36C25626R0044 Asbestos AHERA inspection - Copy.pdf

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AMMENDMENT 001 | Y1DZ | 36C25626R0044 | 564-26-103 | REPLACE CAMPUS STEAM AND CONDENSATE LINES | DESIGN-BUILD | FAYETTEVILLE, ARK.
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This is an AHERA (Asbestos Hazard Emergency Response Act) 3-Year Re-Inspection Report dated July 16, 2021, for the VA Healthcare System of the Ozarks located at 1100 North College Avenue in Fayetteville, Arkansas. The inspection was performed by Environmental Enterprise Group, Inc. (EEG) under project number 21-0111-088 to assess the condition and location of asbestos-containing materials (ACM) throughout the facility's 14 buildings and steam tunnels. The facility, originally constructed beginning in 1932 and completed by 1936, contains various friable and non-friable ACM including floor tile mastic, pipe lagging, thermal system insulation in mechanical chases and hard ceilings, boiler components, and surfacing materials. The report documents that the majority of previously identified ACM has been abated since the original 1988 survey, with remaining materials primarily consisting of 9,769 square feet of floor tile mastic under non-ACM tile in Building 1 and approximately 1,748 square feet of floor tile and black mastic in Connecting Corridor 13 (after 300 square feet was abated in May 2021). Additional friable pipe lagging in mechanical chases and steam tunnels is assumed to remain but was not fully quantified due to inaccessibility.

The report includes six-month surveillance records for December 2021 through December 2023 showing no material changes in identified ACM locations or conditions. The facility designee is identified as Mr. Tod Johnson (GEMS Coordinator) at the VA Healthcare System of the Ozarks. Key recommendations include continuing the Operations and Maintenance (O&M) program for remaining accessible ACM, removing abated materials from the O&M plan, and implementing staff training on asbestos awareness and proper handling procedures as required under 40 CFR Part 763.84. The report notes that a comprehensive asbestos survey should be conducted to accurately identify the full extent of floor tile adhesive throughout the facility, and that any future renovations should be preceded by asbestos surveys of affected areas. The next triennial re-inspection is due in 2024.

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AHERA 3-YEAR RE-INSPECTION

for

VA Healthcare System of the Ozarks 1100 North College Avenue Fayetteville, Arkansas 72703

PROJECT #21-0111-088

Prepared for:

Mr. Tod Johnson VA Healthcare System of the Ozarks

July 16, 2021

Prepared for

Mr. Tod Johnson VA Healthcare System of the Ozarks

The following pages of this report have been prepared for the exclusive use of the VA Healthcare System of the Ozarks at the request of Mr. Tod Johnson. The property is described as the VA Healthcare System of the Ozarks located at 1100 North College Avenue in Fayetteville, Arkansas.

Performed by:

7/16/21

Mr. Greg Millsaps Asbestos Inspector (ADEQ Certification #015533) Environmental Enterprise Group, Inc. (EEG)

Date

Management Planner Review:

7/16/21 Mr. Bob E. Smith Vice President/Senior Project Manager Environmental Enterprise Group, Inc. (EEG)

Date

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 DUTIES AND OBLIGATIONS

2.1 40 CFR Part 763.84 General Local Education Agency Responsibilities

3.0 SIX-MONTH SURVEILLANCE RECORDS

4.0 AHERA RE-INSPECTION 2010

4.1 VA Healthcare System of the Ozarks – Building 1

4.2 VA Healthcare System of the Ozarks – Building 2

4.3 VA Healthcare System of the Ozarks – Corridor Between Buildings 1 & 2

4.4 VA Healthcare System of the Ozarks – Building 3

4.5 VA Healthcare System of the Ozarks – Building 4

4.6 VA Healthcare System of the Ozarks – Building 5

4.7 VA Healthcare System of the Ozarks – Building 6

4.8 VA Healthcare System of the Ozarks – Building 7

4.9 VA Healthcare System of the Ozarks – Building 8

4.10 VA Healthcare System of the Ozarks – Building 10

4.11 VA Healthcare System of the Ozarks – Building 11

4.12 VA Healthcare System of the Ozarks – Building 15

4.13 VA Healthcare System of the Ozarks – Building 16

4.14 VA Healthcare System of the Ozarks – Steam Tunnels

5.0 TRAINING RECORD FOR CUSTODIAL AND MAINTENANCE PERSONNEL

APPENDICES

Appendix A – Inspector Certificates

Appendix B – Management Planner Certificates

Appendix C – Drawings

AHERA 3-YEAR RE-INSPECTION • VA HEALTHCARE SYSTEM OF THE OZARKS

FAYETTEVILLE, ARKANSAS

EEG PROJECT #21-0111-088

1.0 INTRODUCTION

The original VA Healthcare System of the Ozarks in Fayetteville, Arkansas, was built beginning in 1932 and was completed in approximately 1936/37. All of the original structures are constructed of masonry and had radiant steam heating systems supplied by a central steam plant.

During the summer of 1988, an asbestos survey was performed at the facility. The asbestos survey was performed by Occupational Safety and Health Consultants of Tulsa, Oklahoma. The buildings included in the scope of the 1988 asbestos survey were: Building numbers 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 15 and 16.

Building numbers 9, 11, and 16 no longer have known asbestos containing materials. All of the known asbestos-containing materials in these three buildings were abated in approximately 1988. The drawings in the appendices of this report are limited to buildings with remaining ACM.

In 1992, an Operations and Maintenance (O&M) program document was developed by Pandion Consultants of Apex, North Carolina. This document addressed the remaining asbestos-containing materials (ACM) within the original complex after several abatement projects had taken place throughout the facility. Since that time, the VA has loosely adopted the Asbestos Hazard Emergency Response Act (AHERA) regulations in the management of the remaining asbestos containing materials.

Environmental Enterprise Group, Inc. (EEG) performed a re-inspection in 2006 in an effort to identify the extent and condition of the remaining ACM in the original complex and took into consideration all previous reports and known abatement activities. This inspection also addressed Building numbers 22, 24, 25, 26, 29, 34, 37, 40, 41, 42, 43, 44, and 45. These buildings were constructed after 1992 and are considered by the VAMC as harboring no suspect materials. The intent of the report was to inform VAMC employees and contractors of the presence of ACM and to instruct them in procedures to minimize exposure to airborne asbestos.

On June 9 and 10, 2010, Mr. Bob E. Smith and Mr. James Waldo, accredited inspectors with Environmental Enterprise Group, Inc., performed a 3-year re-inspection of the VA Healthcare System of the Ozarks facility as required by the Asbestos Hazard Emergency Response Act (AHERA) Asbestos-in- Schools Rule.

On November 8, 2013, Mr. Bob E. Smith and Mr. Greg Millsaps, accredited inspectors with Environmental Enterprise Group, Inc., performed a 3-year re-inspection of the VA Healthcare System of the Ozarks facility as required by the Asbestos Hazard Emergency Response Act (AHERA) Asbestos-in- Schools Rule.

On November 16, 2016, Mr. Bob E. Smith and Mr. Greg Millsaps, accredited inspectors with Environmental Enterprise Group, Inc., performed a 3-year re-inspection of the VA Healthcare System of the Ozarks facility as required by the Asbestos Hazard Emergency Response Act (AHERA) Asbestos-in- Schools Rule.

On June 30, 2021, Mr. Greg Millsaps, accredited inspector with Environmental Enterprise Group, Inc., performed a re-inspection of the VA Healthcare System of the Ozarks facility as required by the Asbestos Hazard Emergency Response Act (AHERA) Asbestos-in-Schools Rule.

The Six-Month Surveillance Record shows all known asbestos locations for the hospital. Asbestos that has been removed prior to this report can be found in previous records available at the VA safety office.

Included in this report is a RE-INSPECTION INFORMATION form identifying each homogeneous area that contains asbestos. This form includes the building name or number, date of re-inspection, summary of material, classification, changes in condition, primary use of area, comments, and signature of inspector.

Any new construction or renovations since the original or last re-inspection need to be signed off by architects as “Asbestos Free” or include a statement that only asbestos free materials are to be used. This statement should be brought to the attention of the General Contractor.

New Rules and Regulations went into effect July 15, 1997, by the Arkansas Department of Pollution Control and Ecology (ADPC&E), now named Arkansas Department of Environmental Quality (ADEQ).

The major concern will be fees charged for all “Asbestos Notice of Intent” (based on square or linear footage), consultant fees, inspector fees, management planner fees, designer fees, supervisor fees, and air technician fees. Therefore, it is advised to have any abatement projects handled cautiously.

This inspection can serve as a six-month surveillance report. The next triennial re-inspection will be due in the year 2024. Forms for the Annual Notification, Six-Month Surveillance, Duties of the VA and VA Designee, and new employee awareness training are included with this report.

LIMITATIONS

Environmental Enterprise Group, Inc. (EEG) was retained by the Veterans Administration (VA) to perform a re-inspection of the asbestos containing materials (ACM) previously identified at the facility.

This inspection included the assessment of both friable and non-friable acm. This re-inspection was limited to those buildings that comprised the scope of work for the original inspection conducted in 1988.

EEG was given access to asbestos abatement records from projects that occurred since the original inspection. EEG utilized all available information to formulate this report. This work was ordered and authorized by Mr. Tod Johnson.

Since 1988 many renovation projects have occurred at this facility. EEG was informed that all readily accessible friable ACM had been abated. According to the VA, the only remaining friable ACM is in the form of thermal system insulation (TSI) located within chases, above hard ceilings or within steam tunnels. EEG did not assess the conditions of these materials, nor did EEG verify their presence. EEG’s involvement in the planning of abatement activities has been limited to air monitoring. As a result, EEG may not have access to information pertaining to specific areas targeted for abatement.

The majority of the remaining accessible ACM throughout the facility is in the form of floor tile adhesive.

Most of this material is underneath non-ACM 12” x 12” floor tile. Due to this, the extent of the areas where the asbestos-containing adhesive exists is difficult to identify. In 2006, EEG made a cursory attempt to identify the extent of the positive adhesive in Building 1. The analytical results identified areas of both positive and negative adhesive. This information was compared to abatement records for the area in question, and no clear understanding could be obtained from this comparison. Without comprehensive sample collection and analysis, EEG can only report the existence of asbestos-containing floor adhesives in the areas where they were previously identified.

Based on this ambiguous information, it is EEG’s opinion that a thorough asbestos survey be conducted to accurately identify the presence, extent, and condition of the facility’s ACM. This would likely entail a room-to-room investigation requiring sampling in every room. As an alternative, EEG further recommends that any future renovation be preceded by an asbestos survey of the areas to be affected.

All ACBM Locations After Re-Inspection in 2021

HOMOGENEOUS

AREA NO.

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible On Boiler Room Walls up to

Mezzanine Level – Building 10 Positive

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible Connecting Corridor 13 Positive

M = Miscellaneous T = Thermal System Insulation S = Surfacing

A visual inspection of the above listed buildings and homogeneous area(s) have been surveyed.

Were there any changes to the materials in these area(s) that have been identified or assumed to contain asbestos? Yes

If yes, identify the building and homogeneous area(s) stating changes:

• Floor tile mastic under non-ACM 12” x 12” floor tile (Homogeneous Area No. OR-1 or OR-5 & Other) in the basement and 1st and 2nd floors of Building 1 was listed as having 1,430 square feet remaining during the 2016 re-inspection. However, the material has been identified in additional areas. There is now 9,769 square feet known to remain.

• Pipe lagging (Assumed) in mechanical chases and above hard ceilings in Building 3 was removed in 2020-2021. The material can be removed from the O&M plan.

• Approximately 2,048 square feet of ACM floor tile and black mastic has been identified in Connecting Corridor 13. Approximately 300 square feet was removed in May 2021, leaving 1,748 square feet known to remain. The material should be added to the O&M plan.

Was damaged area(s) reported to the VA Healthcare System of the Ozarks? NA

Signed ____________________________ , Surveyor Date _______________

Signed ____________________________ , VA Date _______________

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility’s Management Plan records.

6/15/2021

2.0 DUTIES AND OBLIGATIONS

2.1 40 CFR PART 763.84 GENERAL FACILITY ADOPTED RESPONSIBILITIES

The facility shall:

(a) Ensure that the activities of any persons, who perform inspections, re-inspections, and periodic surveillance, develop and implement response actions, including operations and maintenance are carried out in accordance with Subpart E of this part.

(b) Ensure that all custodial and maintenance employees are properly trained as required by this Subpart E and other applicable Federal and/or State regulations (e.g., the Occupational Safety and Health Administration asbestos standard for construction, the EPA worker protection rule, or applicable State regulations).

(c) Ensure that workers and building occupants, or their legal guardians are informed at least once each school year about inspections, response actions, and post-response action activities, including periodic re-inspection and surveillance activities that are planned or in progress.

(d) Ensure that short-term workers (e.g., telephone repair workers, utility workers, or exterminators) who may come in contact with asbestos in school are provided information regarding the locations of ACBM and suspected ACBM assumed to be

ACM.

(e) Ensure that warning labels are posted in accordance with Part 763.95.

(f) Ensure that management plans are available for inspection and notification of such availability has been provided as specified in the management plan under 763.93(g).

(g) (1) Designate a person to ensure that requirements under this section are properly implemented.

(2) Ensure that the designated person receives adequate training to perform duties assigned under this section. Such training shall provide, as necessary, basic knowledge of:

(i) Health effects of asbestos

(ii) Detection, identification, and assessment of

ACM

(iii) Options for controlling ACBM

(iv) Asbestos management program

(v) Relevant Federal and State regulations concerning asbestos, including those in this Subpart E and those of the Occupational Safety and Health Administration, U.S.

Department of Labor, the U.S. Department of Transportation, and the U.S. Environmental Protection Agency.

(h) Consider whether any conflict of interest may arise from the interrelationship among accredited personnel and whether that should influence the selection of accredited personnel to perform activities under this Subpart.

FACILITY: VA Healthcare System of the Ozarks ADDRESS: 1100 North College Avenue CITY, STATE, ZIP: Fayetteville, Arkansas 72703

ENVIRONMENTAL MANAGER: Mr. Tod Johnson ADDRESS: 1100 North College Avenue

PHONE: (479) 444-5044

SIGNATURE: ____________________________

FACILITY DESIGNEE: Mr. Tod Johnson TITLE: GEMS Coordinator ADDRESS: 1100 North College Avenue

PHONE: (479) 444-5044

TRAINING COURSE: Maintenance

DATES ATTENDED:

NUMBER OF HOURS:

NAME OF TRAINING AGENCY:

SIGNATURE: _____________________________

3.0 SIX-MONTH SURVEILLANCE RECORDS

3.1 6-Month Surveillance Record – December 2021

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible contain asbestos? _____ (yes/no)

Was damaged area(s) reported to the VA Healthcare System of the Ozarks? _____

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility Management Plan records.

No

N/A

12/08/2021

3.2 6-Month Surveillance Record – June 2022

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility

3.3 6-Month Surveillance Record – December 2022

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility

3.4 6-Month Surveillance Record – June 2023

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility

3.5 6-Month Surveillance Record – December 2023

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

VA1-16B NF 720 Sq. Ft. M Floor Tile & Mastic

Good

Accessible T-10 – Building 1 Basement &

Room 110 Positive

OR-1 – OR-5

& Other NF 9,769 Sq. Ft. M

Floor Tile Mastic underneath

Non-ACM 12” x 12” Floor Tile

Good

Accessible Basement, 1st & 2nd Floors –

Building 1 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 1 Assumed

VA2-23 F 300 Sq. Ft. M Soil Good

Accessible Under Porch – Basement, Building 2 Assumed

VA2-29 NF None. Abated in 2009. M Floor Tile N/A Subs Storage – 1st Floor, Building 2 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 2 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible

Mechanical Chases & Above Hard Ceilings – Corridor Between Buildings 1 & 2

Assumed

Assumed F None. Abated in 2020-2021 T Pipe Lagging

Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 3 Assumed

VA4-6D NF None. Abated in 2008 M Floor Tile N/A

2nd Floor Corridor between Elevator Lobby & Room 205

– Bldg. 4 Positive

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 4 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 5 Assumed

Assumed T Unknown T Piping Good

Inaccessible Above Hard Ceilings & Within

Chases – Building 6 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 7 Assumed

Assumed F Unknown T Pipe Lagging Good

Inaccessible Mechanical Chases & Above Hard Ceilings – Building 8 Assumed

VA-Generated Samples NF Unknown S Paint

Damaged

Accessible

FRIABLE OR

NON-

FRIABLE

SF OR LF

TYPE OF

MATERIAL

(M,T,S)

MATERIAL

DESCRIPTION

CONDITION &

ACCESSIBILITY LOCATION POSITIVE OR

ASSUMED

Assumed F

This material no longer exists at the facility.

T Pipe Lagging N/A At Entrance and into Steam Tunnel – Building 15 Assumed

Assumed F Unknown T Pipe Lagging Good

Accessible All Steam Tunnels Assumed

NA NF

2,048 Sq. Ft.

(300 Sq. Ft.

Abated in May 2021, Leaving 1,748 Sq. Ft.)

M Floor Tile & Black Mastic

Good

Accessible

A copy of this report should be placed in both the main Safety Office Management Plan records and the Facility

4.0 AHERA RE-INSPECTION 2021

4.1 VA HEALTHCARE SYSTEM OF THE OZARKS – BUILDING 1

VA HEALTHCARE SYSTEM OF THE OZARKS – BUILDING 1

Fayetteville, Arkansas

Management Plan Implementation: June 1988

Date of Inspection: November 16, 2016

Homogeneous Area: VA1-1B

Date of Construction: Began by 1932; completed by 1935

Square Feet in Building: 220,684 Square Feet

Asbestos Content Determined By: Bulk Sample Analysis

Amount of ACBM in Homogeneous Area: 75 Sq. Ft. Floor Tile Basement Repair Shop

Type of ACBM: Miscellaneous, Non-Friable

Have there been any changes to the material in this area? Yes

If yes, explain: Material was abated prior to this inspection.

Response Action: None. Material abated.

Primary use of this area is for: Repair Shop

Comments: Remove from Operations and Maintenance (O&M) program.

Re-Inspection Conducted by:

ENVIRONMENTAL ENTERPRISE GROUP, INC.

220 North Knoxville, Suite 200 Russellville, Arkansas 72801 Phone: (479) 968-6767

By

Mr. Greg Millsaps, Inspector Certification No. 015533

Mr. Bob E. Smith, Management Planner Inspector Certification No. 011927

The Facility’s response to the above recommendation is Accepted or Not Accepted.

Facility Authorized Signatory ____________________________ DATE _____________________

Date of Inspection: June 30, 2021

Homogeneous Area: VA1-2B

Amount of ACBM in Homogeneous Area: 30 Ft. 1 In. Pipe Lagging Basement A/C Room

Type of ACBM: Thermal, Friable

Primary use of this area is for: A/C Room

220 North Knoxville, Suite 200

Homogeneous Area: VA1-4B

Amount of ACBM in Homogeneous Area: 1,000 Sq. Ft. Floor Tile Basement Records Room 1-40

Primary use of this area is for: Records Storage

220 North Knoxville, Suite 200

Homogeneous Area: VA1-8B

Amount of ACBM in Homogeneous Area: 60 Ft. Pipe Lagging Basement Medical Records Storage

Primary use of this area is for: Records Storage

220 North Knoxville, Suite 200

Homogeneous Area: VA1-10B

Amount of ACBM in Homogeneous Area: Pipe Lagging - Length of Basement Basement Corridor

Primary use of this area is for: Corridor

220 North Knoxville, Suite 200

Homogeneous Area: VA1-16B

Amount of ACBM in Homogeneous Area: 720 Sq. Ft. Floor Tile & Mastic T10 Basement & Room 110

If yes, explain: No Floor Tile was Found in T-10A Telephone Room

Response Action: The Response Action recommendation in the original Management Plan is still appropriate.

Primary use of this area is for: Tele Room

Comments: Continue Operations and Maintenance (O&M) program.

220 North Knoxville, Suite 200

Homogeneous Area: VA7-17B

Amount of ACBM in Homogeneous Area: 368 Ft. Steam Line Basement MB 4

Primary use of this area is for: Steam Line

220 North Knoxville, Suite 200

Homogeneous Area: VA1-18B

Amount of ACBM in Homogeneous Area: 400 Sq. Ft. – 2 Hot Water Tanks Basement – MB 4

Primary use of this area is for: Hot Water Tanks

220 North Knoxville, Suite 200

Homogeneous Area: VA1-20B

Amount of ACBM in Homogeneous Area: 350 Ft. Floor Tile Basement Kitchen Food Area

Primary use of this area is for: Kitchen

220 North Knoxville, Suite 200

Homogeneous Area: VA1-21B

Amount of ACBM in Homogeneous Area: 335 Sq. Ft. Floor Tile Basement – 1-13A

Primary use of this area is for: Basement

220 North Knoxville, Suite 200

Homogeneous Area: VA1-23B

Amount of ACBM in Homogeneous Area: 118 Sq. Ft. Floor Tile Basement BMS Supervisor

Primary use of this area is for: Supervisor Office

220 North Knoxville, Suite 200

Homogeneous Area: VA1-24B

Amount of ACBM in Homogeneous Area: 1 Lin. Ft. Pipe Lagging Basement – MB 3

220 North Knoxville, Suite 200

Homogeneous Area: VA1-26B

Amount of ACBM in Homogeneous Area: 120 Sq. Ft. Floor Tile Basement – 1-25

220 North Knoxville, Suite 200

Homogeneous Area: VA1-27B

Amount of ACBM in Homogeneous Area: 550 Sq. Ft. Floor Tile Basement – 1-25 Clothing

220 North Knoxville, Suite 200

Homogeneous Area: VA1-28B

Amount of ACBM in Homogeneous Area: 265 Ft. Pipe Lagging Basement – 1-22 Clothing

220 North Knoxville, Suite 200

Homogeneous Area: VA1-30B

Amount of ACBM in Homogeneous Area: 35 Ft. Pipe Lagging Basement – 1-2

220 North Knoxville, Suite 200

Homogeneous Area: VA1-31B

Amount of ACBM in Homogeneous Area: 85 Ft. Pipe Lagging Basement – 1-19

220 North Knoxville, Suite 200

Homogeneous Area: VA1-33B

Amount of ACBM in Homogeneous Area: 6 Ft. Pipe Lagging 1-378 Outside Corridor – 3rd Floor

If yes, explain: Material was not present in July 2021.

Response Action: None.

220 North Knoxville, Suite 200

Homogeneous Area: VA1-36B

Amount of ACBM in Homogeneous Area: 48 Sq. Ft. Floor Tile Room 316 – 3rd Floor

Primary use of this area is for: Room

220 North Knoxville, Suite 200

Homogeneous Area: VA1-41B

Amount of ACBM in Homogeneous Area: 200 Lin. Ft. Pipe Lagging 5th Floor Air Handler Room

Primary use of this area is for: Air Handler Room

220 North Knoxville, Suite 200

Homogeneous Area: VA1-42B

Amount of ACBM in Homogeneous Area: 1,000 Ft. Pipe Elbow 5th Floor Air Handler Room

Primary use of this area is for: Air Handler Room

220 North Knoxville, Suite 200

Homogeneous Area: VA1-43B

Amount of ACBM in Homogeneous Area: 60 Sq. Ft. Floor Tile 4th Floor Stairway

Primary use of this area is for: Stairway

220 North Knoxville, Suite 200

Homogeneous Area: VA1-2M

Amount of ACBM in Homogeneous Area: 30 Lin. Ft. Pipe Lagging Pharmacy South Wall – 1st Floor

Primary use of this area is for: Pharmacy

220 North Knoxville, Suite 200

Homogeneous Area: VA1-3M

Amount of ACBM in Homogeneous Area: 20 Sq. Ft. Floor Tile 1st Fl Stairway to Records C-40-So.

Primary use of this area is for: Stairway

220 North Knoxville, Suite 200

Homogeneous Area: VA1-6L

Amount of ACBM in Homogeneous Area: 30 Lin. Ft. Pipe Lagging 2nd Floor, Room 272

Primary use of this area is for: Room

220 North Knoxville, Suite 200

Homogeneous Area: OR-1 – OR-5 & Others

Amount of ACBM in Homogeneous Area: 9,769 Sq. Ft. Floor Tile Mastic under Non-ACM 12 x12 Floor Tile in the Basement & 1st & 2nd Floors

If yes, explain: Additional material has been identified. Total square footage has been adjusted.

Primary use of this area is for: Basement & Hospital

220 North Knoxville, Suite 200 Russellville, Arkansas 72801

Homogeneous Area: NA

Asbestos Content Determined By: Assumed

Amount of ACBM in Homogeneous Area: Pipe Lagging in Mechanical Chases & Above Hard Ceilings

Have there been any changes to the material in this area? No

If yes, explain: NA.

Primary use of this area is for: Piping

Comments: Maintain Operations and Maintenance (O&M) program.

220 North Knoxville, Suite 200

4.2 VA HEALTHCARE SYSTEM OF THE OZARKS – BUILDING 2

VA HEALTHCARE SYSTEM OF THE OZARKS – BUILDING 2

Homogeneous Area: VA2-5

Square Feet in Building: 33,246 Square Feet

Amount of ACBM in Homogeneous Area: 164 Ft. Pipe Lagging Basement Load Area

Type of ACBM: Thermal, Non-Friable

Primary use of this area is for: Load Area

220 North Knoxville, Suite 200

Homogeneous Area: VA2-6

Amount of ACBM in Homogeneous Area: 140 Feet Pipe Lagging

220 North Knoxville, Suite 200

Homogeneous Area: VA2-7

Amount of ACBM in Homogeneous Area: 135 Ft. Pipe Lagging

220 North Knoxville, Suite 200

Homogeneous Area: VA2-8

Amount of ACBM in Homogeneous Area: Pipe Elbow (included above)

220 North Knoxville, Suite 200

Homogeneous Area: VA2-9

Amount of ACBM in Homogeneous Area: 120 Ft. Pipe Lagging

220 North Knoxville, Suite 200

Homogeneous Area: VA2-10

Amount of ACBM in Homogeneous Area: 80 Lin. Ft. Pipe Lagging Basement Toilet

Primary use of this area is for: Restroom

220 North Knoxville, Suite 200

Homogeneous Area: VA2-11

Amount of ACBM in Homogeneous Area: 1 Lin. Ft. Pipe Elbow Basement Toilet

Primary use of this area is for: Restroom

220 North Knoxville, Suite 200

Homogeneous Area: VA2-12

Amount of ACBM in Homogeneous Area: 150 Lin. Ft. Pipe Lagging Basement Storage & Equipment

Primary use of this area is for: Storage

220 North Knoxville, Suite 200

Homogeneous Area: VA2-14

Amount of ACBM in Homogeneous Area: 525 Lin. Ft. Pipe Lagging Basement Locker Room & Lounge

Primary use of this area is for: Locker Room & Lounge

220 North Knoxville, Suite 200

Homogeneous Area: VA2-17

Amount of ACBM in Homogeneous Area: 460 Ft. Pipe Lagging Ingredient Control – Basement

Primary use of this area is for: Ingredient Control

220 North Knoxville, Suite 200

Homogeneous Area: VA2-19

Amount of ACBM in Homogeneous Area: 35 Lin. Ft. Pipe Lagging Basement Corridor

220 North Knoxville, Suite 200

Homogeneous Area: VA2-20

Amount of ACBM in Homogeneous Area: 1 Lin. Ft. Pipe Elbow Electric Repair Shop – Basement

Primary use of this area is for: Electric Repair Shop

220 North Knoxville, Suite 200

Homogeneous Area: VA2-21

Amount of ACBM in Homogeneous Area: 200 Ft. Floor Tile Eye Clinic – Basement

Primary use of this area is for: Eye Clinic

220 North Knoxville, Suite 200

Homogeneous Area: VA2-23

Asbestos Content Determined By: Assumed

Amount of ACBM in Homogeneous Area: 300 Sq. Ft. Soil Under Basement Porch

Type of ACBM: Miscellaneous, Friable

Have there been any changes to the material in this area? No

If yes, explain: N/A

Primary use of this area is for: Area under Porch

220 North Knoxville, Suite 200

Homogeneous Area: VA2-24

Amount of ACBM in Homogeneous Area: 6,000 Sq. Ft. Floor Tile 1st Floor Main Area

Primary use of this area is for: Main Area

E

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