior to or during the renovation process, those materials should be assumed asbestos-containing until sampling and analysis can confirm or deny their asbestos content.

Laboratory analytical reports are included in Appendix II.

Should additional suspect building materials be discovered and found to contain asbestos and if the Client does not intend to renovate or demolish the building, the identified ACM associated with the building should be managed in place. This in-place management should include such operations as repairing any damaged materials, protecting the remaining ACM from further damage, and developing a plan to periodically monitor the condition of the asbestos-containing materials. Notification of the presence of the materials should also be made to employees and outside contractors so that they do not inadvertently disturb the remaining asbestos-containing materials.

If repair, renovation, or demolition operations which may disturb the asbestos-containing materials present in the building are planned, it is recommended that the affected materials be removed. The MDE requires that any removal of asbestos-containing materials associated with the buildings be conducted by trained and licensed asbestos abatement personnel.

According to the MDE, a removal project involving the removal of more than 160 SF or 260 LF of non-friable ACM would need to be designed by a licensed Individual Asbestos Consultant. Air monitoring by a third-party Air Monitor would be required during the actual removal work regardless of the size of the project. Alpha Terra would be pleased to provide a proposal to conduct these services.

It is important to note the MDE and NESHAP require that written notification be submitted before beginning renovation or demolition projects which include the disturbance of any ACM in a building or facility, or before the demolition of a building or facility, even when no asbestos is present. This written notification must be provided to the MDE at least ten (10) working days prior to the commencement of asbestos abatement or demolition activities. These activities must be performed in accordance with the current MDE, EPA, and OSHA guidelines.

Lead Based Paint

The XRF instrument was utilized to analyze surfaces to determine the presence of lead in coated surfaces. The presence of lead above HUD standards (1.0 mg/cm2) was not identified in any of the components tested within the scope of this survey.

The XRF readings indicated painted surfaces analyzed by this testing method are not considered LBP (at or greater than 1.0 mg/cm2). No readings were measured as inconclusive.

No “false” positive readings were observed.

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The possibility exists that LBP/LCP coated surfaces may be hidden from sight or in inaccessible locations, or the homogeneous construction areas identified may not be homogeneous.

The XRF testing results are presented in Appendix V. XRF performance characteristic sheet (PCS) is presented on Appendix VII.

Should additional coated surfaces be found to contain lead in areas where the Client does not intend to renovate or demolish the building, the LBP/LCP materials, which will remain in the building, should be managed in place. It is recommended that this in-place management should include such operations as stabilizing or repairing any damaged to coatings that contain lead, protecting the remaining LBP/LCP coatings from further damage, and developing a plan to periodically monitor the condition of the LBP/LCP materials. Notification of the presence of the materials should also be made to employees and outside contractors so that they do not inadvertently disturb the remaining LBP/LCP materials.

If a project which would disturb the LBP/LCP materials within the building is to be conducted, it is recommended that contracting personnel who may disturb the LBP/LCP materials within the facility be made aware of the lead content in the materials so that they may exercise proper OSHA procedures for personnel protection or possibly employ protective procedures when working with the coatings.

Planned renovation/demolition activities impacting those materials determined to contain measurable concentrations of lead will be subject to OSHA regulations (29 CFR 1926.62 – Lead Exposure in Construction). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard.

There are also federal and state regulations, which require characterization of demolition debris to determine the proper disposal procedures.

Construction work covered by 29 CFR 1926.62 includes any repair, renovation, or other activities that disturb in-place, lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must be assured that no employee will be exposed to lead at concentrations greater than the PEL of 50 mg/m3 averaged over an eight-hour period without adequate protection. The OSHA standard also establishes an action level of 30 mg/m3, which if exceeded, triggers certain requirements, including periodic exposure monitoring and medical monitoring. Alpha Terra recommends performing air sampling of workers that perform work on surfaces with LBP/LCP. Personnel sampling should be performed in compliance with OSHA regulations. As it is understood a partial demolition and renovation activities which would disturb the LBP/LCP on the building is to be conducted, it is recommended that contracting personnel who may disturb LBP/LCP materials associated with the building be made aware of the lead content in the materials so that they may exercise proper OSHA procedures for personnel protection or possibly employ protective procedures when working with the coatings.

Compliance with applicable OSHA lead regulations is the responsibility of the contractor performing the work and it is recommended that they be required to communicate potential lead hazards to their workforce and utilize lead-safe work practices such as outlined in the EPA Renovation, Repair, and Painting (RRP) Final Rule (40 CFR 745) or applicable portions of the Structural Steel Painting Council (SSPC) Guidelines. It is further recommended that activities such as flame/torch dismantling, dry sanding and/or dry grinding of any components that are identified as lead-containing materials should be prohibited as part of any repair, renovation, or demolition activity.

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It is recommended that any painted metal components which are to be removed from the building be segregated from the waste stream and be transferred to a suitable metal recycling facility.

The EPA RCRA regulations set the limit of leachable lead in lead containing waste at 5.0 milligrams per liter (mg/L). Leachable lead means the amount of lead likely to leach from the waste into the surrounding soil of a landfill. This level is established by an analytical method called the Toxicity Characteristic Leaching Procedure (TCLP). Lead-containing waste that equals or exceeds the RCRA limit must be managed in accordance with RCRA regulations. This regulation affects the disposal of demolition or remodel debris containing lead or lead-based paint.

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6.0 GENERAL COMMENTS

This Boiler Room Asbestos and Lead Survey and analysis report included surveys to visually evaluate, identify, and sample homogeneous areas of suspect ACM attached to boiler room equipment located in buildings 1, 2, 4, 5, 6, and 7 on the Loch Raven VAMC campus to identify ACM and LBP/LCP coated surfaces. This survey is intended for exclusive use solely by Above Group, Inc., and the Loch Raven VAMC. The Asbestos and Lead Survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions. The results, findings, and comments expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the date on which this survey was conducted and should not be relied upon to represent conditions at a later date.

In accordance with applicable state and federal regulations prior to renovation or demolition of the building, any identified ACM and/or components coated with LBP/LCP should be removed, segregated, packaged, and properly disposed or recycled.

This report has been prepared on behalf of and exclusively for use by Above Group, Inc. for specific application to their project as discussed.

This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary.

Alpha Terra does not guarantee the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied, is made.

Appendix I

Bulk Sample Collection Summary

Asbestos Bulk Sample Log

Loch Raven VAMC 3901 The Alameda, Baltimore, MD 21218

Material Description Homogeneous Area Sample Location Lab Results

White Boiler Insulation

Utilized Insulation on Boilers 1 & 2 in

Building 1 Mechanical Room.

Boiler 1 – East End

No Asbestos Detected

02 Boiler 1 – Southeast Corner

No Asbestos Detected

03 Boiler 2 – West End

No Asbestos Detected

Steampipe Endcap Mastic

Utilized as Adhesive for Insulating

Materials in Building 1 Mechanical Room.

Southeast Corner Above AC Units

No Asbestos Detected

05 Southeast Corner Above AC Units

No Asbestos Detected

06 West Corner Above Boiler 1

No Asbestos Detected

Yellow Rigid Foam Pipe Insulation

Utilized as Foam Insulation on 8” diameter piping in Building 1 Mechanical

Room.

Southeast Corner Above AC Units

No Asbestos Detected

08 Northeast Corner Above Air Pumps

No Asbestos Detected

09 Northeast Corner Above Air Pumps

No Asbestos Detected

Steampipe End Cap Mastic

Utilized as Adhesive for Insulating

Materials in Building 2 Mechanical Room.

Southwest No Asbestos Detected

11 Southwest No Asbestos Detected

12 Southwest No Asbestos Detected

Loch Raven VAMC 3901 The Alameda, Baltimore, MD 21218

Material Description Homogeneous Area Sample Location Lab Results

Steampipe End Cap Mastic

Utilized as Adhesive for Insulating

Materials in Building 4 Mechanical Room.

Above Boiler 1 South

No Asbestos Detected

14 Above Boiler 2 South

No Asbestos Detected

15 Above Boiler 2 – South

No Asbestos Detected

Steampipe End Cap Mastic

Utilized as Adhesive for Insulating

Materials in Building 7 Mechanical Room.

Above Boiler 1 – North

No Asbestos Detected

17 Above Boiler 2 – Northwest

No Asbestos Detected

18 West Corner No Asbestos Detected

Gray Seam Mastic on Flue

Utilized as Seam Sealant in Building 7 Mechanical Room.

Above Boiler 1 on Flue – Northeast

No Asbestos Detected

20 Above Boiler 2 on Flue – Central

No Asbestos Detected

21 Above Boiler 2 on Flue – Central

No Asbestos Detected

Steampipe End Cap Mastic

Utilized as Adhesive for Insulating

Materials in Building 6 Mechanical Room.

Above Boiler 1 – North

No Asbestos Detected

23 East Central No Asbestos Detected

24 East End No Asbestos

Loch Raven VAMC 3901 The Alameda, Baltimore, MD 21218

Material Description Homogeneous Area Sample Location Lab Results

Steampipe End Cap Mastic

Utilized as Adhesive for Insulating

Materials in Building 5 Mechanical Room.

Above Boiler 2 & 3

– East

No Asbestos Detected

26 Above Boiler 2 & 3

– North

No Asbestos Detected

27 Above Boiler 2 & 3

– North

No Asbestos

Appendix II

Laboratory Analytical Report for Bulk Samples

Customer Project:

Reference #: Date: 11/17/23

Analysis and Method

Discussion

Qualifications

AIHA LAP, LLC Laboratory #102929

A "trace asbestos" will be reported if the analyst observes far less than 1% asbestos. CA Labs defines "trace asbestos" as a few fibers detected by the analyst in several preparations and will indicate as such under these circumstances.

Since allowable variation in quantification of samples close to 1% is high, <1% may be reported. Such results are ideal for point counting, and the technique is mandatory for friable samples (NESHAP, Nov. 1990 and clarification letter 8 May 1991) under 1% percent asbestos or "trace asbestos".

In order to make all initial PLM reports issued from CA Labs NESHAP compliant, all <1% asbestos results (except floor tiles) will be point counted at no additional charge.

CA Labs is accredited by the National Voluntary Accreditation Program (NVLAP) for selected test methods for airborne fiber analysis (TEM), and for bulk asbestos fiber analysis (PLM). CA Labs is also accredited by AIHA LAP, LLC. in the PLM asbestos field of testing for Industrial Hygiene. All analysts have completed college courses or hold a degree in a natural science (geology, biology, or environmental science). Recognition by a state professional board in one these disciplines is preferred, but not required. Extensive in-house training programs are used to augment the educational background of the analyst. The Laboratory Director and Quality Manager have received supplemental McCrone Research training for asbestos identification. Analysis performed at Crisp Analytical Labs, LLC 1929 Old Denton Road Carrollton, TX 75006

Dallas NVLAP Lab Code 200349-0 TEM/PLM TDSHS 30-0235

Summary of polarized light microscopy (PLM / Stereomicroscopy bulk asbestos analysis) using the methods described in 40CFR Part 763

Appendix E to Subpart E (Interim and EPA 600 / R-93 / 116 (Improved). The sample is first viewed with the aid of a stereomicroscope. Numerous liquid slide preparations are created for analysis under the polarized microscope where identifications and quantifications are preformed. Calibrated liquid refractive oils are used as liquid mouting medium. These oils are used for identification (dispersion staining). A calibrated visual estimation is reported, should any asbestiform mineral be present. Other techniques such as acid washing are used in conjugation with refractive oils for detection of smaller quantities of asbestos. All asbestos percentages are based on calibrated visual estimation traceable to NIST standards for regulated asbestos. Traceability to measurement and calibration is achieved by using known amounts and types of asbestos from standards where analyst and laboratory accuracy are measured. As little as 0.001% asbestos can be detected in favorable samples, while detection in unfavorable samples may approach the detection limit of 0.50% (well above the laboratory definition of trace).

Vermiculite containing samples may contain trace amounts of actinolite/tremolite. When not detected by PLM, these samples should be analyzed using TEM methods and / or water separation techniques. Suspected actinolite/vermiculite presence will be indicated through the sample comment section of this report.

Fibrous talc containing samples may contain a regulated asbestos fiber known as anthophyllite. Under certain conditions the same fiber may actually contain both talc and anthophyllite (a phenomenon called intergrowth). Again, TEM detection methods are recommended. CA Labs PLM report comments will denote suspected amounts of asbestiform anthophyllite with talc, where further analysis is recommended.

Some samples (floor tiles, surfacings, etc.) may contain fibers too small to be detectable by PLM analysis and should be analyzed by TEM bulk protocols.

Laboratory Analysis Report - Polarized Light

Alpha Terra Engineering Inc

8626 Tesoro Dr, Suite 810

San Antonio, TX 78217 S230518-636, Loch Raven VAMC Hazmat Survey

CAL23119510EC

CA Labs

Dedicated to Quality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Materials Characterization - Bulk Asbestos Analysis

Labs

A

C

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 6 10/30/2023) Page 1 of 9

Customer Project: S230518-636, Loch Raven VAMC Hazmat Survey CA Labs Project #: CAL23119510EC

No Asbestos Detected.

Glossary of abbreviations (non-asbestos fibers and non-fibrous minerals):

This report relates to the items tested as received. This report is not to be used by the customer to claim product certification, approval or endorsement by NVLAP, NIST, AIHA LAP, LLC, or any other agency of the federal government. This report may not be reproduced except in full without written permission from CA Labs. These results are submitted pursuant to CA Labs' current terms and sale, condition of sale, including the company's standard warranty and limitations of liability provisions and no responsibility or liability is assumed for the manner in which the results are used or interpreted.

Unless notified in writing to return the samples covered by this report, CA Labs will store the samples for a period of ninety (90) days before discarding. A shipping or handling fee may be assessed for the return of any samples.

Dallas NVLAP Lab Code 200349-0 TEM/PLM TDSHS 30-0235

AIHA LAP, LLC Laboratory #102929 ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

Overview of Project Sample Material Containing Asbestos

Laboratory

Sample ID

Sample # Layer # Analysts Physical Description of

Subsample

Asbestos type / calibrated visual estimate percent

List of Affected

Building Material

Types

CA Labs

Dedicated to Quality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 6 10/30/2023) Page 2 of 9

Customer Info: Attn: Customer Project:

Date:

Phone #

Fax #

Jose Matute Senior Analyst

Analyst Julio RoblesTanner Rasmussen

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Approved Signatories:

Technical Manager ca - carbonate gy - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastonite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

100% qu,bi

Dallas NVLAP Lab Code 200349-0 TEM/PLM TDSHS 30-0235

AIHA LAP, LLC Laboratory #102929 Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116). All samples received in good condition unless noted.

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

Steampipe Endcap Mastic/ off-white sealant y None Detected106977 05 05-1

100% qu,bi

106976 04-2 yellow insulation y None Detected 100% fg

Steampipe Endcap Mastic/ off-white sealant y None Detected106976 04 04-1

106975 03 03-1

Boiler Insulation/ white insulation y None Detected 100% fg

Boiler Insulation/ white insulation y None Detected 100% fg 106974 02 02-1

100% qu,bi

106973 01-2 white insulation y None Detected 100% fg

Non-asbestos fiber type / percent

Non-fibrous type / percent

106973 01 01-1

Boiler Insulation/ white sealant y None Detected

Purchase Order #:

Laboratory

Sample ID

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

Homo-geneo us

(Y/N)

Asbestos type / calibrated visual estimate percent

Samples Rec'd: 11/15/23 10:30 AM

210-325-3641 Date Of Sampling: None Given

Polarized Light Asbestiform Materials Characterization

CA Labs Project #:

Alpha Terra Engineering Inc S230518-636, Loch Raven

VAMC Hazmat Survey

CAL23119510EC

8626 Tesoro Dr, Suite 810

San Antonio, TX 78217 Turnaround Time: 11/17/2023

3 days

CA Labs

Dedicated to Quality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 6 10/30/2023) Page 3 of 9

Phone #

Fax #

Jose Matute Senior Analyst

Analyst Julio RoblesTanner Rasmussen

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Approved Signatories:

Technical Manager ca - carbonate gy - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastonite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

90%…