36C24818R0121-0006002.pdf

4902 113 th

Avenue North

Clearwater, Florida 33760

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LIMITED NESHAP RENOVATION

ASBESTOS SURVEY REPORT

Bay Pines VA Medical Center

Building 100 Incinerator Stacks

10000 Bay Pines Boulevard

Bay Pines, Florida 33744

VRG Project No.: 18950-90072

Prepared for:

Ms. Claudia Boutot

Bay Pines VAHCS

PO Box 5005

Bay Pines, Florida 33744

June 2018

Prepared by:

June 5, 2018

Ms. Claudia Boutot

Bay Pines VAHCS

PO Box 5005

Bay Pines, FL 33744

RE: Limited NESHAP Renovation Asbestos Survey Report

Bay Pines VA Building 100

Incinerator Stacks

Bay Pines, Florida

VRG Project No.: 18950-90072

Dear Ms. Boutot:

VRG Services, LLC (VRG) performed a limited survey for asbestos-containing materials (ACM) on May 29, 2018, at the above referenced facility, located in Bay Pines, Florida. The survey was performed by Mr. Jeffrey Rogers. This report outlines the sampling and testing procedures, and presents the results along with our conclusions and recommendations.

VRG appreciates the opportunity to serve as your consultant on this project. If you should have any questions, or if we can be of further service, please do not hesitate to contact us.

Sincerely, VRG Services, LLC

Cathy Meilak Robert B. Greene, PE, PG, CIH, LEED AP

Senior Project Manager Project Principal

Florida LAC, EA 0000009

CCM/RBG/dd

F:\VRG\Projects\18950\90072 Bldg 100 Incinerator Stacks LAS\Report\Final.doc

TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 Introduction 1

1.2 Facility Description 1

2.0 RESULTS 2

2.1 Asbestos Survey Procedures 2

2.2 Identified Suspect Asbestos-Containing Materials 3

Table 2.2-1 — Summary of Homogeneous Sampling Areas

3.0 CONCLUSIONS AND RECOMMENDATIONS 5

3.1 General 5

3.2 Specific 6

4.0 LIMITATIONS AND CONDITIONS 6

APPENDICES

Appendix A – Analytical Results and Chain of Custody

Appendix B – Personnel and Laboratory Certifications

1.0 INTRODUCTION

1.1 INTRODUCTION

The purpose of this limited renovation survey was to identify accessible asbestos-containing materials (ACMs) and their general locations within Building 100 of the Bay Pines VA, located at 10000 Bay Pines Boulevard in Bay Pines, Florida. The survey was limited to the incinerator stack room, where incinerator stacks are scheduled to be removed from the facility.

The survey was conducted pursuant to National Emission Standards for Hazardous Air Pollutants

(NESHAP, 40 CFR 61) requirements, associated with the scheduled renovation plans. The survey was performed on May 29, 2018, by Mr. Jeffrey Rogers, an Environmental Protection

Agency/Asbestos Hazard Emergency Response Act (EPA/AHERA) accredited inspector. The scope of this survey did not include demolition of any building components, evaluation of architectural plans, quantification of materials for abatement purposes, or removal cost estimating.

1.2 FACILITY DESCRIPTION

A summary of the facility investigated is outlined in the table below.

Facility Type: Hospital

Construction Date: Circa 1983

Number of Floors: Five

Structural

Foundation: Concrete Slab

Wall Support: Concrete Block

Exterior Finish: Not In Scope (NIS)

Roof Support: Concrete

Roof System Type: NIS

Mechanical/Plumbing

HVAC Type: Cooling Tower/Chiller with Air Handling Units

Duct Type: Metal and Fiberglass

Pipe Insulation: None Observed

Interior

Wall Substrate: Drywall and Joint Compound

Wall Finishes: Paint, Vinyl Cove Base, Ceramic Tile

Floor Substrate: Concrete

Floor Finishes: Vinyl Floor Tile, Ceramic Tile

Ceiling System: Drywall and Joint Compound, Suspended Ceiling System

Ceiling Finishes: Paint, Suspended Ceiling Tiles

2.0 RESULTS

2.1 ASBESTOS SURVEY PROCEDURES

The limited survey was performed by visually observing accessible areas of the incinerator stack room where stacks are to be removed. An EPA/AHERA accredited inspector performed the visual observations (refer to Appendix B for personnel qualifications).

After the overall visual survey was completed, representative sampling areas were determined.

The surveyor delineated homogeneous areas of suspect materials and samples of each material were obtained, in general accordance with regulations as established by the Occupational Safety and Health Administration (OSHA) and NESHAP. The field surveyor determined sample locations based on previous experience. Both friable and non-friable materials were sampled. A friable material is one that can be crushed when dry by normal hand pressure. This survey did not include the demolition of building components to access suspect material.

After completion of the fieldwork, the samples were delivered to GLE Associates, Inc., a

National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for analysis. The samples were analyzed by Polarized Light Microscopy (PLM) coupled with dispersion staining, in general accordance with EPA-600/R-93/116. Utilizing this procedure, the various asbestos minerals (chrysotile, amosite, crocidolite, actinolite, tremolite, and anthophyllite) can be determined. The percentages of asbestos minerals in the samples were visually determined by the microscopist. Please note that the EPA designates all materials containing greater than 1% asbestos as an “asbestos-containing material” (ACM).

Regulated Asbestos-Containing Material (RACM) is defined as (a) Friable asbestos materials,

(b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Category I and Category II non-friable ACM, as defined by the EPA:

Category I non-friable ACM means asbestos containing packings, gaskets, resilient floor covering, asphalt roofing products, and pliable sealants and mastics that are in good condition and not friable, containing more than 1 percent asbestos, as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM.

Category II non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the methods specified in Appendix E, Subpart E, 40 CFR Part 763 Section 1, PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

2.2 IDENTIFIED SUSPECT ASBESTOS-CONTAINING MATERIALS

A total of eighteen (18) samples of suspect building materials were collected from the facility during the survey, representing six different homogeneous areas. The results of the laboratory analyses are included in Appendix A, and approximate sample locations and the approximate extent to which ACM was observed to be present are indicated on the Asbestos Location Plan in

Appendix C.

A summary of the homogenous sampling areas of suspect ACM determined to be present is outlined in the following table:

ASBESTOS CONTENT

Expressed as percent

* = The facility owner has the option of point-counting by polarized light microscopy (PLM) those RACM whose asbestos content is less than 10% in order to more accurately determine the asbestos content therein.

PC = Results based on Point-Count analysis

FRIABILITY F = Friable Material NF = Non-Friable Material

ACM CATEGORY RACM = Regulated ACM CAT I = Category I non-friable ACM CAT II = Category II non-friable ACM

ABBREVIATIONS: NA = Not Applicable ND = None Detected NIS = Not in Scope C = Chrysotile A = Amosite

HA = Homogeneous Area SF = Square Feet LF = Linear Feet CF = Cubic Feet

TABLE 2.2-1: SUMMARY OF HOMOGENEOUS SAMPLING AREAS

BAY PINES VA – BUILDING 100 INCINERATOR ROOM

HA # HOMOGENEOUS MATERIAL

DESCRIPTION

HOMOGENEOUS MATERIAL LOCATION

FRIABILITY

(F /NF)

% ASBESTOS*

# OF SAMPLES

COLLECTED

APPROXIMATE

QUANTITY

ACM

CATEGORY

M-01 Ash Incinerator Stack F ND 3 NIS NA

TSI-01 Gray Insulation Boiler Stack (Metal Stack) NF ND 3 NIS NA

TSI-02 White Sheet Insulation Boiler Stack Access Door F ND 3 NIS NA

TSI-03 White Insulation Wrap Incinerator Stack

(Insulated Portion, Outer Layer)

NF

10% - Mastic

ND - Insulation

3 500 SF* NA

TSI-04 Gray Block Insulation Incinerator Stack

(Insulated Portion, 2nd Layer)

F ND 3 NIS NA

TSI-05 White Block Insulation Incinerator Stack

(Insulated Portion, 3rd Layer)

F ND 3 NIS NA

* Amount observed in incinerator stack room. Material may extend beyond stack room, but was inaccessible at the time of survey.

3.0 CONCLUSIONS AND RECOMMENDATIONS

3.1 GENERAL

Asbestos-containing materials (ACMs) were identified in the scope of this survey. General and specific conclusions and recommendations are provided below.

The EPA, OSHA and the State of Florida have promulgated regulations dealing with asbestos.

For commercial building owners, the EPA NESHAP (40 CFR 61) regulations require removal of

RACM, prior to conducting activities which might disturb the material. They also deal with notification, handling and disposal of asbestos.

The EPA recommends that an Operations and Maintenance (O&M) Program be developed for any facilities with ACM, and this Program should address all ACM (known and/or assumed) -present. The O&M Program establishes notification and training requirements along with special procedures for working around the ACM. The O&M Program would remain in effect until all asbestos is removed.

Category I and Category II non-friable materials, as defined by the EPA, may remain within a facility during renovation/demolition with no potential cessation of work, provided they remain undisturbed and/or non-friable. However, there is no guarantee that these materials will remain non-friable. If the materials become friable, then they are classified as RACM.

RACM, as defined by the EPA, must be removed prior to renovation or demolition activities that may disturb the materials.

The OSHA regulations deal with employee exposure to airborne asbestos fibers. The regulations restrict employee exposure, and require special monitoring, training and handling procedures when dealing with asbestos. Additionally, OSHA has regulations that may supersede the EPA regulations. In order to protect the worker, OSHA has established a permissible exposure limit

(PEL), which limits employee exposure to airborne fiber concentrations. OSHA requires objective evidence that the PEL will not be exceeded, as justification that personal air monitoring and engineering controls will not be required. OSHA has also established rules requiring the containerization and labeling of asbestos waste.

The State regulations require that anyone involved in asbestos consulting activities be a licensed asbestos consultant and that anyone involved in asbestos abatement, with the exception of roofing materials, be a licensed asbestos abatement contractor.

3.2 SPECIFIC

Mastic Associated with Thermal System Insulation Wrap

This material is defined by the EPA as a Category I non-friable material. Based upon the observed condition of the material, this material does not appear to present a significant issue at the time of the survey. We recommend that the identified ACM be maintained as part of an

O&M Program and periodically monitored for any changes in condition. Additionally, we recommend that a licensed asbestos abatement contractor properly remove and dispose of the

ACM prior to conducting renovation activities that might disturb the ACM.

4.0 LIMITATIONS AND CONDITIONS

As a result of previous renovations, there may be hidden materials, such as floor tile, sheet vinyl flooring, insulation, etc. These materials may be found in various areas hidden under existing flooring materials or in wall cavities. Any materials found during construction activities, either not addressed in this survey report, or similar to the ACM identified in this survey report should be assumed to be ACM until sampling and analysis documents otherwise.

Because of the hidden nature of many building components (i.e. within mechanical chases), it may be impossible to determine if all of the suspect building materials have been located and subsequently tested. Destructive testing in some instances is not a viable option. We cannot, therefore, guarantee that all potential ACM has been located. For the same reasons, estimates of quantities and/or conditions are subject to readily apparent situations, and our findings reflect this condition. We do warrant, however, that the investigations and methodology reflect our best efforts based upon the prevailing standard of care in the environmental industry.

The Florida Department of Environmental Protection (FDEP) has issued an interpretation regarding the testing of concrete flooring, walls and roofing materials, which states that “if concrete will be recycled or reused, the concrete must be sampled and analyzed for the presence of asbestos prior to the commencement of activities that may release asbestos fibers into the environment”, and that “all of the different layers or types of concrete in a sample must be analyzed, individually, using the method specified in Appendix E, subpart E, 40 CFR Part 763, Section 1, Polarized Light Microscopy, with point-counting”, as applicable. Under the presumption that the Client will not be reusing/recycling the concrete, this additional sampling and analysis of concrete is not included with our scope of work. However, if requested by the

Client, VRG will perform this work as an additional service.

The information contained in this report was prepared based upon specific parameters and regulations in force at the time of this report. The information herein is only for the specific use of the client and VRG. VRG accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless prior written authorization has been obtained from VRG.

APPENDIX A

Analytical Results and Chain of Custody

SUMMARY OF BULK SAMPLE ANALYSIS

Bay Pines VA; Incinerator Stack - Building 100 18950-90072

Sample Sample Type Fiber Type

M-01A Ash 100% Quartz, Calcite, Clay, Mica

M-01B Ash 100% Quartz, Calcite, Clay, Mica

M-01C-QC Ash 100% Quartz, Calcite, Clay, Mica

TSI-01A Gray Insulation 100% Quartz, Calcite, Clay, Mica

TSI-01B Gray Insulation 100% Quartz, Calcite, Clay, Mica

TSI-01C Gray Insulation 100% Quartz, Calcite, Clay, Mica

TSI-02A White Sheet Insulation 100% Cellulose/paper

TSI-02B White Sheet Insulation 100% Cellulose/paper

TSI-02C White Sheet Insulation 100% Cellulose/paper

TSI-03A White Mastic 10% Chrysotile Asbestos

90% Polymer

Beige Insulation 100% Quartz, Calcite, Clay, Mica

TSI-03B White Mastic Positive Stop/Sample not analyzed

Beige Insulation 100% Quartz, Calcite, Clay, Mica

TSI-03C White Mastic Positive Stop/Sample not analyzed

Beige Insulation 100% Quartz, Calcite, Clay, Mica

TSI-04A-QC Gray Block Insulation 100% Quartz, Calcite, Clay, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 22675

Analyst / Approved

Signatory:

Feedback regarding laboratory performance should be addressed to lab@gleassociates.com.

Report Date: 5/29/2018

SUMMARY OF BULK SAMPLE ANALYSIS

Bay Pines VA; Incinerator Stack - Building 100 18950-90072

Sample Sample Type Fiber Type

TSI-04B Gray Block Insulation 100% Quartz, Calcite, Clay, Mica

TSI-04C Gray Block Insulation 100% Quartz, Calcite, Clay, Mica

TSI-05A White Block Insulation 100% Quartz, Calcite, Clay, Mica

TSI-05B White Block Insulation 100% Quartz, Calcite, Clay, Mica

TSI-05C White Block Insulation 100% Quartz, Calcite, Clay, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 22675

Analyst / Approved

Signatory:

Feedback regarding laboratory performance should be addressed to lab@gleassociates.com.

Report Date: 5/29/2018

APPENDIX B

Personnel and Laboratory Certifications

JONATHAN ZACHEM, SECRETARYRICK SCOTT, GOVERNOR

STATE OF FLORIDA

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION

ASBESTOS LICENSING UNIT

THE ASBESTOS BUSINESS ORGANIZATION HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 469, FLORIDA STATUTES

VRG SERVICES LLC

Do not alter this document in any form.

ROBERT BLAIR GREENE

LICENSE NUMBER: ZA476

EXPIRATION DATE: NOVEMBER 30, 2019

This is your license. It is unlawful for anyone other than the licensee to use this document.

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