36C25618B0375-00002001.pdf

HGS Engineering, Inc.

1121 Noble Street Anniston, AL 36201 Phone: 256-236-1848 ● Fax: 256-236-2979 www.hgsengineeringinc.com

ENGINEERING AND PROFESSIONAL SERVICES

NESHAP Inspection of the floors in the CLC at the

G.V. (Sonny) Montgomery VA Medical Center

August 2017

TABLE OF CONTENTS

1 REPORT

2 SAMPLING PROTOCOL

3 SAMPLING RESULTS

4 PICTURES

5 CERTIFICATIONS

NESHAP Inspection of the CLC Floors- August 2017

Page 1 of 5 August 2017

AHERA Asbestos Inspection and

Assessment

G.V. (Sonny) Montgomery VA

Medical Center

Page 2 of 5 August 2017

NESHAPASBESTOS INSPECCTION of the CLC Floors – Background

HGS Engineering, Inc was contracted by the Jackson, Mississippi Department of

Veterans Affairs Medical Center Safety Department office to conduct the NESHAP

Asbestos Inspection of the floors in the CLC connected to the main medical facility at the

Jackson, Mississippi location. A project meeting was held in the Safety Department conference room at the Jackson Veterans Health Care System building at 1500 E

Woodrow Wilson Dr. in Jackson, Mississippi on the 13th of June, 2017. Scott Berry, from the Jackson VA’s Safety Department, escorted Tim Thompson, from HGS

Engineering, on a site walkthrough of the CLC. The following day, 14 June 2017, Mr.

Thompson and Mr. Berry gathered samples of floor tiles in question. It was agreed upon that any floor tile that had come up positive during any other AHERA asbestos inspections would not be retested but considered positive.

NESHAPASBESTOS INSPECCTION of the CLC Floors – Sampling

Four areas were tested and samples sent away on 16 July 2017, three resulted in positive results. Because of these and the prior AHERA inspections all floors on both floors and the mastic used should be considered positive for asbestos. Two additional samples and one TEM sample were sent on 11 August 2017; the TEM was sent for confirmation of sample CLC-B-Ele-Clo.

The results of this sampling event were not able to disprove or eliminate any questionable flooring. All white, green and orange tile should be considered suspect and abated properly. The sheet flooring and fake wood flooring is asbestos free but the mastic/glue used is not and must be abated properly.

TEM results of CLC-B-Ele-Clo confirmed the presence of asbestos in the orgional sample.

There were questions about the areas covered in a “wooden” material and the areas around the nurses’ station as being abated but this was not confirmed.

NESHAPASBESTOS INSPECCTION of the CLC Floors – Abatement Costs

HGS contacted Lakeshore Environmental, an asbestos abatement company that we have used on many government and private client abatements and requested an estimate for abatement of the floors. The protocol for the abatement would be one complete floor at a time following all AHERA, VA and safety requirements; the estimated cost was $80-

$90,000.00 per floor. The cost in many cases was more because a second-floor covering was laid over the first one which contained asbestos.

HGS Engineering performed field work at the Jackson VA Medical Center on the 13th and 14th of June, 2017. All field work was supervised by Tim Thompson, a certified state of Mississippi Asbestos Inspector and Asbestos Supervisor.

Page 3 of 5 August 2017

NESHAP Asbestos SURVEY – Abbreviations and Definitions

Asbestos: A group of naturally occurring minerals that separate into fibers. Asbestos fibers are incombustible, are chemically resistant, and are characterized by the properties of thermal and electrical insulation. There are six asbestos minerals used commercially:

chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. This includes any of these minerals that have been chemically treated and/or altered.

Asbestos abatement: Procedures to remove ACBM from buildings with the simultaneous control of the release of asbestos fibers. Additionally, this includes activities focused on the encapsulation, encasement, repair, and enclosure of ACBM.

Asbestos Containing Building Material (ACBM): Surfacing ACBM, TSI ACBM, or miscellaneous ACBM found in or on interior structural members or other parts of a building. This definition is used in the AHERA regulations for school buildings.

Asbestos Hazard Emergency Response Act (AHERA): The federal Asbestos Hazard

Emergency Response Act of 1986 and the Environmental Protection Agency implementing regulations, 40 CFR Part 763, Subpart E - Asbestos-Containing Materials in Schools. The passage of AHERA by Congress led to the promulgation by EPA of two additional regulations: the Asbestos School Hazard Abatement Reauthorization Act

(ASHARA) and the Model Accreditation Plan (MAP), which outlines the requirements for accreditation of inspectors and personnel conducting asbestos activities in schools.

Asbestos inspection: Any activity undertaken to determine the presence or location, or to assess the condition, of asbestos-containing material or suspected asbestos-containing material, whether by visual or physical examination, or by taking samples of the material.

1bis term includes re-inspections of the type described in AHERA, 40 CFR 763.85(b), of known or assumed asbestos-containing material which has been previously identified.

Demolition: The wrecking, salvage, or removal of any load-supporting structural member of a structure together with any related handling operations, or the intentional burning of any structure. 1bis includes the moving of an entire building.

Inaccessible: Physically restricted or obstructed area or covered in such a way that detection or removal is prevented or severely hampered.

Miscellaneous ACM: Interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles. This does not include surfacing material or TSI.

Operations and Maintenance (O&M) Plan: A plan of safe work practices and procedures intended to maintain ACBM in good condition and minimize asbestos exposure to building occupants and VA employees, while complying with federal, state, and local regulations.

Page 4 of 5 August 2017

Regulated Asbestos-Containing Material (RACM): Friable asbestos material, Category I non-friable ACM that has become friable, Category I non-friable ACM (vinyl asbestos tile, roofing felts, gaskets and packing) that will be or has been subjected to sanding, grinding, cutting, or abrading, or Category II non-friable ACM (asbestos board, transite, and asbestos shingles) that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Page 5 of 5 August 2017

AHERA ASBESTOS INSPECCTION AND ASSESSMENT SURVEY – Executive

Summary

HGS Engineering, Inc was contracted by the Jackson, Mississippi Department of

Veterans Affairs Medical Center Safety Department office to conduct the NESHAP

Asbestos Inspection of the floors in the CLC connected to the main medical facility at the

Jackson, Mississippi location. A project meeting was held in the Safety Department conference room at the Jackson Veterans Health Care System building at 1500 E

Woodrow Wilson Dr. in Jackson, Mississippi on the 13th of June, 2017. Scott Berry, from the Jackson VA’s Safety Department, escorted Tim Thompson, from HGS

Engineering, on a site walkthrough of the CLC. The following day, 14 June 2017, Mr.

Thompson and Mr. Berry gathered samples of floor tiles in question. It was agreed upon that any floor tile that had come up positive during any other AHERA asbestos inspections would not be retested but considered positive.

Four additional areas were tested and three resulted in positive results. Because of these and the prior AHERA inspections all floors on both floors and the mastic used should be considered positive for asbestos.

There were questions about the areas covered in a “wooden” material and the areas around the nurses’ station as being abated but this was not confirmed.

HGS Engineering performed field work at the Jackson VA Medical Center on the 13th and 14th of June, 2017. All field work was supervised by Tim Thompson, a certified state of Mississippi Asbestos Inspector and Asbestos Supervisor.

LRS, Inc.

Laboratory Resources & Solutions, Inc.

163 5th Street Ashville, AL 35953

(205) 683-6731 www.lab-resource.com

Analytical Data Report

Customer: HGS Engineering

Anniston, AL 36201

Attention: Mr. Tim Thompson

Project ID: CLC – PLM Asbestos Analysis (June 16, 2017)

Lab Reference: 2017-0912

Report Date: June 27, 2017

Data Reviewed by:

Wayne Gaston Project Manager

Laboratory Resources & Solutions, Inc. (LRS) wgaston@lab-resource.com

All data contained herein is derived from analysis performed at Safety Environmental Laboratories & Consulting, Inc., 989 Yeager Parkway, Pelham, AL 35124.

These results relate only to the item(s) tested. This report may only be reproduced in full.

Local support services are provided via Laboratory Resources & Solutions, Inc. (LRS).

All inquiries regarding the data should be directed to LRS.

Safety Environmental Laboratories and Consulting, Inc.

Page 1 of 3 Analyst

Taliesen Partridge– Microscopy Analyst Technical Review

Carol Findlay – Microscopy Manager

Quality Review

Carol Findlay – Microscopy Manager

Copyright© All rights reserved; copyright protected; Safety Environmental Laboratories and Consulting, Inc. 2017

Asbestos Bulk Sample Analysis Report

989 Yeager Pkwy. Phone: (205) 823-6200

Pelham, AL 35124 Fax: (205) 823-9066

Customer:

Laboratory Resources and Solutions, Inc.

163 5th Street Ashville, AL 35953

Sample Receipt Date: 06/20/2017

Sample Analysis Date: 06/22/2017

Telephone: 205-683-6731 Fax: 205-594-7302 Sample Report Date: 06/23/2017

Client Name:

Telephone:

HGS Engineering Attn: Mr. Tim Thompson 1121 Noble Street Anniston, AL 36201 256-225-5550

Analysis:

Method:

Asbestos Identification in Bulk Materials by Polarized Light Microscopy EPA/600/R-93/116 July 1993 – Method for the Determination of Asbestos in Bulk Building Materials Note: See Attached Notes and Descriptions Sheet for Applicable Abbreviations and Notes

SELC Project #: 2017-0912

Customer Sample No.

Lab Sample

No.

Sub-sample

No.

Layer No.

Sample Location / Description Homo-geneous (yes/no)

Asbestos % and Type

% Non-Asbestos Fibers

% Non- Fibrous Material

CLC-G-B31 01 N/A Floor

Floor Backing/Mastic – Gray/Yellow, Fibrous, Organically Bound

N None Detected

15% Cellulose Fibers

5% Fiberglass

2% Synthetic Fibers

78%

2 Floor Tile – Green, Organically Bound Y None Detected None Detected 100%

3 Mastic – Black, Organically Bound Y 10% Chrysotile None Detected 90%

CLC-G-

HB06

02 N/A Floor

1 Floor Tile – White, Organically Bound Y None Detected None Detected 100%

2 Adhesive – Clear/White, Organically Bound, Fibrous Y None Detected 2% Cellulose Fibers

3% Synthetic Fibers 95%

CLC-B-Elec Closet

03 N/A 1 Floor

Mastic – Black/Yellow, Organically Bound N 5% Chrysotile None Detected 95%

Page 2 of 3 Analyst

Technical Review

Carol Findlay – Microscopy Manager

Quality Review

Carol Findlay – Microscopy Manager

Copyright© All rights reserved; copyright protected; Safety Environmental Laboratories and Consulting, Inc. 2017

Customer:

Ashville, AL 35953

Sample Receipt Date: 06/20/2017

Sample Analysis Date: 06/22/2017

Telephone: 205-683-6731 Fax: 205-594-7302 Sample Report Date: 06/23/2017

Client Name:

Telephone:

HGS Engineering Attn: Mr. Tim Thompson 1121 Noble Street Anniston, AL 36201 256-225-5550

Analysis:

Method:

Asbestos Identification in Bulk Materials by Polarized Light Microscopy EPA/600/R-93/116 July 1993 – Method for the Determination of Asbestos in Bulk Building Materials Note: See Attached Notes and Descriptions Sheet for Applicable Abbreviations and Notes

SELC Project #: 2017-0912

Customer Sample No.

Lab Sample

No.

Sub-sample

No.

Layer No.

Sample Location / Description Homo-geneous (yes/no)

Asbestos % and Type

% Non-Asbestos Fibers

% Non- Fibrous Material

CLC-B-

Elec-Clo

04 N/A Floor

1 Dust – Gray, Fibrous Y None Detected

70% Cellulose Fibers

3% Synthetic Fibers

5% Animal Hair

22%

2 Floor Tile – Orange, Organically Bound Y 3% Chrysotile None Detected 97%

3 Mastic – Black, Organically Bound Y 10% Chrysotile None Detected 90%

This report is FINAL This report is PRELIMINARY – pending final QC

Page 3 of 3 Analyst

Technical Review

Carol Findlay – Microscopy Manager

Quality Review

Carol Findlay – Microscopy Manager

Copyright© All rights reserved; copyright protected; Safety Environmental Laboratories and Consulting, Inc. 2017

PLM Notes and Descriptions

1. Upper detection limit: 100%. Lower detection limit: <1%.

2. Bulk Samples will be stored for 3 months and will then be disposed of in an approved EPA landfill.

3. Analysis of floor tile or any other resinously bound materials by polarized light microscopy (PLM) using EPA Method 600/R-93/116 dated July 1993 may yield false-negative results because of method limitations in separating closely bound fibers from matrix material and in detecting fibers of small length and/or diameter. When analysis of such materials by the EPA PLM Method yields negative results for the presence of asbestos we recommend utilizing alternative methods of identification such as Gravimetry, XRD or AEM.

4. Samples are not homogenized by SELC prior to analysis. Distinct material layers within a sample are analyzed and reported separately by SELC. When multiple products are submitted by the customer under one sample number, SELC indicates those distinct products as sub-samples. SELC retains all samples numbers but will designate a sample number to those that are not given a sample number by the customer.

5. Percentages given are based on a visual estimated calibration.

6. Safety Environmental Laboratories and Consulting, Inc. is a NVLAP accredited laboratory, Lab Code: 200873-0 (ISO/IEC Standard 17025:2005

Compliant).

7. Results relate only to the samples tested. All tests were performed under the scope of SELC’s NVLAP accreditation, unless indicated otherwise.

8. All samples were received in a condition suitable for analysis (“Good”), unless otherwise noted.

9. This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government.

10. Analytical Instrument: Olympus Polarized Light Microscope Series BH-2 Model BHT-002

LRS, Inc.

Laboratory Resources & Solutions, Inc.

163 5th Street Ashville, AL 35953

(205) 683-6731 www.lab-resource.com

Analytical Data Report

Customer: HGS Engineering

Anniston, AL 36201

Attention: Mr. Tim Thompson

Project ID: CLC – TEM Asbestos Analysis (June 16, 2017) Sample #4: CLC-B-Ele-Clo

Layer: Floor Tile

Lab Reference: 2017-0912

Report Date: August 14, 2017

Data Reviewed by:

Wayne Gaston Project Manager

Laboratory Resources & Solutions, Inc. (LRS) wgaston@lab-resource.com

All data contained herein is derived from analysis performed at EMSL Analytical, Inc., 200 Route 130 North, Cinnaminson, NJ 08077, via Safety Environmental Laboratories & Consulting, Inc., 989 Yeager Parkway, Pelham, AL 35124.

These results relate only to the item(s) tested. This report may only be reproduced in full.

Local support services are provided via Laboratory Resources & Solutions, Inc. (LRS).

All inquiries regarding the data should be directed to LRS.

August 14, 2017

Ashville, AL 35953

Re: Samples results for Transmission Electron Microscopy (TEM)

Job Name: HGS Engineering

Anniston, AL 36201

To Whom It May Concern:

Safety Environmental Laboratories and Consulting, Inc. (SELC) is pleased to present you with the attached TEM results under the project name of HGS Engineering.

This sample was analyzed by EMSL Analytical, Inc. This laboratory is accredited by NVLAP to provide reliable analysis.

Please let us know if you have any questions or require additional information.

Sincerely, Carol Findlay Microscopy Manager

Attachment

P. O. Box 1848 Phone: 205-823-6200 Environmental, Health, and Safety Solutions

Pelham, AL 35124 Fax: 205-823-9066

SAMPLE ID COLOR

APPROX.

MATRIX

MATERIAL

NON-ASBESTOS

FIBERS

ASBESTOS

RANGE TYPE AVG Notes

Test Report: Asbestos Analysis of Bulk Materials via Transmission Electron Microscopy. Chatfield Method (rev 2)

Attn: Accounts Payable Safety Env. Lab. & Consulting 989 Yeager Parkway PO Box 1848 Pelham, AL 35124

Received: 08/10/17 9:20 AM

HGS Engineering / 2017-0912

Fax: (205) 823-9066 Phone: (205) 823-6200

Project:

8/12/2017Analysis Date:

Collected:

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com cinnasblab@EMSL.com

041723593 CustomerID: SELC78 CustomerPO: 2017-0912 ProjectID:

EMSL Order:

2017-0912 041723593-0001

Red 73.0% Chrysotile24.0-29.0 27.0%

Benjamin Ellis, Laboratory Manager or other approved signatory

Analyst(s)

THIS IS THE LAST PAGE OF THE REPORT.TEMChatver2-7.26.0 Printed: 8/12/2017 10:40:02 AM 1

EMSL maintains liability limited to the cost of analysis. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. Samples received in good condition unless otherwise noted.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NYS ELAP 10872, PA ID# 68-00367

Samantha Rundstorm-Cruz (1)

Initial report from 08/12/2017 10:40:02 http://www.EMSL.com mailto:cinnasblab@EMSL.com

OrderID: 041723593