Hampton VAMC Bathroom Renovation Asbestos _ Lead Based Paint Survey - (F).pdf

Froehling & Robertson, Inc. 833 Professional Place West Chesapeake, Virginia 23320 T 757.436.1111 www.fandr.com

A Minority-Owned Business

January 2019 Update

Restroom Pre-Renovation Asbestos and Lead Based Paint Survey Report p

Hampton Veterans Administration Medical Center

100 Emancipation Drive Hampton, Virginia 23667

Prepared For:

Avetech Design Group 123 Bruton Court, suite 100 Chesapeake, Virginia 23322

Phone: (757) 389-5518 Attention: James Collins, P.E., President

Email: jcollins@avetechdg.com

Issue Date: July 19, 2019

F&R Project Number: 61X-0126

Conducted By:

Jason Cobb Industrial Hygienist

Conducted/Prepared By:

James A. Wallace Industrial Hygienist

Reviewed By:

E. Glenn Hargrove, CIH Director of Industrial Hygiene

Hampton VAMC Restroom Renovation F&R Project Number 61X-0126 i July 19, 2019

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1. PURPOSE

1.2. SITE DESCRIPTION

1.3. BACKGROUND

2.0 SCOPE OF SERVICES

3.0 LIMITED ASBESTOS-CONTAINING MATERIALS SURVEY

3.1. ASBESTOS-CONTAINING MATERIALS (ACM) METHODOLOGY

3.2. ASBESTOS-CONTAINING MATERIALS FINDINGS

3.3. ASBESTOS-CONTAINING MATERIALS INVENTORY

3.3.1. Wallboard System Discussion

3.3.2. Presumed Asbestos-Containing Materials

3.4. ASBESTOS-CONTAINING MATERIALS RECOMMENDATIONS

3.5. APPLICABLE REGULATIONS

3.5.1. EPA/NESHAP Regulations for Asbestos-Containing Materials

3.5.2. Virginia Asbestos Regulations

3.5.3. OSHA Asbestos Regulations

4.0 LIMITED LEAD-BASED PAINT SURVEY

4.1. LEAD-BASED PAINT SURVEY METHODOLOGY

4.1.1. XRF Testing

4.2. LEAD-BASED PAINT SURVEY FINDINGS

4.2.1. XRF Survey Results

4.2.1.1. Locations of Detected Lead-Based Paint

4.2.1.2. Inaccessible or Presumed Lead-Based Paint

4.3. LEAD-BASED PAINT CONCLUSIONS & RECOMMENDATIONS

4.4. APPLICABLE REGULATIONS

4.4.1. OSHA Regulations for Lead

4.4.2. EPA Regulations for Lead

5.0 LIMITATIONS

F&R Project Number 61X-0126 ii July 19, 2019

APPENDICES

Appendix A

F&R Personnel and Laboratory Accreditations

Appendix B

Asbestos Sample Diagrams

Appendix C

Historical Documentation

Appendix D

Asbestos Containing Material Summary Results Table Laboratory Certificates of Analysis

Bulk Sample Chain of Custody Forms

Appendix E

Photographic Documentation

Section 1 Asbestos-Containing Materials

Section 2 Lead-Based Paint

Appendix F

Explanation of XRF Data Table

XRF Data Table XRF Performance Characteristic Sheet

F&R Project Number 61X-0126 1 July 19, 2019

1.0 INTRODUCTION

Froehling & Robertson, Inc. (F&R) conducted a pre-renovation Asbestos and Lead Based Paint (LBP), Survey on July 1, 2, 3, and 11, 2019 of 132 interior restrooms of the Hampton Veterans Administration Medical Center located in Hampton, Virginia. It is F&R’s understanding that the restrooms are the subject of planned renovations which may impact building materials. The following sections document the survey procedures and results. Refer to Appendix A for Personnel Accreditation documentation of F&R personnel associated with this survey.

1.1. Purpose

The purpose of the Asbestos and LBP Survey is to identify Asbestos-Containing Materials (ACMs) and LBP coatings that may require appropriate removal, handling, and disposal procedures prior to scheduled renovation activities at the subject property. This survey is to aid in the determination of health and safety requirements during the conduct of work which may impact identified materials, as well as the preliminary classification of select regulated building materials for possible recycling activities.

1.2. Site Description

The Hampton Veterans Administration Medical Center facility consists of numerous medical and administrative buildings distributed throughout a 100.9-acre parcel of land in Hampton, Virginia.

F&R performed sampling for the identification of ACM and LBP within 132 interior restrooms of Buildings 33 (3 restrooms), 35 (1 restroom), 36 (3 restrooms), 37 (3 restrooms), 43 (6 restrooms), 52 (2 restrooms), 110 (47 restrooms), 110A (9 restrooms), 110B (35 restrooms), 116 (4 restrooms), 135 (7 restrooms), 137 (4 restrooms), 138 (3 restrooms), and 146 (5 restrooms).

Refer to Appendix B for site sketches of the facility, including asbestos sample locations.

Note that F&R utilizes Housing and Urban Development methodology for location identification modifiers: Side A is always the address side or the main entry side of the building. Then, proceeding in a clockwise direction the adjacent sides are labeled B, C and D; for example, the wall on the left side as one enters the building would be denoted as side B. Rooms with similar use patterns are numbered sequentially, generally with the first being the one that is encountered as one moves clockwise through the building from the main entry; unless room numbers are clearly identified on-site or on provided architectural/mechanical drawings which are expected to persist throughout the project. Note that F&R utilized Hallway and Room numbers as they were labeled on-site; such designations are expected to persist throughout the project. Architectural/Mechanical drawings were provided. Refer to Appendix B for facility sketches based upon site conditions observed at the time this survey was conducted.

It should be noted that material and color descriptions are subjective and that, due to the nature of the environment, identical materials and colors may have been labeled as different depending on the lighting, other colors in the area, and other factors.

F&R Project Number 61X-0126 2 July 19, 2019

1.3. Background

F&R was provided with previous asbestos and survey reports. A report prepared by Castle Hill Associates, LLC titled Asbestos Reinspection Report and dated September 2018 (Project Number VA- 17-902700). An additional summary report prepared by an unknown party titled Asbestos Sample Results by Building Number and dated October 10, 2011 was also provided to F&R. Historic survey data has not been tabulated within this report; however, the aforementioned previous survey reports are included for reference as Appendix C – Historical Documentation.

2.0 SCOPE OF SERVICES

As outlined in F&R proposal number 1961-00432, the survey included the following services with respect to the proposed renovation activities:

Identification and sampling, as necessary, of suspect ACMs.

Testing, as necessary, of surface coatings for the presence and concentration of lead.

Based on information provided by the client, it is F&R’s understanding that the restrooms are planned for renovation.

3.0 LIMITED ASBESTOS-CONTAINING MATERIALS SURVEY

F&R’s Virginia Licensed Asbestos Building Inspector, Jason Cobb (Virginia Asbestos License #3303004305), conducted the Asbestos Survey of the targeted property structure areas of concern (restrooms) located at Hampton VA Medical Center complex on July 1, 2, and 3, 2019.

The noted Inspector was assisted by F&R industrial hygienists Sam Bedinger and James Wallace.

Federal Regulations (40 CFR Part 61, Subpart M – National Emission Standard for Asbestos (NESHAP)), as well as Virginia Department of Labor and Industry regulations require a thorough asbestos inspection of the structure to be conducted prior to the commencement of renovation and/or demolition activities. An ACM is defined by the Occupational Safety & Health Administration (OSHA) and the Environmental Protection Agency (EPA) as material containing greater than one percent (1%) asbestos.

F&R Project Number 61X-0126 3 July 19, 2019

3.1. Asbestos-Containing Materials (ACM) Methodology

This survey was conducted in general accordance with the Federal NESHAP and applicable State regulations for the presence of ACMs. The survey was characterized by a visual inspection and sampling of suspect building components within the areas of concern at the subject property to be impacted by the proposed demolition activities.

Guidelines utilized in the asbestos survey were established by the EPA, ASTM International (ASTM), and The Environmental Information Association, Inc. (EIA). Utilized guidelines included:

the Asbestos Hazard Emergency Response Act (40 CFR Part 763, Subpart E – Asbestos-Containing Materials in Schools (cited as AHERA)), ASTM Standard E2356-14 Standard Practice for Comprehensive Building Asbestos Surveys, and the EIA publication Managing Asbestos in Buildings: A Guide for Owners and Managers – A Revision to the United States Environmental Protection Agency’s 1985 document Guidance for Controlling Asbestos-Containing Materials in Buildings (EPA 560/5-85-024) Known as the Purple Book.

F&R’s aforementioned industrial hygienist(s) collected and submitted suspect asbestos-containing bulk samples to the laboratory, of which, a total of six hundred sixty-seven (667) suspect asbestos-containing bulk samples with discernable layers were submitted for analysis on July 5, 2019. Due to multiple layers, a total of eleven hundred eighty-eight (1,188) samples were analyzed.

Samples of suspect ACMs were organized as per the AHERA concept of Homogeneous Area (HA), collected, and transported to the Environmental Hazards Services, L.L.C. (EHS) testing laboratory.

EHS is a National Institute for Standards and Technology (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory (NVLAP Lab Code: 101882-0) and Virginia licensed asbestos laboratory, in Richmond, Virginia, for analysis by Polarized Light Microscopy (PLM) following EPA Method 600/R-93/116. Refer to Appendix A for Laboratory Certificates of Accreditations. Refer to Appendix D for Laboratory Certificates of Analysis and Bulk Sample Chain of Custody Forms for further description of sampled materials/analytical results.

3.2. Asbestos-Containing Materials Findings

The following material types were identified, sampled, and accordingly assigned to homogeneous areas based upon similar construction discovered during bulk sampling:

Dry Wall and Joint Compound Floor Materials

Block /Mortar Caulking – Various Applications

Concrete – Various Applications Mastics – Various Applications

Ceramic Tile Mortar Base/Grout Thermal System Insulation

The summary of survey results from sampling events performed on July 1, 2, and 3, 2019 are located in Appendix C. Refer to Appendix B for illustration of the locations of collected bulk

F&R Project Number 61X-0126 4 July 19, 2019 samples. Positive asbestos samples (samples containing >1% asbestos) are in BOLD type.

Identified or presumed ACMs are detailed in the next section.

3.3. Asbestos-Containing Materials Inventory

F&R conducted a survey of the reasonably and safely accessible portions of the restrooms located within each targeted building.

The following table presents identified materials containing greater than 1% asbestos, as well as materials for which asbestos was detected, but in a concentration less than 1%, and presumed materials with regard to F&R survey activities. Further, comprehensive delineation was not performed; therefore, the table below may not completely represent locations of identified ACMs. It is the responsibility of the client or contractor to verify material locations. Photographic documentation of ACMs for reference is provided as Appendix E.

TABLE 1. ASBESTOS-CONTAINING MATERIALS INVENTORY

Sample Number

Material Description Sample Location(s) Result

(Percent ACM)

NESHAP

Category

Estimated Quantities

36-7A/B

Joint compound associated with 4” Gray

Cove Base and Associated Mastic

Building 36 – Room 7 2% Chrysotile Friable

350 SF

36-9A Drywall and Joint Compound (JC)

Building 36 – Room 7

JC = 2% Chrysotile;

0.25% Chrysotile via Composite 400-Point

Count Method

Friable

36-10A/B 1’X1’ Concealed Grid

Ceiling Tile Building 36 – Room 7 4% Chrysotile

Category II Non-Friable

150 SF

43-3F Drywall and Joint

Compound Building 43 – Room 203

JC = 2% Chrysotile;

0.25% Chrysotile via Composite 400-Point

Count Method

Friable 400 SF

43-17A/B/C 12”X12” Tan and Green

VFT and Associated Black Mastic

Building 43 – Rooms 202 and

VFT = 3% Chrysotile Category I

Non-Friable

350 SF

Mastic = 3 – 6%

Chrysotile Category II Non-Friable

43-20B 12”X12” Tan/Yellow VFT

Patch and Associated Black/Brown Mastic

Building 43 – Room 203 Mastic = 4% Chrysotile

Category II Non-Friable

52-11A/B Metal HVAC Black Duct

Mastic Building 52 – Rooms 111 and

4% Chrysotile

Category II Non-Friable

20 SF

(1 inch wide mastic seam

X 96” = ~1

SF)

F&R Project Number 61X-0126 5 July 19, 2019

Sample

Material Description Sample Location(s) Result

(Percent ACM)

NESHAP

Category

Estimated Quantities

110-2-14A/B Maroon Floor Tile and

Associated Mastic Building 110 – Room D203A

VFT = 3% Chrysotile Category I

Non-Friable

25 SF

Mastic = <1%

Chrysotile

NA

110-2-15A/B Black Floor Tile Building 110 – D203A 4% chrysotile Category I

Non-Friable

110-2-16A/B 12”X12” Green VFT and

Associated mastic Building 110 – D207

VFT =-3% Chrysotile Category I

Non-Friable

25 SF

Mastic = 6% Chrysotile

Category II Non-Friable

110A-4C/D Mortar for White 2”X4”

Ceramic tile Building 110A – Rooms C110, C112 and C120 2% Chrysotile

Category II Non-Friable

400 SF

110A-8A/B/C Drywall and Joint

Compound Building 110A – Rooms C231 and C240

JC = 2% Chrysotile;

0.50% Chrysotile via Composite 400-Point

Count Method

Friable 550 SF

110A-10B White Exterior Door

Frame Caulk Building 110A – Room C240 3% Chrysotile

Category II Non-Friable

9 SF

(1 inch wide caulk seam X 1,224” =

~9 SF)

110A-12A/B 12”X12” Multicolored

VFT

Building 110A – C240 VFT = 2% Chrysotile

Category I Non-Friable

120 SF

146-16A/B Off-White HVAC

Insulation Seam Mastic Building 146 – Room 9 and

Room 10 2% Chrysotile

Category II Non-Friable

20 SF

F&R presumes that, where materials have been documented to be ACMs and where those materials are similar to other materials which have not been found to be positive, those similar materials will be considered to be ACMs (i.e. where one material was analyzed and found to be positive, it is prudent to consider other similar materials positive, despite potential analytical data to the contrary).

3.3.1. Wallboard System Discussion

EPA NESHAP regulations indicate that “wallboard systems” where joint compound is used only at the joints and nail holes may be represented by a composite sample (walls which include other layers such as skim coat are not exempted from a requirement to conduct discrete sampling of each layer). Conversely, for wallboard systems with surfacing, NESHAP regulations require individual samples of the drywall and surfacing and prohibit compositing of the wall system.

For this survey, F&R collected individual samples of both the drywall and joint compound; this individual sampling approach was performed in response to OSHA guidelines for worker exposure. Analysis of the three drywall and joint compound samples (36-9A, 43-3F, and 110A-

F&R Project Number 61X-0126 6 July 19, 2019

8A/B/C) found that the drywall tested negative for asbestos and that the joint compound contained asbestos at a concentration of 2%.

The laboratory was requested to analyze one sample where asbestos was identified (36-9A, 43- 3F, and 110A-8A/B/C) as a composite comprising both joint compound and drywall. The PLM results of the composite sample indicated that the sample composite was <1% Chrysotile. The composite sample was then subjected to a more stringent and lower detection limit point count analytical method and found to be 0.25% Chrysotile for samples 36-9A and 43-3F, and 0.50% Chrysotile for sample 110A-8A/B/C. Note that sample layers which were subjected to composite sampling were not collected utilizing the NESHAP methodology specific to composite sampling;

however, they were sampled in the field and consequently represent an approximately one to one ratio. This sampling method may not represent the current joint compound to wallboard ratio; however, samples collected with a representative ratio would be further diluted by the non-asbestos-containing wallboard and therefore the overall concentration of asbestos would be further reduced.

Because OSHA requirements still consider each wallboard system component separately, work which impacts the wallboard system would still be considered Class II Work and subject to those regulations. Based on the composite result indicating that the overall concentration of asbestos in the wallboard system is less than 1%, the material may be able to be disposed of as non-asbestos containing. However, best practices dictate that the wallboard system be treated as ACM during impact and disposal.

3.3.2. Presumed Asbestos-Containing Materials

During the conduct of this survey, sampling was limited to those materials which were within the areas designated by the client, which were safely accessible, and which were able to be sampled without damaging systems or structures. As such, some materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed asbestos containing materials (PACM) include, but are not limited to:

Fire door interiors, Gaskets and packing materials in plumbing or hydraulic systems, where present, Electrical panel backing/arc deflectors/spark arresters, Wiring insulation or other live electrical system components, Chimneys and flues or other cementitious pipes or panels, Note that asbestos was used in over 3,000 known products and was used extensively in construction materials including in insulation and finish materials such as drywall-based systems, acoustical tiles, caulks and mastics, vinyl-based materials, and specialty products. Asbestos also continues to be used in new construction because, as stated by the EPA, "the manufacture, importation, processing, and distribution in commerce of [various] products […] are not banned.”

F&R Project Number 61X-0126 7 July 19, 2019

3.4. Asbestos-Containing Materials Recommendations

Except for those building materials listed in Table 1, laboratory analysis of the collected, submitted, and analyzed samples indicated an analytical result of “No Asbestos Detected” with regard to asbestos content. Photographic Documentation of site conditions and sampled materials is provided as Appendix E.

Should additional suspect ACMs be discovered during renovation activities that have not been sampled and will be disturbed, F&R recommends work be temporarily halted. Samples of suspect materials should be collected, analyzed, and handled accordingly prior to the resumption of renovation activities.

F&R further recommends that an Asbestos Abatement Contractor, utilizing appropriately accredited personnel, be engaged to properly remove newly discovered ACMs prior to renovation activities that would impact the ACM. If asbestos abatement activities are performed within the building, the work should be performed by an appropriately licensed asbestos abatement contractor.

The Client should note that F&R has encountered instances in which materials were analyzed by Polarized Light Microscopy (PLM) (following EPA Method 600/R-93/116) for the presence of asbestos with a result of “None Detected”, but when analyzed by Transmission Electron Microscopy (TEM) for Non-friable Organically Bound (NOB) bulk material, analytical results have indicated that asbestos is present in quantities greater than 1%. The client should be aware that F&R has samples analyzed by the PLM method for a number of reasons (including financial and time considerations) and that this method is considered acceptable in this state; however, some firms employ the more stringent TEM method which is required in some states. Therefore, it is possible that some materials identified as containing no asbestos within this report may, if subjected to a more stringent analytical method, reveal the presence of asbestos at concentrations of 1% or greater.

In addition, it should be noted that through NESHAP Applicability Determinations, asbestos bulk samples analyzed via PLM which indicate a result of asbestos content to be less than ten (10) percent, including trace amounts (<1%), the material in question shall either be assumed to be an ACM or further analyzed via PLM Point Count or TEM to verify asbestos content. Results obtained via PLM Point Count or TEM analysis shall supersede previous results obtained by standard PLM analysis. Samples with analytical results via PLM which indicate that no asbestos was detected are not required to be further analyzed via PLM Point Count or TEM.

As detailed above, several materials were identified as asbestos-containing, utilized in various instances through the structure. Prior to renovation activities, F&R recommends that the identified ACMs be appropriately removed, handled, and disposed of by an appropriately licensed/accredited Abatement Contractor utilizing appropriately licensed/accredited personnel.

F&R Project Number 61X-0126 8 July 19, 2019

F&R further recommends that a third party Asbestos Professional be retained to provide on-site surveillance and guidance of the Asbestos Abatement Contractor to confirm complete and proper removal/disposal of ACMs in accordance with applicable federal, state, and local regulations. This recommendation is made as a best practice to reduce potential exposure to workers and limit liability.

3.5. Applicable Regulations

3.5.1. EPA/NESHAP Regulations for Asbestos-Containing Materials

The U.S. Environmental Protection Agency promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) [40 CFR Part 61], which addresses the application, removal, and disposal of asbestos-containing materials (ACM). Under NESHAP the following categories are defined for asbestos-containing materials:

Friable - When dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable - When dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable ACM - Packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos.

Category II Non-friable ACM – Material, excluding Category I Non-friable ACM, which contains more than 1% asbestos.

Regulated Asbestos Containing Material (RACM) – One of the following:

1. Friable ACM

2. Category I Non-friable ACM that has become friable.

3. Category I Non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading.

4. Category II Non-friable ACM that has a high probability of becoming, or has become, friable by the forces expected to act on the material in the course of demolition or renovation operations.

Under NESHAP, the following actions are required:

1. Prior to the commencement of demolition or renovation activities, the building owner must inspect the affected facility or part of the facility where the demolition or renovation activities will occur for the presence of asbestos.

F&R Project Number 61X-0126 9 July 19, 2019

2. Remove RACM from the facility before activities begin that would break up, dislodge, or similarly disturb the material or preclude access for subsequent removal.

3. RACM need not be removed if:

a) It is Category I non-friable ACM that is not in poor condition.

b) It is on a facility component that is encased in concrete or other similar material and is adequately wet whenever exposed.

c) It was not accessible for testing and was therefore not discovered until after demolition began and because of the demolition the material cannot be safely removed.

d) It is Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

3.5.2. Virginia Asbestos Regulations

The Virginia Department of Labor and Industry (DOLI) regulates asbestos through enforcement of the Virginia Occupational Safety and Health (VOSH) regulations, enforcement of the Environmental Protection Agency's National Emission Standards for Hazardous Air Pollutants (NESHAP), and enforcement of the Asbestos Notification regulations found in the Labor Laws of Virginia (§40.1-51.20). Agency locations and regulations can be found on the agency Web site http://www.doli.virginia.gov.

The Virginia Department of Professional and Occupational Regulation (DPOR) is responsible for company and individual licensure in Virginia. Licensure and regulatory information can be found on DPOR's Web site http://www.dpor.virginia.gov/

The Virginia Department of Environmental Quality (DEQ) is responsible for the regulation of landfills in Virginia. Information on the disposal of asbestos in Virginia landfills can be obtained from the DEQ Web site http://www.deq.state.va.us/.

3.5.3. OSHA Asbestos Regulations

The Occupational Safety and Health Administration (OSHA) regulates employee exposure to asbestos under 29 CFR 1926.1101 and 29 CFR 1910.1001. Work associated with known or suspect ACMs must be conducted according to these regulations in addition to the noted EPA regulations.

http://www.doli.virginia.gov/ http://www.dpor.virginia.gov/ http://www.deq.state.va.us/

F&R Project Number 61X-0126 10 July 19, 2019

4.0 LIMITED LEAD-BASED PAINT SURVEY

F&R’s Industrial Hygienist, Jason Cobb, performed the testing of surface coatings for lead on July 3 and 11, 2019. Refer to Appendix A for F&R Personnel Accreditation Documentation.

For definitions of terms used in this document with regard to Lead-Based Paint, please reference the Glossary of the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based paint Hazards in Housing (Second Edition, July 2012).

Based on the nature of this survey, when one component tests positive for the presence of lead similar painted/coated components shall be assumed to be lead-containing, unless additional testing is performed.

4.1. Lead-Based Paint Survey Methodology

The survey was conducted in general accordance with EPA’s work practice standards for conducting LBP activities (40 CFR 745.227), and the HUD Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (Second Edition, July 2012); however, this was not a comprehensive surface-by-surface investigation for LBP, but rather a screening survey of major coated surfaces where the presence of LBP is suspected.

Several components, particularly high ceilings, were not safely accessible for testing or required invasive sampling techniques during the survey. Therefore, F&R has employed professional judgment in making determinations about the homogeneity of components determined to be “positive.”

4.1.1. XRF Testing

Sampling of surface coatings was conducted utilizing a Niton XL2-980 X-Ray Fluorescence (XRF) Lead Paint Analyzer (Serial Number 82040) and Niton XL2-980 GOLDD XRF Lead Paint Analyzer (Serial Number 92183). Only accessible painted, coated, and/or varnished surfaces were tested using the XRF.

The XRF contains a small radioisotopic source and operates on the principle of x-ray fluorescence, whereby lead atoms in a surface coating are stimulated to emit characteristic x-rays, which are then detected by the instrument. Levels of lead are reported in units of milligrams per square centimeter (mg/cm2). The XRF can measure surface or non-surface concentrations of lead with 95% accuracy at the HUD action level of 1.0 mg/cm2. The XRF is able to accurately detect a concentration as low as 0.1 mg/cm2 of lead. The XRF classifies coated surfaces as “positive”, “negative”, or “null” for lead content based on the action level (1.0 mg/cm2) and the performance characteristics of the XRF. The XRF was checked for calibration before and after the survey. The calibration was checked against a standard reference material (1.04 mg/cm2 NIST Standard) supplied by the XRF manufacturer. A copy of the XRF Performance Characteristic sheet is https://portal.hud.gov/hudportal/documents/huddoc?id=second_edition_2012.pdf https://portal.hud.gov/hudportal/documents/huddoc?id=second_edition_2012.pdf

F&R Project Number 61X-0126 11 July 19, 2019 included as an attachment to this report.

Positive: Lead is present at or above the action level of 1.0 mg/cm2 on one or more of the components tested.

Negative: Lead is not present at or above the action level of 1.0 mg/cm2 on any of the components tested.

Null: Insufficient data was collected by the XRF during the sample time to determine if the surface is positive or negative (i.e. – premature removal or instrument slippage, terminating the test).

4.2. Lead-Based Paint Survey Findings

4.2.1. XRF Survey Results

A total of seven hundred-fifty (730) XRF readings, excluding calibration readings, were collected from the interior and exterior of the building. Twenty-one (21) of the readings collected at the Project site were positive for LBP when compared to the action level of 1.0 milligrams per square centimeter (mg/cm²). However, those materials that tested positive for LBP were not painted surfaces. Refer to Appendix F, XRF Data Table for a listing of the readings and respective information as well as an explanation of the data table and the Performance Characteristic Sheet.

The following table presents the positive readings collected.

Reading

Component Substrate Building Room Floor Condition Color

July 3 & 11, 2019 Readings

19 Door Wood 35 8 1 Intact Gray

21 Door Wood 35 8 1 Intact Gray

25 Ceiling Wood 35 8 1 Intact White

47 Wall Ceramic

Tile 37 109 1 Intact Green

50 Wall Ceramic

Tile 37 109 1 Intact Green

Window Casing

Wood 37 109 1 Intact White

8 Window Wood 37 205 2 Intact White

11 Window Wood 37 205 2 Intact White

12 Window Wood 37 205 2 Intact White

13 Window Wood 37 205 2 Intact White

14 Trim Wood 37 205 2 Intact White

24 Window Wood 37 206 2 Intact White

25 Window Wood 37 206 2 Intact White

575 Door Frame Metal 110 B423A 4 Intact Gray

576 Door Frame Metal 110 B423A 4 Intact Gray

580 Door Frame Metal 110 B423A 4 Intact Gray

F&R Project Number 61X-0126 12 July 19, 2019

Reading Number

Component Substrate Building Room Floor Condition Color

July 3 & 11, 2019 Readings

583 Door Frame Metal 110 B423A 4 Intact Gray

586 Door Frame Metal 110 B433 4 Intact Gray

587 Door Frame Metal 110 B433 4 Intact Gray

594 Door Frame Metal 110 B412 4 Intact Gray

596 Door Frame Metal 110 B411 4 Intact Gray

4.2.1.1. Locations of Detected Lead-Based Paint

Based on the detection of positive LBP readings on specific component types and our observation of an apparent homogenous painting history, the following building components should be considered as regulated materials with regards to lead content:

LEAD-BASED PAINT MATERIALS INVENTORY

Material

Description Color Substrate

Material Location(s)

Photo #

Interior

Door Gray Wood Building 35

1st floor Restroom Lead 01

Ceiling White Wood Building 35

1st Floor Restroom Lead 02

Wall Green Ceramic Tile Building 37

1s floor restroom Lead 03

Window Casing White Wood Building 37

1st Floor Restroom Lead 04

Window White Wood Building 37 Room 205

Lead 05

Trim White Wood Building 37 Room 205

Lead 06

Window White Wood Building 37 Room 206

Lead 07

Door Frame Gray Metal Building 110 Room B423A

Lead 08

Door Frame Gray Metal Building 110 Room B433

Lead 09

Door Frame Gray Metal Building 110 Room B412

Lead 10

Door Frame Gray Metal Building 110 Room B411

Lead 11

The above table details only those building materials with surfaces with a reported lead concentration greater than or equal to 1.0 mg/cm2. However, readings of the majority of painted or coated surfaces indicated a lead content between 0.1 mg/cm2 and 0.9 mg/cm2.

F&R Project Number 61X-0126 13 July 19, 2019

4.2.1.2. Inaccessible or Presumed Lead-Based Paint

During the conduct of this survey, testing was limited to those materials which were safely accessible and readily visible. As the proposed scope of renovations is limited to the interior of the one hundred and thirty two restrooms specified by the client, no exterior building components were included in the lead-based paint scope of work. Some painted materials should be presumed to be positive, unless sampling is conducted and shown to be negative. Such presumed LBP coated components include, but are not limited to:

Decorative ceilings in Room 202 and Room 203 of Building 43 were inaccessible due to the height.

It should be noted that the renovation plans provided to F&R indicate that the ceilings in Room 202 and Room 203 of Building 43 are to remain in place. Should the scope of renovations alter to include the anticipated removal of the ceiling, F&R recommends that the ceiling be screened for lead-based paint.

4.3. Lead-Based Paint Conclusions & Recommendations

This survey concludes that certain building components located in the interior of the targeted structures of the Hampton VA Medical Center complex contain lead in a quantity that could cause them to become a regulated waste. Photographic documentation of select lead-containing building materials is presented in Appendix E: Section 2.

F&R recommends that activities which may disturb such materials be conducted following appropriate Federal and State regulations. Federal regulations with regard to worker safety and disposal requirements are summarized in the following Section – Applicable Regulations; this is not an exhaustive list.

4.4. Applicable Regulations

4.4.1. OSHA Regulations for Lead

While the majority of materials tested at the site were negative for lead based paint and/or surface coatings, other painted and/or coated surfaces or materials containing lead may contain sufficient concentrations of lead, which when disturbed, may generate lead dust greater than the “Action Level” concentration of 30 micrograms per cubic meter (µg/m3) or greater than the “Permissible Exposure Limit” of 50 µg/m3 established by the OSHA “Lead Exposure in Construction Rule” (29 CFR 1926.62). The OSHA standard does not define acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected;

however, guidance is available for work practices which present the highest risk for lead exposure to workers. Rather, OSHA defines airborne concentrations and references specific types of work

F&R Project Number 61X-0126 14 July 19, 2019 practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during removal or demolition processes (as applicable) to determine actual personal exposure. This monitoring information can be used to determine the levels of personnel protection and environmental controls required for work involving specific removal/demolition processes on specific structures.

Under OSHA requirements, the Contractor performing the work will be required to conduct this monitoring. It is important to note that environmental controls will vary dependent upon the content of lead in paint, the process used to remove it, duration of the work, and the amount of paint to be removed.

F&R recommends that workers disturbing painted (or coated) surfaces as part of this project receive OSHA Lead in Construction Awareness training and that engineering controls and hygiene practices described in 29 CFR 1926.62 be followed during the disturbance of painted (or coated) surfaces.

4.4.2. EPA Regulations for Lead

For disposal of construction/demolition debris that contains lead, testing may be required as specified by the Environmental Protection Agency (EPA) for lead content to determine proper disposal. EPA regulations require that a generator of waste determine if that waste is hazardous by performing testing in accordance with the requirements of 40 CFR 261.11 or for wastes that may be RCRA hazardous (such as items with high lead content), the generator may assume that the waste is hazardous and comply with the hazardous waste regulation. The need for determination of disposal may be additionally subject to the disposal and/or recycling facility utilized.

5.0 LIMITATIONS

This report has been prepared for the exclusive use of Avetech Design Group and/or their agents.

This service was performed in accordance with generally accepted environmental practices. No other warranty, expressed or implied, is made. Conclusions and recommendations are based, in part, upon information provided to us by others and site observations. We have not verified the completeness or accuracy of the information provided by others, unless otherwise noted.

Observations and recommendations are based upon conditions readily visible at the site at the time of the site visit, and upon current industry standards.

During this study, suspect asbestos samples were submitted for analysis at a NVLAP-accredited laboratory via polarized light microscopy and suspect LBP was field characterized using industry standard methods and practices. Inaccessible areas, such as behind solid ceilings or behind solid walls were not surveyed; therefore, some target materials may not have been identified. As with similar surveys of this nature, actual conditions exist only at the precise locations from which samples were collected or tested. Areas inspected were limited to those designated by the scope of services by the Client. Certain inferences are based on the results of this sampling and related

F&R Project Number 61X-0126 15 July 19, 2019 testing to form a professional opinion of conditions in areas beyond those from which the samples were collected. Unless otherwise noted, F&R does not claim to have performed exhaustive delineation and/or quantification of identified materials; it is the responsibility of the client or abatement contractor to verify locations and quantities of regulated materials. Visual evaluation of other materials of concern conducted comprised a cursory visual review of the building materials and, to a limited extent, contents of the facility. It is also understood that this is a non-invasive survey so that it is possible that concealed materials may be present that were not accessible during the original survey. No other warranty, expressed or implied, is made.

Reasonable effort was made by inspection personnel to locate and sample suspect materials within the structure with regard to the scope of services. However, for a facility, the existence of unique or concealed ACMs or LBP and debris is a possibility. F&R does not warrant, guarantee or profess to have the ability to locate or identify all ACMs, LBP, or other chemicals of concern in a facility.

Under this scope of services, F&R assumes no responsibility regarding response actions (e.g.

O&M Plans, Encapsulation, Abatement, Removal, Tenant Notification, etc.) initiated as a result of these findings. F&R assumes no liability for the duties and responsibilities of the Client with respect to compliance with appropriate regulations. Compliance with regulations and response actions are the sole responsibility of the Client and should be conducted in accordance with local, state, and/or federal requirements and should be performed by appropriately qualified and licensed/accredited personnel, as warranted.

Froehling & Robertson, Inc. by virtue of providing the services described in this report, does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to local, state, or federal public agencies conditions at the site that may present a potential danger to public health, safety, or the environment. The Client agrees to notify the appropriate local, state, or federal public agencies as required by law, or otherwise to disclose, in a timely manner, information that may be necessary to prevent danger to public health, safety, or the environment. The contents of the report should not be construed in any way as a recommendation to purchase, sell, or develop the project site. F&R retains the right to revise this report if new information is later discovered or made available. The report must be presented in its entirety.

Appendix A

F&R Personnel and Laboratory Accreditations

Appendix B

Asbestos Sample Diagrams

Project No.: 61X-0126 Scale: NTS

Date: 19-Jul-19 Drawn: SMH

Drawing No.: 1 Checked: JAC

5B

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 33 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

2B

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

5A

2A/3A1A/6A

4A

1B/3B

7A/B

6B

4B

9B 9A

Drawing No.: 1 Checked: JAC

5B/3B

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 35 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

4B

1B/2B1A/2A

4A 3A

5A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 36 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

5B

9A

10B

6A 7A

8A 6B 8B

10A

7B 9B 3A

1A/2A

4A 4B 5A

3B

1B/2B

5A

Date: 19-Jul-19 Drawn: SMH

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 37 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

12B

13A

11A 12A

1B

9A

9B

5B

8B 8A4C

10B

10A 7A/B

11B 4D

13B

2A/B 1A4B

6B

4A 3A

5A6A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 43 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

12A

15A

14A

1B/2B/3B

9A9B 5C

5A

5B

3A

13B

10A 11B

11A

1A/2A 4A

7A

13A 12B

10B

111F

3C

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 43 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

1B16B 16A

3D

20B

4B

6B9C

14B

18B

17A

18A

17B 15B

19B

3E/19A 3F

17C

20A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 52 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

11B

9B

10A

11A

8A

1B/2B

8B

10B

3B

9A

4A

3A

4B

1A/2A

5A/B

6A/B

7A/B

111114

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110A - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

C231C112C110

C120

1B

8A

9A

5D

2A

15A

15B

5E

10B

3B

2B

8B

6A/7A

4C

4A

8C

9B 14A

14B 5C

3C 4B

5B

3A

1A 5A

4D10D

12B

11B

12A

13 A/B

11A

C216D C216F

C240

16A/B

10C

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110B - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

GA-155GB-111

11A

1B

13A

6A 8A

10A

1A

3B/5B

19A

19B

4A

7A

9B

2A

12A

18A

13A 14A

15A/

19C

13I

4B/6B

13H

5A

9A

18B15B/16B

7B

13C

13F

13D

13E

13B 14B

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

GC-103 & GC-103A

GA-137

GA-154

GB-113GB-120GB-122CGB-121J

GC-102 & GC-102A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110B - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

4D

5C

4E

19D

23A/B

4C

22E

21A/B 22A/B

19E

21C

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

GA-127

GD-109GD-114 & GD-114A GD-113 & GD-113A

13G

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110B - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

2D-1462C-102A

16M

25B

16K

39A/B19C 18A

40A/B

16L

22A 21A

16J

2A 3A

9A

1A

4A

16I

20A

41A

19A

16N

7A 5A

8A

6A 10B

7B 5B2B

6B

23A

16O

10A

9B 3B 4B

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

2A-119A

2A-160 2A-143A 2A-145A 2A-144A

2A-120

2D-111A 2A-111

16A/17A25A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110B - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

2D-109A 2C

29B

8B

34C

2D

16H

31B

16F 26, 27, 28 B

16E 24C

33A/B

30B 34A/B

37, 38 A/B

12, 13, 14, 15 A

24A

35, 36 A/B

29A 19B

30A

32A/B

16B

16G

1B

7C

9C

18B

6C

11A

16C

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

2C-101

2D-100H2D-106A

2D-107A

2C-100

2D-102

2D-104A

26, 27, 28 A

2D-100G

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110- Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

DG01C

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

1F

DG05J.1

DG05EDG20ADG50D.1DG05C.1

DG29

BG16BBG16N1 DG05H.1BG19

6B

16A 15A/B

1D 30A/B 1K

1A

2A 3A 11A

4A

8A

10A

7A

17A

22A

19A 21A

3C

20A

18A 1H

25A

9B

8B

9A

5A 6A 12A

1G

1E

18B

25B

1I

17B 10C

26A 25C

23A/B

24A/B

11B

4B

2B 1B

5B7B 12B

1C

27A/B

26B

22C

21C

28A/B 1J29A/B

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110, Floor 2 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

N

D203A

D203A

B219 B201

B216 D207 D220A

14A/B

1B

2B

5B 12A

9A

10A

6B 8A

2-3A

5A 6A

2-4A 4B 7A/B

3B

15A/B

11A

8B 2-1A2-2A

9B

1C

16A/B

8C

10B

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110, Floor 4 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

D429A

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

N

1N

1T

1Q

14B

23A 13A/B

23B

15B

1F

2B

1H 1S

22A

13C

18B

D402A

B433

B412D403A

B423A D417A1

D419A1

C401B

D412A1

19A/20A

19B20BIR

21A/B

1B

14A

1P14A

15A

17A/B

16A/BC401A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110, Floor 4- Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

N

10A/B

4, 5, 6 A/B

D404A

D420A

1D

D411A

D428AD415A1 D416A

D414A

B417B1

1T

1C

1K

7,8,9 A/B

3A/B

11B

1G

IL

1A

12B

1M

22B

11A 2A

1J 12A

D415B1

D430A

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110, Floor 5 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

4B

3B

4A 1A

3A

2 A/B

6A

5A

7A

7B

5B

6B1B

Drawing No.: 1 Checked: JAC

2A

7A 4A

1A

2B1B

3A

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 110, Floor 6 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

Sample Key:

● = No Asbestos Identified In Sample

● = Trace (<1%) Asbestos Identified In Sample

● = >1% Asbestos Identrified In Sample (Material is ACM)

4B

C602

6A

6B

7B5A5B

Drawing No.: 1 Checked: JAC

Froehling & Robertson, Inc.

Engineering • Environmental • Geotechnical 833 Professional Place Chesapeake, Virginia 23320 I USA

T 757.436.1111 I F 757.436.1674

Building 116 - Asbestos Sample Diagram Hampton Veteran Administration Medical Center

100 Emancipation Drive Hampton, Virginia

N

8B

3C

7A/B

4B

5B/6B

3A

4, 5, 6 A

9A

12A

13B

1A/2A

1B/2B 5C

3B

11A 8A

10A13A

12B 11B

10B

Sample Key:

● = No Asbestos…