589A5-22-106 Asbestos and Lead Paint Report.pdf

ASBESTOS & LEAD PAINT SAMPLING REPORT

for

TOPEKA VA MEDICAL CENTER

TOPEKA, KS

PROJECT:

BUILDING 4

REPLACE HVAC

INSPECTION DATE:

JULY 7, 2022

ENVIRONMENTAL CONSULTANT:

CASTLE HILL ASSOCIATES, LLC

1197 FARNSWORTH RD., UNIT E

WATERVILLE, OH 43566

567-952-0212 www.CASTLEHILLASSOCIATES.com

TABLE OF CONTENTS

ASBESTOS & LEAD PAINT SAMPLING SUMMARY

ABESTOS BULK SAMPLING DESCRIPTIONS AND LAB RESULTS

LEAD XRF SAMPLING RESULTS

ASBESTOS LABORATORY REPORT

ASBESTOS LABORATORY CERTIFICATIONS

INSPECTOR CERTIFICATIONS

APPENDIX A PREVIOUS ASBESTOS INSPECTION REPORT FOR BUILDING 4

ASBESTOS & LEAD-BASED PAINT SURVEY REPORT

BUILDING 4 REPLACE HVAC

ASBESTOS INSPECTION SUMMARY

On July 7, 2022, Brett Brumbaugh of Castle Hill Associates performed an asbestos survey and lead XRF testing prior to the planned HVAC renovations in Building 4 which involves the replacement of HVAC and the associated HVAC equipment in Building 4 of the Topeka VAMC in Topeka, KS. Bulk samples were collected of suspect asbestos containing materials that had not been previously sampled during previous asbestos surveys in the building. There were 14 bulk samples taken as part of this survey with the materials identified in the report included in this submission.

The asbestos bulk sampling conducted as part of this project was based upon the appearance, texture, and location of the suspect materials. All bulk samples were analyzed utilizing current EPA methods for PLM (Polarized Light Microscopy) by EMSL Analytical in Indianapolis, IN. EMSL is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program) and also an American Industrial Hygiene Association (AIHA) accredited laboratory.

Prior to this sampling, Castle Hill was provided with previous sampling results conducted by the VA including the as survey completed for the VA which is included in Appendix A.

Lead paint testing was conducted on all painted surfaces in the renovation areas using a Viken Detection Pb200i direct read XRF analyzer. Painted components that were tested in the areas are considered to be

The inspection was conducted and the report was prepared by Brett Brumbaugh who is an EPA certified Asbestos Inspector, Management Planner, and Project Designer. He is also an EPA Licensed Lead Risk Assessor. Mr. Brumbaugh has been conducting asbestos surveys and lead sampling since 1987, and is a registered environmental property assessor (REPA) and certified environmental and safety officer (CESCO) through the NREP (National Registry of Environmental Professionals)

Asbestos Materials Findings As a result of the bulk sampling conducted during this inspection and previous testing, the following asbestos containing materials were identified in the renovation areas of the building:

Asbestos Containing Material Locations Quantity

Transite cement board behind radiators inside recessed wall radiator units

1st and 2nd floors (all rooms) 1,440 sf

Lead-Based Paint Findings As a result of the XRF testing for lead-based paint conducted during this inspection and previous testing, there was no lead-based paint detected on any building components in the renovation areas of the building.

BUILDING 4 REPLACE HVAC

UNIVERSAL WASTES FINDINGS

As a result of this inspection, the following Universal Wastes were identified in the renovation areas of the building:

Hazardous Materials Locations Fluorescent tubes & CFL Bulbs Basement, 1st and 2nd floors Batteries in exit light fixtures Basement, 1st and 2nd floors

COINLUSIONS/RECOMMENDATIONS

ASBESTOS: The asbestos containing materials identified in the renovation area must be removed if they will be disturbed as part of the renovation activities. If no disturbance is planned, they can be left in-place indefinitely until removal is required prior to demolition. All removal must be conducted by a Kansas licensed Asbestos Contractor.

UNIVERSAL WASTES: The identified Universal Wastes are not required to be removed prior to renovation, however if they are removed then they must be handled, transported, and disposed/recycled in an EPA approved facility by persons with proper training in the handling of Universal Wastes.

Respectfully Submitted, Brett L. Brumbaugh, REPA, CESCO EPA Asbestos Inspector Lead Risk Assessor EPA License # LBP-R-I216003-1

BUILDING 4 REPLACE HVAC

ASBESTOS SAMPLING PROTOCOL

The bulk samples were collected from locations that were selected to be representative of the building materials. Sampling was accomplished using the simplified sampling scheme referred in the AHERA red on this report.

The samples were either collected with a coring tool designed for asbestos sampling or placed into a plastic bag for laboratory analysis. The samples were analyzed via polarized light microscopy with

The regulations require specific numbers of samples be obtained per homogeneous area. For example, when sampling for joint compound or asbestos in hard plaster (sprayed-on or troweled-on surfacing materials) samples are to be taken based on the following increments: 0 to 1000 square feet of material, 3 samples are necessary. From 1001 to 5000 square feet, 5 samples are necessary, over 5000 square feet 7 samples are required. If during analysis any samples are found to contain asbestos, the entire homogeneous area is delineated as asbestos containing material. In the case of pipe insulation or other types of manufactured materials, the regulations require only enough samples to ascertain whether asbestos is present. In this case, the minimum number of samples to collect and analyze is usually three. The sampling performed in this inspection followed these sampling guidelines.

ASBESTOS GLOSSARY OF TERMS

Friable asbestos material: means any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763 section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable Asbestos Containing Material (ACM) means asbestos containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more that 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy.

Category II Non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos Containing Material (RACM): means (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 expected in the course of demolition or renovation operations regulated by this subpart.

ASBESTOS BULK SAMPLE DESCRIPTIONS & RESULTS

Facility: Topeka VA Medical Center Building: Building 4 Project: Replace HVAC Sampling Date: July 7, 2022 Analysis Date: July 9, 2022 Laboratory: EMSL Analytical, Inc. Indianapolis, IN Accreditation: NVLAP Asbestos Bulk Accredited Laboratory Sampler: Brett Brumbaugh

SAMPLE

# MATERIAL DESCRIPTION SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1 Hard ceiling plaster (base & finish coat) B120 No Asbestos Detected 2 Hard ceiling plaster (base & finish coat) A103 No Asbestos Detected 3 Hard ceiling plaster (base & finish coat) B117 No Asbestos Detected 4 Gray duct seam mastic on metal ducts B117 No Asbestos Detected 5 Gray duct seam mastic on metal ducts B131 No Asbestos Detected 6 Gray duct seam mastic on metal ducts Hall by B121 No Asbestos Detected 7 White duct seam mastic Basement crawl space No Asbestos Detected 8 White duct seam mastic Basement HVAC area No Asbestos Detected 9 White duct seam mastic Basement chiller room No Asbestos Detected

10 Black tar exterior wall coating above ceilings Hall by lounge No Asbestos Detected 11 Black tar exterior wall coating above ceilings Hall by B117 No Asbestos Detected 12 Black tar exterior wall coating above ceilings Hall by front entry No Asbestos Detected 13 Transite cement flat sheets Radiator in A138 25% Chrysotile Asbestos 14 Transite cement flat sheets Radiator in 1st floor hall 25% Chrysotile Asbestos

Notes:

Asbestos containing materials are defined by containing greater than 1% asbestos.

Previously tested Asbestos materials were not re-sampled as part of this project.

PHOTOGRAPHS OF ASBESTOS MATERIALS

Photo A-1 Transite cement board behind radiators in recessed radiator units

Photo A-2

Transite cement board behind radiators in recessed radiator units

ASBESTOS LABORATORY REPORT

EMSL ANALYTICAL, INC.

LEAD XRF TESTING DATA

Project: Topeka VA Medical Center - Topeka, KS Project: Replace HVAC Inspector: Brett Brumbaugh Date: 7/6/2022 XRF Mfg.: Viken Detection Model: Pb200i Type: XRF Lead Paint Analyzer Serial # 2757

Reading # Room/Area Component Paint Color Pb Conc.

mg/cm2 Result

1 1st floor lobby Hard plaster Tan 0.1 Negative 2 1st floor E. hallway Hard plaster Tan -0.1 Negative 3 1st floor B120 Hard plaster ceiling White 0.1 Negative 4 1st floor A103 Hard plaster ceiling White 0.2 Negative 5 1st floor A103 Hard plaster wall Tan 0.3 Negative 6 1st floor hallway at A138 Hard plaster wall Tan 0.1 Negative 7 1st floor A138 Radiator cover Tan 0.4 Negative 8 1st floor lobby Radiator cover Tan 0.3 Negative 9 1st floor lobby Ceiling tile grid White -0.1 Negative

10 2nd floor lobby Hard plaster wall Tan -0.1 Negative 11 2nd floor E. hallway Hard plaster wall Tan 0.1 Negative 12 Basement hallway Hard plaster wall Tan -0.1 Negative

LABORATORY CERTIFICATIONS

INSPECTOR CERTIFICATIONS

APPENDIX A

PREVIOUS INSPECTION REPORT

COMPREHENSIVE INTERIOR ASBESTOS SURVEY

VA Eastern Kansas Health Care System

Colmery- VAMC Building 04

Topeka, Kansas 66622

Prepared for:

Department of Veterans Affairs Network Contracting Office (NCO) 15

3450 S. 4th Street Trafficway Leavenworth, KS 66048

Prepared by:

Inspection Start Date:

September 25, 2020

ENCON International, Inc.

7307 Remcon Circle, #103

El Paso, TX 79912

October 09, 2020

Ms. Linda Lawrence, CIH Industrial Hygienist Eastern Kansas Healthcare System 2200 SW Gage Blvd.

Topeka, KS 66622 Email: Linda.Lawrence3@va.gov

RE: Submittal of Comprehensive Interior Asbestos Surveys Contract No. 36C25520P0345, Obligation No. 589C02185 Colmery- VAMC, Topeka, KS - Bldg. #04

Dear Ms. Lawrence, This document summarizes the Asbestos Survey Report for the subject building. The below listed information was utilized to complete the Scope of Work Tasks:

Bldg. No. 04 POC: Linda Lawrence, CIH Phone No: 785-350-9777 ext.52831

Approximate Building Square Footage (SF) Reported by VA: 57,602 SF

ASBESTOS SUMMARY: A total of sixty-four (64) bulk samples were effectively collected for lab analysis from within the building interior. The attached analytical results indicated that asbestos containing materials were not present within the subject building. Contact the Eastern Kansas Healthcare System, Colmery- VAMC regarding the latest overall status of any asbestos materials.

SUMMARY TABLE

Were Found

Were Not Found

Future Mgt.

Actions

Required?

Asbestos Containing Materials (>1 %) X No

Please contact ENCON with any technical questions, or follow-up needs that you may have.

Sincerely, Alex Woelper, P.E.

Sr. Project Manager

CC: Emilio Ballentos (Contract Specialist)

ATTACHMENTS:

Asbestos Survey Report

COMPREHENSIVE INTERIOR ASBESTOS SURVEY

Colmery- VAMC Building 04

PURPOSE

The ENCON International, Inc., (ENCON) was contracted by the Department of Veterans Affairs Network Contracting Office (NCO) 15, to perform Comprehensive Interior Asbestos Building Materials Surveys to identify the presence of any asbestos at a number of buildings at the Topeka and Leavenworth VA Complexes. This project also included the updating of the Asbestos Management plans for each campus. The following buildings have been included within this contract scope of work for the Colmery- 23, 24, 25, 40, 41, 42, 43, 44, 45, 48, 50, 51, 53, 54, 55, 56, 57 and 58. The technical objective of this project was to gather information regarding any existing asbestos materials within the assigned buildings, by inspecting and sampling suspect asbestos materials. The overall purpose was to and maintain its buildings, in compliance with federal regulations been provided at Attachment 3.

BACKGROUND

The VA has a number of buildings constructed before 1990 when the use of asbestos was prevalent in the construction of buildings. Because these materials still exist in some of these buildings, the VA is required to identify, assess the condition (stable or deteriorating), determine the nature of building materials (i.e., drywall or floor tile), and the extent of asbestos materials. In accordance with the Clean Air Act (40 CFR 61 Subpart M, Asbestos), any renovation, remodeling or demolition of any structure, (i.e., buildings, facilities, etc.), shall be surveyed for asbestos-containing materials (ACMs) and properly abated prior to any disturbance of the material.

INTRODUCTION

The sixty-one (61) buildings selected for Inspection during this project were contractually provided to ENCON by the VA. The selected buildings were located in two (2) geographic areas:

Topeka Campus (26 buildings) and Leavenworth Campus (35 buildings). Partial records were available for some of these buildings where previous asbestos inspections had been performed.

When available, prior asbestos reports were referenced to enhance the thoroughness of the comprehensive interior asbestos inspections performed for these buildings. The goal of this project was to provide comprehensive interior inspections of the designated facilities, utilizing non-destructive sampling methods. Therefore, on rare occasion some ACMs may be hidden behind walls, under subfloors, or located in other areas that were inaccessible to the inspection personnel, per standard general AHERA sampling protocols. Therefore, there is a very remote chance that limited additional destructive sampling may be required, only if hidden suspect ACMs are found in the future.

REGULATORY STANDARDS

Asbestos in building materials is regulated on the federal level by the Environmental Protection Agency (EPA), and the Occupational Safety and Health Administration (OSHA). On the state level, Kansas also has regulations pertaining to sampling and abatement of asbestos in buildings.

The inspection was conducted to ensure compliance with National Emission Standards for Hazardous Air Pollutants (NESHAP) commencement of the demolition or renovation, thoroughly inspect the affected facility or part of the facility where the demolition or renovation operation(s) will occur for the presence of asbestos, including Category I and Category II non-have been designated as RACM. All Asbestos Inspectors were trained under the EPA AHERA (40 CFR 763) standards. These facilities were sampled under the applicable regulations from the EPA, 40 CFR 61, and sampling protocols were generally based on EPA AHERA standards, per EPA 40 CFR 763.86, and in compliance with VHA Directive 7714.

FACILITY DESCRIPTION

Building 04 was constructed in 1958, and was in use at the time of inspection. Its previous use was NHCU Building building is presented in Table 1 below.

TABLE 1 BUILDING DESCRIPTION

Building Items Description

Area of building 57,602 square feet

Date of Construction 1958

Number of floors Three (3) floors & two (2) basements

Exterior wall materials Brick

Interior walls Plaster, drywall

Interior floors Concrete

Interior floor coverings 12x12 vinyl tiles, carpet, sheet vinyl

Ceilings Drywall, plaster, 2x2 lay-in ceiling tiles, 2x4 lay-in ceiling tiles

Notes: None

The main function or purpose, of this facility was identified as follows:

NHCU Building.

HOMOGENEOUS AREAS

Within the facility homogeneous areas were determined. Homogeneous areas are defined as areas of suspect asbestos containing materials including surfacing materials, thermal system insulation (TSI), or miscellaneous materials that were uniform in color, texture, substrate, and were relatively of the same age. Table 2 below lists the homogeneous areas and the general locations where they were identified.

TABLE 2 - Homogeneous Areas and Locations Identified

# Homogeneous Areas (Suspect Materials)

Location

1 Drywall (Walls / Ceilings) Throughout Building 2 12x12 Vinyl Floor Tiles (Cream w/ Tan Streaks) / Mastic Basement: Throughout 3 Vinyl Cove Base (Tan) / Mastic Throughout Building 4 2x2 Lay-In Ceiling Tiles (White) Basement: Throughout 5 Textured Plaster w/ Skim Coat (Walls) Throughout Building 6 2x4 Lay-In Ceiling Tiles (Small Fissures & Pinholes) Throughout Building 7 2x2 Lay-In Ceiling Tiles (Ridges / Textured) Basement: Room A14 8 Red Fire Caulk Throughout Building 9 Carpet Mastic Basement: Throughout Offices 10 12x12 Vinyl Floor Tiles (White) / Mastic First Floor: Throughout

11 Vinyl Cove Base (White) / Mastic First Floor: Throughout Hallways Second Floor: Throughout

12 2x2 Lay-In Ceiling Tiles (Small Fissures & Pinholes) First Floor: Throughout Hallways & Rooms

13 Sheet Vinyl (Blue Green) / Mastic First Floor: B Wing 14 Sheet Vinyl (Light Green) / Mastic First Floor: Foyer, Restrooms 15 Mastic Under Green Carpet Tile First Floor: Hallway C1-3 16 12x12 Vinyl Floor Tiles (Brown & Tan) / Mastic First Floor: Hallway C1-3

17 12x12 Vinyl Floor Tiles (Black & White) / Mastic Second Floor: Doorway To Rooms B257, B228, B216, B220

18 12x12 Vinyl Floor Tiles (Tan & White) / Mastic Second Floor: Room B213 19 4 Vinyl Cove Base (Brown) / Mastic Second Floor: Room B213

SAMPLING METHODOLOGY

The building materials survey tasks were performed in accordance with the EPA NESHAPs and/or AHERA Regulations. An initial visual inspection of the building was conducted to develop a sampling strategy. This task included determining homogeneous areas / materials, and sample collection locations. Friability was assessed by manually manipulating the suspect asbestos materials utilizing hand pressure to determine if the materials, when dry, could be crumbled, pulverized, or reduced to powder. Nineteen (19) homogeneous areas were established and at least three (3) samples were collected from each area to adequately identify accessible asbestos in the building. Portions of the subject building that had suspect asbestos-containing surfacing, thermal system insulation, or miscellaneous materials were divided into homogeneous areas for sampling.

These samples were each uniquely and individually identified and logged into a chain of custody document and prepared for shipment to a third-party, independent laboratory for analysis. Building materials that were not considered suspect ACM included the following: concrete, metal, glass, and wood. As is commonly practiced, destructive sampling was not authorized or performed to locate hidden or inaccessible materials.

Sixty-four (64) suspect ACM samples were collected and submitted for laboratory analysis. Refer to Appendix A for Asbestos sample location drawing(s). Bulk sample analyses were conducted utilizing polarized light microscopy (PLM), as per EPA Test Method 600/R-93/116. This method separates the sample material into various layers based on their morphology, and then identifies the presence of the different asbestos fibers in each of these layers when detected. The laboratory testing was performed by Apex Precision Analytical Services, Inc., located in Friendswood, TX.

Asbestos-Containing Material is defined as a material that contains greater than 1% of any asbestos type including Chrysotile, Amosite, Crocidolite, Tremolite, Anthophyllite, and Actinolite, or combinations of these materials. Asbestos materials are typically determined as recommended in the July 1993 EPA/600/R-93/116 document titled, "Method for the Determination of Asbestos in Bulk Building Materials." Copies of the asbestos laboratory test results and related laboratory documentation have been provided in Appendix B of this Report.

LABORATORY ANALYSIS

The sample collection and subsequent laboratory analysis indicated that asbestos was not identified in the building, as per Table 3 as follows. The NESHAPs definitions were used to define the condition of ACMs, per 40 CFR 61, Subpart M.

QUALIFICATIONS

This Comprehensive Interior Asbestos Survey was performed by ENCON Sr. Field Inspector Tim Jones on September 25, 2020, and was conducted in accordance with the EPA National Emission Standards for Hazardous Air Pollutants (NESHAP): 40 CFR Part 61, Subpart M. Sampling protocols were performed in general accordance with AHERA. The Inspector had received training under the AHERA required Asbestos Inspector Course and had received annual refresher training within the past year.

LIMITATIONS

The overall purpose of this Comprehensive Interior Asbestos Survey was to identify if ACM was present, within the qualifications and limitations summarized below. Reliance on this report is specifically limited to gathering initial information regarding the presence of asbestos in building

TABLE 3 Identified Asbestos Containing Materials (> 1%)

Sample No. Asbestos Containing Materials

Approx.

Qty.

Location Condition (friable, cat, damaged)

- No ACM Identified N/A N/A N/A materials. Any time that ACMs may be identified during the performance of an asbestos survey, the owner of the building is responsible to the occupants and to the public to manage these materials properly, per Local, State and Federal regulations. Prior to the abatement or removal of any ACMs, an asbestos project design should be properly created, by a qualified asbestos consulting firm, 1) to ensure that materials will be properly managed, and 2) to prepare a more accurate estimate of materials to be abated. This Survey Report was specifically prepared for the Department of Veterans Affairs Network Contracting Office (NCO) 15, and the extent of liability incurred by ENCON, is limited to the amount of the report fee paid by its Client. The VA agrees that ENCON cannot be held responsible for any liability based on reliance of this report by any third party for any business reasons.

CONCLUSIONS

1. The survey for the subject building was successfully completed, as required, per State and Federal environmental standards. Refer to Table 1 for building details.

2. Suspect ACMs were potentially identified in nineteen (19) homogeneous areas at the subject building. Refer to Table 2 for a listing of homogeneous areas.

3. A total of sixty-four (64) suspect ACM samples were collected from the building interior, and were properly analyzed by an independent, qualified third-party laboratory. Refer to Appendix A for details regarding sample locations and descriptions.

4. A review of the laboratory test results indicated that ACMs were not identified at the subject building. Refer to Table 3 for a listing of any identified ACMs.

5. ACMs were not confirmed in any homogeneous areas at the subject building. Refer to the Appendices for details regarding sample locations and descriptions.

6. The VA is responsible for properly managing all materials at the subject building.

7. A comprehensive NESHAP survey should be performed in any areas to be renovated.

Future Contingent Requirements: The following requirements would need to be followed, only if hidden ACMs are identified through future destructive sampling activities.

1. If no additional ACMs are confirmed in the future, then no further actions would be required.

2. In the unlikely event that additional are encountered during any future renovation or demolition activities, further limited sampling and lab analysis will be required. VA asbestos and / or safety personnel should be notified immediately for public safety and environmental compliance actions to properly manage any confirmed additional ACMs.

3. Any ACMs should not be disturbed by unlicensed and / or untrained personnel.

4. Proper 10-day advance NESHAP notification would need to be made to the appropriate authorities prior to disturbance of any newly identified ACMs. Such disturbance would potentially include abatement activities, building renovations, routine operation & maintenance activities, or any planned demolition in facilities or public buildings.

5. If disturbance of any newly identified ACMs is required in the future, then these materials should be properly removed in advance of disturbance by licensed and trained personnel, as required by State and Federal regulations.

6. Any future abatement activities would need to be performed by a licensed Asbestos Abatement Contractor, with project management and air monitoring support by an experienced, certified Asbestos Consulting Firm.

ATTACHMENTS

Refer to a copy of personnel certifications and VA document VHA Directive 7714 titled, tachment 2 and Attachment 3, respectively. Additionally, Contact the personnel listed below with any clarifications that may be needed.

Inspected by:

Tim Jones Sr. Asbestos Inspector ENCON International, Inc.

Reviewed by:

Rosie Jimenez Project Coordinator ENCON International, Inc.

Approved by:

Alex Woelper, P.E.

Sr. Project Manager ENCON International, Inc.

APPENDICES:

A. Asbestos Sample Location Drawing(s) B. Laboratory Documentation

APPENDIX A

Asbestos Sample Location Drawing(s)

APPENDIX B

Laboratory Documentation