B1 - 26187111 Asbestos and Lead Paint Survey Report.pdf

Supplemental Pre-Renovation

Asbestos and Lead-Paint Survey

Sheridan VAMC

Building 1

1898 Fort Road

Sheridan, Wyoming, 82801

January 7, 2019

Terracon Project No. 26187111

Prepared for:

GCH Construction

Windsor, Colorado

Prepared by:

Terracon Consultants, Inc.

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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................... i

INTRODUCTION

1.1 Project Objective

1.2 Reliance

BUILDING INFORMATION

ASBESTOS FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Suspect ACM

3.3 Physical Assessment

3.4 Sample Collection

3.5 Sample Analysis

3.6 Previous Asbestos Surveys

LEAD PAINT FIELD ACTIVITIES

4.1 Visual Assessment

4.2 Lead Paint Sampling and Laboratory Analysis

REGULATORY OVERVIEW

5.1 Asbestos

5.2 Lead Paint

LIMITATIONS/GENERAL COMMENTS

APPENDIX A IDENTIFIED ASBESTOS-CONTAINING MATERIALS BY HA

MATERIALS CONTAINING 1% OR LESS ASBESTOS BY HA

APPENDIX B ASBESTOS SURVEY SAMPLE LOCATION SUMMARY

APPENDIX C LEAD SCREEN SAMPLE LOCATION SUMMARY

APPENDIX D ANALYTICAL LABORATORY DATA

APPENDIX E DRAWINGS

APPENDIX F PHOTO LOG

APPENDIX G ACCREDITATIONS

Terracon Consultants, Inc. 2110 Overland Ave, Ste 124 Bi l l ings, Montana 59102

P [406] 656-3072 F [406] 656-3578 terracon.com

SUPPLEMENTAL PRE-RENOVATION ASBESTOS AND LEAD PAINT

SURVEY

Building 1

Sheridan Veteran’s Affairs Medical Center

1898 Fort Road, Sheridan, Wyoming, 82801

EXECUTIVE SUMMARY

Terracon Consultants, Inc. (Terracon) conducted a Supplemental Pre-Renovation Asbestos and

Lead Paint Survey of Building 1 located at the Sheridan Veteran’s Affairs Medical Center (VAMC), 1898 Fort Road, Sheridan, Wyoming. The survey was conducted in accordance with Terracon proposal No. P26187111 dated October 8, 2018 and GCH Construction Purchase Order No.

218095 dated November 9, 2018. We understand the pre-renovation asbestos survey was conducted to satisfy the requirements of the United States Environmental Protection Agency

(USEPA) 40 Code of Federal Regulations (CFR) Part 61 National Emission Standards for

Hazardous Air Pollutants (NESHAP), Subpart M. The lead paint survey was conducted to provide information for compliance with the Occupational Health and Safety Administration (OSHA) 29

CFR 1926.62 Lead.

The purpose of the asbestos survey was to supplement previous survey data, including the

Asbestos Testing Services Report (Amec Foster Wheeler Environment & Infrastructure, Inc., dated February 2018) and the 2018 Asbestos Re-Inspection Report (Northern Industrial Hygiene, dated July 26, 2018). Terracon accepted the findings of the reports where (1) building materials were identified as asbestos containing material (ACM) and (2) building materials identified as non-detected for asbestos were documented on laboratory reports provided by laboratories accredited under the National Voluntary Laboratory Accreditation Program (NVLAP). Previously sampled building materials not meeting these criteria were to be resampled. Sampling of Rooms 105, 103, 201, 202, 204, 207, the attic, and the roof were not included in this survey. Room 002 was not accessible.

The purpose of the lead paint survey was to provide information for compliance with OSHA and was not intended to meet the requirements of the U.S. Department of Housing and Urban

Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP)

Hazards in Housing or the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination. There was no previous paint data provided for this survey.

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Supplemental Pre-Renovation Asbestos and Lead Paint Survey

Sheridan VAMC, Building 1 ■ Sheridan, Wyoming

January 7, 2019 ■ Terracon Project No. 26187111

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The asbestos survey was performed on November 26-27, 2018 by AHERA1-accredited asbestos inspectors in accordance the sampling protocols established in EPA 40 CFR Part 763-Asbestos, Subpart E-Asbestos-Containing Materials in Schools (known as AHERA). Terracon collected 76 samples from 24 homogeneous areas of suspect ACM from Building 1.

CONCLUSIONS

Asbestos

The following ACMs were identified in previous asbestos surveys.

Asbestos Testing Services Report (Amec Foster Wheeler, February 2018)

HA No. Material Description Homogenous Area

Location

% and Type

Asbestos

Estimated

Quantity

FT-01

Beige floor tile with black mastic2 2nd Floor, Room 2023

Tile 1.1% Chrysotile

Black mastic, ND

Yellow mastic, ND

Quantity not provided

DT-01 Drywall with texture2 2nd Floor, Room 2074 Texture, PC5 0.5% Chrysotile

Plaster, ND

Quantity not provided

DT-01 Plaster/drywall with texture6 2nd Floor, Rooms 204 and 2057

Texture, PC 1.1% Chrysotile

Plaster, ND

Quantity not provided

2018 Asbestos Re-Inspection Report (Northern Industrial Hygiene, dated July 26, 2018)

Homogenous Area

Location

% and Type

Asbestos

Estimated

Quantity

F2 Unknown floor tile and mastic8 2nd Floor, Room 2079

Tile 1.1% Chrysotile

Black mastic, ND

Yellow mastic, ND

~140 SF

F2.3

9"x9" green floor tile (black mastic, ND; over 9"x9" brown floor tile, ND)

1st Floor, Rooms 105, 106, 107, 108, 109, 11010

Green tile, 5% Chrysotile

Black mastic, ND

Brown tile, ND

~1,176 SF

M03.A Drywall A (second floor only)7 2nd Floor, Room 2079

Joint compound 3% Chrysotile

Gypsum, ND

~765 SF

M10.1 Undercoating/stainless steel sink 1st Floor, Room 109 10% Chrysotile ~4 SF

1 AHERA = Asbestos Hazard Emergency Response Act 2 Removed in May 2018 by Horsley Specialties, Inc.

3 Room 203A in Asbestos Testing Services Report (2018), Room 202 for this survey.

4 Room 212 in Asbestos Testing Services Report (2018), Room 207 for this survey.

5 PC = point count 6 IATL laboratory report in the survey report indicates asbestos was in the off-white texture of off-white/brown drywall.

7 Rooms 204 and 205 in Asbestos Testing Services Report (2018); Rooms 204 and 206 for this survey.

8 Data from Asbestos Testing Services Report (2018); removed in May 2018 by Horsley Specialties, Inc.

9 Room 212 in 2018 Re-Inspection Report; Room 207 for this survey.

10 Rooms 108, 109, 110, 111, and 11A for this survey.

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The following ACMs sampled by Terracon, were identified as a result of laboratory analysis.

Homogenous Area

Location

% and Type

Asbestos

Estimated

Quantity

03-FT5 9"x9" lt. green vinyl floor tile11

1st Floor, Rooms 102, 104, 108, 110, 111, 111A, 109, 107, and C-101

4.1 to 4.4% Chrysotile ~2,453 SF

19-MG5

Brown mastic (behind lt. brown wood wall paneling)

1st Floor, Rooms 108, 109, and 111

1.2 to 1.5% Chrysotile ~2,158 SF

22-MG5

Black mastic (behind dk. brown wood wall paneling) 1st Floor, Room 110 1.7 to 2.1% Chrysotile ~504 SF

24-FT5 9"x9" beige vinyl floor tile12

2nd Floor, Rooms 206, 206A, 208, 208A, 209A, 209B, C-201, and S-201

1.2 to 1.5% Chrysotile ~1,531 SF

The wall texture (identified in Amec Foster Wheeler report), is a Category II nonfriable ACM under

USEPA NESHAP and a surfacing ACM under OSHA in good condition. Under USEPA NESHAP, Category II nonfriable ACMs that could be crumbled, pulverized, or reduced to powder during renovation or demolition activities, must be removed prior disturbance.

The brown mastic (behind light brown wood wall paneling) and black mastic (behind dark brown wood wall paneling) are Category II nonfriable ACMs under USEPA NESHAP and miscellaneous

ACM under OSHA in good condition. Under USEPA NESHAP, Category I nonfriable ACMs that have become friable or that will be or have been subjected to sanding, grinding, cutting, or abrading, must be removed prior to demolition operations.

The 9”x9” vinyl floor tiles are considered Category I nonfriable ACM under USEPA NESHAP and miscellaneous ACM under OSHA in good condition. Per USEPA NESHAP, Category I nonfriable

ACMs that have become friable or that will be or have been subjected to sanding, grinding, cutting, or abrading, must be removed prior to renovation or demolition operations.

Removal of ACM must be conducted by an asbestos abatement contractor with AHERA-accredited personnel in accordance with applicable federal and state regulations. Abatement contractors should be contacted to obtain competitive bids for removal of ACM.

The following materials containing 1% or less asbestos were identified as a result of laboratory analysis, including point count analysis. USEPA does not regulate materials containing 1% or less asbestos; however, the OSHA permissible exposure limits (0.1 f/cc of air as an 8-hour time-weighted average or 1.0 f/cc of air over 30 minutes) for asbestos apply when materials containing

1% asbestos or less are disturbed during renovations or demolitions.

11 Black, yellow mastic, black mastic/brown VSF, and black felt layers were reported as “none detected” for asbestos.

12 Black mastic (bottom) and yellow mastic (top) layers were reported as “none detected” for asbestos.

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HA No. Material Description Homogenous Area Location % and Type

Asbestos

Estimated

Quantity

12-CP5

5/8" painted white drywall with white taping mud

2nd Floor, Rooms 203, 206, 206A, 208, 209, 209A, 209B, C-201, and S-201

PC 0.75 Chrysotile ~3,730 SF

No building materials were assumed to be ACM by the inspectors.

A summary of the location, condition, and approximate quantity of identified ACM is presented in

Appendix A. The summary of sample locations is presented in Appendix B. Laboratory analytical reports are presented in Appendix D.

Lead Paint

Laboratory analysis identified detectable quantities of lead in the following painted building components.

SAMPLE

NUMBER

SAMPLE

LOCATION

COMPONENT SUBSTRATE COLOR CONDITION

RESULT

(% by wt.)

P01 Basement Wall Plaster White paint Poor 0.15%

P02 1st Floor 8" Baseboard Wood Brown paint Intact 0.066%

P03 1st Floor 8" Baseboard Wood White paint Intact 0.39%

P04 1st Floor 4" Baseboard Wood White paint Intact 0.0087%

P05 1st Floor Door frame Wood Lt. brown paint Intact 0.0.18%

P06 1st Floor Wall Plaster Cream paint Intact 0.31%

P07 1st Floor Wall Plaster Lt. aqua-blue paint Intact 0.18%

P08 2nd Floor 4" Baseboard

(flat) Wood White paint Intact 0.047%

P09 2nd Floor 4" Baseboard

(rounded) Wood Lt. brown paint Intact 0.079%

P10 2nd Floor Door frame Metal Gray paint Intact 0.69%

P11 1st and 2nd

Floors Wall Drywall

Brownish-beige paint Intact 0.026%

P12 2nd Floor Wall Plaster White paint Intact 0.055%

Disturbance of paints containing detectable lead concentrations are regulated by OSHA’s construction lead standard (29 CFR 1926.62). Disposal of lead-contaminated waste is regulated by USEPA under RCRA.

A summary of the lead paint sample locations and analysis is presented in Appendix C. Laboratory analytical reports are included in Appendix D.

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RECOMMENDATIONS

Asbestos

Friable ACM and nonfriable ACM that has become or will become friable during demolition must be removed prior to renovation or demolition operations. Removal of ACM must be conducted by an asbestos abatement contractor with AHERA-accredited personnel in accordance with applicable federal and state regulations. Abatement contractors should be contacted to obtain competitive bids for removal of ACM.

Materials that contain 1% or less asbestos through point count analysis are not considered ACM and are not subject to USEPA NESHAP regulations. However, OSHA regulates any detectable amount of asbestos and compliance with all applicable OSHA regulations regarding occupational exposure during renovation or demolition activities is mandatory.

If additional but unsampled suspect ACMs are revealed during renovation activities, the material(s) must be assumed to contain asbestos and treated as such unless sampled by an accredited inspector and laboratory analysis determines otherwise.

Lead Paint

Compliance with OSHA 29 CFR 1926.62 Lead is required for employees that may be occupationally exposed to lead and waste determination for disposal of lead waste must comply with USEPA regulations under RCRA.

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SUPPLEMENTAL PRE-RENOVATION ASBESTOS AND LEAD PAINT

SURVEY

Building 1

Sheridan Veteran’s Affairs Medical Center

1898 Fort Road, Sheridan, Wyoming, 82801

INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted an Supplemental Pre-Renovation Asbestos and

Lead Paint Survey of Building 1 located at the Sheridan Veteran’s Affairs Medical Center (VAMC), 1898 Fort Road, Sheridan, Wyoming. The survey was conducted on November 27, 2018 by

AHERA1-accredited asbestos inspectors in accordance with Terracon proposal No. P26187111 dated October 3, 2018 and GCH Construction (GCH) Purchase Order No. 218095 dated

November 9, 2018 and executed on November 15, 2018.

1.1 Project Objective

We understand this asbestos and lead paint survey was requested to satisfy the requirements of the United States Environmental Protection Agency (USEPA) 40 Code of Federal Regulations

(CFR) Part 61-National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M-

Asbestos in support of the planned renovation of Building 1. Sampling of Rooms 105, 103, 201, 202, 204, 207, the attic, and the roof were not included in this survey.

1.2 Reliance

This report is for the exclusive use of GCH Construction for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and GCH

Construction. Reliance on this report by GCH Construction and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report, and Terracon’s

Agreement for Services. The limitations of liability defined in Terracon’s Agreement for Services is the aggregate limit of Terracon’s liability to GCH Construction.

1 AHERA = Asbestos Hazard Emergency Response Act

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BUILDING INFORMATION

The following table provides a summary of pertinent building information and construction information such as structure and finishes used within the building.

Table 1: Building Descriptions and Information

Description and Information

Building Use Building 1

Owned/Leased Owned by VA

Plans Reviewed Yes (not originals)

Building Square Footage Not provided Number of Floors 2

Construction Date ~1907 Renovation Date(s) N/A

Construction

Main Structure Sandstone foundations and masonry

Building Insulation Not observed

Flooring Structure Concrete slab/wood Flooring Finishes

Bare concrete, floor tile, sheet flooring, ceramic tile, and carpet

Exterior Walls Brick and Wood Interior Wall Finishes Plaster/drywall

Roof Type Hip Roof Finishes Shingles

Ceilings Lower: Ceiling panels Upper: Plaster and/or ceiling tiles

HVAC2 Equipment Heating:

Radiant/steam heat Cooling: Not observed

The building was unoccupied at the time of the survey. Drawings can be found in Appendix E.

ASBESTOS FIELD ACTIVITIES

The asbestos survey was conducted November 26-27, 2018 by Mr. Brian Ramsell and Cameron

Sapp, AHERA-accredited asbestos inspectors. Copies of Mr. Ramsell and Mr. Sapp’s asbestos inspector accreditations can be found in Appendix G. A summary of survey activities is provided below.

3.1 Visual Assessment

Survey activities were initiated with visual observation of the interior and exterior (excluding previously identified ACMs and Rooms 103, 105, 202, 203, 204, 205, and the roof) of the building to identify and document homogeneous areas of suspect ACM. A homogeneous area (HA)

2 HVAC – heating, ventilation, and air conditioning

Responsive ■ Resourceful ■ Reliable 3 consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application. Although reasonable effort was made to survey accessible suspect materials, additional suspect but unsampled materials could be located in voids or in other concealed areas.

Room 002, located in the basement, was not accessible and was not inspected or assessed.

3.2 Suspect ACM

The following listed materials were determined by the inspector to be suspect ACM. This list excludes suspect materials present in the building but not anticipated to be disturbed by emergency renovation activities.

01-CP5 - Gray concrete

02-MG5 - White leveling compound

03-FT5 - Layered black, yellow mastic, 9"x9" lt. green vinyl floor tile (VFT), black mastic, brown vinyl sheet flooring (VSF), black felt

04-FT2 - 12"x12" light gray VFT with gray and white mottling and yellow mastic

05-FT2 - 12"x12" off-white, blue-gray, and beige mottled VFT and black mastic

06-CP5 - Red vinyl sheet flooring

07-CP5 - 4" dark gray base cove and cream mastic

08-CP5 - 4" gray base cove and cream mastic

09-CP5 - 4" gray base cove and tan mastic

10-CP5 - White pookie (on fiberglass insulated pipes)

11-CP5 - 5/8" painted white drywall w/ white taping mud (1st Floor)

12-CP5 - 5/8" painted white drywall w/ white taping mud (2nd Floor)

13-CT1 - 12"x12" ceiling tile w/ randomly spaced large and small holes (stapled to wood grid)

14-CT1 - 12"x12" ceiling tile w/ uniform holes and brown mastic (some floors, stapled to wood grid)

15-CT4 - 2'x4' lay-in panel, off-white w/ deep jagged fissures, small pits, and randomly spaced Large, medium, & small pinholes

16-CT4 - 2'x4' lay-in panel, off-white w/ jagged fissures, and randomly spaced large & small pinholes

17-CT4 - 2'x4' lay-in panel, off-white w/ snake fissures, small pits, and randomly spaced large & small pinholes

18-PM5 - Black tar paper

19-MG5 - Brown mastic (behind wood wall paneling)

20-HP1 - Gray plaster (over concrete & brick walls)

21-HP2 - Gray plaster with white skim coat

22-MG5 - Black mastic (behind wood wall paneling)

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23-CT1 - 12"x12" ceiling tile w/ large & small pinholes in a wave-like pattern

(stapled to wood grid)

24-FT5 - 9"x9" beige vinyl floor with black mastic (bottom) and yellow mastic (top)

Photographs of suspect ACM can be found in Appendix F.

3.3 Physical Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.4 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in accordance with the sampling protocols outlined in 40 CFR 763.86-Sampling. Samples of suspect materials were collected from randomly selected locations in each HA. Bulk samples were collected using wet methods, as applicable, to reduce the potential for fiber release. Samples were 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.

Terracon collected 76 samples from 24 homogenous areas of suspect ACM from Building 1. A summary of the classification, assessment category, and approximate quantity of identified ACM is presented in Appendix A and a summary of suspect ACM samples collected during the survey is included as Appendix B. Sample location diagrams are included as Appendix E. Photographs of suspect ACM can be found in Appendix F.

3.5 Sample Analysis

Bulk samples were submitted under chain of custody (COC) to iATL of Mount Laurel, New Jersey for analysis by polarized light microscopy (PLM) with dispersion staining techniques in accordance with EPA’s Method for the Determination of Asbestos in Bulk Building Materials

(600/R-93/116). The percentage of asbestos, if present, was determined by microscopic visual estimation. iATL is accredited under the National Voluntary Laboratory Accreditation Program

(NVLAP) Accreditation No. 101165-0. The laboratory analytical report and COC are provided in

Appendix D.

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NESHAP requires that any analytical detection of asbestos by PLM less than 10% must be assumed to contain greater than 1% unless analysis by PLM point count proves that the samples contained less than or equal to 1% asbestos. Samples with results less than 10% were reanalyzed by point counting.

3.6 Previous Asbestos Surveys

ACMs identified in previous asbestos surveys are provided in Appendix A.

LEAD PAINT FIELD ACTIVITIES

The lead (LP) survey was conducted on November 27, 2018 by Mr. Brian Ramsell. The lead paint inspection sampling was performed in accordance with the procedures prescribed in the USEPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The lead paint inspection was performed to satisfy the requirements of OSHA’s construction standard for lead

(29 CFR 1926.62), which defines lead-containing paint as paint containing any detectable lead.

The sampling conducted for this project was not intended to meet the requirements of USEPA regulations under the Resource Conservation and Recovery Act (RCRA) for waste determination.

Paint sampling did not include building components that were not expected to be disturbed by the renovation project, such as windows.

4.1 Visual Assessment

Sampling activities began with visual observation to identify unique combinations of paint most prevalent in the building. A unique combination of paint consists of paint that is applied to a building material and has similar color, substrate and component.

A physical assessment of each unique combination of paint was conducted to assess the condition of the paint. Paint was visually assessed and assigned a condition of intact, top layer failure, multi-layer failure and substrate failure.

4.2 Lead Paint Sampling and Laboratory Analysis

The painting history of a given location in older buildings often will vary from place to place due to factors including variability in paints used, paint film thickness, variable retention of older paint layers before repainting, demolition/installation of walls during renovations, and unknown historic non-homogenous painting schemes. As such, a given color and building component combination that is apparent often will not provide consistent testing results for lead.

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Terracon attempted to conduct lead paint testing in a sufficient number of areas to establish trends in lead content based on distinguishable characteristics such as color or building component.

Photographs of painted components can be found in Appendix F.

Based on Terracon’s visual observations, chip samples were collected from painted building components. Paint chip samples included all layers of paint with care taken to minimize collection of the substrate. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. This number (along with other information such as sample location, color, substrate, and condition) was recorded in the sample log.

Terracon collected 12 paint chip samples from Building 1.

The inspector shipped the samples along with a completed COC document to the laboratory. The laboratory then arranged the samples in numerical order. If a discrepancy between the samples exists, this is noted and initialed on the log sheet. The laboratory signed a copy of the chain-of-custody to acknowledge receipt. The inspector retained the signed copy for evidentiary purposes.

Further, the laboratory assigned a laboratory number to each sample received. The laboratory labeled both the analytical report and the sample container with this laboratory number for cross-reference purposes.

The paint chip and soil samples were received under chain of custody by iATL) in Mt. Laurel, New

Jersey. iATL is accredited by the AIHA® Laboratory Accreditation Programs, LLC under the

Industrial Hygiene Laboratory Accreditation Program (IHLAP; Accreditation No. 100188).

Paint chip samples were analyzed using USEPA SW-846 Methods 3050B/7000B Acid Digestion of Sediments, Sludges, and Soils / Flame Atomic Absorption Spectrophotometry. The laboratory analytical reports and COCs are provided in Appendix D.

REGULATORY OVERVIEW

5.1 Asbestos

The Wyoming Department of Environmental Quality (WDEQ), enforces the asbestos NESHAP as adopted by reference under authority of Sections 35-11-110, 112, 114, and 202 through 212 of the Wyoming Environmental Quality Act, 1993 and in accordance with provisions of Sections 16-

3-101 through 16-3-115 of the Wyoming Administrative Procedures Act. The owner or operator must provide WDEQ with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb regulated asbestos containing material (RACM) in amounts greater than or equal to 160 square feet, 260 linear feet or 35 cubic feet.

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The asbestos NESHAP (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 renovation or demolition 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 is considered RACM.

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 in the course of 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. Category II nonfriable ACM generally includes, but is not limited to, cementitious material such as cement pipes, cement siding, cement panels, glazing, mortar, and grouts.

The OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos be maintained below the permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) or 1.0 f/cc as a 30-minute excursion limit. 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.

5.2 Lead Paint

Applicable certification, occupant protection, and clearance requirements and work practice standards for lead-based paint (LBP) are found in regulations issued by EPA at 40 CFR part 745, subpart L and in regulations issued by the U.S. Department of Housing and Urban Development

(HUD) at 24 CFR Part 35, Subpart R.

HUD and USEPA define lead-based paint as any coating that has a lead concentration equal to or greater than (≥) 1.0 mg/cm2 or ≥0.5% by weight. The Consumer Product Safety Commission

(CPSC) currently considers paint to be lead-containing if the concentration of lead exceeds 90 parts per million (ppm) or 0.009% by weight. Both the CPSC and HUD definitions of lead paint are aimed at protecting the general population from exposure to lead in the residential setting.

The OSHA lead standard for construction (29 CFR 1926.62) regulates workplace exposure to lead. OSHA regulates construction activities that disturb lead-containing material regardless of the

Responsive ■ Resourceful ■ Reliable 8 concentration. Personnel performing renovation or demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure.

Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than the PEL of 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection. The OSHA standard also establishes an action level of 30 g/m3, which if exceeded, triggers requirements for recurrent exposure monitoring, medical surveillance program, and training about lead. OSHA does not define the amount of lead in paint that constitutes lead containing paint. An exposure assessment for each trigger task should be conducted to determine if actual airborne levels are below the required OSHA action and permissible levels.

RCRA gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic

Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L). USEPA exempts from most RCRA requirements for those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

LIMITATIONS/GENERAL COMMENTS

Terracon was limited to sampling suspect materials in rooms of Building 1 at the Sheridan VAMC expected to be impacted by the planned renovation work. Areas excluded from the survey included

Rooms 105, 103, 201, 202, 204, 207, the attic, and the roof. Should renovation work require disturbance of any other building material not identified in this survey report, an asbestos inspection must be conducted by an AHERA-accredited asbestos inspector in accordance with state and federal regulations prior to disturbance. If additional but unsampled suspect ACMs are revealed during renovation activities, the material(s) must be assumed to contain asbestos and treated as such unless sampled by an accredited inspector and laboratory analysis determines otherwise.

This asbestos survey 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. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our survey of Building 1 at the Sheridan VAMC.

The information contained in this report is relevant to the date on which this survey was performed and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by GCH Construction for specific application to their

Responsive ■ Resourceful ■ Reliable 9 project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. 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.

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APPENDIX A

SHERIDAN VAMC BUILDING 64, ROOMS 104 AND 105

1898 FORT ROAD, SHERIDAN, WYOMING

Identified Asbestos-Containing Materials by Homogeneous Area (HA)

The materials listed in this table have been sampled and determined to contain asbestos in concentrations greater than 1%. When disturbed, various federal, state, and local regulations may apply. See Appendix B for a summary of samples collected. See Appendix

D for detailed analytical results.

HA No. Material Description Material Location % and Type

Asbestos1

NESHAP

Classification

OSHA

Classification

Estimated

Quantity2

03-FT5 9"x9" lt. green vinyl floor tile3

1st Floor, Rooms 102, 104, 108, 110, 111, 111A, 109, 107, and

C-101

PC4 4.1 to 4.4% Chrysotile Category I Miscellaneous ~2,453 SF

19-MG5

Brown mastic (behind lt. brown wood wall paneling)

1st Floor, Rooms 108, 109, and

PC 1.2 to 1.5% Chrysotile Category II Miscellaneous ~2,158 SF

22-MG5

Black mastic (behind dk. Brown wood wall paneling) 1st Floor, Room 110 PC 1.7 to 2.1% Chrysotile Category II Miscellaneous ~504 SF

24-FT5 9"x9" beige vinyl floor tile5

2nd Floor, Rooms 206, 206A, 208, 208A, 209A, 209B, C-201, and S-201

PC 1.2 to 1.5% Chrysotile Category I Miscellaneous ~1,531 SF

M10.1 Undercoating/stainless steel sink 1st Floor, Room 109 10% Chrysotile Category II Miscellaneous ~4 SF

1 % & 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.

2 Estimated quantities are 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. SF = square feet 3 Black, yellow mastic, black mastic/brown VSF, and black felt layers were reported as none detected for asbestos.

4 PC = Point Count 5 Black mastic (bottom) and yellow mastic (top) layers were reported as none detected for asbestos.

Responsive ■ Resourceful ■ Reliable A-2

MATERIALS CONTAINING 1% OR LESS ASBESTOS BY HA

OSHA regulates materials containing detectable concentrations of asbestos. Disturbance of materials containing 1% asbestos or less (but greater than zero percent) must comply with the work practices in 29 CFR 1926.1101 Asbestos.

OSHA permissible exposure limits (0.1 f/cc of air as an 8-hour time-weighted average or 1.0 f/cc of air over 30 minutes) for asbestos apply when materials containing detectable asbestos concentrations are disturbed during renovations or demolitions.

% and Type

Asbestos

Estimated

Quantity2

12-CP5 5/8" painted white drywall with white taping mud 2nd Floor, Rooms 203, 206, 206A, 208, 209, 209A, 209B, C-201, and S-201 PC 0.75% Chrysotile ~3,730 SF

SUMMARIES OF PREVIOUS REPORTS

Asbestos Testing Services Report (Amec Foster Wheeler, February 2018)

% and Type

Asbestos

NESHAP

Classification

OSHA

Classification

Estimated

Quantity

FT-01 Beige floor tile with black mastic6 2nd Floor, Room 2027

Tile 1.1% Chrysotile

Black mastic, ND

Yellow mastic, ND

Category I Miscellaneous Quantity not provided

DT-01 Drywall with texture2 2nd Floor, Room 20738

Texture, PC 0.5%

Chrysotile

Plaster, ND

Category II Miscellaneous Quantity not provided

DT-01 Plaster/drywall with texture9 2nd Floor, Rooms 204 and

20510

Texture, PC 1.1%

Chrysotile

Plaster, ND

Category II Miscellaneous Quantity not provided

6 Removed in May 2018 by Horsley Specialties, Inc.

7 Room 203A in Asbestos Testing Services Report (2018), Room 202 for this survey.

8 Room 212 in Asbestos Testing Services Report (2018), Room 207 for this survey.

9 IATL laboratory report in the survey report indicates asbestos was in the off-white texture of off-white/brown drywall.

10 Rooms 204 and 205 in Asbestos Testing Services Report (2018), Rooms 204 and 206 for this survey.

Responsive ■ Resourceful ■ Reliable A-3

2018 Asbestos Re-Inspection Report (Northern Industrial Hygiene, dated July 26, 2018)

HA No. Material Description Material Location % and Type

Asbestos

NESHAP

Classification

OSHA

Classification

Estimated

Quantity

F2 Unknown floor tile and mastic11 2nd Floor, Room 2078

Tile 1.1% Chrysotile

Black mastic, ND

Yellow mastic, ND

Category I Miscellaneous ~140 SF

F2.3 9"x9" green floor tile (black mastic, ND; over 9"x9" brown floor tile, ND)

1st Floor, Rooms 105, 106, 107, 108, 109, 11012

Green tile, 5% Chrysotile

Black mastic, ND

Brown tile, ND

Category I Miscellaneous ~1,176 SF

M03.A Drywall A (second floor only)7 2nd Floor, Room 2078

Joint compound 3%

Chrysotile

Gypsum, ND

Category II Miscellaneous ~765 SF

M10.1 Undercoating/stainless steel sink 1st Floor, Room 109 10% Chrysotile ~4 SF

11 Data from Asbestos Testing Services Report (2018); removed in May 2018 by Horsley Specialties, Inc.

12 Rooms 108, 109, 110, 111, and 11A for this survey.

Responsive ■ Resourceful ■ Reliable B-1

APPENDIX B

Asbestos Survey Sample Location Summary

HA No.

Sample

Number Sample Location Material Description Layer

Lab Results

% Asbestos

NESHAP

Category Condition HA Locations

Estimated

Quantity1

01 01-CP5-01

Room 003, 1' from north wall, 2.5' from east wall, floor Gray concrete L1 Grey cementitious None detected Non-ACM Good

Basement floor, All

Rooms

~0 SF 01 01-CP5-02

Room 005, 9' from north wall, 4' from west wall, floor Gray concrete L1 Grey cementitious None detected Non-ACM Good

01 01-CP5-03

Room 005, 1.5' from north wall, 4' from west wall, floor Gray concrete L1 Grey cementitious None detected Non-ACM Good

02 02-FC6-04 Room 111A, north wall, 8' from west wall, floor White leveling compound L1 White leveling compound

L2 Yellow mastic

None detected

None detected Non-ACM Good

1st Floor, Rooms

111A and 111; 2nd

Floor, Rooms S-201

~0 SF 02 02-FC6-05 Room 111A, north wall, 5' from west wall, floor White leveling compound L1 White leveling compound

L2 Yellow mastic

None detected

None detected Non-ACM Good

02 02-FC6-06 Room S-201, northeast corner, floor White leveling compound L1 White leveling compound

L2 Yellow mastic

None detected

None detected Non-ACM Good

03 03-FT5-07 Room 108, southwest corner, floor

Black/yellow mastic, 9”x9” lt. green vinyl floor tile

(VFT), black mastic, brown vinyl sheet flooring

(VSF), and black felt

L1 White floor tile

L2 Brown floor tile

L3 Yellow mastic

L4 Black mastic

L5 Brown mastic

L6 Black fibrous

4.1% Chrysotile2

None detected

None detected

None detected

None detected

None detected

Category I Good

1st Floor, Rooms

102, 104, 108, 110, 111, 111A, 109, 107, and C-101

~2,453 SF

03 03-FT5-08

Room 110, 6.5' from south wall, 8.5' from west wall, floor

Black/yellow mastic, 9”x9” lt. green VFT, black mastic, brown VSF, and black felt

L1 Off-white floor tile

L2 Brown floor tile

L3 Tan mastic

L4 Black mastic

L6 Black fibrous

4.4% Chrysotile2

None detected

None detected

None detected

None detected

Category I Good

03 03-FT5-09

Room 111A, south wall, 8' from west wall, floor

Black/yellow mastic, 9”x9” lt. green VFT, black mastic, brown VSF, and black felt

L1 Off-white floor tile

L2 Brown floor tile

L3 Tan mastic

L4 Black mastic

L6 Black fibrous

4.3% Chrysotile2

None detected

None detected

None detected

None detected

Category I Good

04 04-FT2-10 Room S-001, northwest corner, floor 12" x 12" Light gray VFT with gray and white mottling

L1 Grey floor tile

L2 Yellow mastic

L3 White leveling compound

None detected

None detected

None detected

Non-ACM Good

Basement, Room S-

001, 001, 008, E-

101A, floors

~0 SF

04 04-F2-11 Room S-001, southwest corner, floor

12" x 12" Light gray VFT with gray and white mottling

L1 Grey floor tile

L2 Yellow mastic

None detected

None detected Non-ACM Good

04 04-FT2-12 Room S-001, northeast corner, floor 12" x 12" Light gray VFT with gray and white mottling

L1 Grey floor tile

L2 Yellow mastic

None detected

None detected Non-ACM Good

1 Estimated quantities are 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. ~ = approximately; SF = square feet; LF = linear feet; CF = cubic feet.

2 Point counted

Responsive ■ Resourceful ■ Reliable B-2

Sample

Number Sample Location Material Description Layer

Lab Results

% Asbestos

NESHAP

Category Condition HA Locations

Estimated

Quantity1

05 05-FT2-13 Room 004, southwest corner, floor 12" x 12" Off-white, blue-gray, and beige mottled

VFT

L1 Grey floor tile

L2 Black mastic

L3 Brown leveling compound

None detected

None detected

None detected

Non-ACM Good

Basement, Room

004 floors

~0 SF

05 05-FT2-14 Room 004, northwest corner, floor 12" x 12" Off-white, blue-gray, and beige mottled

VFT

L1 Grey floor tile

L2 Black mastic

None detected

None detected Non-ACM Good

05 05-FT2-15 Room 004, northeast corner, floor 12" x 12" Off-white, blue-gray, and beige mottled

VFT

L1 Grey floor tile

L2 Black mastic

None detected

None detected Non-ACM Good

06 06-FC1-16

Room 005, 12' from south wall, 4' from west wall, floor Red VSF

L1 Red floor tile

L2 Black mastic

L3 Gray fibrous

None detected

None detected

None detected

Non-ACM Good

Basement, Rooms

C-001, 005 floors

~0 SF

06 06-FC1-17

Room 005, 7' from north wall, 4' from west wall, floor Red VSF

L1 Red floor tile

L2 Black mastic

L3 Gray fibrous

None detected

None detected

None detected

Non-ACM Good

06 06-FC1-18

Room C-001, north wall, 3' from west wall, floor Red VSF

L1 Red floor tile

L2 Black mastic

None detected

None detected Non-ACM Good

07 07-FC3-19 Room S-001, northwest corner, floor 4" Dark gray base cove and cream mastic L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

Basement, Room

S001 walls ~0 SF 07 07-FC3-20 Room S-001, southwest corner, floor 4" Dark gray base cove and cream mastic

L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

07 07-FC3-21 Room S-001, northeast corner, floor 4" Dark gray base cove and cream mastic L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

08 08-FC3-22 Room 106, southwest corner, floor 4" Gray base cove and cream mastic L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

1st Floor, Room

106, E-101A, walls ~0 SF 08 08-FC3-23 Room 106, northwest corner, floor 4" Gray base cove and cream mastic

L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

08 08-FC3-24 Room 106, northeast corner, floor 4" Gray base cove and cream mastic L1 Grey cove base

L2 Yellow mastic

None detected

None detected Non-ACM Good

09 09-FC3-25 Room 004, southwest corner, floor 4" Gray base cove and tan mastic L1 Grey cove base

L2 Tan mastic

None detected

None detected Non-ACM Good

Basement, Room

004 walls ~0 SF 09 09-FC3-26 Room 004, northwest corner, floor 4" Gray base cove and tan mastic

L1 Grey cove base

L2 Tan mastic

None detected

None detected Non-ACM Good

09 09-FC3-27 Room 004, northeast corner, floor 4" Gray base cove and tan mastic L1 Grey cove base

L2 Tan mastic

None detected

None detected Non-ACM Good

10 10-SC7-28 Room 006, 5' from south wall, west wall, 7' up White pookie L1 Off-white coating

L2 Yellow insulation

None detected

None detected Non-ACM Good

Pipe insulation on boiler system piping, Ts and elbows only

~0 SF 10 10-SC7-29

Room 004, 3' from north wall, 5.5' from west wall, 7' up White pookie

L1 Off-white coating

L2 Yellow insulation

None detected

None detected Non-ACM Good

10 10-SC7-30

Room 005, 9’ from north wall, 1’ from west wall, 7’ up White pookie L1 Off-white wrap None detected Non-ACM Good

11 11-WB1-31 Room 107, southwest corner, 4' up 5/8" Painted white drywall w/ white taping mud -

1/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

None detected

None detected

Non-ACM Good 1st Floor, Rooms

007A, 001, S-001, S-101, 101, 103, 105, 107, 111A walls (some rooms only partial)

~0 SF 11 11-WB1-32 Room 107, northeast corner, 4' up 5/8" Painted white drywall w/ white taping mud -

1/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

None detected

None detected

Non-ACM Good

11 11-WB1-33

Room 111A, north wall, 8' from west wall, 7' up

5/8" Painted white drywall w/ white taping mud -

1/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

None detected

Non-ACM Good

Responsive ■ Resourceful ■ Reliable B-3

Sample

Number Sample Location Material Description Layer

Lab Results

% Asbestos

NESHAP

Category Condition HA Locations

Estimated

Quantity1

12 12-WB1-34 Room 203, northeast corner, 4' up 5/8" Painted white drywall w/ white taping mud -

2/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

None detected

None detected

Non-ACM Good 2nd Floor, Rooms

203, 206, 206A, 208, 209, 209A, 209B, C-201, and S-

201 (some rooms only partial)

~3,730 SF 12 12-WB1-35 Room 208, northwest corner, 4' up 5/8" Painted white drywall w/ white taping mud -

2/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

2.9% Chrysotile2

0.75% Chrysotile2

Category II Good

12 12-WB1-36 Room 209, southwest corner, 4' up 5/8" Painted white drywall w/ white taping mud -

2/F

L1 White drywall

L2 White joint compound

L3 Composite

None detected

3.1% Chrysotile2

0.75% Chrysotile2

Category II Good

13 13-CT1-37 2nd Floor, Room 209, ceiling 12” x 12” Ceiling tile (CT) w/ randomly spaced large and small holes (stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good 2nd Floor, Rooms

203, C-201, 206, 208, 209, 209A, 209B, 107, 109, ceiling

~0 SF 13 13-CT1-38 2nd Floor, Room 208, ceiling 12” x 12” CT w/ randomly spaced large and small holes (stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good

13 13-CT1-39 2nd Floor, Corridor C201, ceiling 12” x 12” CT w/ randomly spaced large and small holes (stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good

14 14-CT1-40 1st Floor, Room 111A, ceiling 12” x 12” CT w/ uniform holes and brown mastic

(some floors, stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good

1st Floor Rooms except C-101, S-

101, 106

~0 SF 14 14-CT1-41 1st Floor, Room 111, ceiling 12” x 12” CT w/ uniform holes and brown mastic

(some floors, stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good

14 14-CT1-42 1st Floor, Room 110, ceiling 12” x 12” CT w/ uniform holes and brown mastic

(some floors, stapled to wood grid) L1 Tan ceiling tile None detected Non-ACM Good

15 15-CT4-43 1st floor, Room 101, ceiling

2’x4’ Lay-In Panel (LIP) Off-white w/ deep jagged fissures, small pits, and randomly spaced lg., med., & sm. pinholes

L1 Tan ceiling tile None detected Non-ACM Good

1st Floor, Rooms

101, 102, 104, 108, 110, 111, 111A, 109

~0 SF 15 15-CT4-44 1st floor, Room 102, ceiling

2’x4’ LIP Off-white w/ deep jagged fissures, small pits, and randomly spaced lg., med., & sm.

pinholes

L1 Tan ceiling tile None detected Non-ACM Good

15 15-CT4-45 1st floor, Room 111, ceiling

2’x4’ LIP Off-white w/ deep jagged fissures, small pits, and randomly spaced lg., med., & sm.

pinholes

L1 Tan ceiling tile None detected Non-ACM Good

16 16-CT4-46 1st floor, Room 101, ceiling 2’x4’ LIP White w/ jagged fissures, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

1st Floor, Rooms

101, 102, 104, 110, 111, 111A, 120

~0 SF 16 16-CT4-47 1st floor, Room 102, ceiling 2’x4’ LIP White w/ jagged fissures, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

16 16-CT4-48 1st floor, Room 111, ceiling 2’x4’ LIP White w/ jagged fissures, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

17 17-CT4-49 1st floor, Room 104, ceiling 2’x4’ LIP White w/ snake fissures, small pits, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

1st Floor, Room

~0 SF 17 17-CT4-50 1st floor, Room 104, ceiling

2’x4’ LIP White w/ snake fissures, small pits, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

17 17-CT4-51 1st floor, Room 104, ceiling 2’x4’ LIP White w/ snake fissures, small pits, and randomly spaced lg. & sm. pinholes L1 Tan ceiling tile None detected Non-ACM Good

18 18-PM5-52

Basement, Room 004, E side of door, above

12" x 12" ceiling tiles (stapled) Black vapor barrier tar paper L1 Black tar paper None detected Non-ACM Good

Basement ceiling, 1st floor sub-floor

~0 SF 18 18-PM5-53

Basement, Room 004, E side, above 12" x 12" ceiling tiles (stapled) Black vapor barrier tar paper L1 Black tar paper None detected Non-ACM Good

18 18-PM5-54

Basement, Room 004, above door, above 12" x 12" ceiling tiles (stapled) Black vapor barrier tar paper L1 Black tar paper None detected Non-ACM Good

Responsive ■ Resourceful ■ Reliable B-4

Sample

Number Sample Location Material Description Layer

Lab Results

% Asbestos

NESHAP

Category Condition HA Locations

Estimated

Quantity1

19 19-MG5-55 1st Floor, Room 108, N wall Brown mastic (behind wood wall paneling) L1 Brown mastic 1.4% Chrysotile2 Category II Good

1st Floor, Rooms

108, 109, and 111

~2,158 SF

19 19-MG5-56

1st Floor, Room 111, S wall by door to Room

Brown mastic (behind wood wall paneling) L1 Brown mastic 1.5% Chrysotile2 Category II Good

19 19-MG5-57

1st Floor, Room 111, W wall by door to Room

Brown mastic (behind wood wall paneling) L1 Brown mastic 1.2% Chrysotile2 Category II Good

20 20-HP1-58 Basement, Room 007, N wall, W end by door Gray plaster (over concrete & brick walls) L1 Gray plaster None detected Non-ACM Good Basement, Rooms

001, 002, 003, 005, 005A, 005B, 005C, 006, and 007

~0 SF

20 20-HP1-59 Basement, Room 005, N side column Gray plaster (over concrete & brick walls) L1 Gray plaster None detected Non-ACM Good

20 20-HP1-60 Basement, room 005a, S wall, at E window Gray plaster (over concrete & brick walls) L1 Gray plaster None detected Non-ACM Good

21 21-HP2-61 Basement, elevator lobby s-001, ceiling Gray plaster with white skim coat L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

Basement, Room

S-001; 1st Floor, Rooms 101, 102, 104, 105, 107, 108, 109, 110, 111, 111A; C-101, and

S-101,2nd Floor, Rooms 201, 202, 203, 204, 206, 208, 208A, 209, 209A, 209B, C-201, and

S-201, walls and ceilings (some rooms only partial)

~0 SF

21 21-HP2-62 Basement, Room 001, W side, windowsill wall Gray plaster with white skim coat L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

21 21-HP2-63 1st Floor, Room 102, W wall, N End Gray plaster with white skim coat L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

21 21-HP2-64

1st Floor, Room 111, N wall between Rooms

108 and 110 Gray plaster with white skim coat

L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

21 21-HP2-65

1st Floor, Room 111A, S wall, by top of E window Gray plaster with white skim coat

L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

21 21-HP2-66

2nd Floor, Room 209A, S wall at E side of window Gray plaster with white skim coat

L1 White plaster

L2 Gray plaster

None detected

None detected Non-ACM Good

21…