ThinkForm_St. Louis VAMC Renovate Lobby_RBM Survey Report 1.pdf
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This is a Regulated Building Materials Survey Report prepared for the Renovate Building 1 Ambassador Suite & Main Lobby project at the John J. Cochran VA Medical Center in St. Louis, Missouri (VA Project No. 657-24-111JC). The survey was conducted on June 12, 2025, by Mabbett & Associates, Inc., with asbestos inspection oversight by State of Missouri licensed inspector Michael Mosier.
The survey identified asbestos-containing materials (ACM) in two locations: gray/black backing associated with tan speckled linoleum (2% Chrysotile) covering 300 square feet in Corridor H118, and white pipe insulation (60% Chrysotile) measuring 65 linear feet in the Pharmacy Waiting Room above the ceiling. One hundred ten bulk samples were collected from 36 homogeneous areas and analyzed using Polarized Light Microscopy (PLM) by EMSL Analytical laboratories. Four paint chip samples were collected and analyzed for lead content using atomic absorption spectroscopy by Scientific Analytical Institute; all samples tested below the HUD threshold of 0.5 percent by weight and 1.0 mg/cm². The report includes detailed laboratory analytical results, chain of custody documentation, asbestos and lead sampling location plans, photographic documentation, and recommendations for proper handling and disposal of identified ACM in compliance with EPA NESHAP, AHERA, and OSHA regulations.
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| 36C25526R0167 0003.docx | DOCX document | |
| Questions and Responses 1- 43 657-24-111JC.docx | DOCX document | |
| 36C25526R0167 0002.docx | DOCX document | |
| REVISED 852.219-75 VA NOTICE OF LIMITATIONS ON SUBCONTRACTING.docx | DOCX document | |
| 36C25526R0167 0001.docx | DOCX document | |
| Sign in Sheet.pdf | ||
| REVISED CALCULATION OF SELF PERFORMED-SUBCONTRACTOR WORK_r 02.docx | DOCX document | |
| S04- Pre-bid visit agenda 657-24-111JC pdf.pdf | ||
| 36C25526R0167.docx | DOCX document | |
| P09 657-24-111JC DRAWINGS.pdf | ||
| P09 657-24-111JC Specs Combined.pdf |
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REGULATED BUILDING MATERIALS
SURVEY REPORT
Renovate Bldg. 1 Ambassador Suite & Main Lobby VA Project No. 657-24-111JC
John J. Cochran VA Medical Center 915 North Grand Boulevard St. Louis, MO 63106
Mabbett Project No. R2023211.001.001
July 28, 2025
Prepared For:
ThinkForm Design Architects, LCC 38 E Broad Street, Suite 3 Hopewell, NJ 08525
© 2025, Mabbett & Associates, Inc.
Mabbett & Associates, Inc. www.mabbett.com 105 Central Street, Suite 4100 Stoneham, MA 02180-1260 T. 781-275-6050 F. 781-954-5155 Massachusetts | Virginia | Rhode Island | New York
REGULATED BUILDING MATERIALS SURVEY REPORT
Renovate Bldg. 1 Ambassador Suite & Main Lobby | St. Louis VAMC
© 2025, Mabbett & Associates, Inc. Page i July 28, 2025 Project No. R2023211.001.001 ThinkForm_St. Louis VAMC Renovate Lobby_RBM Survey Report
ACKNOWLEDGEMENT
This Regulated Building Materials Survey Report has been prepared by Mabbett & Associates, Inc. (Mabbett®) for the Renovate Bldg. 1 Ambassador Suite & Main Lobby VA Project No. 657-24-111JC at the John J. Cochran VA Medical Center (St. Louis VAMC) located at 915 North Grand Boulevard in St. Louis, Missouri. The information presented herein is based on the facts and information conveyed to or received by Mabbett during the preparation of this report. If any of the information provided to Mabbett that was used in preparing this report is incorrect, incomplete, or subject to change, Mabbett would wish to alter its opinions accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to Mabbett as of the date of this report and considered applicable to this report.
Mabbett does not claim to have identified all hazardous materials that could be present in the facility. Mabbett has conducted this assessment with reasonable care and has performed this project in accordance with industry standards. There can be no assurances, and Mabbett makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported herein.
The attached Regulated Building Materials Survey Report was prepared by Mr. Andrew P. Beaton, Environmental and Regulated Building Materials Technician of Mabbett & Associates, Inc.
This report has been reviewed and approved by:
Michael F. Delaney Practice Lead, Building Sciences
APB/MFD
© 2025, Mabbett & Associates, Inc. Page ii July 28, 2025
TABLE OF CONTENTS
SECTION PAGE
1.0 INTRODUCTION
1.1 Purpose and Objectives
1.2 Summary of Survey Results
2.0 ASBESTOS CONTAINING MATERIAL (ACM) SURVEY
2.1 Sampling Methodology
2.2 Analytical Methodology
2.3 ACM Results
3.0 LEAD CONTAINING PAINT (LCP) SURVEY
3.1 Sampling Methodology
3.2 Analytical Methodology
3.3 LCP Results
4.0 RECOMMENDATIONS
4.1 Asbestos
4.2 Lead Containing Paint
TABLES
Table 2-3 – Estimated Quantities of Asbestos Containing Materials Table 3-3 – Summary of Lead Paint Chip Analytical Results
FIGURES
Pb-1 Ambassador Suite Lead Sampling Location Plan Pb-2 Main Lobby Lead Sampling Location Plan
APPENDICES
Appendix A – Terracon Pre-Renovation Asbestos Inspection Report Appendix B – LCP Laboratory Report and Chain of Custody Documentation
© 2025, Mabbett & Associates, Inc. Page 1 July 28, 2025
1.0 INTRODUCTION
Mabbett and Associates, Inc. (Mabbett®), performed a survey for regulated building materials (RBM) as part of the Renovate Bldg. 1 Ambassador Suite & Main Lobby project at the St. Louis VA Medical Center located at 915 North Grand Boulevard, St. Louis, Missouri, VA Project No. 657-24-111JC. The survey was limited to the locations outlined in the A/E SOW. Site survey work was performed on June 12th, 2025, by Mr. Jacob Walsh of Mabbett and State of Missouri licensed asbestos inspector Mr. Michael Mosier of Terracon and consisted of the following activities:
Asbestos Containing Material (ACM) survey of suspect materials (analysis by Polarized Light Microscopy
[PLM]
Lead Containing Paint (LCP) sampling (analysis by atomic absorption [AA] spectroscopy)
1.1 Purpose and Objectives
This regulated building material survey was comprised of three primary project tasks including:
Evaluation of existing site conditions and formulation of a sampling plan Site survey to collect building material samples for laboratory analysis Development of this Regulated Building Materials Survey Report
This project was designed to accomplish two primary objectives: (1) to collect a representative number of building materials for laboratory analysis and reporting; and (2) to use data from the laboratory analysis efforts to estimate the volume of hazardous and regulated building materials present within the building’s interior and exterior for subsequent use in development of an abatement scope. These two objectives were met through a combination of a site inspection to collect building material samples for laboratory analysis; interpretation of qualitative data collected in the field; and the quantitative laboratory data generated from analysis of the building materials as summarized in this survey report.
1.2 Summary of Survey Results
As required by State and Federal regulations, bulk samples of suspected ACM were collected by Terracon and submitted using chain of custody (COC) procedures to EMSL Analytical, Inc. (EMSL) located in St. Louis, Missouri.
Due to a high workload at the St. Louis EMSL, samples from the Ambassador Suite project were redirected to the EMSL Indianapolis, Indiana laboratory for analysis. EMSL St. Louis is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP), accreditation number 200742-0. EMSL Indianapolis is accredited for bulk asbestos analysis under the National Voluntary Laboratory Accreditation Program (NVLAP), accreditation number 200188-0 and National Institute Standards and Technology (NIST). The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) define ACM as any material that contains greater than one percent (>1%) asbestos.
Paint chip samples were collected by Mabbett for lead analysis using AA spectroscopy and submitted under COC procedures to Scientific Analytical Institute, Inc. (SAI) located in Greensboro, North Carolina.
Current survey efforts yielded the following results:
One-hundred and ten (110) bulk samples for suspect ACM were collected for laboratory analysis and reporting. Two (2) of the materials collected were found to contain greater than one percent (<1%) asbestos.
© 2025, Mabbett & Associates, Inc. Page 2 July 28, 2025
Four (4) paint chip samples were collected from painted building surfaces collected during this survey effort. None of the collected samples revealed concentrations of lead in paint that exceed the U.S.
Department of Housing and Urban Development (HUD) threshold of 0.5 percent by weight and 1.0 mg/cm2 by XRF.
© 2025, Mabbett & Associates, Inc. Page 3 July 28, 2025
2.0 ASBESTOS CONTAINING MATERIAL (ACM) SURVEY
The asbestos survey was performed on June 12th, 2025, by Mr. Jacob Walsh of Mabbett and State of Missouri licensed asbestos inspector Mr. Michael Mosier (#7118051525MOIR23654). Prior to collecting samples, a visual screening assessment was conducted to identify locations of suspect ACM and develop a sampling plan. The area was occupied at the time of the inspection. Only areas that were accessible during the field work phase were included in the survey, with reasonable efforts made to access areas needed to complete the asbestos survey and sampling program. Any unsampled or new materials discovered during demolition activities must be sampled and submitted to a laboratory for analysis. Destructive investigation of operating equipment was not conducted.
2.1 Sampling Methodology
Bulk samples for asbestos analysis were collected using EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763, and Asbestos Hazard Emergency Response Act (AHERA) protocols. Bulk suspect ACM sampling was conducted according to the following standard sampling protocol:
Friable surfacing material:
• At least three bulk samples shall be collected from each homogeneous area of surfacing material that is 1,000 ft2 or less.
• At least five bulk samples shall be collected from each homogeneous area of surfacing material that is greater than 1,000 ft2 but less than or equal to 5,000 ft2.
• At least seven bulk samples shall be collected from each homogeneous area of surfacing material that is greater than 5,000 ft2.
Thermal system insulation:
• At least three bulk samples shall be collected from each homogeneous area of thermal system insulation.
• At least one bulk sample shall be collected from each homogeneous area of patched thermal system insulation.
• Sufficient samples shall be collected from elbows and fittings.
• Bulk samples shall not be collected from any homogeneous area where the inspector determines that the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACM.
Miscellaneous material (e.g., joint compound, roofing, gaskets, floor coverings, decorative coatings, wire insulation):
• At least two bulk samples shall be collected from each homogeneous area of miscellaneous material that is less than 100 ft2.
• At least three bulk samples shall be collected from each homogeneous area of miscellaneous material that is greater than 100 ft2.
Areas that were inaccessible or where the survey was limited to visual observation only:
Within walls and enclosed pipe/duct chases Inside mechanical equipment/ductwork and electrical equipment
© 2025, Mabbett & Associates, Inc. Page 4 July 28, 2025
2.2 Analytical Methodology
One hundred and ten (110) bulk samples were collected from thirty-six (36) homogeneous areas and submitted under chain of custody (COC) procedures to EMSL. Bulk samples were analyzed by phase light microscopy (PLM) with dispersion staining techniques in accordance with USEPA’s Method for Determination of Asbestos in Bulk Building Materials (600/R-93-116)
2.3 ACM Results
The EPA, Occupational Safety and Health Administration (OSHA), and the Missouri Department of Natural Resources (MDNR) define any material that contains greater than one percent (>1%) asbestos as ACM. Two (2) materials sampled as part of this survey were found to contain greater than one percent (<1%) asbestos. A summary of bulk sample results and the Terracon Pre-renovation Asbestos Inspection Survey Report is provided in Appendix A.
Estimated quantities of materials identified as ACM during this survey are presented in Table 2-3.
TABLE 2-3
Estimated Quantities of Asbestos Containing Materials
Renovate Bldg. 1 Ambassador Suite & Main Lobby John J. Cochran VA Medical Center
Sample Location Description of Material Percent and Type of Asbestos
Estimated Quantity
Amount Units Ambassador Suite, Corridors
H118 and H119 Gray/Black Backing associated with Tan Speckled Linoleum 2% Chrysotile 300 SF
Ambassador Suite, Pharmacy Waiting Room B102 White Pipe Insulation 60% Chrysotile 65 LF
Notes: SF = Square Feet; LF = Linear Feet
© 2025, Mabbett & Associates, Inc. Page 5 July 28, 2025
3.0 LEAD CONTAINING PAINT (LCP) SURVEY
An LCP survey was conducted by collecting and analyzing paint chips from painted surfaces and systems that may be impacted by the Renovate Bldg. 1 Ambassador Suite & Main Lobby Project.
3.1 Sampling Methodology
Paint chip samples were collected using a sharp hand tool to score and peel paint off an approximate 1 square inch area of the substrate. Different tools such as chisels, putty knives, and hammers may also be needed in the collection of paint chips. All tools are cleaned after each sampling to prevent cross contamination. Collected paint chip samples are submitted under COC procedures to an accredited laboratory and analyzed via atomic absorption
(AA).
3.2 Analytical Methodology
The regulations addressing LCP in non-residential buildings are focused on occupational exposures involved with paint-disturbing activities and related waste-disposal activities. Occupational exposure to lead is regulated by OSHA regulation 29 CFR 1926.62, Lead in Construction, as well as other applicable state and local regulations.
An LCP survey cannot determine a safe level of lead for the purpose of paint-disturbing/waste-disposal activities but is intended to provide guidance as to the locations of surfaces containing lead. Contractors may use this information to better determine where worker exposures to airborne lead and other hazards may occur. They can then assess the potential magnitude of exposure to their employees and identify the controls necessary to limit health risks. This information can also be used for pre-characterization of demolition waste streams prior to toxicity characteristic leaching procedure (TCLP) sampling in accordance with 40 CFR Part 261.
Four (4) samples, each from a different homogenous areas were collected during this survey. Paint chip samples were submitted using COC procedures to SAI for analysis. Analysis was conducted using EPA SW-846 Test Method 7000B: Flame Atomic Absorption Spectrophotometry.
3.3 LCP Results
A concentration of lead greater than or equal to 0.5 percent by weight (equivalent to 5,000 ppm) or 1.0 mg/cm² exceeds EPA and HUD residential standards and is considered an indicator of risk. The results of this LCP sampling survey indicated that none of the samples indicate risk and are presented in Table 3-3. The laboratory report and COC documentation are provided in Appendix B.
TABLE 3-3
Summary of Lead Paint Chip Analytical Results
Renovate Bldg. 1 Ambassador Suite & Main Lobby John J. Cochran VA Medical Center
Sample # Location Substrate and Component Color Concentration (% by weight)
PC-Pb-01 A100D Gypsum Wall White <0.0036%
PC-Pb-02 A100D Metal Pipe Black <0.0069%
PC-Pb-03 B100 West Corner Gypsum Wall White <0.0031%
PC-Pb-04 B100 West Corner Metal Pipe Black <0.0054%
© 2025, Mabbett & Associates, Inc. Page 6 July 28, 2025
4.0 RECOMMENDATIONS
4.1 Asbestos
Two (2) materials sampled as part of this survey were found to contain greater than one percent (<1%) asbestos.
Any suspect materials encountered during renovation activities that were not identified in this report as being non-ACM should be assumed to be ACM unless sample results prove otherwise. Suspect ACM that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, should be assumed to contain asbestos if discovered during any renovation or demolition process or until otherwise verified.
4.2 Lead Containing Paint
The purpose of the LCP screening survey was to identify patterns of LCP. For the purpose of this LCP screening survey a limited amount of representative interior building components were tested. The regulations addressing LCP in non-residential buildings are focused on protecting workers involved with paint-disturbing activities and related waste-disposal activities.
Occupational exposure to lead in construction is regulated by OSHA regulation 29 CFR 1926.62 “Lead in Construction”, as well as other applicable state and local regulations. These regulations involve the air monitoring of workers to determine exposure levels when disturbing paint containing measurable concentrations of lead. An LCP survey cannot determine the safe level of lead for the purpose of paint-disturbing activities but is intended to provide guidance as to the locations of LCP. Employers and contractors may use this information to better determine where worker exposures to airborne lead may occur and, through the interpretation of LCP concentration data, assess the potential magnitude of exposure to their employees and identify the controls necessary to limit health risks.
A concentration of lead greater than or equal to 0.5 mg/Kg percent by weight or 1.0 mg/cm2 exceeds EPA and HUD residential standards is considered an indicator of risk. Representative samples of LCP waste to be generated during building renovation, or following demolition but prior to disposal, should be collected and analyzed using toxicity characteristic leaching procedure (TCLP) in accordance with 40 CFR Part 261. Management and disposal of lead containing waste must be done in accordance with all applicable local, state, and federal regulations. OSHA regulations may require certain procedures for any paint that contains lead, even if it is below these levels. All LCP identified, regardless of the lead content, should either be sampled and analyzed by TCLP and then handled/disposed of accordingly, or segregated from other large-scale debris and then managed as hazardous waste in accordance with federal, state, and local hazardous waste disposal regulations.
© 2025, Mabbett & Associates, Inc. FIGURES July 28, 2025
FIGURES
Lead Sample Location Plans
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© 2025, Mabbett & Associates, Inc. APPENDIX A July 28, 2025
APPENDIX A
Terracon Pre-Renovation Asbestos Inspection Report
Pre-Renovation Asbestos Inspection Report
John Cochran VA Hospital Ambassador Suite and Main Lobby
915 North Grand Boulevard
St. Louis, Missouri 63106
July 9, 2025 | Report Number: 15257097
Prepared for:
Mabbett & Associates, Inc.
105 Central Street Suite 4100 Stoneham, MA 02180
11600 Lilburn Park Road
St. louis, Missouri 63146
P (314) 692-8811
Terracon.com
Facilities | Environmental | Geotechnical | Materials 1
July 9, 2025
Mabbett & Associates, Inc.
105 Central Street Suite 4100 Stoneham, MA 02180
Attn: Mr. Darren Andrews
(781) 275-6059 andrews@mabbett.com
Re: Pre-Renovation Asbestos Survey John Cochran VA Hospital- Main Lobby and Ambassador Entrance 915 N. Grand Boulevard St. Louis, Missouri 63106 Terracon Project No. 15257097
Dear Darren Andrews:
Terracon Consultants, Inc. (Terracon) appreciates the opportunity to submit this report to Mabbett & Associates Inc. (Mabbett, or the Client) regarding the Pre-Renovation Asbestos Inspection conducted on June 12, 2025. The purpose of this report is to present the findings of the inspection, which was conducted in general accordance with Terracon Proposal #P15257097, dated and signed March 24, 2025.
Asbestos was identified by laboratory analysis in the following materials at amounts >1%.
Material Description Material Location
NESHAP
Category
Estimated Quantity
Gray/Black Backing Associated With Tan Speckled Linoleum
Ambassador Suite, Corridor H118, Floor Category I non-friable
180 square feet
White Pipe Insulation Ambassador Suite, Pharmacy Waiting
Room, Ceiling Space RACM 65 linear feet
If you have questions regarding this report or require additional services, please call George Jones at
(314) 692-8811 or email George at george.jones@terracon.com.
Sincerely, Terracon Consultants, Inc.
Prepared By: Reviewed By:
Michael Mosier William L Wright Assistant Scientist Department Manager
Pre-Demolition Asbestos Inspection Report John Cochran VA Hospital Pre-Reno ACM Inspection | 915 North Grand Blvd, St. Louis, MO July 9,2025| Terracon Project No. 15257097
Facilities | Environmental | Geotechnical | Materials 3
TABLE OF CONTENTS
PROJECT DESCRIPTION
1.1 Scope of Services
1.2 Limitations
1.3 Building Description
1.4 Standard of Care
FIELD ACTIVITIES
2.1 Asbestos Inspection
Visual Assessment Physical Assessment Sample Analysis
REGULATORY REVIEW
3.1 Asbestos
FINDINGS AND RECOMMENDATIONS
4.1 Asbestos Inspection Findings
GENERAL COMMENTS
APPENDIX A IDENTIFIED ASBESTOS-CONTAINING MATERIALS
APPENDIX B BULK SAMPLE LOCATION SUMMARY
APPENDIX C ASBESTOS CHAIN OF CUSTODY AND LABORATORY ANALYTICAL REPORT
APPENDIX D CERTIFICATIONS
APPENDIX E PHOTO LOG
APPENDIX F SAMPLE LOCATION MAP
July 9,2025| Terracon Project No. 15257097
Facilities | Environmental | Geotechnical | Materials 4
PROJECT DESCRIPTION
On June 12, 2025, at the request of Mabbett & Associates, Inc. (Mabbett), Terracon Consultants, Inc.
(Terracon) conducted a Pre-Renovation Asbestos Inspection of the Main Lobby Entrance and Ambassador Suite of the John Cochran VA Hospital addressed at 915 North Grand Boulevard, St. Louis, Missouri. Limited invasive and destructive sampling techniques were utilized when collecting samples from the interior and exterior of the building. Destructive sampling involved temporary repairs to affected areas where possible.
The sampling event was conducted in general accordance with Terracon Proposal #P15257097, dated and signed March 24, 2025.
The objective of the inspection was to determine the presence of asbestos-containing materials (ACM) within building components prior to and in areas where renovation is scheduled to occur.
1.1 Scope of Services
The scope of services included:
A visual survey of the interior and exterior of the building per area, scheduled to be renovated, to determine the extent of potential ACM.
Bulk sampling of suspect ACM in anticipation of removal and disposal of any identified
ACM.
Laboratory analysis of bulk ACM samples to determine the levels of asbestos (as applicable) present in the samples.
Preparation of the associated technical report.
1.2 Limitations
Terracon did not encounter significant limitations during the performance of the asbestos inspection.
1.3 Building Description
The John Cochran VA hospital Patient Care building, located at 915 North Grand Boulevard, is an approximately 1,000,000 square-foot (SF) plus, seven-story, hospital, in which this survey was conducted. The two areas surveyed in the Patient Care building were the Ambassador Suite and the Main Entrance Lobby. The Ambassador Suite area is approximately 6,000 SF, and the Main Entrance Lobby is approximately 4,000 SF. The exterior of the building consists primarily of red brick and mortar, and concrete walls. The interior of the building is made up of concrete flooring with vinyl floor tiles, linoleum, ceramic floor tiles, and carpeting in office areas. Walls are made up of painted drywall, and ceilings consist of 2’x4’ and 2’x2’ drop ceiling tiles. The Ambassador Suite entryway does have brick, mortar, and concrete on the interior. Plaster is also present in the entryway of the Ambassador Suite.
The Main Entrance Lobby does have wood ceilings for part of the lobby and 2’ x 4’ white smooth ceiling tiles. The floor of the Main Entrance Lobby consists of newer green poured floor with crystal type specks/inlay.
July 9,2025| Terracon Project No. 15257097
Facilities | Environmental | Geotechnical | Materials 5
1.4 Standard of Care
This evaluation was conducted based on information provided to Terracon by the Client and was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. Terracon did not attempt to identify every potential exposure or hazard present. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during the assessment.
The information contained in this report should not be relied upon to represent conditions that existed before or after this investigation. Terracon does not warrant the services of regulatory agencies, laboratories, or other third parties supplying information that may have been used in the preparation of this report.
FIELD ACTIVITIES
2.1 Asbestos Inspection
The asbestos survey was conducted and overseen by Michael Mosier, a State of Missouri-certified asbestos inspector in accordance with the sample collection protocols established in USEPA regulation 40 CFR Part 763, Subpart E (AHERA), referenced in greater detail in section 3.1. A summary of inspection activities is provided below. A copy of Terracon’s asbestos inspector credentials is included in Appendix D.
Visual Assessment
Survey activities were initiated with visual observations of the interior and exterior of the inspection areas to identify readily accessible homogeneous areas of suspect ACM to be disturbed during renovations. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application.
Physical Assessment
A physical assessment of each readily accessible HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure and includes previously nonfriable material when the material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure. Friability was assessed by physically touching suspect materials. Sample collection was based on results of the visual observations and bulk samples of suspect ACM were collected in accordance with USEPA sampling protocols. Samples of suspect materials were collected from random locations for each HA. Bulk samples were collected using hand tools and placed in sealable containers and labeled with unique sample numbers using an indelible marker.
The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content. With respect to the inspection scope, Terracon collected a total of 86 samples from 28 HA’s from the Ambassador Suite area and 26 samples from eight HA’s from the Main Entrance area. In accordance with the method, analysis is required to be performed on each layer of the bulk samples resulting in a total of 160 samples analyzed. A sample summary is included in Appendix B. Appendix E includes photographs from the inspection activities.
July 9,2025| Terracon Project No. 15257097
Facilities | Environmental | Geotechnical | Materials 6
Sample Analysis
The bulk samples were submitted under chain of custody (COC) to EMSL Analytical, Inc. (EMSL) of St.
Louis, Missouri for analysis by polarized light microscopy (PLM) with dispersion staining techniques in accordance with USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R- 93-116). Due to a high workload at the St. Louis EMSL, samples from the Ambassador Suite were redirected to the EMSL Indianapolis, Indiana laboratory for analysis. The asbestos content, if present, was determined by microscopic visual estimation using PLM. EMSL St. Louis is accredited for bulk asbestos analysis under the National Voluntary Laboratory Accreditation Program (NVLAP), accreditation number 200742-0. EMSL Indianapolis is accredited for bulk asbestos analysis under the National Voluntary Laboratory Accreditation Program (NVLAP), accreditation number 200188-0.
Results are included with the sample summary in Appendix B. The laboratory analytical reports are included in Appendix C.
REGULATORY REVIEW
3.1 Asbestos
The asbestos National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. All friable ACM or asbestos containing materials which can be rendered friable are considered regulated asbestos-containing material (RACM).
The asbestos USEPA regulation 40 CFR Part 763, Subpart E (AHERA) describes the management of asbestos found in schools through a plan of identification, management, and abatement. Within this regulation methods of identification of asbestos, managing of ACM, and response actions are delineated for the inspector to follow.
The asbestos NESHAP regulation classifies ACM as RACM, Category I nonfriable ACM, or Category II nonfriable ACM. RACM includes all friable ACM, along with Category I and Category II nonfriable ACMs that have become friable; will be or have been subjected to sanding, grinding, cutting, or abrading; or that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder during renovation or demolition activity. Category I nonfriable ACMs are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics, and asphalt roofing products that contain more than 1% asbestos. Category II nonfriable ACMs are all other nonfriable materials other than Category I nonfriable ACM that contain more than 1% asbestos. Asbestos concentrations less
-asbestos according to NESHAP.
The Missouri Department of Natural Resources, (MDNR) Air Pollution Control Program, enforces the asbestos NESHAP as adopted by reference at 10 Code of State Regulations (CSR) 10-6.080. The owner or operator must provide MDNR with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than or equal to 160 square feet, 260 linear feet, or 35 cubic feet. MDNR has delegated authority of this regulation to several local agencies, including the St. Louis City Department of Air Pollution Control. In St. Louis City, asbestos abatement projects involving 10 square feet or 16 linear feet or more of friable
July 9,2025| Terracon Project No. 15257097
Facilities | Environmental | Geotechnical | Materials 7 asbestos-containing material require a permit from the Department of Air Pollution Control at least 10 working days prior to commencement prior to commencement of the abatement.
The federal OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos and establishes permissible exposure limits (PELs) and an Action Level (AL) for exposure to airborne asbestos. The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work. The standard also specifies requirements for handling materials containing asbestos in concentrations less than or equal to 1%.
FINDINGS AND RECOMMENDATIONS
4.1 Asbestos Inspection Findings
Asbestos was identified at a concentration greater than 1% in samples collected from the following materials located at 915 North Grand Boulevard:
Asbestos Containing Materials Ambassador Suite, 915 North Grand Boulevard
Material Description Material Location
NESHAP
Category
Estimated Quantity
Gray/Black Backing Associated With Tan Speckled Linoleum
Ambassador Suite, Corridor H118 Category I non-friable
180 square feet
White Pipe Insulation Ambassador Suite, Pharmacy Waiting
Room RACM 65 linear feet
The above listed RACM and Category I non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder when dry, making it friable, must be properly removed prior to any activities (renovation and/or demolition) that may disturb this material in accordance with applicable federal, state and local regulations. USEPA believes that most demolition activities will subject Category I non-friable ACM to the asbestos NESHAP regulation.
Asbestos containing building materials were not identified in the samples collected and analyzed from the Main Entrance of 915 North Grand Boulevard.
GENERAL COMMENTS
This report has been prepared on behalf of and exclusively for use by Mabbett & Associates, Inc., for specific application to their project as discussed herein. The analysis and conclusions in this report are based upon data obtained during asbestos inspection activities. The professional services provided, and judgments rendered on this project are consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. Terracon does not warrant the work of regulatory agencies, laboratories, or other third parties supplying information that may have been used in the preparation of this report. No warranty, express or implied, is made.
Facilities | Environmental | Geotechnical | Materials
Appendix A Identified Asbestos Containing Materials
Facilities | Environmental | Geotechnical | Materials 1
ASBESTOS-CONTAINING MATERIAL SUMMARY
INSPECTION DATE: JUNE 12, 2025
TERRACON PROJECT NO. 15257097
REPORT DATE: July 9, 2025
ACM Materials >1% Chrysotile
*% & Type Asbestos this column contains both the analytical result of the sample with the highest concentration of asbestos detected in the samples that make up the HA and the types of asbestos identified.
**Estimated quantities quantities based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos-containing materials are present in hidden and/or inaccessible areas not evaluated as part of this survey. This is not a bidding document; contractors are responsible for determining their own opinion of quantities.
HA
No.
Material Description Sample Layer Description
% and Type Asbestos*
Estimated Quantity** Location
12 Black Linoleum Backing Paper Backing
2% Chrysotile/ Category I non-friable
180 Square Feet
Corridor H118 Ambassador Suite
26 White Pipe Insulation Insulation 60%
Chrysotile/
RACM
65 Linear Feet
Pharmacy Waiting Room Above
Ceiling Ambassador Suite
Appendix B Bulk Sample Location Summary a ci li ti e n v ir o n m e n ta l
G o te ch n ic a te ri ls
P E N
D
IX
B
U
L K
S U
R V
E Y
S A
M P
L E L
O C
A T
IO
N
S U
M M
A
Y
B
A S
S A
D O
R S
U
IT
IN
P E
C T
IO
N
D A
T E
JU
N E
2, T
E R
R A
C O
N P
R O
JE
C
T N
O
R
E P
O R
T D
A T
E
J U
L Y
H o
M a te ri a l D e sc ri p ti m p le u m b e r
S a m p le
L o ca ti m p le
L a y e r
D e sc ri p ti b
R e su lt ile a n d M a st ic
-F
T -0 y E n tr y D o o rs t o L o b b
W h it e F lo o r n e D e te ct d llo w M a n e D e te ct
T
B
M
R o m it e F lo o r n e D e te ct llo w M a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
T h in d T ra sh
C a n b y P ill a r
W h it e F lo o r n e D e te ct llo w M a n e D e te ct d G o u g e C e ili g
-C
T
E n tr y D o o rs t o L o b b y S o th ra y /W h it e C e ili n e D e te ct
T
E n tr y D o o rs t o L o b b y N o rt y /W h it e C e ili n e D e te ct
T
W e st
W a ll in L o b y /W h it e C e ili n e D e te ct d M a
-M
G
E n tr y D o o rs t o L o b b y N o la ck C o v e B se n e D e te ct n M a n e D e te ct
G
E n tr y D o o rs t o L o b b y S o u th
C o rn e r
B la ck C o v e B n e D e te ct n M a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
G
Lo b y W e st
W a ll N e a r
W in d w ck C o v e B n e D e te ct n M a n e D e te ct ry w a ll
S y st
-W
B -1
Lo b y W e st
W ll ro w n /W h it e D ry w n e D e te ct it e T a n e D e te ct it e J o in t C o m p o u n e D e te ct
B
E n tr y D o o rs t o L o b b y N o rt h w w n /W h it e D ry w n e D e te ct it e T a n e D e te ct it e J o in t C o m p o u n e D e te ct
B cr o ss
F ro m S e cu ri ty
/P o lic e O ff w n /W h it e D ry w n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri it e T a n e D e te ct it e J o in t C o m p o u n e D e te ct ck S ta ir
T re d M a
G b a ss ad o r
S u it e E n tr y R a u th e as t
B la ck S ta ir
T re n e D e te ct a r
M a n e D e te ct
G b a ss ad o r
S u it e E n tr y R a rt h e ck S ta ir
T re n e D e te ct a r
M a n e D e te ct
G b a ss ad o r
S u it e E n tr y R a rt h w ck S ta ir
T re n e D e te ct a r
M a n e D e te ct d B ri ck
A b a ss ad o r
S u it e E n tr y R a u th w e st
W a ll
P ill a r
R e d B n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
A b a ss ad o r
S u it e E n tr y R a rt h e a st
W a ll
P ill a r
R e d B n e D e te ct
A x te ri o r o f
B u ild in d B n e D e te ct y B ri ck
M o rt a r
-M
A b a ss ad o r
S u it e E n tr y R a u th w e st
W a ll
P ill a r
G ra y M o rt n e D e te ct
A -2 b a ss ad o r
S u it e E n tr y R a rt h e a st
W a ll
P ill a r
G ra y M o rt n e D e te ct
A te ri o r o f
B u ild y M o rt n e D e te ct y C e ra m ic rt a r
-M
A
E n tr y D o o rs t o L o b y M o rt n e D e te ct
A b a ss ad o r
S u it e E n tr y R a u th e as t C o rn e r
N e a r
M a in
D o rs y M o rt n e D e te ct
A b a ss ad o r
S u it e E n tr y R a u th w e st
C o rn e r
N e a r
M a in
D o y M o rt n e D e te ct n W a ll
C a lk
G b a ss ad o r
S u it e E n tr y R a u th e as t W a ll P ill a r
C e n te r T a n C a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
G b a ss ad o r
S u it e E n tr y R a u th e as t W a ll P ill a r
T o w a rd
S o n C a n e D e te ct
G b a ss ad o r
S u it e E n tr y R a u th w e st
W a ll
P ill a r
T o w a rd
S o n C a n e D e te ct it e P la st e r
-H
P b a ss ad o r
S u it e E n tr y R a u th e as t C o rn e r
W h it e F in is h C o n e D e te ct y B a se
C at n e D e te ct
-H
P rr id o r
H C o rn er it e F in is h C o n e D e te ct y B a se
C n e D e te ct
-H
P -3 rr id o r
H C o rn er it e F in is h C o n e D e te ct y B a se
C n e D e te ct d M a
-M
G rr id o r
H S o u th w w n C o v e B as n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri n M a n e D e te ct
-M
G rr id o r
H S o w n C o v e B n e D e te ct n M a n e D e te ct
-M
G rr id o r
H N o w n C o v e B n e D e te ct n M a n e D e te ct n
S p e c k o le u m
F lo o r
T il
-F C rr id o r
H
S o u th w e s t
G ra y /B la ck
L in o le n e D e te ct n M a n e D e te ct y
B la c k c k
C h ry s o ti
-F C rr id o r
H
N o rt h w e s t
G ra y /B la ck
L in o le n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri n M a n e D e te ct y
B la c k s it iv e
S to p
N o t A n a ly ze d
-F C rr id o r
H
S o u th w e s t
G ra y /B la ck
L in o le n e D e te ct n M a n e D e te ct y
B la c k s it iv e
S to p
N o t A n a ly ze d it e
G ra y w it
V y l Fl o o r
-F
T rr id o r
H S o u th w y /W h it e F lo o r n e D e te ct w n /T a n M a n e D e te ct
-F
T rr id o r
H N o rt h w y /W h it e F lo o r n e D e te ct w n /T a n M a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-F
T rr id o r
H N o rt h w y /W h ti e F lo o r n e D e te ct w n /T a n M a n e D e te ct ili n g
-C
T -4 a rm a cy
W a it in g R o y /W h it e C e ili n e D e te ct
-C
T a rm a cy
W a it in g R o y /W h it e C e ili n e D e te ct
-C
T a rm a cy
W a it in g R o y /W h it e C e ili n e D e te ct d F ir e st o p C a
-C
A
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d C a n e D e te ct
-C
A
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d C a n e D e te ct
-C
A
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d C a n e D e te ct y D o o r
C a
-C
A in
E xt e ri o r
D o o r
G ra y C a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-C
A in
E xt e ri o r
D o o r
G ra y C a n e D e te ct
-C
A in
E xt e ri o r
D o o r
G ra y C a n e D e te ct n E xp a n si o n J o in t C a
-C
A te ri o r
C o n cr e te
W y /T an C a n e D e te ct
-C
A -5 te ri o r
C o n cr e te
S o u th w y /T an C a n e D e te ct
-C
A te ri o r
C o n cr e te b y M a in
D o y /T an C a n e D e te ct y W in d o w
F ra
-C
A te ri o r
W in d o w s S o u th w y C a n e D e te ct
-C
A y C a n e D e te ct
-C
A y C a n e D e te ct y S ea la n t
-C
A u th w e st
E xt e ri o r
G ra y S e a la n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-C
A u th e as t E xt e ri o r
G ra y S e a la n e D e te ct
-C
A u th e as t E xt e ri o r
G ra y S e a la n e D e te ct re e n A d h e si v
-M
G
S o u th e a st
C o rn e r
A b o ve
C e ili s G re e n A d h e si ve n e D e te ct
-M
G
S o u th e a st
C o rn e r
A b o ve
C e ili s G re e n A d h e n e D e te ct
-M
G -6
S o u th e a st
C o rn e r
A b o ve
C e ili s G re e n A d h e n e D e te ct ck B ri ck
C o a ti
-S
C
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d /B la ck
B a ti n e D e te ct
-S
C
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d /B la ck
B a ti n e D e te ct
-S
C
S o u th e a st
C o rn e r
A b o ve
C e ili s R e d /B la ck
B a ti n e D e te ct it e D o o r
C a
-C
A te ri o r
D o o r in W e st
C o rn e r o f
B u ild it e /R u st
C a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-C
A te ri o r
D o o r in W e st
C o rn e r o f
B u ild it e /R u st
C a n e D e te ct
-C
A te ri o r
D o o r in W e st
C o rn e r o f
B u ild it e /R u st
C a n e D e te ct n S ti ck h e
-M
G
S o u th e a st
C o rn e r
A b o ve
C e ili s T a n A d h e n e D e te ct
-M
G
S o u th e a st
C o rn e r
A b o ve
C e ili s T a n A d h e n e D e te ct
-M
G
S o u th e a st
C o rn e r
A b o ve
C e ili s T a n A d h e n e D e te ct y F lo o r u t
-M
A -7 b a ss ad o r
S u it e E n tr y R a u th e as t C o rn e r
G ra y G ro n e D e te ct
-M
A b a ss ad o r
S u it e E n tr y R a u th e as t C o rn e r
G ra y G ro n e D e te ct
-M
A b a ss ad o r
S u it e E n tr y R a u th e as t C o rn e r
G ra y G ro n e D e te ct lu e a n d Y e llo w rp e t
M a
-M
G
O ff ic e C a rp e t
M a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-M
G
O ff ic e C a rp e t
M a n e D e te ct
-M
G
O ff ic e C a rp e t
M a n e D e te ct it e P ip e W d
I n s u la ti
-P I5 a rm a c y W a it in g
R o o m
A b o il in g
T il it e P ip e W n e D e te ct it e I n s u la ti
C h ry s o ti
-P I5 a rm a c y W a it in g
R o o m
A b o il in g
T il it e P ip e W n e D e te ct it e I n s u la ti s it iv e
S to p
N o t A n a ly ze d
-P I5 a rm a c y W a it in g
R o o m
A b o il in g
T il it e P ip e W n e D e te ct it e I n s u la ti s it iv e
S to p
N o t A n a ly ze d
-P
I4
C o rr id o r
N o llo w P ip
In su la ti n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
Fi e rg la ss
P la ti o n a p e r
W h it e P a p n e D e te ct
-P
I4 -8
C o rr id o r
N o llo w P la ti n e D e te ct it e P a p n e D e te ct
-P
I4
C o rr id o r
N o e I n su la ti n e D e te ct it e P a p n e D e te ct y C e ra m ic
F lo o r
T ile a n d B e d d
-F
T b a ss ad o r
S u it e E n tr y R a u th w e st
C o rn e r
G ra y C e ra m ic n e D e te ct y B ed d n e D e te ct
-F
T b a ss ad o r
S u it e E n tr y R a u th w e st
C o rn e r
G ra y C e ra m ic n e D e te ct y B ed d n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
-F
T b a ss ad o r
S u it e E n tr y R a u th w e st
C o rn e r
G ra y F lo o r n e D e te ct y B ed d n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
M a te ri a l D e sc ri p ti m m b e r
S a m p le
L o ca ti m p le
L a y e r
D e sc ri p ti b
R e su lt o o th
C e ili n g
T o m
A ili n g n e D e te ct
T in
L o b b y S o u th e ili n g n e D e te ct
T in
L o b b y N o rt h w ili n g n e D e te ct tr ip e d C a rp e t
M a
G lo se d O ff R o u n d a b o u t
D o rp e t
M a n e D e te ct
G se d O ff R o u n d a b o u t
D o rp e t
M a n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
G se d O ff R o u n d a b o u t
D o rp e t
M a n e D e te ct y C o n cr e te
C a
A te ri o r
N o rt h e n e D e te ct
A te ri o r
S o u th e n e D e te ct
A te ri o r
E n e D e te ct n C a u lk f u n d a b o u t
D o o to n cr te
A a ll
S tr ip o n R o u n d a b o u t
D o o r
C a n e D e te ct
A a ll
S tr ip o n R o u n d a b o u t
D o o r
C a n e D e te ct
A a ll
S tr ip o n R o u n d a b o u t
D o o r
C a n e D e te ct y S p ra y -o
Fi re p ro o f
In su la ti
-A
W la ti n e D e te ct
W la ti n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri
W in
L o b b y N o rt h w la ti n e D e te ct
W in
L o b b y N o la ti n e D e te ct
W in
L o b b y N o rt h e la ti n e D e te ct d M a
G v e B n e D e te ct n e D e te ct
G a r
A D
W e st
W v e B n e D e te ct n e D e te ct
G a r
A D
N o rt h W al l
C o v e B n e D e te ct n e D e te ct ci li ti e v ir o n m e n ta o te ch n ic a te ri n P ip e I n su la ti
-P
I5 in
L o b b y N o rt h e la ti n e D e te ct
I5 in
L o b b y N o rt h e la ti n e D e te ct
I5 in
L o b b y S o u th e la ti n e D e te ct y D o o r
C a
A in
E n tr y D o o r to L o b n e D e te ct
A in
E n tr y D o o r to L o b n e D e te ct
A in
E n tr y D o o r to L o b n e D e te ct
Appendix C Asbestos COC and Laboratory Analytical Reports
08-CA2-24
08-CA2-25
08-CA2-26
8 Main Lobby Entrance Door Gray Caulk
Appendix D Certifications
Appendix E Photolog
Ambassador Suite John Cochran VA
St. Louis, Missouri 63106
Photo 1: Ambassador Suite Entrance Photo 2: Entry Ramp
Photo 3: Entry Doors Photo 4: Waiting Area
Photo 5: Entry Ramp Pillar Photo 6: Entry Ramp Stair Tread
Photo 7: Waiting Area Southwest Wall Photo 8: Entry Ramp Looking into H118
Corridor
Photo 9: Tan Wall Caulk Photo 10: Entry Ramp Southeast Corner
Photo 11: Flooring in H118 (Lower portion of photograph shows H118 floor)
Photo 12: H119 Corridor Viewing Pharmacy Waiting Room
Photo 13: Ambassador Waiting Room Ceiling
Photo 14: Entryway Wall Plaster
Photo 15: Corridor H118 Photo 16: West Corner Door
Photo 17: Identified ACM Linoleum Floor Backing
Main Lobby John Cochran VA
St. Louis, Missouri 63106
Photo 1: Main Lobby Center Ceiling Photo 2: Exit Door on Left
Photo 3: Roundabout Door Photo 4: Main Lobby Floor
Photo 5: A100D Room Photo 6: Main Lobby Ceiling Tiles
Photo 7: Roundabout Door Caulk Photo 8: Exterior Concrete Caulk
Appendix F Sample Location Maps
7 8
6 1
8 2
9 3
-4
-4
-5
-6
-6
-6
-6
File details come from the government source that posted it. Updated .