Attachment 0004C -Triennial Asbestos Inspection Rpt Updated 2023.pdf

TRIENNIAL ASBESTOS

INSPECTION REPORT

PREPARED FOR

Birmingham Veterans Administration Health Care System 700 South 19th Street

Birmingham, AL 35233

PREPARED BY

Melbourne (Trey) D. Pierce III Charles Daley Speer

August 2020

Table of Contents

1.0 EXECUTIVE SUMMARY

2.0 INTRODUCTION

2.1 SCOPE OF WORK

2.2 SAMPLING METHODS, PROCEDURES AND PERSONNEL ............ 4-5

2.2.1 REVIEW OF PROCEDURES: ASBESTOS INSPECTION, BULK

SAMPLING, LABORATORY INFORMATION, AND RISK

ASSESSMENT.................................................................................................5-7

2.3 PROJECT CHARACTERISTICS………………………………………...

3.0 BUILDING SUMMARY

4.0 SURVEY RESULTS

4.1.1 SUMMARY OF PREVIOUIS SAMPLING EVENTS

4.1.2 FINDINGS OF 2017 & TRIENNIAL SURVEY & ASSESSMENT .... 9-10

5.0 INSPECTOR NAMES AND CONTACT INFORMATION……………. 11

6.0 LABORATORY IDENTITY AND IFORMATION

7.0 CONCLUSIONS AND RECOMMENDATIONS..................................... 13-15

8.0 LIMITING CONDITIONS

Appendices Asbestos Laboratory Sample Data ................................................... Appendix A

Asbestos Finish schedule & Hazard Assessment ............................. Appendix B

Sample Location Maps ..................................................................... Appendix C

Photographs ……………………………………………………….. Appendix D

VA Directive 7714 – Asbestos Management Program …………… Appendix E

1.0 EXECUTIVE SUMMARY

Federal Asbestos Hazard Emergency Act (AHERA) (40 CFR 763) and Environmental Protection Agency (EPA) require commercial buildings to reinspect previously identified and assumed asbestos-containing building materials (ACBM) in all facilities which or owned, leased or otherwise used every three (3) years. The AHERA triennial inspection must be performed by individual(s) certified as asbestos inspectors and management planners.

The objectives of the survey are:

Review previous Birmingham Veterans Administration Health Care System (BVAHCS) asbestos surveys, assessments and abatement records.

Conduct a comprehensive site evaluation of accessible locations within each specified building to identify, assess ad evaluate conditions(s) and collect representative bulk samples of previously unsampled or newly observed presumed asbestos containing material (ACBM) and suspect asbestos containing materials

(ACM).

Provide an asbestos health risk assessment and determine location and quantity estimates of ACBM and suspect ACBM.

A summary of the survey final results is incorporated into this report, providing a means for the BVAHCS to more efficiently plan for repairs, renovations and/or demolition.

2.0 INTRODUCTION

The BVAHCS Safety Office performed a Comp Comprehensive Triennial Asbestos Survey of the VA Health Care System in Birmingham, Alabama. The project was conducted to determine the existence and condition of Asbestos Containing Materials (ACM) in specified buildings. A summary of the survey final results is incorporated into this report providing a means for the VA to more efficiently plan for repairs, renovations and/or demolition projects. In addition, a comprehensive Access database was developed specifically to manage the asbestos and lead data obtained for this project.

2.1 SCOPE OF WORK

This survey is intended for the sole purpose of identifying suspect materials that may contain asbestos at the Birmingham VA Medical Center (BVAMC). A visual inspection was performed of previously sampled asbestos containing building material (ACBM) in the main facility, the Research Wing and the Z Wing (Blind Rehabilitation) of the BVAMC. The survey compiles, updates, and expands upon the original asbestos management plan and previous re-inspection surveys. Areas which have been completely abated and homogeneous areas that no longer remain were eliminated from the asbestos containing building materials (ACBM) inventory and information as to the location and quantity of ACBM was updated. Each homogeneous area of asbestos The survey specifically accomplished the following:

A. Obvious and accessible friable and non-friable ACBM within the three (3) areas mentioned above were documented.

B. A visual inspection of the specified areas was conducted (by an accredited asbestos inspector) and identified suspect ACBM.

C. Suspect materials were sampled as required.

D. Materials suspected of containing were sampled and analyzed (by Polarized Light

Microscopy (PLM) and dispersion staining techniques IAW the Environmental Protection Agency’s (EPA) Bulk Analysis Method (600/R-93/116.

E. A description is provided of those materials identified in the facility as containing asbestos.

F. The survey also documents the following:

Presence of ACBM in the facility at specific sampling locations.

An estimate of the quantities of identified ACBM.

Courses of action and recommendations for abatement/remediation options relative to existing ACBMs.

Drawings identifying sample locations and previously identified ACBM.

While the survey attempted to be a thorough and comprehensive as possible, some suspect ACBM (e.g., floor tile, ceiling tile, pipe insulation, plaster, various mastics) could have been concealed under or above other building material (e.g., carpet, suspended ceiling). Any concealed suspect ACBM that is discovered in future renovations will be sampled and analyzed for asbestos content prior to any removal/demolition activities.

Because of the age of the facility and past renovation projects, suspect ACBMs might be concealed (e.g., under carpet, above suspended ceilings) from sight. Multiple layers of floor tiles or multiple layers of roofing materials may hide suspect ACBMs.

The objective of this limited asbestos and lead survey is to provide the following information:

1. Identify, document and sample previously un-sampled suspect ACM;

2. Report, assess, and quantify all ACM discovered during the survey;

3. Provide comprehensive spreadsheet (finish schedule) of asbestos-containing materials identified.

The asbestos survey tasks included a review of previous asbestos surveys, abatement response action records, a thorough walk-thru of accessible areas within each building within the contract to identify accessible suspect asbestos finish/material, collection of representative samples for asbestos, assessment of the condition of the materials and quantification of the asbestos-containing materials throughout the specified buildings.

In accordance with the project requirements, samples were not taken if it rendered the material unstable, had the potential to cause leaking or other deterioration of the base material or if the sampling posed a hazard to those working in and around the building.

2.2 SAMPLING

A detailed sampling and analysis plan was prepared to facilitate sampling of homogeneous materials for asbestos. These are materials that are similar in appearance and texture, based on the substrate and/or suspect material. The asbestos survey was performed using general procedures and protocols defined in EPA 40 CFR, part 763.

The asbestos analyses were performed at an independent 3rd party accredited laboratory (Safety Environmental Laboratories & Consulting Inc., Pelham, Alabama) using the EPA 600/R-93/116 method. All locations within the scope of work were physically inspected and categorized by homogeneous area, to determine the presence of ACM.

BVAHCS personnel held accreditations for the respective type of work they performed.

These asbestos specific accreditations include: Asbestos Management Planner and Asbestos Building Inspector.

The team members and their respective accreditations that performed site assessment activities are:

1. Mr. Melbourne (Trey) Pierce (APL111983284),

2. Mr. Charles Daley Speer, PE (APL111983284)

Physical Inspection, material sampling and physical assessment of the materials within the BVAHCS was conducted between February and July 2020 by the personnel above.

2.2.1 REVIEW OF PROCEDURES: ASBESTOS INSPECTION, BULK

SAMPLING, LABORATORY INFORMATION, AND RISK ASSESSMENT

The asbestos inspection and bulk sampling procedures were based on the guidelines established by the U.S. EPA in the Guidance for Controlling Asbestos Containing Materials in Buildings, Office of Pesticides and Toxic Substances, DOC #560/5-85-024 and 40 CFR Part 763, Asbestos Hazard Emergency Response Act (AHERA). Field information was organized according to the AHERA concept of Homogeneous Areas (HA). A HA is defined as a suspect material of similar age, appearance, function, and texture. Each homogeneous material was grouped together as a specific HA, sampled, and then assessed for condition. The AHERA guidelines represent an industry standard sampling protocol and as such was utilized during the inspection and sampling.

The locations within the buildings were physically inspected on a space-by-space and homogeneous area by-homogeneous area basis, to determine the presence of ACM. Core samples of friable and non-friable suspect materials were collected by penetration of the suspect material to its substrate where possible. The bulk samples collected were placed in individual sealed containers and labeled with unique sample identification numbers.

Representative samples of each homogeneous sampling area were then submitted to the laboratory to be analyzed for asbestos content.

Specifically, the inspection involved the following tasks:

1. Visual determination as to the extent of visible and accessible suspect materials and conditions of the material;

2. Collection and analyses of suspect building materials for asbestos content;

3. Determining condition (i.e., friable or non-friable) of suspect materials by physically touching, assessing, and placing the material into the correct ACM category (i.e., Physical Condition Assessment);

4. Quantification of the amount of ACM friable and non-friable materials along with their location;

5. Identification of all suspect materials sampled on the appropriate building floor plan diagram with the sample number; and

6. Preparation of a Chain-of-Custody form that accompanied the samples to the laboratory.

2.2.1.a SAMPLE CHAIN OF CUSTODY AND CONTRACT LABORATORY

Chain-of-Custody procedures and records provide a means of tracing each sample from the time of collection through the shipment and final analyses. Proper Chain-of-Custody procedures also provide a written record of all persons handling the samples. The information necessary to relate sample locations for reporting purposes is documented with each sample. This information is essential to proper completion of a sample results report and typically includes client and facility information; unique sample identification number; date and time sampled; sampler name and signature; sample location including the room/area; and field sketches of sample locations.

All sample analyses were performed by Safety Environmental Laboratories & Consulting (SELC) Inc., located in Pelham, AL. SELC is a laboratory which is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP No. 200855-0) for bulk asbestos analyses.

2.2.1.b ASBESTOS MATERIAL PHYSICAL CONDITION ASSESSMENT

The U.S. EPA AHERA specifies that a physical assessment of all friable suspect material must be performed during the inspection. The physical condition assessment consists of determining the condition of the ACM, and the potential for future disturbance. AHERA lists seven categories in which to assess the current condition and potential for damage for those asbestos materials having an asbestos content greater than 1%. These are considered Asbestos Containing Materials (ACM). These categories are as follows:

1. Damaged or Significantly Damaged Friable Thermal System Insulation;

2. Damaged Friable Surfacing Material;

3. Significantly Damaged Friable Surfacing Material;

4. Damaged or Significantly Damaged Friable Miscellaneous Material;

5. ACM with potential for damage;

6. ACM with the potential for significant damage; and

7. Any remaining Friable ACM or Assumed Friable ACM.

Additionally, as part of the assessment and categorization of materials, the ACMs are further defined by the current condition of the ACM, and the potential for future damage.

These are defined as follows:

1. Current Condition of ACM: Intact, damaged or significantly damaged. The criteria for determining the damaged and significantly damaged conditions are as follows:

a. Damaged: The overall damage is up to ten percent (≤10%) and/or any localized damage is up to twenty-five percent (≤25%).

b. Significantly damaged: The overall damage is greater than ten percent (>10%) a and/or any localized damage is greater than (>25%).

2. Potential for Future Damage of ACM: Another step in the assessment process is to determine the potential for future damage or deterioration for material classified as good or fair. The potential for future damage was classified as High, Moderate, or Low for Human Contact, Vibration and Air Erosion.

3. Friability Rating: All material was given a friability rating and classified as either Friable ACM or Non-Friable ACM. Friable ACM is defined as any material that contains more than one percent (>1%) asbestos and can be crumbled, pulverized, or reduced to powder by hand pressure. It is a description of risk and refers to a material’s likeliness to release airborne fibers.

2.3 PROJECT CHARACTERISTICS

The BVAMC consist of fourteen (14) levels and is located at 700 South 19th Street, Birmingham, AL 35233. The initial building was constructed in 1946 and there have been several additions, modifications, renovations and upgrades over the past 70+ plus years. The basement and sub-basement consist of mechanicals rooms/spaces, crawl spaces and offices. The ground floor through the 9th floor includes: administrative offices, examinations rooms, operating rooms, patient rooms, food preparation areas, mechanical spaces and closets (electrical, OIT & janitorial). The Research Wing consists of four (4) levels above 19th Street South. The research area contains spaces for administrative offices, laboratories, mechanical spaces and storage areas. The Z wing consists of four (4) levels and has patient rooms, administrative areas, mechanical/electrical rooms and a woodworking shop area.

The asbestos survey as performed by the Safety Staff of the BVAMC. Samples were collected from all levels of the main facility, the Research Wing and the Z Wing. The total number of samples taken was nineteen (19) from six (6) homogeneous locations. A thorough visual inspection was conducted of all ACBMs that were discovered during previous surveys or were identified during recent renovations projects. Areas that have been abated since the last report (2014) have been removed from this survey.

Photographs of all sampled areas and visually inspected homogeneous areas are included in this survey.

2.4 HOMOGENOUS MATERIAL ASSESSMENT

2.4.1 HOMOGENOUS AREAS

Prior to collecting samples, distinct homogeneous sampling areas and specific sampling sites were determined. A homogeneous sampling area is any material of the same type. A homogeneous area is uniform throughout in structure, makeup and appearance (i.e., color, texture, date of application/construction). Homogeneous areas are further classified as surfacing material, thermal system insulation, and miscellaneous materials. Samples were taken of each specific homogeneous material that was identified.

Appendix A contains photographs of the positive homogeneous areas.

2.4.2 HAZARD ASSESSMENT FACTORS

Friability (the ability of a solid substance to be reduced to smaller pieces with little effort, especially by rubbing) was determined each time a suspect ACBM was sampled. The EPA and OSHA have determined that friable ACBM is more hazardous than non-friable ACBM. Friable ACBM can create airborne asbestos fibers more readily than non-friable ACBMs. In determining the fiber release potential, only the current conditions of ACBMs were noted.

The survey tried to sample all materials that were suspect, even those hidden or difficult to access. Even with this intent, there may have been areas containing ACBM that somehow were overlooked. If t inaccessible materials are discovered at a later date during a renovation or demolition activity, they should be sampled and analyzed. All materials visibly identified as non-asbestos (e.g., fiberglass, foam rubber, steel, wood) were not sampled/analyzed.

3.0 BUILDING SUMMARY

BUILDING 1 Main Hospital The Main Hospital was built in 1946 and was renovated in 1990. The building has sixteen

(16) floors and is approximately 613,547 ft2 in size. Previous inspection dates include 2007, 2010, 2014, 2015, and 2017. The building is considered to be in good overall condition.

BUILDING 1RD Research Wing The Research Wing was built in 1967 and was renovated in 2010. The building has four

(4) floors and is approximately 27,272 ft2 in size. Previous inspection dates include 2007, 2010, 2014, 2015, and 2017. The building is considered to be in good overall condition.

BUILDING 1Z Wing The Z Wing was built in 1973 and was renovated in 1983. The building has eight (8) floors and is approximately 68,959 ft2 in size. Previous inspection dates include 2007, 2010, 2014, 2015, and 2017. The building is considered to be in good overall condition.

4.0 SURVEY RESULTS

4.1 ACM DATA RESULTS

4.1.1 SUMMARY OF PREVIOUS SAMPLING EVENTS

The BVAHCS Safety Office reviewed previous Triannual Surveys (2019, 2020, 2022, 2023) detailing previous asbestos-related matters associated with the BVAHCS. Included in these documents were the following:

1. Asbestos Bulk Sampling events,

2. Photographs of ACM and HA.

4.1.2 FINDINGS OF 2020 TRIENNIAL SURVEY & ASSESSMENT

The BVAHCS Safety Office conducted a site inspection and assessment of the BVAHCS in February-July 2020 and Aug 2022 -2023. At the time of the survey, the Safety Office reviewed three (3) sampling events that had occurred since the 2019 Triannual Survey. The sampling events occurred in the following locations and with the following results:

Date Sample # Location Material Result

2/14/2019 01 Nuclear Medicine Flooring/mastic None detected 2/14/2019 02 Room 2346 Flooring/mastic None detected 2/14/2019 03 Room 2333 Flooring/mastic None detected 2/14/2019 04 G308G Flooring/mastic None detected 2/14/2019 05 G308G Flooring/mastic None detected 2/14/2019 06 Far back left corner, gated side Flooring/mastic None detected

11/15/2019 1 Atrium, North Sub-floor mastic None detected 11/15/2019 2 Atrium, East Sub-floor mastic None detected 11/15/2019 3 Atrium, South Sub-floor mastic None detected

5/05/2020 BVAMC20A001 2344 Hot Laboratory Pipe Insulation None detected 5/05/2020 BVAMC20A002 2344 Hot Laboratory Pipe Insulation None detected 5/05/2020 BVAMC20A003 2344 Hot Laboratory Pipe Insulation None detected 5/05/2020 BVAMC20A004 2344 Hot Laboratory Pipe Insulation None detected 5/05/2020 BVAMC20A005 2344 Hot Laboratory Terra Cota brick None detected 5/05/2020 BVAMC20A006 2344 Hot Laboratory Terra Cota brick None detected 5/05/2020 BVAMC20A007 2344 Hot Laboratory Terra Cota brick None detected 5/05/2020 BVAMC20A008 2344 Hot Laboratory Pipe Insulation None detected 5/05/2020 BVAMC20A009 2344 Hot Laboratory Pipe Insulation None detected /05/2020 BVAMC20A010 2344 Hot Laboratory Coating on cinder block None detected

Additionally, ten (10) samples were taken after a walk-thru of the entire facility. The sampling events occurred in the following locations and with the following results:

5/05/2020 BVAMC20A001 G208A Spray-on Insulation (concrete) None detected 5/05/2020 BVAMC20A002 G204 Floor Tile/mastic None detected 5/05/2020 BVAMC20A003 G311 Spray-on Insulation (concrete) None detected 5/05/2020 BVAMC20A004 G406 Spray-on Insulation (concrete) None detected 5/05/2020 BVAMC20A005 Electrical Closet Concrete None detected 5/05/2020 BVAMC20A006 Sub-basement Spray-on Insulation None detected 5/05/2020 BVAMC20A007 Basement Tile Tile/mastic None detected 5/05/2020 BVAMC20A008 Sub-basement Tile/mastic None detected 5/05/2020 BVAMC20A009 Dental 2604 Peg Board - white None detected 5/05/2020 BVAMC20A010 Dental, 1607 Peg Board - yellow 55% Chrysotile

Also, during the walk-thru of the basement it was discovered there was gasket material on an incinerator door in BC 108 that contained asbestos. The equipment and the material were in poor condition.

Building 1-Main

4/1/2022 1 6304 & closet on floor 6 by elevator

#5 12” vinyl floor tile & mastic 1% removed 11/8 –

11/11-2017 4/1/2022 2 Vertical pipe chase on Floor 6 east of elevator 5

Tar paper wrap on mineral wool pipe insulation

None detected

4/1/2022 3 All rooms and floors in original building

Transite sheets in recessed radiator units

None detected

4/1/2022 4 inaccessible wall and ceiling chases on all floors Layered paper pipe insulation

None detected

Building 1-Main

5/1/2022 1 G306B, G30, G512A and a closet on ground floor by elevator #5 12” vinyl floor tile & mastic Removed 11/8-

11/11-2017 5/1/2022 2 Vertical pipe chase on ground floor east of elevator 5

Tar paper wrap on mineral wool pipe insulation

None detected

5/1/2022 3 G406 and G413

Spray-on fire-proofing on beams & deck

None detected

5/1/2022 4 G415

Spray-on fire-proofing on beams & deck

Removed 2/24- 2/26/20

5/1/2022 5 All rooms and floors in original building

Transite sheets in recessed radiator units

None detected

5/1/2022 6 inaccessible wall and ceiling chases on all floors

Layered paper pipe insulation None detected

5/1/2022 7 G512D 12” vinyl floor tile & mastic None detected 5/1/2022 8 G512 Layered paper pipe insulation Removed 2/4/21 5/1/2022 9 G306B, G30, G512A and a closet on ground floor by elevator #5 12” vinyl floor tile & mastic Removed 3/13-

3/14/20

Building 1-Main MRI Mechanical

15/2/2023 1 Floor Tile-Light Gray/White, Resinously Bound None Detected 15/2/2023 2 Mastics/Leveling Compound-Black, Yellow, Off-white, Resinously Bound

3% Cellulose Fibers

Building 1-Main ACM Rm #3417A

23/2/2023 1 Room #3417A Rubbery, Fibrous None Detected

Building 1-Main RM G506

8/6/2023 1 G506 Insulation None Detected

Building 1- Room Number 2305

6/25/2023 1 Floor Tile-Light Gray/White, Resinously Bound None Detected 6/28/2023 2 Mastics/Leveling Compound-Black, Yellow, Off-white, Resinously Bound

3% Cellulose Fibers

5.0 INSPECTOR NAMES AND CONTACT INFORMATION

Management Planner & Building Inspector: Charles Daley Speer, PE

University of Alabama College of Continuing Studies Building Inspector & Management Planner Original Training: 2014 Annual Refresher Training: 2019 - 2020

State of Alabama Accreditation No.:

AIN111983284

APL111983284

Professional Engineer License No. 23145 State Certified: Alabama

Management Planner & Building Inspector: Melbourne Pierce

University of Alabama College of Continuing Studies Building Inspector & Management Planner Original Training: 2017 Annual Refresher Training: 2019 - 2020

State of Alabama Accreditation No.:

AIN1118693178

APL1118693178

6.0 LABORATIRY IDENTITY AND INFORMATION

Laboratory: Safety Environmental Laboratories & Consulting, Inc.

989 Yaeger Parkway Pelham, AL 35124

(205) 823-6200

Accreditation: NVLAP accredited laboratory (ISO/IEC Standard 17025:

2005 Compliant)

Accreditation No.: 200873-0

Expires: September 30, 2020

Accreditation: AIHA Laboratory Accreditation Programs, LLC (Accreditation No.: LAP-100766)

Expires: June 30, 2022

7.0 CONCLUSIONS AND RECOMMENDATIONS

7.1 CONCLUSIONS

Based on this survey and a review of previous surveys, the following materials contained asbestos:

BUILDING SUMMARY: Building 1 – Main Hospital

Homogenous Area

ACBM

Locations

Quantity

AHERA

Assessment

Recommendation

Removal Priority

H2

Tar paper wrap on mineral wool pipe insulation

Vertical pipe chase from 1st- 10th floor east of elevator 5

180 + linear ft.

H3 Spray-on fireproofing on beams & deck

G406 & G413

750 ft2

No change in condition

H5 Transite sheets in fume hood

2344, 3429, 225 ft2

H6 Transite sheets in recessed radiator units

All rooms & floors in original building

10 ft2 each

H7 Layered paper pipe insulation

8306 and in inaccessible wall and ceiling chases on all floors

Not determined

H8 Tar roofing 1st floor by elevator 15/16, 3rd floor by 3308 and 3309

5,800 ft2

H9 Black tar on exterior brick walls

Basement and 10th floor

Not determined

H10

Transite sheets on exterior siding

Auditorium 9211 exterior walls

2,240 ft2

BUILDING SUMMARY: Building 1RD – Research Wing

Location(s)

H1

12” vinyl floor tile & mastic

2702, 3702, 3703, 3704, 3705, 4701, 4702, 4704, 4705, 4706

670 - ft2

O & M, Remove at renovation.

H5

Transite vent pipe

Pipe chase 3711 and linear ft.

H-10 Transite sheets on exterior siding

Exterior walls on all floors

12,200 -ft2

1 O & M, Remove

BUILDING SUMMARY: Building 1Z – Blind Rehabilitation

Location(s)

H1

12” vinyl floor tile & mastic

6601, 6602 &

7800 - ft2

H4 Perforated Transite wall panels

5 ft2

H11 Ebony Black Lab Counter

Tops

Dental Laboratory

280 ft2 1 O & M, Remove

7.2 RECOMMENDATIONS

Observations and results from samples taken at specific locations during the survey conducted for buildings: 1, 1RD and 1Z from March through July 2020 dictate that some areas receive immediate abatement because of the condition of the material. Other areas will only require abatement if they will be disturbed during demolition, renovation, or remodeling activities. Additional ACBM identified during previous sampling events and prior triannual surveys were observed for condition during the March through July 2020 time period.

If, in the future, suspect materials that were hidden and/or not accessible during this and previous sampling events are encountered/discovered during any demolition, renovation, or remodeling activities, the suspect materials must be analyzed for asbestos content.

For materials that are to remain in place, an Operations and Maintenance (O&M) Plan should be written (in accordance with (IAW) Title 29 of the Code of Federal Regulations, Part 1910.1001, Subpart K (29 CFR § 1919.1001, Subpart K)) and maintained on-site to manage the ACBM in place.

There are two (2) areas that requirement immediate abatement: 1) the gasket material on the incinerator door in room BC 108 located in the basement and 2) the perforated Transite wall panels in room 1607, building 1Z.

8.0 LIMITING CONDITIONS

The BVAHCS Safety Office conducted the survey between March and July 2020 in accordance with industry standards in existence at the time of the survey. The conclusions and recommendations presented in this report are based on the applicable standards of the profession at the time this report was prepared.

The data, analysis and recommendations provided in the report are solely for use by the BVAHCS. It may not be relied upon by third party use. This report/survey has been prepared for the exclusive use of the BVAHCS for specific application to the survey preformed of the facility.

The survey was limited to the collection of bulk samples from readily accessible locations.

Laboratory analysis utilizing PLM was used to determine content in those samples taken.

The results, findings, observations, and recommendations in this survey are based on the conditions observed during the survey period mentioned above. While care and due diligence had been taken in compiling and checking information contained in the survey to verify that it is current and accurate, there always exist the possibility of errors or omissions or inaccuracies. The recommendations provided in this survey are based on priority to protect the health and safety of VA employees, VA patients and the general public that interact within the facility. The information contained within this survey applies only to the buildings listed during the time. As the facility’s use and/por condition changes, information, observations and recommendations found within this survey may no longer apply and would have to be modified or updated as necessary. This survey should be used in its entirety.

The purpose of this survey was to identify suspect materials in specific locations that may contain asbestos in the subject buildings. As noted in prior/previous Triannual Surveys, an asbestos survey is typically not sufficient to obtain access to areas that may not be exposed until renovation or remodeling is initiated.

APPENDIX A

Asbestos Laboratory Sample Data

APPENDIX C

Sample Location Maps

APPENDIX E

VA DIRECTIVE 7714

ASBESTOS MANAGEMENT PROGRAM