S02_Att13 Abatement Survey 2065101 N. Chicago VAMC report_Optimized.pdf

Guidon Design

Indianapolis, IN

NESHAP Asbestos Survey

Hemodialysis Renovation Design

Building 133 – 3rd Floor

Captain James A Lovell FHCC

VA Medial Center

North Chicago, Illinois

August 2021

1915 North 12th Street Toledo, OH 43604-5305

T 419-324-2222 F 419-241-1808 www.ttlassoc.com

August 12, 2021 TTL Project No. 2065101

Mr. David Vallandingham

Guidon Design

1221 Pennsylvania Street

Indianapolis, IN 46202

NESHAP Asbestos Survey

Building 133-3rd Floor

Captain James A Lovell FHCC

VA Medical Center

North Chicago, Illinois

Dear Mr. Vallandingham:

The National Emissions Standard for Hazardous Air Pollutants (NESHAP) Asbestos survey report prepared for Guidon Design (Guidon) for the above-referenced site is enclosed.

TTL appreciates the opportunity to provide Guidon with our consulting and testing services.

Should you have any questions or require additional information, please contact Mr. Harry Singh at (419) 214-5058.

Sincerely, TTL Associates, Inc.

Harjot Singh

Project Manager

Veronica Winkeljohn, P.E., PMP

Vice President, Environmental Services

V:\Toledo\Guidon Design\Standalone Projects\Chicago, IL\Hemodialysis Renovation Design, James Lovell FHCC (2065101)\Deliverables\2065101 N. Chicago VAMC report_TF edits.docx

NESHAP ASBESTOS SURVEY

HEMODIALYSIS RENOVATION DESIGN

BUILDING 133-3RD FLOOR

CAPTAIN JAMES A LOVELL FHCC

VA MEDICL CENTER

NORTH CHICAGO, ILLINOIS

FOR

GUIDON DESIGN

1221 PENNSYLVANIA STREET

INDIANAPOLIS, IN 46202

SUBMITTED

AUGUST 12, 2021

TTL PROJECT NO. 2065101

TTL ASSOCIATES, INC.

1915 NORTH 12TH STREET

TOLEDO, OHIO 43604

(419) 324-2222

Captain James A Lovell FHCC VA Medical Center August 2021

TTL Project No. 2065101 Page i

TABLE OF CONTENTS

Section No. Page No.

EXECUTIVE SUMMARY ...................................................................................................... E-1

1.0 INTRODUCTION

1.1 Project Purpose and Objectives

1.2 Personnel

2.0 ASBESTOS SURVEY

2.1 Homogenous Areas

2.2 Sampling and Analysis Methods

2.3 Survey Analytical Results

3.0 CONCLUSIONS/RECOMMENDATIONS

3.1 Asbestos Survey

3.2 Limitations

APPENDICES

Appendix A: TTL Certifications

Appendix B: NESHAP Survey Summary Table

Appendix C: Asbestos Analytical Report

Appendix D: ACM Sample Location Map

Appendix E: Previous Survey Results

TTL Project No. 2065101 Page E-1

EXECUTIVE SUMMARY

TTL Associates, Inc. (TTL) conducted a United States Environmental Protection Agency (U.S.

EPA) National Emissions Standard for Hazardous Air Pollutants (NESHAP) asbestos survey for

Project 556-17-001 Hemodialysis Renovation Design (HRD), Building 133-3rd Floor at the

Captain James A Lovell Federal Health Care Center Medical Center (FHCC) hospital located in

North Chicago, Illinois. The purpose of the survey was to identify potential asbestos-containing materials (ACM) in the proposed new Hemodialysis Renovation location in room 3A-106 (former kitchen space).

The survey was conducted on July 23, 2021 by Mr. Rob Serlin of TTL.

TTL’s scope of work included the following:

• Review the existing asbestos survey report for Building 133 provided by Guidon.

• Complete a survey of Building 133 room 3A-106 areas for suspect ACM.

• Collection of suspect ACM bulk samples for analysis by Polarized Light Microscopy (PLM) to determine asbestos content.

Asbestos Survey

TTL used the previous ACM data report provided by Guidon to assess if previously identified

ACM was present in the renovation areas. No ACM was identified in room 3A-106 based on the previous report. Suspect materials that were not sampled in the previous data report were identified, quantified and samples were collected and analyzed.

TTL identified eight new suspect materials in the proposed HRD location area in room 3A-106 which may contain ACM. A total of 20 samples were collected and 36 layers were analyzed by a laboratory for the presence of ACM. The laboratory analysis of the samples was conducted by an accredited laboratory using the PLM method. Laboratory analytical results indicated that one ACM was identified in the new material collected in the proposed HRD location area in Building 133.

The newly identified ACM material includes:

Building 133 3rd Floor

Material Description Location Quantity

4” to 6” Mud fitting on fiberglass line Room 3A-106 1 EA

EA- each

TTL Project No. 2065101 Page 1

1.0 INTRODUCTION

TTL Associates, Inc. (TTL) conducted a United States Environmental Protection Agency (U.S.

EPA) National Emissions Standard for Hazardous Air Pollutants (NESHAP) asbestos survey for the proposed Hemodialysis Renovation Design (HRD) in Building 133 room 3A-106 at the

Captain James A Lovell Federal Health Care Center Medical Center (FHCC) hospital located in

North Chicago, Illinois.

1.1 Project Purpose and Objectives

The purpose of the survey was to identify potential asbestos-containing materials (ACM) in the proposed new Hemodialysis Renovation location in room 3A-106: former kitchen space.

1.2 Personnel

The non-destructive survey was conducted on July 23, 2021 by Mr. Rob Serlin of TTL. Mr. Serlin is an Illinois Department of Public Health (IDPH) certified Asbestos Inspector (a copy of his certificate is included in Appendix A).

TTL Project No. 2065101 Page 2

2.0 ASBESTOS SURVEY

This section documents the methodology and results of the asbestos survey.

2.1 Homogenous Areas

Each accessible area within the proposed new HRD location areas was surveyed which included the identification of suspect materials and the definition of homogeneous sampling areas (HSA), assessment of the condition of each material, estimation of the approximate quantity of the suspect

ACM, and collection and analysis of representative bulk samples from each identified HSA. An

HSA is defined as a material that exhibits similar physical characteristics (e.g., texture, surface color, and appearance) and was applied or installed during the same construction period (if known) as determined by TTL’s inspector utilizing professional judgment, experience, and historical building information. The previous asbestos survey provided by Guidon was reviewed prior to performing the sampling.

2.2 Sampling and Analysis Methods

TTL provided a certified Asbestos Inspector to conduct the non-destructive survey of the proposed new HRD location area.

Suspect ACM samples were collected using a coring device or other means, as appropriate, to collect a cross section of the suspect material. The samples were placed into clean, unused sealable bags and marked with a unique sample identification number. The samples of suspect ACM were transported to International Asbestos Testing Laboratories, Inc. (IATL) and analyzed by PLM using U.S. EPA Method 600/R-93/116. The EPA/600/R-93/116 “Method for the Determination of

Asbestos in Bulk Building Materials” requires that all multiple, distinct layers must be analyzed individually. Sample analytical results are provided for each distinct layer of each sample submitted to the laboratory.

IATL is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), which is administered by the National Institute of Standards and Technology (NIST). The laboratory accreditation number is included in the analytical report.

2.3 Survey Analytical Results

TTL identified eight new suspect materials in the proposed HRD location area in room 3A-106 which may contain ACM. A total of 20 samples were collected and 36 layers were analyzed by

IATL for the presence of ACM. The laboratory analysis of the samples was conducted by an accredited laboratory using the PLM method. Laboratory analytical results indicated that one ACM was identified in the new material collected in the proposed HRD location area in Building 133.

The newly identified ACM material includes:

TTL Project No. 2065101 Page 3

4” to 6” Mud fitting on fiberglass line Room 3A-106 1 EA

EA- each

A table summarizing the HSAs is included in Appendix B. Appendix C includes the asbestos analytical report from the laboratory. The HSA sample locations map is included in Appendix D.

The previous asbestos survey provided by Guidon is included in Appendix E.

TTL Project No. 2065101 Page 4

3.0 CONCLUSIONS/RECOMMENDATIONS

This section summarizes the results of the asbestos survey and sampling and provides conclusions and recommendations.

3.1 Asbestos Survey

The U.S. EPA defines regulated asbestos-containing material (RACM) as: (a) Friable asbestos material, (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.

Friable ACM was identified in Building 133 3rd floor room 3A-106

4”to 6” Mud fitting on fiberglass line Room 3A-106 300 SF

SF – square feet

The National Emissions Standard for Hazardous Air Pollutants (NESHAP) asbestos regulations require the removal of all RACM from a facility being demolished or renovated prior to beginning any activity that might damage or disturb the material. The U.S. EPA requires written notification if the combined amount of RACM to be removed is at least 260 linear feet, at least 160 square feet, or at least one cubic meter of facility components where length or area could not be measured.

Based on the condition of the material, the identified ACM is expected to be a RACM during renovation activities. TTL recommends the removal of the ACM that might become RACM based on the project-specific renovation techniques by a licensed asbestos abatement contractor. The renovation contractor must be notified of the presence, quantity and location of the material so as to avoid project specific renovation techniques that may render the material friable and create

RACM.

3.2 Limitations

TTL has made reasonable efforts to identify and quantify suspect ACM based upon the standard of care in the environmental industry existing at the time of the survey. This survey only summarizes the potential presence and estimated quantities of visually observed ACM within the designated areas.

Additional material disturbed during renovation or demolition activities should be evaluated on a case-by-case basis, especially materials that were previously hidden, obscured or inaccessible, to determine if the material is included in this survey. If a given material is not described in this

TTL Project No. 2065101 Page 5 survey or cannot be identified as a non-suspect material, the material should be assumed to contain asbestos and renovation and/or demolition activities should be halted until sampling and analysis can be accomplished. Parties conducting renovation and/or demolition activities should follow all applicable federal, state, and local regulations in handling identified and suspect ACM.

The information contained in this report was based upon specific parameters and regulations in place at the time of the survey. The information herein is only for the specific use of Guidon and

TTL, unless written authorization is obtained from TTL. TTL accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, nor does this report represent an instrument of regulatory compliance or an asbestos abatement specification.

APPENDIX A

TTL CERTIFICATION

APPENDIX B

TTL HSA TABLE

NESHAP Abestos Survey Summary Table

Building 133-3rd Floor North Chicago, Illinois

HSA HSA Description Functional Area Quantity Unit Friability Condition Result

1 2"x 2" Tan & blue ceramic wall tile with associated grout/bed compound Room 3A-106 1,500 s.f. NF-II Good Negative

#REF!

Total 1,500 s.f.

2 6"x 6" Red ceramic floor tile with associated grout Room 3A-106 2,800 s.f. NF-II Good Negative

Total 2,800 s.f.

3 2"x 2" Beige grainy ceramic floor tile with associated grout Room 3A-106 50 s.f. NF-II Good Negative

Total 50 s.f.

4 Cement board with bed compound Room 3A-106 300 s.f. NF-II Good Negative

Total 300 s.f.

5 I-Beam spray on insulation Room 3A-106 200 s.f. F Good Negative

Total 200 s.f.

6 Plaster with skim coat Room 3A-106 500 s.f. NF-II Good Negative

Total 500 s.f.

7 4"to 6" Mud fitting on fiberglass line Room 3A-106 1 e.a. F Poor Positive

Total 1 e.a.

8 4" Brown covebase with associated adhesive Room 3A-106 10 l.f. NF-II Good Negative

Total 10 l.f.

TTL Project # 2065101 Page 1 of 1

APPENDIX C

ASBESTOS ANALYTICAL REPORT

Lab No.: 7263269 Client No.: 2065101-01A

Analyst Observation: Blue/Tan Ceramic Tile Client Description: 2"x2" Tan And Blue Ceramic Wall Tile, Grout, Red Compound

Location: 3rd Floor Renovation; 3A-106 Facility:

Percent Asbestos:

None Detected

Percent Non-Asbestos Fibrous Material:

Percent Non-Fibrous Material:

Lab No.: 7263269(L2)

Analyst Observation: Lt Grey Grout

Lab No.: 7263269(L3)

Analyst Observation: Off-White Mastic

Lab No.: 7263269(L4)

Analyst Observation: Grey Mortar

Lab No.: 7263270 Client No.: 2065101-01B

Analyst Observation: Tan Ceramic Tile

Lab No.: 7263270(L2)

Analyst Observation: Lt Grey Grout

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

David Hayes

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Client: TTL381

Dated : 8/2/2021 5:57:33 Page 1 of 10

Lab No.: 7263270(L3)

Analyst Observation: White Mastic

Lab No.: 7263271 Client No.: 2065101-02A

Analyst Observation: Red Brick Client Description: 6'x6' Red Ceramic Floor Tile And Grout

Lab No.: 7263271(L2) Client No.: 2065101-02A

Lab No.: 7263272 Client No.: 2065101-02B

Analyst Observation: Red Brick

Lab No.: 7263272(L2) Client No.: 2065101-02B

Lab No.: 7263273 Client No.: 2065101-03A

Analyst Observation: Beige Ceramic Tile Client Description: 2"x2" Beige Grainy Ceramic Floor Tile And Grout

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

David Hayes

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 2 of 10

Lab No.: 7263273(L2) Client No.: 2065101-03A

Analyst Observation: Grey Grout

Lab No.: 7263274 Client No.: 2065101-03B

Analyst Observation: Beige Ceramic Tile

Lab No.: 7263274(L2) Client No.: 2065101-03B

Analyst Observation: Grey Grout

Lab No.: 7263275 Client No.: 2065101-04A

Analyst Observation: Off-White Non-Fibrous Client Description: Cement Board With Red Compound

Lab No.: 7263275(L2) Client No.: 2065101-04A

Trace Cellulose

Lab No.: 7263276 Client No.: 2065101-04B

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

David Hayes

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 3 of 10

Lab No.: 7263276(L2) Client No.: 2065101-04B

Lab No.: 7263277 Client No.: 2065101-04C

Lab No.: 7263277(L2) Client No.: 2065101-04C

Lab No.: 7263278 Client No.: 2065101-05A

Analyst Observation: Grey Insulation Client Description: I-Beam Spray On Insulation

60 Fibrous Glass

Lab No.: 7263279 Client No.: 2065101-05B

Lab No.: 7263280 Client No.: 2065101-05C

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

David Hayes

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 4 of 10

Lab No.: 7263281 Client No.: 2065101-06A

Analyst Observation: White Plaster Client Description: Plaster With Silver Coat

Lab No.: 7263281(L2) Client No.: 2065101-06A

Analyst Observation: Grey Plaster

Trace Hair

Lab No.: 7263282 Client No.: 2065101-06B

Analyst Observation: White Plaster

Lab No.: 7263282(L2) Client No.: 2065101-06B

Analyst Observation: Grey Plaster

Trace Hair

Lab No.: 7263283 Client No.: 2065101-06C

Analyst Observation: White/Grey Plaster

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

David Hayes

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 5 of 10

Lab No.: 7263284 Client No.: 2065101-07A

Analyst Observation: White Insulation Client Description: 4"-6" Mud Fitting On Fiberglass Lane

Percent Asbestos:

13 Chrysotile PC 4.8 Amosite

10 Cellulose

72.2

Lab No.: 7263285 Client No.: 2065101-07B

Analyst Observation: Sample Not Analyzed

Sample Not Analyzed

Lab No.: 7263286 Client No.: 2065101-07C

Analyst Observation: Sample Not Analyzed

Lab No.: 7263287 Client No.: 2065101-08A

Analyst Observation: Brown Cove Base Client Description: 4" Brown Cove Base With Associated Adhesive

Lab No.: 7263287(L2) Client No.: 2065101-08A

Lab No.: 7263288 Client No.: 2065101-08B

Analyst Observation: Brown Cove Base

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Ellen Smith

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 6 of 10

Lab No.: 7263288(L2) Client No.: 2065101-08B

Laboratory Director

Approved By:

Date Analyzed:

7/28/2021Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Ellen Smith

08/02/2021 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 8/2/2021 5:57:33 Page 7 of 10

Appendix to Analytical Report Customer Contact: Sara Vogelpohl Method:40 CFR Appendix E to Subpart E of Part 763, interim method for the Determination of Asbestos in Bulk Insulation Samples, USEPA 600, R93-116 and NYSDOH ELAP 198.1 as needed.

This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.

Please note the following points of contact for any questions you may have.

iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Kelly Klippel Sample Login Notes: See Batch Sheet Attached Sample Matrix: Bulk Building Materials Exceptions Noted: See Following Pages

General Terms, Warrants, Limits, Qualifiers:

General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.

iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.

This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.

This report shall not be reproduced except in full, without written approval of the laboratory.

Information Pertinent to this Report:

Analysis by US EPA 600 93-116: Determination of Asbestos in Bulk Building Materials by Polarized Light Microscopy (PLM).

Certifications:

NIST-NVLAP No. 101165-0• NYSDOH-ELAP No. 11021• AIHA-LAP, LLC No. 100188•

Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. PC Trace represents a <0.25% amount. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.

Analytical Methodology Alternatives: Your initial request for analysis may not have accounted for recent advances in regulatory requirements or advances in technology that are routinely used in similar situations for other qualified projects. You may have the option to explore additional analysis for further information. Below are a few options, listed as the matrix followed by the appropriate methodology. Also included are links to more information on our website.

Bulk Building Materials that are Non-Friable Organically Bound (NOB) by Gravimetric Reduction techniques employing PLM and TEM: ELAP 198.6 (PLM-NOB), ELAP 198.4 (TEM-NOB) See additional information at the end of this appendix.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

Page 8 of 10Dated : 8/2/2021 5:57:33

Loose Fill Vermiculite Insulation, Attic Insulation, Zonolite (copyright), etc.: US EPA 600 R-4/004 (multi-tiered analytical process) Sprayed On Insulation/Fireproofing with Vermiculite (SOF-V): ELAP 198.8 (PLM-SOF-V)

Soil, sludge, sediment, aggregate, and like materials analyzed for asbestos or other elongated mineral particles (ex. erionite, etc.): ASTM D7521, CARB 435, and other options available

Asbestos in Surface Dust according to one of ASTM's Methods (very dependent on sampling collection technique – by TEM): ASTM D 5755, D5756, or D6480

Various other asbestos matrices (air, water, etc.) and analytical methods are available.

Disclaimers / Qualifiers:

There may be some samples in this project that have a "NOTE:" associated with a sample result. We use added disclaimers or qualifiers to inform the client about something that requires further explanation. Here is a list with highlighted disclaimers that may be pertinent to this project. For a full explanation of these and other disclaimers, please inquire at customerservice@iatl.com.

1) Note: No mastic provided for analysis.

2) Note: Insufficient mastic provided for analysis.

3) Note: Insufficient material provided for analysis.

4) Note: Insufficient sample provided for QC reanalysis.

5) Note: Different material than indicated on Sample Log / Description.

6) Note: Sample not submitted.

7) Note: Attached to asbestos containing material.

8) Note: Received wet.

9) Note: Possible surface contamination.

10) Note: Not building material. 1% threshold may not apply.

11) Note: Recommend TEM-NOB analysis as per EPA recommendations.

12) Note: Asbestos detected but not quantifiable.

13) Note: Multiple identical samples submitted, only one analyzed.

14) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.080%.

15) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.125%.

16) Note: This sample contains >10% vermiculite mineral. See Appendix for Recommendations for Vermiculite Analysis.

Recommendations for Vermiculite Analysis:

Several analytical protocols exist for the analysis of asbestos in vermiculite. These analytical approaches vary depending upon the nature of the vermiculite mineral being tested (e.g. un-processed gange, homogeneous exfoliated books of mica, or mixed mineral composites).Please contact your client representative for pricing and turnaround time options available.

iATL recommends initial testing using the EPA 600/R-93/116 method. This method is specifically designed for the analysis of asbestos in bulk building materials. It provides an acceptable starting point for primary screening of vermiculite for possible asbestos.

Results from this testing may be inconclusive. EPA suggests proceeding to a multi-tiered analysis involving wet separation techniques in conjunction with PLM and TEM gravimetric analysis (EPA 600/R-04/004).

For New York State customers, NYSDOH requires disclaimers and qualifiers for various vermiculite containing samples that direct analysis via ELAP198.6 and ELAP198.8 for samples that contain >10% vermiculite mineral where ELAP198.6 may be used to evaluate the asbestos content of the material. However, any test result using ELAP198.6 will be reported with the following disclaimer: “ELAP198.6 method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing >10% vermiculite.”

Further information on this method and other vermiculite and asbestos issues can be found at the following: Agency for Toxic Substances and Disease Registry (ATSDR) www.atsdr.cdc.gov, United States Geological Survey (USGS) www.minerals.usgs.gov/minerals/, US EPA www.epa.gov/asbestos. The USEPA also has an informative brochure "Current Best Practices for Vermiculite Attic Insulation" EPA 747F03001 May 2003, that may assist the health and remediation professional. NYS customers please follow current NYSDOH ELAP requirements per policy on subject of surfacing and vermiculite, May 6, 2016, Testing Requirements for Surfacing Material Containing Vermiculite (https://www.wadsworth.org/sites/default/files/WebDoc/I198_8_02_2.pdf)

The following is a summary of the analytical process outlines in the EPA 600/R-04/004 Method:

1)Analytical Step/Method: Initial Screening by PLM, EPA 600R-93/116 Requirements/Comments: Minimum of 0.1 g of sample. ~0.25% for most samples.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

Page 9 of 10Dated : 8/2/2021 5:57:33

2)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

3)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Floats" only.

4)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

5)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Suspension" only.

*With advance notice and confirmation by the laboratory.

**Approximately 1 Liter of sample in double-bagged container (~9x6 inch bag of sample).

New York State Department of Health requires that samples originating from NYS that they categorize as Non-friable Organically Bound materials can only be confirmed as None Detected for asbestos by method 198.4. See the table below for a list of those materials. (ENVIRONMENTAL LABORATORY APPROVAL PROGRAM CERTIFICATION MANUAL - ITEM No. 198.1, Revision Date 5/6/16)

*Asphalt Shingles, Caulking, Ceiling Tiles with Cellulose, Duct Wrap, Glazing, Mastic, Paint Chips, Resilient Floor Tiles, Rubberized Asbestos Gaskets, Siding Shingles, Vinyl Asbestos Tile, NOB materials (other that SM-V) with <10% vermiculite, Any material (Friable or NOB other than SM-V) with >10% vermiculite.

Statistically derived uncertainty with any measure should be taken into consideration when reviewing and interpreting all reported data and results. A more comprehensive listing of accuracy, precision, and uncertainty as it impacts this method is available upon request.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associates Inc.

1915 N. 12th Street Toledo OH 43604

8/2/2021Report Date:

Report No.: 641660 - PLM Project: N Chicago VA Project No.: 2065101

Page 10 of 10Dated : 8/2/2021 5:57:33

APPENDIX D

ACM SAMPLE LOCATION MAP

APPENDIX E

PREVIOUS ACM SURVEY RESULTS

Tropical Environmental, Inc.

10976 Fairbluff Ave.

Huntley, IL. 60142

(224) 569-3277 (224) 569-3278 fax www.TropicalEnvironmental.com

December 27, 2011

Mr. Royal Eckstein Captain James A. Lovell FHCC 3001 Green Bay Road North Chicago, Illinois 60064

RE: U.S. Department of Veterans Affairs (VA)

Captain James A. Lovell Federal Health Care Center Building # 133 CA

Dear Mr. Eckstein:

Tropical Environmental, Inc. (Tropical) performed a limited asbestos assessment of the above referenced location in general accordance with:

• The Commercial and Public Buildings Asbestos Abatement Act (225 ILCS 207) enforced by the Illinois Department of Public Health (IDPH)

• The Asbestos Hazard Emergency Response Act (40 CFR 763) enforced by the U.S.

Environmental Protection Agency (USEPA), and

• The Asbestos Hazard Communication requirements (29 CFR 1910.1001(i) enforced by the U.S. Occupational Safety and Health Administration (OSHA).

Tropical performed the limited survey to identify and sample suspect asbestos-containing materials (ACM) in the facility. Samples of suspect asbestos-containing material (ACM) were submitted to a National Voluntary Laboratory Accreditation Program (NVLAP) certified laboratory for analysis. Laboratory results indicate that some of the suspect material contains asbestos. Please refer to the attached report for details on the survey.

Please feel free to contact me at (224) 269-3277 or by email at info@tropicalenvironmental.com with any comments or questions regarding Tropical’s investigation and this report.

Sincerely, Mark Haines President mailto:info@tropicalenvironmental.com

Table of Contents Page

Executive Summary

1.1 Project Purpose and Background

2.0 Asbestos Survey

2.1 Asbestos Survey Methodology

2.2 Asbestos Results

2.3 Applicable Regulations

3.0 Findings and Recommendations

4.0 Limitations

5.0 References & Definitions

Appendices

Appendix A: Asbestos Survey Analytical Summary Table Appendix B: Asbestos Laboratory Results, Laboratory Certifications and Chain-of-Custodies Appendix C: Tropical Employee Certifications Appendix D: Material/Sample Location Drawings

Building # 133 CA North Chicago, IL www.TropicalEnvironmental.com

Executive Summary

Tropical Environmental, Inc. (Tropical) was retained by the VA to provide an Asbestos Survey of all buildings, as defined by VA representatives, located on the Captain James A. Lovell Federal Health Care Center Campus in North Chicago, IL. The field assessment and sampling was performed from July 19, 2011 to October 5, 2011.

Building 133 CA is a six story brick-clad building that is used as a hospital/clinic. The building was constructed in 1961. The building has approximately 383,216 square feet of floor space.

Tropical performed a visual survey of building materials and collected representative samples of homogeneous suspect ACM, in accordance with EPA requirements, guidelines and standard industry practices. The samples were submitted to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for bulk analysis.

This report addresses the asbestos survey completed for Building #133 CA.

Based on the bulk sampling and laboratory analyses, suspect materials were reported to contain asbestos, including the following:

HSA

Sample #

Material Description

Material Condition

Material Quantity

Material Location

Laboratory Results

FT8 FLOOR TILE

AND MASTIC

NON

FRIABLE 334 SF

HALL

OUTSIDE OF

ROOMS 1D101

<0.25% – 4.6%

CHRYSOTILE

Based on the bulk sampling and laboratory analyses, suspect materials were reported to contain asbestos at less than 1%, including the following:

HSA

Sample #

Material Description

Material Condition

Material Quantity

Material Location

Laboratory Results

BM

EXPOSED

BLACK

FLOOR

MASTIC

NON

FRIABLE ROOM 2D-154 <0.25%

CHRYSOTILE

http://www.tropicalenvironmental.com/

Building # 133 CA www.TropicalEnvironmental.com

Every attempt was made to thoroughly evaluate and assess the presence and condition of suspect ACM throughout the building. Any suspect ACM identified during renovation that is not specifically listed in this report should be assumed positive until it can be thoroughly evaluated, assessed, sampled, and analyzed prior to disturbance, in accordance with applicable regulatory standards.

Building # 133 CA www.TropicalEnvironmental.com

1.0 Introduction

Tropical Environmental, Inc. (Tropical) was retained by the VA to provide an Asbestos Survey of all buildings, as defined by VA representatives, located on the Captain James A. Lovell Federal Health Care Center Campus in North Chicago, IL. The field assessment and sampling was performed from July 19, 2011 to October 5, 2011.

This report addresses the asbestos survey completed for Building #133 CA.

The asbestos survey was performed by Illinois Department of Public Health (IDPH) licensed asbestos inspectors Mr. Mark Haines, license #100-00919, and Ms. Terri Lewis, license #100- 07366.

1.1 Project Purpose and Background

The asbestos survey was conducted to identify accessible asbestos containing materials in the building.

1.2 Scope of Work

Tropical performed an asbestos survey to determine and quantify ACM in accessible areas. The ACM survey included the following activities:

• Visual inspection of all accessible areas of the building, as identified by VA representatives to be included in the scope of this project.

• Collection of bulk samples of identified suspect ACM per homogeneous materials in accessible areas of the building.

• NVLAP accredited laboratory analysis of suspect ACM bulk samples by polarized light microscopy (PLM) to first positive result per homogeneous material.

• Preparation of a final report that includes sample locations of representative ACM and the laboratory’s analytical report.

Building # 133 CA www.TropicalEnvironmental.com

2.0 Asbestos Survey

2.1 Asbestos Survey Methodology

Only currently certified and licensed inspector(s) and (if appropriate) trainee(s) were utilized for this inspection.

The inspector(s) first reviewed supplied building documents, if applicable, which may have included the asbestos management plan, previous inspection reports, blue prints, and as built drawings, etc. A property/structure(s) walk-thru was then conducted to locate, identify, measure and separate previously identified asbestos containing materials and suspect asbestos containing materials into homogeneous areas. The material’s current condition was also evaluated during the walk-thru. Material conditions were evaluated utilizing the following terminology, Good, Damaged & Significantly Damaged.

Samples were collected using EPA approved methods specifically designed for sample collection. Samples were taken utilizing the randomly distributive manner method while simultaneously applying amended water. Samples were immediately placed in a pre-labeled re-sealable plastic bag. To prevent accidental exposure, sample containers are made of a durable plastic designed to provide and airtight seal. The sampling instrument was subsequently wiped with a clean moist cloth to decontaminate the tool, prevent the potential release of asbestos fibers, and prevent cross contamination of subsequent samples. Following the collection of each sample, the sample location was patched as appropriate. Sample areas were touched to determine friability.

The following chart, as detailed by 40 CFR 763.86, is typically used (and in certain cases, required) for sampling surfacing building materials for asbestos content:

< 1000 s/f 3 samples 1000 – 5000 s/f 5 samples >5000 s/f 7 samples

9 samples are recommended by the EPA for all samples

A group letter or combination of letter and number was assigned to each homogenous material.

This combination serves as a prefix to identify materials of similar composition, texture, color, and date of installation. Each sample was then assigned a sample number such as 01, 02, 03, etc.

All samples were identified on a signed and dated Chain-of-Custody document, which accompanied the samples to the laboratory.

Building # 133 CA

To ensure both quality and objectivity, an independent laboratory was used. Laboratories are selected based on their current accreditations. The laboratory chosen participates in the National Voluntary Laboratory Accreditation Program (NVLAP) for quality control procedures (NVLAP Lab Code: 101202-0). As specified in 40 CFR Chapter I (1-1-87 edition) Part 763, Subpart F, Appendix A.

Suspected asbestos samples were analyzed using polarized light microscopy (PLM) / dispersion staining techniques in accordance with the EPA Method documents “US EPA 600/M4-82-020, 1982” & “US EPA 600/R-93/118, 1993”. Detection limits for this type of analysis are approximately one percent (by volume). All samples were analyzed by International Asbestos Testing Laboratories of Mt. Laurel, New Jersey (IATL), a National Voluntary Laboratory Accreditation Program (NVLAP) accredited asbestos laboratory. Laboratory accreditations are provided in Appendix B.

Some materials may not be accurately identified and/or quantified by PLM. As an example, the original fabrication of vinyl floor tile routinely involved milling of asbestos fibers to extremely small sizes. As a result, these fibers may go undetected under the standard PLM method.

Transmission Electron Microscopy (TEM) is required for a more definitive analysis of these materials. These types of flooring materials that are reported by laboratory analysis to be non-asbestos by PLM analysis are routinely submitted to an accredited laboratory for analysis under TEM for verification of asbestos content. One hundred and sixty-two (162) samples were tested with TEM analysis for this building.

2.2 Asbestos Results

ASBESTOS CONTAINING MATERIALS

Suspect asbestos containing materials were identified and sampled in accordance with the above-referenced survey methodology. Laboratory results for suspect materials that were identified and sampled are included in Appendix A, entitled “Table I, Asbestos Survey Analytical Summary.”

Please reference the material location included on the drawings provided in Appendix D.

According to the AHERA Model Accreditation Plan, non-suspect material such as fiberglass, foam rubber and plastics do not warrant sampling.

2.3 Applicable Regulations

EPA's National Emission Standard for Hazardous Air Pollutants (NESHAP) (40 CFR 61, Building # 133 CA www.TropicalEnvironmental.com

Subpart M) categorizes asbestos-containing thermal system insulation (TSI) and sprayed-on or troweled-on asbestos as regulated ACM (RACM). Miscellaneous materials (floor tile and floor tile mastic) are classified as Category I Non-Friable Asbestos; and transite material is classified as Category II Non-Friable Asbestos, unless the material is made friable during demolition.

Friable ACM is material that can be crumbled, pulverized, or reduced to a powder by hand.

NESHAP requires at least ten working days’ notification prior to any renovation or demolition activity that will disturb greater than 160 square feet or 260 linear feet of ACM materials. ACM removed during abatement must be disposed of at a landfill approved by the EPA to receive asbestos wastes. NESHAP states that regulated asbestos-containing material (RACM), including friable ACM and non-friable ACM that has become or has a high probability of becoming friable, present in quantities exceeding 260 lineal feet on pipes or 160 square feet on facility components must be removed prior to the commencement of any demolition activities.

NESHAP also states that Category 1 non-friable ACM does not need to be removed prior to demolition if it is not in poor condition and has become friable. Friable materials (with the exception of roofing products) and transite are typically required to be removed prior to a demolition. Asbestos containing floor tile and mastic are typically required to be removed from concrete prior to recycling. Agencies such as Cook County require all asbestos containing materials be removed prior to demolition. If a facility is demolished by intentional burning, all regulated asbestos containing materials including Category I and Category II non-friable ACM must be removed before burning.

The Occupational Safety and Health Administration (OSHA) Construction Industry Standard (29 CFR 1926.1101) categorizes the removal of asbestos containing materials by “class” of material.

Specific requirements for the removal of OSHA classified materials include, but are not limited to, regulated work areas, air monitoring, engineering controls, work practices, personal protective equipment, notification and training.

The U.S. Department of Transportation (DOT) requires special procedures for packaging, labeling and transportation of asbestos wastes to disposal facilities. Other regulations may apply depending upon the contractor’s means and methods.

Tropical recommends the use of certified and licensed asbestos personnel for all planned disturbance of known and suspect asbestos containing products. In accordance with IDPH, IEPA, U.S.EPA and OSHA regulations asbestos containing materials must be removed by and disposed of by a certified/licensed asbestos abatement personnel/contractor.

Building # 133 CA

3.0 Findings and Recommendations

Suspect materials identified, sampled and analyzed as part of this survey were reported to contain asbestos in regulated quantities.

Materials identified in this report as ACM must be handled in accordance with applicable regulations as provided herein, and must be abated if they will be impacted by any planned renovation activity.

The owner or operator of a demolition or renovation activity and prior to the commencement of the demolition or renovation shall thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation will occur for the presence of asbestos, including Category I and Category II non-friable ACM.

It shall be at the owner’s discretion that a copy of this report is provided to any contractor bidding on work in the area(s) covered by this assessment. The owner may also elect to provide a copy of the report to the contractor on site during any renovation and/or demolition activities.

Contractors should use caution and be advised and directed that during renovation or demolition of a structure that concealed materials may be discovered, therefore, should suspect materials not identified in this inspection become exposed or made aware, you should cease operations that may disturb, dislodge or disrupt the material until it is sampled and analyzed for its possible asbestos content.

Although the efforts and intentions of our inspector(s) are always to sample all suspect materials, due to the nature of sampling, (destructive sampling, limited sample locations, visual assumption, etc.) some materials (such as floor tile/linoleum mastic/adhesive) may be excluded from the sampling process. These materials shall be assumed positive for asbestos unless sampled and analyzed otherwise. The client assumes and retains all responsibility and authority to conduct further sampling and analysis at their expense.

If additional suspect asbestos containing materials are identified during the renovation, those materials should be assumed to be positive for asbestos until they can be assessed, sampled, and analyzed by a NVLAP accredited laboratory.

Building # 133 CA www.TropicalEnvironmental.com

4.0 Limitations

The conclusions of this report are Tropical’s professional opinions, based solely upon visual site observations and interpretations of laboratory analyses, as described in this report. The opinions presented herein apply to the site conditions existing at the time of Tropical’s investigation and interpretation of current regulations pertaining to asbestos. Therefore, Tropical’s opinions and recommendations may not apply to future conditions that may exist at the site, which we have not had the opportunity to evaluate. It should be noted that conditions change and that materials constantly degrade. All applicable federal, state and local regulations should always be verified prior to any work that will disturb or dislodge materials confirmed, assumed or presumed to contain asbestos, Tropical’s assessment was limited to observation, sampling and the analysis of suspect asbestos containing products in accessible portions of the area(s) covered by this survey. Materials in the building that are not considered building materials, are unusual or de minimis, or were inaccessible, due to common construction techniques, to the inspector were excluded from the inspection. As a result, additional asbestos containing building materials may be present in inaccessible areas (e.g. between walls, ceiling spaces enclosed by wallboard, interior of fire doors, etc.) of the structure that were not observed during the survey.

This inspection report is designed to assist the client in the understanding of the regulations regarding asbestos, however, it should not be used as a substitution for obtaining and familiarizing yourself with, including the compliance of, all asbestos related regulations including, but not limited to, 40 CFR, Chapter 61, Subpart M (National Emission Standard for Asbestos) prior to the start of any renovation or demolition activity that will disturb or dislodge asbestos containing materials or suspect/assumed asbestos containing materials.

This report has been prepared for the exclusive use of the intended client, for the specific application to the defined property as addressed in this report. Any additional user of this report shall determine the suitability of the material contained herein for their intended use, and any such user assumes all risks and liability in connection therewith. No claim is made that these findings will remain applicable to future site activities and conditions. Interpretations by any such user from information contained in this report or the drawing of conclusions by any such user from information contained in this report shall be undertaken solely at the risk of said party.

At all times during the performance of the inspection, safety was a priority. Due to the emphasis on safety, there were no injuries, there was no building contamination, and there were no asbestos exposures to either Tropical Environmental, Inc personnel or building occupants.

Building # 133 CA www.TropicalEnvironmental.com

The asbestos survey was conducted in a manner consistent with that level of care and skill ordinarily exercised by members of the environmental profession under similar conditions. No other warranty or guarantee, express or implied, is included or intended in this Report or otherwise.

Building # 133 CA www.TropicalEnvironmental.com

5.0 References & Definitions

Illinois Department of Public Health (IDPH)

Asbestos Abatement Act, 105 ILCS 105

Asbestos Abatement for Public and Private Schools and Commercial and Public Buildings in Illinois, 77 Illinois Administrative Code 855

Commercial and Public Building Asbestos Abatement Act, 225 ILCS 207

United States Environmental Protection Agency (USEPA)

Asbestos Hazard Emergency Response Act (AHERA), 40 CFR, Part 763

National Emission Standards for Hazardous Air Pollutants (NESHAP), Asbestos, 40 CFR, Part 61, November 20, 1990

Guidance for Controlling Asbestos-Containing Materials in Buildings (EPA…