B185 Asbestos Lead Survey.pdf

Pre-Demolition/Renovation Asbestos & Lead Survey Report (Option Year 4, Project #14)

Project Location:

Ralph H. Johnson Veterans Affairs Medical Center 109 Bee Street Charleston, SC 29401

Prepared for:

Jasmine Herbert, Industrial Hygienist Trainee

RHJ VAMC

109 Bee Street Charleston, SC 29401 Email: Jasmine.Herbert@va.gov

Prepared by:

Thunderbird Environmental, LLC 14 Leffingwell Road Clinton, CT 06413 Email: darby@tbirdenv.com

December 5, 2024

Pre-Demolition/Renovation Asbestos & Lead Paint Survey RHJ VAMC, Charleston, SC i

TABLE OF CONTENTS

EXECUTIVE SUMMARY ........................................................................................................... II

1. INTRODUCTION

1.1. Purpose

1.2. Scope of Services

1.3. Project Limitations

2. ASBESTOS BULK SAMPLING

2.1. Previous Asbestos Survey(s)

2.2. Sampling Methodology

2.3. Non-Suspect Material(s)

3. SITE PROVIDED INFORMATION

3.1. Site Provided Information

3.2. Previous Assessment Activities

4. FINDINGS AND CONCLUSIONS

5. RECOMMENDATIONS

6. SIGNATURE PAGE

7. REFERENCES

FIGURES

Figure 1 Room B185 Sample Locations Figure

TABLES

Table 1 Suspect ACM Sampling Information Table 2 Lead Paint Sampling Information

APPENDICES

Appendix A Laboratory Analytical Report(s) Appendix B Photograph Log of Homogenous Areas Appendix C Asbestos Inspector License(s) ii

EXECUTIVE SUMMARY

Limited Pre-Demolition/Renovation Asbestos and Lead Paint Survey Summary

Assessment Location: Ralph H. Johnson Veterans Affairs Medical Center located at 109 Bee Street, Charleston, South Carolina 29401 (referred to herein as “the Site”).

Purpose of Assessment: Perform a limited pre-demolition/renovation asbestos and lead paint survey to identify, quantify, and sample suspect asbestos-containing materials (ACM) and potentially lead based paint (LBP), which could potentially be disturbed during the facility’s planned renovation activities within selected areas specified by the Site representatives. The asbestos survey specifically included suspect flooring, wall, ceiling / plenum space systems in the following locations: Room B185

(and also plenum space in Room B184). The lead paint survey specifically included sampling of the paint on the entrance door / door frame of Room B185.

Assessment Activities: The survey was conducted on November 12, 2024, by Mr. William Swain (BI-

002267) of Thunderbird Environmental, LLC (Thunderbird). Within each inspected area noted above, suspect materials were sampled based on those materials identified by Site representatives with the potential for disturbance. Samples were submitted to CEI Eurofins (CEI) in Cary, North Carolina, a

National Voluntary Laboratory Accreditation Program accredited laboratory (NVLAP code 101768-0), for analysis of asbestos content by the Polarized Light Microscopy (PLM) method. Non-friable organically bound materials with negative PLM results were further analyzed by the Transmission

Electron Microscopy (TEM) method, as required by South Carolina Department of Health and

Environmental Control (SCDHEC). Additionally, one paint chip sample (collected from the door/ door frame) was submitted to CEI in Fort Mill, South Carolina (NVLAP code 600323-0) for lead content in paint via EPA SW846 7000B (Flame AA) method. A summary of suspect materials included in the asbestos survey, with those confirmed to have detections of asbestos (if any) indicated in bold, is included in Table 1. Additionally, a summary of sampled paint materials is included in Table 2, with those detections of lead content in paint in excess of the Federal Environmental Protection Agency (US

EPA) lead based paint threshold of 0.5% lead by weight, or SC Department of Environmental Services

(SC DES) lead based paint threshold of 600 ppm indicated in bold (if any).

Key Findings

As detailed in Table 1, none of the materials sampled were reported to contain asbestos.

Additionally, as detailed in Table 2, the paint chip sample collected from the entrance door / door frame of Room B185 had lead detected at 0.0106% (106 ppm) concentration by weight, which is below both the EPA and SC DES thresholds for classification as lead-based paint.

Recommendations iii

Recommendations resulting from the limited pre-demolition/renovation ACM & LBP survey include the following:

Asbestos:

Any suspect material not included in this report should be treated as ACM, and should not be disturbed until sampled, tested, and proven otherwise.

Lead Paint:

Although the paint sample collected from the Room B185 entrance door / door frame had lead detected below the EPA and SC DES thresholds for classification as lead based paint, OSHA Lead

Construction Standards (29 CFR 1926.62) applies to all demolition or construction activities were lead or materials containing lead are present. As such, appropriate precautions and safe work practices should be implemented in accordance with the standard to prevent dust generation and potential occupational exposures.

1. INTRODUCTION

Thunderbird Environmental, LLC (Thunderbird) was retained by Ralph H. Johnson Veterans Affairs Medical

Center (RHJ VAMC) located at 109 Bee Street Charleston, South Carolina (hereinafter referred to as “the

Site”) to conduct a limited pre-demolition/renovation asbestos and lead paint survey of specific areas planned for future renovations. This included suspect flooring, wall, and ceiling / plenum space systems in the following locations: Room B185. The plenum space in Room B184 was also inspected, as requested by site representatives. The specific locations included in the survey are detailed in Section 2.0 of this report.

1.1. Purpose

The purpose of this limited pre-demolition/renovation asbestos and lead paint survey was to identify, quantify, and sample suspect asbestos containing material (ACM) and potential lead based paint (LBP), which could potentially be disturbed during the Site’s planned renovation activities within selected areas specified by the Site representatives. No non-suspect materials, which are defined as materials that are not expected to contain asbestos, were sampled or analyzed as part of this survey.

1.2. Scope of Services

This limited pre-demolition/renovation survey was performed in accordance with SCDHEC and Asbestos

National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations and included the following general components: (1) Site walkthrough, (2) Identification, classification, bulk sample collection of suspect ACM, and (3) interpretation of laboratory analytical results. Information provided by the Site contact about the specific areas and planned renovation tasks was used to determine what suspect material to be included in the survey. Additionally, as requested by site representatives, a paint chip sample was collected from the entry door / door frame to determine if the door paint contained lead. The scope of services provided by Thunderbird, during the completion of this limited pre-demolition/renovation ACM sand LBP survey, included the following tasks:

Review of applicable regulatory standards on asbestos, lead-based paint, and pre-demolition/renovation requirements;

Coordination with a NVLAP accredited laboratory for bulk sample analysis;

Walkthrough of all areas of interest with the Site representatives and review the scope of the pre-demolition/renovation project;

Identification, classification, quantification, and bulk sample collection of suspect ACM and LBP which could potentially be disturbed during the planned pre-demolition/renovation project; and

Interpretation of laboratory analytical reports.

No significant scope-of-work additions or modifications other than that noted above was included in this limited pre-demolition/renovation ACM an lead paint survey.

1.3. Site Provided Information

During the performance of this assessment, background information received from Site contacts included the following: Identification of areas and materials with the potential to be impacted during future renovation activities within Room B185 and air plenum space in Room B184.

The Site representatives specifically requested the inspection for suspect ACM / lead paint which could potentially be disturbed during planned renovations. During this survey, Site contacts provided details on the planned renovation activities to aid Thunderbird’s inspector in determining which suspect ACM materials could potentially be disturbed.

1.4. Project Limitations

This pre-demolition/renovation asbestos and lead paint survey was focused solely on suspect materials with the potential for disturbance during the planned renovation in areas specified by the Site representatives. If any additional materials other than those sampled and reported in this survey are identified within these areas during the renovation activities, they should be treated as asbestos-containing until proven otherwise via sampling and analysis in accordance with SC DES regulations.

2. ASBESTOS BULK SAMPLING

On November 12, 2024, Mr. William Swain (BI-002267) of Thunderbird conducted a pre-demolition/renovation ACM survey for selected areas of the Ralph H. Johnson VA Medical Center. The scope of this survey was limited to the following specific areas and building components/systems as designated by Site contacts with the potential to be disturbed during planned renovation activities:

• Room B185: Flooring (vinyl floor tile, mastic, leveling compound), wall (vinyl cove base, mastics, joint compound, drywall), and ceiling / plenum space (ceiling tile) systems

• Room B184: Air plenum space

This survey was conducted in accordance with the requirements set forth by NESHAP for pre-renovation asbestos surveys outlined in the United States Environmental Protection Agency (US EPA) document 40

CFR Part 61 Subpart M, and as such, both destructive and non-destructive sampling techniques were employed by Thunderbird to the extent necessary to collect all samples. This survey also complies with SC

DES specific requirements set forth in Regulation R.61-86.1 Standards for Performance of Asbestos

Projects. Reasonable effort was made during the survey to limit damage caused to the building and to eliminate the creation of a safety hazard or affect the overall integrity of the Site structures.

2.1. Previous Asbestos Survey(s)

No previous pre-demolition/renovation survey (if any) was provided for review by Thunderbird for the

Site-specific areas of planned renovation. Thunderbird has previously conducted asbestos surveys within the same floor and have encountered flooring systems similar to flooring systems encountered during this survey. This includes but is not limited to Thunderbird’s Pre-Demolition/Renovation Asbestos Surveys

Report (Option Year 4, Project #1/#5/#8) dated May 1, 2024. A copy of the report has not been included as an attachment to this report, as it has previously been provided to the RHJ VACM.

2.2. Sampling Methodology

Thunderbird personnel systematically inspected specific portions of the Site building which could potentially be impacted during future renovation activities, as described above, and specified by the Site representatives. During the survey, the inspector classified each suspect ACM as one (1) of three (3) types:

Surfacing Materials - ACM sprayed or troweled on surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes.

Thermal System Insulation (TSI) - Insulation used to inhibit heat transfer or prevent condensation on pipes, boilers, tanks, ducts, and various other components of hot and cold-water systems and heating, ventilation, and air conditioning (HVAC) systems. This includes pipe lagging, pipe wrap;

block, batt, and blanket insulation; cements and “muds”; and a variety of other products such as gaskets and ropes; or, Miscellaneous Material – Other, largely non-friable products and materials such as floor tile, ceiling tile, roofing felt, concrete pipe, outdoor siding, and fabrics.

The inspector touched all suspect materials specified for disturbance by Site contacts to determine the extent to which the material, when dry, may be crumbled, pulverized, or reduced to powder by hand.

During the survey, suspect materials identified by the inspector were also evaluated for overall condition, and each suspect material was assigned a condition of significantly damaged, damaged, or good overall condition for the locations the materials were observed. As defined by the US EPA under Asbestos Hazard

Emergency Response Act (AHERA), a material is significantly damaged if ten percent (10%) or greater of the material is evenly deteriorated, crumbling, hanging, or if the material contains over 25% localized damage. A damaged material is one that has less than 10% evenly distributed damage or less than 25% localized damage. A material in good condition is a material with no visible damage or deterioration or showing only very limited damage or deterioration.

Each suspect ACM was also classified into a homogeneous sampling area (HA). An HA is an area which is uniform in texture and appearance, was likely installed during the same period, and is unlikely to consist of more than one type or formulation of material. The inspector collected samples of each material from each HA, with multiple samples of a single material collected as appropriate. Samples were not collected from materials that were readily identifiable as non-asbestos containing (i.e., wood, fiberglass, foam, rubber, paper wraps, etc.) or previously confirmed to be asbestos containing (if applicable).

To avoid disturbing the material any more than necessary and to minimize any unnecessary release of potential asbestos fibers during collection, Thunderbird’s inspector performed bulk sampling of suspect

ACM in accordance with generally accepted procedures outlined in the US EPA document "Guidance for

Controlling Asbestos-Containing Materials in Buildings" (EPA-560/5-85-024, June 1985). Each sample was collected using wet methods and placed in clean, sealable plastic bags and labeled with a unique sample identification number.

Bulk samples were submitted for analysis of asbestos content by Eurofins CEI Labs, Inc. (CEI), located in

Cary, North Carolina, a NVLAP accredited laboratory (NVLAP code 101768-0). CEI analyzed each material using polarized light microscopy (PLM) analysis method. Non-friable organically bound materials with negative PLM results were further analyzed by the Transmission Electron Microscopy (TEM) method, as required by South Carolina Department of Health and Environmental Control (SCDHEC).

2.3. Sampling Results

As detailed in Table 1, none of the materials sampled were reported to contain asbestos.

2.4. Non-Suspect Material(s)

Non-suspect materials, which are defined as materials that are not expected to contain asbestos, were not sampled, or analyzed. Non-suspect materials typically include general building materials (e.g., glass, metals, brick, fiberglass, concrete, wood, cinderblock, and rubber). Non-suspect material observed during this survey included:

Concrete floor surfaces underneath the sampled flooring systems.

White fiberglass reinforced plastic (FRP) wall panel in Room B185.

Please note that if a suspect material is later identified on-site and is not among those materials identified in this report, that material must be assumed to be asbestos containing until sampled and proven otherwise.

3. LEAD BASED PAINT SAMPLING

On November 12, 2024, Thunderbird additionally conducted a pre-demolition/renovation lead survey for selected areas of the Ralph H. Johnson VA Medical Center. The scope of this survey was limited to the following specific areas and building components/systems as designated by Site contacts with the potential to be disturbed during planned renovation activities:

Room B185: Paint on entrance door / door frame.

During Thunderbird’s visual assessment, no visual paint deterioration/chipping was observed in the survey area. Reasonable effort was made during the survey to limit damage caused to the building and to eliminate the creation of a safety hazard or affect the overall integrity of the Site structures.

This survey was conducted to identify if lead was present in the painted surfaces with the potential for disturbance, for a comparison with lead based paint classification thresholds provided within SC DES

Regulation R.61-107.19, EPA / Housing and Urban Development (HUD), and to generally determine applicability of the Occupational Safety and Health Administration (OSHA) Lead Construction regulation.

3.1. Sampling Results

As detailed in Table 2, one paint chip sample (collected from the door/ door frame) was submitted to CEI in Fort Mill, South Carolina (NVLAP code 600323-0) for lead content in paint via EPA SW846 7000B (Flame

AA) method.

Based on laboratory analytical results, lead was detected in the paint sample at 0.0106% concentration by weight. This percentage is below the SC DES lead based paint threshold of 600 ppm and Federal Lead

Standard / HUD standard of 0.05% concentration by weight. However, as lead was present within the sampled painted surface, the OSHA Lead Construction regulation would apply.

4. FINDINGS AND CONCLUSIONS

As detailed in Table 1, none of the materials sampled were reported to contain asbestos.

Additionally, as detailed in Table 2, the paint chip sample collected from the entrance door / door frame of Room B185 had lead detected at 0.0106% concentration by weight, which is below the SC DES threshold of 600 ppm and Federal Lead Standard (0.5% lead by weight), and therefore is not considered lead-based paint. However, it is important to note that the OSHA Lead Construction standard (29 CFR 1926.62) generally applies to all construction/demolition activities were lead or materials containing lead are present.

A summary of suspect materials included in the asbestos survey, with those confirmed to have detections of asbestos (if applicable) indicated in bold, is included in Table 1. Additionally, a summary of sampled paint materials is included in Table 2, with any observed in excess of the SC DES or federal EPA/HUD lead based paint thresholds indicated in bold (if applicable). The complete asbestos and lead paint laboratory analytical report is provided in Appendix A, and a figure depicting sample locations are provided in Figures

1. A photograph log depicting each homogeneous sampling area is also provided in Appendix B, with

Thunderbird’s inspector license documentation provided in Appendix C.

5. RECOMMENDATIONS

Based on the findings of this pre-demolition/renovation asbestos and lead paint survey, Thunderbird recommends the following:

Asbestos:

Any other suspect material not included in this report should be treated as ACM, and should not be disturbed until sampled, tested, and proven otherwise.

Lead Based Paint:

Although the paint sample collected from the Room B185 entrance door / door frame had lead detected below the SC DES and Federal EPA/HUD Lead Standard, OSHA Lead Construction

Standards (29 CFR 1926.62) applies to all construction or demolition activities were lead or materials containing lead are present. As such, appropriate precautions and safe work practices should be implemented when disturbing the Room B185 entrance door / door frame in accordance with the standard to prevent dust generation and potential occupational exposures.

6. SIGNATURE PAGE

Thunderbird Environmental, LLC, with over 40 years of combined experience in environmental consulting certify that this limited pre-demolition/renovation survey has been completed in accordance with the

NESHAP and SCDHEC current regulations and requirements.

SC DHEC

Expiration.

Date

Signature Date

Survey Conducted by:

Mr. William Swain, Thunderbird

BI-002267 1/17/25

11/12/24

Signature Date

Report Reviewed by:

Mr. Jacob C. Smith, CIH HRP Associates, Inc.

Principal and Sr. Project Manager

12/5/2024

Report Issued by:

Darby W. Hittle, L.E.P Thunderbird Environmental LLC.

President/Owner

12/5/24

7. REFERENCES

Code of Federal Regulations Title 40, Chapter 1, Subpart C, Part 61, Subpart M (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-61/subpart-M)

Code of Federal Regulations Title 24, Subtitle A, Part 35, Subpart B (https://www.ecfr.gov/current/title-

24/subtitle-A/part-35/subpart-B)

Code of Federal Regulations Title 40, Part 745: Lead; Identification of Dangerous Levels of Lead https://www.govinfo.gov/content/pkg/FR-2001-01-05/pdf/01-84.pdf

Occupational Health and Safety Administration, Standard Interpretations, Section 1910.1001(j)(8). (Bulk asbestos analysis and worker air exposures to less than 1% asbestos | Occupational Safety and Health Administration (osha.gov))

Occupational Health and Safety Administration. 29 CFR 1926.62 – Lead Exposure in Construction.

https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.62

SC DES Solid Waste Management Regulation R.61-107.19, Solid Waste Management https://des.sc.gov/sites/des/files/Library/Regulations/R.61-107.19.pdf

South Carolina DES Regulation 61-86.1, Standards of Performance of Asbestos Projects (https://live-sc-dhec.pantheonsite.io/sites/default/files/media/document/R.61-86.1.pdf)

United States Environmental Protection Agency, Asbestos and School Buildings

(https://www.epa.gov/asbestos/asbestos-and-school-buildings)

United States Code Title 15, Chapter 53, Subchapter IV, Section 2681 https://www.govinfo.gov/content/pkg/USCODE-2009-title15/html/USCODE-2009-title15-chap53-subchapIV-sec2681.htm

FIGURE(S)

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FIGURE NO.

LEGEND

Green sample location indicates no asbestos reported.

Blue sample location (paint on door) indicates no lead reported above Federal Lead Standard / HUD or SC DES LBP Threshold.

Thunderbird Callout

HA-1-A

Thunderbird Callout

HA-1-B,C

HA-6-C

Thunderbird Callout

HA-2-A,B

HA-3-A,B,C

HA-4-A,B

Thunderbird Callout

HA-4-C

HA-5-A,B,C

Thunderbird Callout

HA-6-A,B

Thunderbird Callout

HA-2-C

Thunderbird Callout

PC-1

TABLE(S)

Table 1 of 2

TABLE 1: SUSPECT ACM SAMPLING INFORMATION

HA # Sample IDs Material Description Material

Locations(1) Sample

Locations Type, Condition

Friable (Y/N)

Approx.

Quantity (1)

ACM

(Y/N)

Asbestos Type

HA-1 HA-1-A, B, C

12”x12” Tan Vinyl Composite Tile

B185 B185 Misc., Good N 100 ft2

N ND

Clear Mastic(2) N ND Grey leveling compound N ND

HA-2 HA-2-A, B, C

Tan Vinyl Covebase

B185 B185 Misc., Good N 30 LF

N ND

Tan Mastic N ND HA-3 HA-3-A, B, C Tan Mastic (located behind non-suspect white FRP wall panel) B185 B185 Misc., Good N 120 ft2 N ND

HA-4 HA-4-A, B,C white joint compound B185/B184 B185 Surfacing, Good Y 40 ft2 N ND

HA-5 HA-5-A, B, C white drywall B185/B184 B185 Surfacing, Good Y 400 ft2 N ND

HA-6 HA-6-A, B, C 12”x12” white fissured ceiling tile B185/B184 B185 Misc., Good Y 200 ft2 N ND

(1) Homogeneous sampling areas identified in this table are based on information provided by the site. Material locations and total quantities for each suspect material were estimated at the discretion of the survey inspector(s) based on only the accessed interior locations noted which were reported by the site to be a part of the planned demolition/renovation activities. These should not be construed with total locations/quantities for the site building.

(2) Insufficient sample for TEM analysis. Thunderbird has previously encountered clear flooring mastic on this floor during prior asbestos surveys which were non-detect for asbestos via TEM analysis and were consistent with the clear mastic encountered during this survey.

ND: No Asbestos Content Detected LF: linear feet

Table 2 of 2

TABLE 2: Lead Paint Sampling Information

Sample ID Lab ID Material Description Material

Locations(1) Substrate

Type Condition Sampling Results(2) (% Weight / PPM)

Federal Lead Standard / HUD(3)

(% Weight)

SC DES LBP

Threshold(4)

(% Weight / PPM) PC-1 L06719 Tan paint sample on Room B185 entrance door / door frame B185 Metal Intact (paint) 0.106 / 106 0.5 0.06 / 600

(1) Sampling areas identified in this table are limited to select locations requested by site representatives; these results should not be construed to represent lead in paint results throughout the site building.

(2) Lead sampling via method EPA SW846 7000B (Flame Atomic Absorption Spectrophotometry).

(3) Lead-Based Paint by definition - Lead Poisoning Prevention Act (42 U.S.C. 4822(c)) and TSCA section 401(9) (15 U.S.C. 2681(9).

(4) South Carolina Department of Environmental Services Lead-Based Paint Threshold (Regulation 61-107.19 Solid Waste Management: Solid Waste Landfills and Structural Fill).

PPM = parts per million

APPENDIX A

LABORATORY ANALYTICAL REPORT(S)

November 15, 2024

HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

CLIENT PROJECT: YR 4 - Project #14, 2020-04-14

CEI LAB CODE: B2422447

Dear Customer:

Enclosed are asbestos analysis results for PLM Bulk samples received at our laboratory on November 14, 2024. The samples were analyzed for asbestos using polarizing light microscopy (PLM) per the EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building Materials and EPA 40 CFR Appendix E to Subpart E of Part 763: Interim Method of the Determination of Asbestos in Bulk Insulation Samples.

Sample results containing >1% asbestos are considered asbestos-containing materials (ACMs) per EPA regulatory requirements. The detection limit for the EPA 600/R-93/116 Method and EPA 40 CFR Appendix E to Subpart E of Part 763 is <1% asbestos as determined by visual estimation.

Thank you for your business and we look forward to continuing good relations.

730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Tianbao Bai, Ph.D., CIH Laboratory Director

Kind Regards, ASBESTOS ANALYTICAL REPORT

By: Polarized Light Microscopy

Prepared for

HRP Associates

CLIENT PROJECT:

LAB CODE:

TEST METHOD: EPA 600 / R-93 / 116 and EPA 40 CFR Appendix E to Subpart E of Part 763

REPORT DATE:

TOTAL SAMPLES ANALYZED:

# SAMPLES >1% ASBESTOS:

YR 4 - Project #14, 2020-04-14

11/15/24

B2422447

730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Asbestos Report Summary By: POLARIZING LIGHT MICROSCOPY

PROJECT: YR 4 - Project #14, 2020-04-14 LAB CODE: B2422447

Client ID Lab ID Color Sample Description

ASBESTOS

%Layer

METHOD: EPA 600 / R-93 / 116 and EPA 40 CFR Appendix E to Subpart E of Part 763

HA-1-A B2422447.01A Tan Floor Tile None DetectedHA-1-A

Layer 1 B2422447.01B Clear Mastic None Detected

Layer 2 B2422447.01B Gray Leveling Compound None Detected

HA-1-B B2422447.02A Tan Floor Tile None DetectedHA-1-B

Layer 1 B2422447.02B Clear Mastic None Detected

Layer 2 B2422447.02B Gray Leveling Compound None Detected

HA-1-C B2422447.03A Sample Submitted for TEM Analysis

HA-1-C

Layer 1 B2422447.03B Sample Submitted for TEM Analysis

Layer 2 B2422447.03B Gray Leveling Compound None Detected

HA-2-A B2422447.04A Tan Covebase None DetectedHA-2-A

B2422447.04B Tan Mastic None Detected

HA-2-B B2422447.05A Tan Covebase None DetectedHA-2-B

B2422447.05B Tan Mastic None Detected

HA-2-C B2422447.06A Sample Submitted for TEM Analysis

HA-2-C

B2422447.06B Sample Submitted for TEM Analysis

HA-3-A B2422447.07 Tan Frp Mastic None DetectedHA-3-A

HA-3-B B2422447.08 Tan Frp Mastic None DetectedHA-3-B

HA-3-C B2422447.09 Sample Submitted for TEM Analysis

HA-3-C

HA-4-A B2422447.10 White Joint Compound None DetectedHA-4-A

HA-4-B B2422447.11 White Joint Compound None DetectedHA-4-B

HA-4-C B2422447.12 White Joint Compound None DetectedHA-4-C

HA-5-A B2422447.13 White,Tan Drywall None DetectedHA-5-A

HA-5-B B2422447.14 White,Tan Drywall None DetectedHA-5-B

HA-5-C B2422447.15 White,Tan Drywall None DetectedHA-5-C

HA-6-A B2422447.16 White,Tan Ceiling Tile None DetectedHA-6-A

HA-6-B B2422447.17 White,Tan Ceiling Tile None DetectedHA-6-B

HA-6-C B2422447.18 White,Tan Ceiling Tile None DetectedHA-6-C

Page 1 of 1730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

ASBESTOS BULK ANALYSIS

Lab Code: B2422447 Date Received: 11-14-24 Date Analyzed: 11-15-24 Date Reported: 11-15-24

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600/R-93/116 METHOD and EPA 40 CFR Appendix E Subpart E to Part 763

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

Project: YR 4 - Project #14, 2020-04-14

Fibrous

Tan Floor TileHA-1-A

B2422447.01A 10%Heterogeneous

Fibrous Bound

90%Synthetic Fiber Vinyl None Detected

Clear Mastic

B2422447.01B Homogeneous

Non-fibrous Bound

100% Mastic None DetectedLayer 1

Gray Leveling Compound

B2422447.01B <1%Heterogeneous

Non-fibrous Bound

65% 35%

Cellulose Silicates Binder

None DetectedLayer 2

Tan Floor TileHA-1-B

B2422447.02A 10%Heterogeneous

Fibrous Bound

90%Synthetic Fiber Vinyl None Detected

Clear Mastic

B2422447.02B Homogeneous

Non-fibrous Bound

100% Mastic None DetectedLayer 1

Gray Leveling Compound

B2422447.02B <1%Heterogeneous

Non-fibrous Bound

65% 35%

Cellulose Silicates Binder

None DetectedLayer 2

Sample Submitted for TEM Analysis

HA-1-C

B2422447.03A

Sample Submitted for TEM AnalysisB2422447.03B

Layer 1

Page 1 of 5730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Lab Code: B2422447 Date Received: 11-14-24 Date Analyzed: 11-15-24 Date Reported: 11-15-24

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600/R-93/116 METHOD and EPA 40 CFR Appendix E Subpart E to Part 763

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

Project: YR 4 - Project #14, 2020-04-14

Fibrous

Gray Leveling Compound

B2422447.03B <1%Heterogeneous

Non-fibrous Bound

65% 35%

Cellulose Silicates Binder

None DetectedLayer 2

Tan CovebaseHA-2-A

B2422447.04A Heterogeneous

Non-fibrous Bound

100% Vinyl None Detected

Tan MasticB2422447.04B Homogeneous

Non-fibrous Bound

100% Mastic None Detected

Tan CovebaseHA-2-B

B2422447.05A Heterogeneous

Non-fibrous Bound

100% Vinyl None Detected

Tan MasticB2422447.05B Homogeneous

Non-fibrous Bound

100% Mastic None Detected

Sample Submitted for TEM Analysis

HA-2-C

B2422447.06A

Sample Submitted for TEM Analysis

B2422447.06B

Tan Frp MasticHA-3-A

B2422447.07 Homogeneous

Non-fibrous Bound

100% Mastic None Detected

Page 2 of 5730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Lab Code: B2422447 Date Received: 11-14-24 Date Analyzed: 11-15-24 Date Reported: 11-15-24

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600/R-93/116 METHOD and EPA 40 CFR Appendix E Subpart E to Part 763

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

Project: YR 4 - Project #14, 2020-04-14

Fibrous

Tan Frp MasticHA-3-B

B2422447.08 Homogeneous

Non-fibrous Bound

100% Mastic None Detected

Sample Submitted for TEM Analysis

HA-3-C

B2422447.09

White Joint CompoundHA-4-A

B2422447.10 Heterogeneous

Non-fibrous Bound

65% 35%

Binder Calc Carb

None Detected

White Joint CompoundHA-4-B

B2422447.11 Heterogeneous

Non-fibrous Bound

65% 35%

Binder Calc Carb

None Detected

White Joint CompoundHA-4-C

B2422447.12 Heterogeneous

Non-fibrous Bound

65% 35%

Binder Calc Carb

None Detected

White,Tan DrywallHA-5-A

B2422447.13 20%Heterogeneous

Fibrous Bound

80%Cellulose Gypsum None Detected

White,Tan DrywallHA-5-B

B2422447.14 20%Heterogeneous

Fibrous Bound

80%Cellulose Gypsum None Detected

White,Tan DrywallHA-5-C

B2422447.15 20%Heterogeneous

Fibrous Bound

80%Cellulose Gypsum None Detected

Page 3 of 5730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Lab Code: B2422447 Date Received: 11-14-24 Date Analyzed: 11-15-24 Date Reported: 11-15-24

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600/R-93/116 METHOD and EPA 40 CFR Appendix E Subpart E to Part 763

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

Project: YR 4 - Project #14, 2020-04-14

Fibrous

White,Tan Ceiling TileHA-6-A

B2422447.16 60% 20%

Heterogeneous

Fibrous Loosely Bound

15% 5%

Cellulose Fiberglass

Perlite Paint

None Detected

White,Tan Ceiling TileHA-6-B

B2422447.17 60% 20%

Heterogeneous

Fibrous Loosely Bound

15% 5%

Cellulose Fiberglass

Perlite Paint

None Detected

White,Tan Ceiling TileHA-6-C

B2422447.18 60% 20%

Heterogeneous

Fibrous Loosely Bound

15% 5%

Cellulose Fiberglass

Perlite Paint

None Detected

Page 4 of 5730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

LEGEND: Non-Anth = Non-Asbestiform Anthophyllite Non-Trem = Non-Asbestiform Tremolite Calc Carb = Calcium Carbonate

METHOD: EPA 600 / R-93 / 116 and EPA 40 CFR Appendix E to Subpart E of Part 763

REPORTING LIMIT FOR PLM: 1% by calibrated visual estimation

REPORTING LIMIT FOR POINT COUNTS: 0.25% by 400 Points or 0.1% by 1,000 Points

REGULATORY LIMIT: >1%

Due to the limitations of the EPA 600/R-93/116 method, nonfriable organically bound materials (NOBs) such as vinyl floor tiles can be difficult to analyze via polarized light microscopy (PLM). EPA recommends that all NOBs analyzed by PLM, and found not to contain asbestos, be further analyzed by Transmission Electron Microscopy (TEM). Please note that PLM analysis of dust and soil samples for asbestos is not covered under NVLAP accreditation. Estimated measurement of uncertainty is available on request.

This report relates only to the samples tested or analyzed and may not be reproduced, except in full, without written approval by Eurofins CEI. Eurofins CEI makes no warranty representation regarding the accuracy of client submitted information in preparing and presenting analytical results.

Interpretation of the analytical results is the sole responsibility of the client. Samples were received in acceptable condition unless otherwise noted. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. Government.

Information provided by customer includes customer sample ID and sample description.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH Laboratory Director

Regan Kerns

November 18, 2024

701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

CLIENT PROJECT: YR 4 - Project #14, 2020-04-14

LAB CODE: T241969

Dear Customer:

Enclosed are asbestos analysis results for TEM bulk samples received at our laboratory on November 15, 2024. The samples were analyzed for asbestos using transmission electron microscopy (TEM) per Chatfield/EPA 600/R-93/116 Sec. 2.5.5.1 method.

Sample results containing > 1% asbestos are considered asbestos-containing materials (ACMs) per the EPA regulatory requirements. The detection limit for the TEM Chatfield/EPA 600/R-93/116 Sec. 2.5.5.1 method is <1% depending on the processed weight and constituents of the sample.

Thank you for your business and we look forward to continuing good relations.

Tianbao Bai, Ph.D., CIH Laboratory Director

Kind Regards, ASBESTOS ANALYTICAL REPORT

By: Transmission Electron Microscopy

Prepared for

HRP Associates

CLIENT PROJECT:

LAB CODE:

TEST METHOD: Bulk Chatfield EPA 600 / R93 / 116 Sec. 2.5.5.1

REPORT DATE:

YR 4 - Project #14, 2020-04-14

11/18/24

T241969

By: TRANSMISSION ELECTRON MICROSCOPY

Lab Code: T241969 Date Received: 11-15-24 Date Analyzed: 11-18-24 Date Reported: 11-18-24

Client ID Lab ID

Material Description

TEM BULK CHATFIELD / EPA 600 / R93 / 116 Sec. 2.5.5.1

Client: HRP Associates 701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

Project: YR 4 - Project #14, 2020-04-14

Sample Weight

(g)

Organic Material

Acid Soluble Material

Acid Insoluble Material

Asbestos

T83351 HA-1-C Tan Floor Tile 0.414 50.5 49.3 .2 None

Detected

T83352 HA-1-C Clear Mastic 0-27.91 0 100 0 <1%Insufficient

T83353 HA-2-C Tan Covebase 0.441 56.5 40.6 2.9 None

Detected

T83354 HA-2-C Tan Mastic 0.14 45 47.1 7.9 None

Detected

T83355 HA-3-C Tan Frp Mastic 0.214 34.6 27.6 37.8 None

Detected

LEGEND: None

METHOD: CHATFIELD & EPA/600/R-93/116 Sec. 2.5.5.1

LIMIT OF DETECTION: Varies with the weight and constituents of the sample (<1%)

REGULATORY LIMIT: >1% by weight

This report relates only to the samples tested or analyzed and may not be reproduced, except in full, without written approval by Eurofins CEI (ECEI). ECEI makes no warranty representation regarding the accuracy of client submitted information in preparing and presenting analytical results.

Interpretation of the analytical results is the sole responsibility of the client. Estimated measurement of uncertainty is available on request and in compliance with regulatory requirements. Samples were received in acceptable condition unless otherwise noted.

Information provided by customer includes customer sample ID, location, volume and area as well as date and time of sampling.

ECEI recommends between 0.20 and 0.50 grams of sample material for TEM bulk analysis.

Any weight below 0.10 grams is considered below protocol guidelines.

**Indicates sample weight below 0.05 grams and is considered insufficient for quantitative analysis.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH Laboratory Director

Partima Poudel Acharya

701 Easley Bridge Road, Suite 4130, Building 4000 Greenville, SC 29611

11-14-24 11-18-24Analyzed:

LABORATORY REPORT

LEAD IN PAINT

Lab Code: L241208

LAB ID

Received:

CLIENT ID

YR4-Project 14Project:

Client:

PPM (µg/g) CONCENTRATION

% BY WEIGHT

2752 Pleasant Rd Suite 100A • Fort Mill, SC 29708

TEL: 803-526-5146

METHOD: EPA SW846 7000B

11-18-24Reported:

PC-1 L06719 0.0106106

LEGEND µg = microgram ml = milliliter ppm = parts per million Pb = lead g = grams

Reviewed By:

This method has been validated for sample weights of 0.25g or greater. When samples with a weight of less than that are analyzed those results fall outside of the scope of accreditations.

* The analysis of composite wipe samples as a single samples is not included under AIHA LAP, LLC accreditation.

Minimum reporting limit is 13.7 µg total lead. Sample results denoted with a “less than” (<) sign contain less than 13.7 µg total lead, based on a 50ml sample volume.

REGULATORY

LIMITS

Federal Lead Standard / HUD: 0.5% lead by weight.

wt = weight

Consumer Products Safety Standard: Greater than 0.009% lead by weight.

OSHA Standard: No safe limit.

Lead samples are analyzed by Eurofins CEI, an AIHA LAP, LLC ELLAP accredited laboratory (AIHA Lab ID: LAP-290960) for lead analysis of air, soil, wipes, and paint samples.

Laboratory results represent the analysis of samples as submitted by the client. Information regarding sample location, description, area, volume, etc., was provided by the client. Unless notified in writing to return samples, Eurofins CEI discards client samples after 30 days. This report shall not be reproduced, except in full, without the written consent of Eurofins CEI. Information provided by customer includes customer sample ID, location, volume and area as well as date and time of sampling.

Tianbao Bai, Ph.D.

Laboratory Director

End of Report

L01 - Insufficient sample weight L02 - Endcaps missing; possible cross contamination or sample loss L03 - Sample weight below protocol guidelines L04 - Sample contains substrate, potentially affecting results L05 - Sample weight below protocol guidelines and contains substrate, potentially affecting results

Page 12752 Pleasant Rd Suite 100A • Fort Mill, SC 29708 • 803.526.5146

APPENDIX B

HOMOGENEOUS AREA PHOTO LOG

Site Address: 109 Bee Street, Charleston, SC Photographed: Nov. 12, 2024 https://netorg189821.sharepoint.com/Shared Documents/2020/2020_013 - VA Charleston IH Services/Option Year 4_2024 Projects/11_06_2024 - Project #14 - Option Yr 4 Task 5_14 - ACM and LBP Sampling B185/Photos/_Photograph Log.docx

HA-1: 12”x12” tan vinyl floor tile, white mastic, and grey/white leveling compound HA-2: tan vinyl cove base, tan mastic

HA-3: tan mastic (located behind white FRP wall panel)

HA-4-A,B also collected from behind white FRP wall panel HA-5: white drywall (on western wall)

Site Address: 109 Bee Street, Charleston, SC Photographed: Nov. 12, 2024 https://netorg189821.sharepoint.com/Shared Documents/2020/2020_013 - VA Charleston IH Services/Option Year 4_2024 Projects/11_06_2024 - Project #14 - Option Yr 4 Task 5_14 - ACM and LBP Sampling B185/Photos/_Photograph Log.docx

HA-6: 12” x 12” white fissured ceiling tile PC-1: Paint sample collected from B185 Door and Door Frame

Interior of Room B185 (Exam / Treatment Room) Plenum Space above Room B184 and B185

(no suspect ACM identified in planned renovation area)

APPENDIX C

INSPECTOR ASBESTOS LICENSE(S)