Attachment 12 - 20-058.5-A_ VAMC, Bldg. 1 Bsmt_ L-HazMat All Rpt.doc.pdf

LIMITED “GOOD-FAITH” REGULATED &

HAZARDOUS MATERIALS SURVEY REPORT

FOR THE

BASEMENT LEVEL INTERIOR AREA OF BUILDING 1

LOCATED ON THE MANN-GRANDSTAFF VETERAN AFFAIRS

MEDICAL CENTER CAMPUS ADDRESSED AT 4815 NORTH

ASSEMBLY STREET IN SPOKANE, WASHINGTON

Project No: 20-058.5-A

Prepared for Mann-Grandstaff VA Medical Center

4815 North Assembly Street Spokane, WA 99205

(509) 354-7179

Prepared By Mountain Consulting Services

9922 East Montgomery Drive, Suite 9 Spokane Valley, WA 99206

(509) 924-9236

September 29, 2020

Mountain Consulting Services

PROJECT NO: 20-058.5-A

L-HAZMAT SURVEY

September 29, 2020 Mountain Consulting Services

TOC

CONTENTS

SURVEYS REPORT SUMMARY ............................................................................Section 1

LIMITED ASBESTOS SURVEY .............................................................................Section 2

LIMITED LEAD COATINGS SURVEY ....................................................................Section 3

OTHER POTENTIAL HAZARDOUS MATERIALS INV. .........................................Section 4

APPENDICES

A: Certifications & Accreditations B: Asbestos Bulk Sampling Analysis Report C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Coating & TCLP Sampling Analysis Reports E: Lead Bulk Sampling Locations Drawing F: Project Photographs

SECTION 1

REPORT SUMMARY

L-HAZMAT SUMMARY

September 29, 2020 S-1 Mountain Consulting Services

LIMITED “GOOD-FAITH” HAZMAT SURVEY; BUILDING 1; BASEMENT AREA

INTERIOR; MANN-GRANDSTAFF VA MEDICAL CENTER; SPOKANE, WA.

REPORT SUMMARY

Mann-Grandstaff Veteran Affairs Medical Center (VAMC) contracted Mountain Consulting Services (Mountain Consulting) to conduct a Limited “Good-Faith” Regulated & Hazardous Materials Survey for the Entire Basement Level Interior of the Building 1 Structure located on the VA Medical Center campus addressed at 4815 North Assembly Street in Spokane, Washington.

This survey project was conducted in good-faith to verify existing regulated and/or hazardous building materials present throughout the basement level interior of the Building 1 structure located on the VAMC property.

The survey services included: a limited good-faith asbestos building materials survey, limited good-faith lead coatings survey and an investigation for the presence of any other readily visible potentially hazardous materials/conditions that may be present with the structure.

The field investigation activities for this survey were conducted on September 8th of 2020 by Todd A. Lewis, AHERA Building Inspector BIR20200820-01; David A. Jones, State Certified Lead Risk Assessor 0567; and, Samuel W. Bailey Jr., AHERA Building Inspector BIR20190927-03, State Certified Lead Risk Assessor 0168 & HAZWOPER Accredited Project Manager.

SURVEY SITE DESCRIPTION

The Building 1 Structure of the Mann-Grandstaff VAMC is the main emphasis hospital structure of the facility that is a multiple-story, large square footage, masonry constructed commercial building.

The building is at the approximate center of the VAMC Campus.

For this Limited HazMat Survey Callout, Mountain Consulting was tasked to survey the entire basement level area interior of the Building 1 Structure of the VAMC Campus to confirm Asbestos Materials & Lead Coatings content or absence; and to investigate HVAC & Electrical Lighting system components for potential hazardous materials. The Building 1 Basement Area interior included for survey is approximately 40,500 square feet (ft²) in size.

Interior finishes of the select survey area consist of various types of concrete, ceramic block, ceramic tile, plaster & sheetrock wallboard systems; various type of suspended fiber ceiling tile systems; and, various types of vinyl tile, carpeting, ceramic & painted concrete flooring systems.

Heating, Ventilation & Air Conditioning (HVAC) present consists of insulated steam supply piping systems, stemming from the central boiler plant that feed multiple air handler units with areas of supply ducting and/or heat radiators.

The Mann-Grandstaff VAMC is located in the eastern light industrial-residential housing portion of the City of Spokane, bounded by an adjacent US Naval facility to the north; North Assembly Street to the East; West Wellesley Avenue to the south and the Joe Albi Stadium facility to the west. The closest main arterial is North Assembly Street.

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LIMITED “GOOD-FAITH” ASBESTOS SURVEY SUMMARY

Mountain Consulting performed destructive bulk materials testing of the suspect building materials present with the Basement Level Interior Area of the VAMC Building 1 Structure of the site to determine the presence or absence of asbestos minerals.

Mountain Consulting collected 83 bulk material samples from 43 different homogeneous suspect building materials (including composite soil samples) identified during survey activities. Laboratory analysts sub-divided 8 submitted bulk samples and did not analyze 5 submitted bulk samples (from multiple sample materials groups proven asbestos containing), resulting in a total of 86 bulk material/composite soil samples analyzed for this project.

REGULATED ASBESTOS CONTAINING MATERIALS

The following homogeneous building materials & exposed soils tested from the Basement Level Interior of the VAMC Building 1 Structure were proven to contain greater than one percent (>1%) asbestos by laboratory analysis (for materials) or were proven to be asbestos fibers contaminated (for exposed soils) by local SRCAA regulatory guidance and are considered to be (Regulated ACM) requiring abatement prior to being impacted by building renovation:

Asbestos Contaminated Soils present exposed throughout the large east-side mechanical room area accessed from Room C005; exposed with the main steam piping entry area vault within Room C005A; exposed throughout the upper files storage Room A004B area; and, exposed behind the laundry shute within Room A005 are proven to be contaminated with chrysotile & amosite asbestos fibers. Asbestos contaminated soil is considered to be class I, friable, Thermal systems insulation (TSI) abatement work. Asbestos soil analysis only provides presence or non-presence results. Combined there is approximately 4,200 square feet (ft²) of exposed soils present in the basement of Building 1. It should be noted that SRCAA regulatory compliance requires that ACM-soils must to be removed under the guidance of a properly prepared Asbestos-Alternate Work Method (AWM). AWMs generally require that 6” of soils must be removed, that calculates to approximately 80 cubic yards of soils present.

Represented by Composite Soil Samples 20-058.5-A- 01, 02, 03, 82 & 83.

TSI “Aircel” Piping Run’s & Mudded Joint Pipe Fitting’s Insulations were visibly identified hidden & running above suspended ceiling systems & feeding wet-walls throughout the Central Hallways System & above Rooms A002, A002A, A003, A005, A007, B001, B002, B004, B006, C002, C002A, C002B, C002C, Men’s Locker-Restroom C003 Area, Women’s Locker-Restroom C004 Area, C005, C005A, C005B, C005C & C007 are proven asbestos containing. The class I, friable, TSI aircel-piping-runs insulation contains 4-12% chrysotile asbestos; and, the class I, friable, TSI mudded-joint-pipe-fittings insulation contains 65-70% chrysotile asbestos. Combined there is approximately 3,000 linear feet of TSI piping runs & approximately 280 individual TSI mudded pipe fittings insulation materials present.

Represented by Bulk Samples 20-058.5-A-30, 31, 36, 37, 70 & 71. There is a moderately-high potential that additional hidden quantities of these materials could exist especially with wet-wall areas.

September 29, 2020 S-3 Mountain Consulting Services

Off White w/Tan Streaks 12 VFT & Black Flooring Mastic Materials exposed or hidden under gray epoxy floor paint throughout the Central Hallways System and in Rooms A005, A006, A006C, B001, B002, B003, B004, B006, B005, Entry Hallway Area of B005A, B005E, B005E, B005F, B007, B009, B009A, B011, B016, B018, C005, C005A, C005C & C005D are asbestos containing. The class II non-friable miscellaneous VFTs are either Non-Detect (but contaminated w/asbestos black mastic) or contain <1-2% chrysotile asbestos; and, the class II, non-friable miscellaneous black mastic’s contain 4-8% chrysotile asbestos or are assumed asbestos containing. Combined there is approximately 10,300 ft² of these materials present.

Represented by Bulk Samples 20-058.5-A-04, 05, 06, 07, 08, 09, 62, 63, 78 & 79.

Dark Brown 9”x 9” VFT & Black Flooring Mastic Materials exposed in Storage Room A001 are asbestos containing. The class II non-friable, miscellaneous VFT contains 6-8% chrysotile asbestos; and, the class II, non-friable, miscellaneous black mastic was too thin to be analyzed (from collected VFT samples) but based upon multiple other black mastic samples analyzed with this project is being assumed asbestos containing. There is approximately 60 ft² of these materials present. Represented by Bulk Samples 20-058.5-A-74 & 75.

MATERIALS PROVEN TO BE ASBESTOS-FREE

Microscopic examination of bulk material samples tested from the Basement Level Interior of the VAMC Building 1 Structure, did not detect the presence of asbestos minerals (ACM-Free):

Gray Epoxy Coating (on ACM-VFT in C005 area) (samples 08 & 09) 4” Gray Vinyl Cove Base (VCB) & White Mastic (C005 area) (samples 10 & 11) White Paper Backed F/G Piping Runs Insulation (throughout Bsmt) (samples 12 & 13) Red (Fire-Stop) Caulking Sealant (throughout Bsmt) (samples 14 & 15) 12”x 12” White Fiber Ceiling Tile (of C005D area) (samples 16 & 17) Brown Mastic Dots (of C005D, 12” ceiling tile) (samples 18 & 19) 2’x 4’ White Fiber Ceiling Tiles (of various types TO Bsmt) (samples 20, 21, 22, 23, 50 & 51) White Brush-Applied Bridging Sealant (on F/G piping ins; TO Bsmt) (samples 24 & 25) Sheetrock Wallboard Paneling Systems (sporadic throughout) (samples 26, 27, 46 & 47) Joint & Taping Compound Muds (of S/R systems TO) (sub-samples 26A, 27A, 46A, 47A, 68A & 69A) Gray Brush Applied Duct Sealant (on air ducting systems TO) (samples 28 & 29) Gray Mortar (of terracotta block type wall finish TO) (samples 32 & 33) Gray Concrete (of interior building area foundation) (samples 34 & 35) White 12”x 12” Vinyl Floor Tile & Yellow Mastic (of D008 hallway) (samples 38 & 39) Clear Blue Carpet Mastic (of Suite D008 area) (samples 40 & 41) 4” Dark Gray VCB & White Mastic (of Suite C008 area) (samples 42 & 43) 2’x 2’ White Fiber Ceiling Tile (of Suite D008 area) (samples 44 & 45) Gray Mortar (of RRs & Kitchen area ceramic floor tiling) (samples 48 & 49) Black Tar & Gold F/G Insulation System (of C002B&C walls) (samples 52 & 53) Gray Plaster Walls Skim coating (installed o/samples 52 & 53 ins.) (samples 54, 55 & 56) Gray Structural Fireproofing Insulation (of Suite C008 area ceilings) (samples 57, 58 & 59) Gray Caulking Sealant (of air-handler-unit frame joints TO) (samples 60 & 61) White 4” Ceramic Wall Tile & Gray Grout (of B016 area) (samples 64 & 65)

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Tan, Beige & Pink Pebble-Pattern Vinyl Sheet Flooring & Yellow Mastic (of B014 area) (samples 66 & 67)

Brown 4” VCB & White Mastic (of B014 area) (samples 68 & 69) Clear Gold Carpet Mastic (of A003 area) (samples 72 & 73) Tan & Beige 12”x 12” VFT & Yellow Mastic (of B014 area) (samples 76 & 77) Black Floor Mastic Dobbs (of elevated floor system mounting post bases in B005G area)

(samples 80 & 81)

Materials that contain greater than one percent (>1%) asbestos or are ASSUMED asbestos containing are considered Regulated ACMs that must be properly removed by a certified asbestos abatement contractor prior to being impacting by building renovation or demolition operations.

Materials proven to be “Asbestos-Free” maybe impacted without any specialized personnel training and disposed of as general construction waste.

The building owner or tenant is responsible, under OSHA regulations, to notify all maintenance and custodial workers of the presence and location of ACM. Asbestos containing materials must be handled and disposed of in accordance with OSHA, NESHAP, and local regulations.

LIMITED “GOOD-FAITH” LEAD COATINGS SURVEY SUMMARY

Mountain Consulting performed destructive bulk testing of suspect coatings (Paint Films & Glazed Ceramic Tile Materials) present with the Basement Level Interior Area of the VAMC Building 1 Structure of the site for total lead content.

Mountain Consulting collected Twenty-One (21) Bulk Coating Samples (16 paint films & 5 glazed ceramic tile materials) for this project. The results of the bulk coating samples collected for this project are listed as follows by component type:

Samples 20-058.5-A-Pb-

1. Green Paint on Interior Cement Walls <80 ppm

2. White Paint on Interior Cement Walls <120 ppm

3. Green Paint on Int. Metal Doors & Door-Frames <180 ppm

4. White Paint on Interior 12”x 12” Fiber Ceiling Tiles <80 ppm

5. White Paint on Interior Sheetrock Walls <80 ppm

6. White Paint on Interior 2’x 4” Fiber Ceiling Tiles <80 ppm

7. Gray Speckled Epoxy Flooring Paint <80 ppm

8. Gray Paint on Interior Cement Walls 330 ppm

9. Green Paint on Interior Sheetrock Walls <80 ppm

10. White Paint on Interior Metal Doors & Door-Frames <80 ppm

11. Red Paint on Interior Concrete Floors <80 ppm

12. Gold Varnish on Interior Wood Doors & Moldings <190 ppm

13. Tan Glazed 6”x 12” Terracotta Wall Block 960 ppm

14. Brown Glazed 1”, 1”x 2” & 2”x 4” Ceramic Floor Tiling <83 ppm

15. Lt. Brown Glazed 6”x 6” Ceramic Floor Tiling <44 ppm

16. White Paint on Interior Plaster Walls 420 ppm

17. Tan Paint on Interior Sheetrock Walls <80 ppm

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18. White Paint on Interior Sheetrock Walls <80 ppm

19. White Glazed 4”x 4” Ceramic Wall Tiling 290 ppm

20. White Glazed 1”, 1”x 2” & 2”x 4” Ceramic Floor Tiling <65 ppm

21. Yellow Paint on Interior Plaster Walls <80 ppm Note: ppm = parts per million

The bold-italicized coatings present with the Basement Level Interior Area of the Building 1 Structure are considered to NOT BE Regulated for Lead Content. The other listed coatings are Regulated Lead-Based Paints (Regulated LBPs). The lead coated building components may pose potential lead exposure hazards. Contractors working on or around this building area of the structure should be informed of the potential lead hazards.

The bulk coating samples collected for this project were submitted following proper chain of custody procedures to EMSL Analytical, Inc. located in Cinnaminson, New Jersey for analysis by method SW846, 3050B/7000B*. EMSL is an ACGIH accredited analytical laboratory.

Any paint coating or material that contains greater than >100 ppm lead from bulk analysis associated with this project are regulated by Federal & State Regulations.

EXPLANATIONS OF LEAD REGULATIONS:

The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62 and Washington State Department of Labor & Industries (L&I) WAC 296-155-176 lead in construction standards do not define a definition for lead based coatings, but do establish safe airborne exposure limits for employees working with lead containing materials, by permissible exposure limit (PEL).

If any material or coating contains lead in excess of >100 ppm then abatement, renovation or demolition contractors must demonstrate worker health and safety due diligence.

This includes “lead in construction” awareness training for all affected employees, establishment of employee personnel protective equipment (PPE), proper demarcation of effected lead work areas and performance of exposure assessment (EA) lead air monitoring prior to any PPE downgrading.

The Washington State Dangerous Waste Regulation (WAC 173-303) requires that renovation waste stream(s) must be assumed to be lead hazardous waste, until testing for leachable lead content by, Toxic Characterization Leeching Procedure (TCLP) bulk waste-stream sampling proves otherwise.

The TCLP lead characterization threshold is 5 ppm.

Since this project is being conducted for good-faith knowledge purposes, Mountain Consulting collected Two (2) composite bulk building materials, Lead-TCLP waste-stream samples for this project to represent an area-wide renovation impacting scheme for the original building age of construction and for the eastern central remodeled area of the surveyed basement.

The results of the Lead-TCLP sample collected for this project is listed as follows:

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Mann-Grandstaff VAMC – Building 1, Basement Level Interior Area (Lead Renovation TCLP Waste-Stream Sample Results)

Sample # Sample Make-Up Results ppm

20-058.5-A-TCLP-1 Lead Renovation Waste-Stream (original age of construction areas)

Non-Detect (ND) (for leachable lead content)

20-058.5-A-TCLP-2 Lead Renovation Waste-Stream (eastern central remodeled building area) ND

The composite Lead TCLP waste-stream samples collected for this project were submitted following proper chain of custody procedures to Eurofins TestAmerica located in Spokane Valley, Washington for analysis by method SW846-1311 (for Lead-TCLP). TestAmerica is an accredited analytical laboratory by the Washington State Department of Ecology (WDOE). A copy of their accreditation certificate is provided in Appendix A.

OTHER HAZARDOUS MATERIALS SUMMARY

Mountain Consulting performed an investigation throughout the Basement Level Interior Area of the VAMC Building 1 Structure of the site to determine the presence of any other potentially hazardous materials or hazardous conditions present with the select structure area.

The investigation targeted the following potential hazardous building components:

• Electrical Lighting (elements/ballasts)

• Polychlorinated Biphenyls (PCB's with transformers/ballasts)

• Ozone Depleting Substances

• Mercury Containing Components

• Fuel / Oil Storage Tanks (Above and Underground)

• Radioactive Materials

• Other Biological Hazards (Mold, Fungi, Bacteria)

LIGHTING OBSERVATIONS

The visual inspection / inventory of suspect potential hazardous material containing electrical lighting components present with the basement level interior of Building 1 are detailed in the following table:

Building or Area Florescent Tubes by Length

“PCB-Free” Oil Containing

Lighting Ballasts

Compact Florescent

Bulbs

Metal Halide Light

Bulbs

Back-up Lighting with

Batteries Building 1 Basement

Interior 824 ea. (4’ tubes) 64ea. (2’ U-tubes) 435 ea. - - 16 ea.

TOTALS 888 each 435 each None None 16 each

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LIGHTING FINDINGS AND RECOMMENDATIONS

• Fluorescent Lighting Tubes were identified throughout the interior of the basement level within the Building 1 Structure of the site within sheet-metal lighting fixtures. All visually inspected fluorescent tube-type light elements present were identified as environmentally friendly (with green end caps or green printed labeling).

The Environmental Protection Agency (EPA) has determined that environmentally friendly elements, may not be disposed of as construction waste in large-quantities as they still contain low amounts of mercury vapor. There are approximately 888 fluorescent light tubes (4’ Long & 2’ U-Shaped Tubes) present within 273 light fixtures within the surveyed building area. The light-tube elements must be collected for reuse, proper recycling or for disposal as hazardous waste, prior to being impacted by any building renovation or demolition activities.

• No-PCBs (Polychlorinated Biphenyls) Labeled Start-up Lighting Ballasts were identified within the fluorescent lighting fixtures present throughout the surveyed basement area within the building. All fluorescent lighting fixtures present have modern start-up ballasts that are either labeled “No-PCBs” or are detailed as electronic ballasts. It should be noted that PCB- Free ballasts can still contain dielectric cooling oils and in large quantities may not be disposed of as construction waste. There are approximately 435 lighting ballasts present with the surveyed building area. The ballasts must be collected for reuse or for proper recycling prior to impacting by building renovation or demolition activities. If disposal is to occur, prior landfill approval should be obtained.

• Dry-Cell-Type Chemical Reaction Batteries were identified within wall & ceiling mounted emergency lighting unit present throughout the basement area within Building 1. There are approximately 16 back-up lighting units present that contain small dry-cell battery packs.

The battery packs must be collected for reuse, proper recycling or for disposal as hazardous waste, prior to impacting by building renovation or demolition activities.

• No Compact Fluorescent light bulbs were identified present with the surveyed area within the structure.

• No High Intensity Type Light Bulbs (Metal Halide or Low Sodium Types) were identified present with the surveyed area within the structure.

OTHER POTENTIALLY HAZARDOUS MATERIAL OBSERVATIONS

• Ozone Depleting Compounds in the form of Air Conditioning Refrigerants are assumed to be present with Five (5) individual Air Conditioning Units installed within Rooms B008A, B012, the East & West Mechanical Rooms Accessed from Room C005 and in Room C005D of the Basement Level Interior of Building 1 of the site. Any contained refrigerant compounds must be reclaimed by a certified HVAC contractor, prior to impacting by building renovation, demolition or unit recycling operations.

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• No Electrical Transformers were identified present with the surveyed area within the structure that could contain PCB (Polychlorinated Biphenyl) cooling oils.

• No Mercury Vial Rocker Switches or Thermometers were identified with any mechanical or electrical systems present with the surveyed area within the building.

• No Above Ground or Underground Fuel Storage Tanks (ASTs/USTs) were identified present with the surveyed area within the building.

• No Radioactive Materials were identified to be present with smoke detectors systems associated with the surveyed area within the building.

• No Hazardous Biological Contamination or indications of fungal, bacteria or biological contamination was observed to be present with surveyed area within the building.

LIMITING CONDITIONS

A complete discussion of survey parameters and applied methods are enclosed in the following sections of this report. Only general conclusions should be made from the information provided within this summary.

During this regulated/hazardous materials assessment, Mountain Consulting endeavored to observe, inventory, and sample (if appropriate) potentially regulated and or hazardous materials associated with the structure included for demolition activities. During renovation or demolition activities for the included structure, if any unidentified suspect materials are encountered that were not observed during this assessment may warrant additional sampling, analysis or assumption.

CLOSURE

The results, conclusions, and recommendations presented in this report were prepared following our inspection of suspected materials at the subject property. Methods used by Mountain Consulting for this study are consistent with the standard of care and professionalism normally exercised by consultants in the environmental science and engineering fields.

The Client acknowledges that Mountain Consulting has been retained for the sole purpose of assisting the Client in identifying Regulated and Hazardous Materials, if any, associated with the subject facility.

It is agreed that Mountain Consulting has assumed responsibility only for performing this assessment and presenting this report and conclusions to the Client. The Client acknowledges that Mountain Consulting is not acting as an “agent” for the Client, or any other user or entity, for work associated with any regulated and/or hazardous materials.

Mountain Consulting does not act or have authority to act for or in place of the Client or its successors or assigns. Mountain Consulting does not represent the Client nor does it authorize or allow any construction, renovation, remodeling, maintenance, repair, or demolition work by performing this assessment.

SECTION 2

LIMITED ASBESTOS

MATERIALS SURVEY

L-ACM SURVEY

ASBESTOS SURVEY – TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 SCOPE OF WORK

3.0 ASSESSMENT SURVEY PARAMETERS

3.1 HOMOGENEOUS AREAS

3.2 BULK SAMPLING

3.3 LABORATORY AND ANALYTICAL METHODS

4.0 RESULTS

4.1 REGULATED ASBESTOS CONTAINING MATERIALS

4.2 MATERIALS ASSUMED TO CONTAIN ASBESTOS

4.3 MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1%

4.4 NON-ACM MATERIALS IDENTIFIED

4.5 MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 CONCLUSIONS

5.2 RECOMMENDATIONS

C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Coating & TCLP Sampling Analysis Reports

September 29, 2020 ACM - Page 1 Mountain Consulting Services

INTERIOR; MANN-GRANDSTAFF VA MEDICAL CENTER; SPOKANE, WA

ASBESTOS MATERIALS SURVEY REPORT

1.0 INTRODUCTION

Mann-Grandstaff Veteran Affairs Medical Center (VAMC) contracted Mountain Consulting Services (Mountain Consulting) to conduct a Limited “Good-Faith” Asbestos Building Materials Survey for the Entire Basement Level Interior Area of the Building 1 Structure located on the VA Medical Center campus addressed at 4815 North Assembly Street in Spokane, Washington.

This survey project was conducted in good-faith to verify existing regulated asbestos containing building materials present throughout the basement level interior of the Building 1 structure located on the VAMC property. The Building 1 Basement Area interior included for survey is approximately 40,500 square feet (ft²) in size.

Mr. Todd A. Lewis, EPA-accredited AHERA Building Inspector, certification BIR20200820-01, expiration 8-20-2021, conducted a field survey of the select building area on September 8th of 2020.

[See Appendix A for inspector and laboratory certifications.]

2.0 SCOPE OF WORK

The scope of work was designed to meet the requirements for asbestos inspection and due diligence notification as defined within the Occupational Safety & Health Administration (OSHA) Asbestos Standard (29 CFR 1926.1101); Washington Industrial Safety & Health Act (WISHA) standard (WAC 296-62-077); National Emission Standards for Hazardous Air Pollutants (NESHAP 40 CFR 61);

applicable portions of the Asbestos Hazardous Emergency Response Act (AHERA 40 CFR 763);

and, the Spokane Regional Clean Air Agency (SRCAA) Regulation I, Article IX.

The survey was conducted through visual evaluation, classification and analysis of suspected asbestos containing materials (ACMs) used in the construction or remodeling of the surveyed basement level interior area of Building 1 located on the Spokane VAMC campus.

The survey included the following tasks:

Visual survey and assessment of the location and condition of suspected materials.

Collection and analysis of bulk samples from suspected asbestos containing materials.

Preparation of a report summarizing the identification and assessment of any asbestos containing materials and material found not to contain asbestos.

September 29, 2020 ACM - Page 2 Mountain Consulting Services

3.0 ASSESSMENT SURVEY PARAMETERS

3.1 HOMOGENEOUS AREAS

Homogeneous materials are those considered to be consistent throughout an area based on color, texture, and construction era. For the purpose of this survey, homogeneous areas were delineated using the construction era, material composition, and material location as the primary considerations.

Material appearance, texture, size, color, and analytical results may support assumptions about each material’s homogeneity.

3.2 BULK SAMPLING

Suspected ACMs were collected according to guidelines in 40 CFR 763.85 and were sampled to determine the type and percentage of asbestos by volume. At least two samples were collected from selected miscellaneous materials; at least three samples from thermal system insulation materials;

and, suspect surfacing materials were sampled according to the AHERA “3/5/7 rule.”

For other types of suspect materials, or materials assumed to be non-ACM, regulations require the on-site AHERA building inspector to determine the appropriate number of samples. The quantity of material present, manufacturer’s labels, appearance, construction or renovation era, and inspector’s expertise were used to determine the number of samples. A homogeneous material is an ACM if one or more sample results are equal to or greater than 1% asbestos.

The EPA recommends that at least three samples be analyzed by polarized-light microscopy (PLM) for the following types of materials to prevent false negative results (less than 1% asbestos):

Materials that contain low concentrations of asbestos fibers (less than 10%);

Materials with asbestos fibers tightly bound in a matrix;

Materials with milled asbestos fibers (fine fibers);

Materials with hand-mixed asbestos fibers; and Materials with a combination of these characteristics.

All bulk samples must have results below 1% asbestos before the material may be classified in accordance with AHERA rules as not being an ACM. However, if asbestos is detected in the material at less than 1%, OSHA / WISHA worker health and safety regulations still apply.

3.3 LABORATORY AND ANALYTICAL METHODS

Mountain Consulting performed destructive bulk materials testing of the suspect building materials present with the Basement Level Interior Area of the VAMC Building 1 Structure of the site to determine the presence or absence of asbestos minerals.

Mountain Consulting collected 83 bulk material samples from 43 different homogeneous suspect building materials (including composite soil samples) identified during survey activities.

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Laboratory analysts sub-divided 8 submitted bulk samples and did not analyze 5 submitted bulk samples (from multiple sample materials groups proven asbestos containing), resulting in a total of 86 bulk material/composite soil samples analyzed for this project.

All samples were submitted for analysis to Mountain Laboratories of Spokane, Washington using chain of custody procedures. Mountain Laboratories participates in the national voluntary laboratory accreditation program (NAVLAP) and is a NAVLAP accredited asbestos testing laboratory, NAVLAP code: 101890-0. All samples were analyzed to determine asbestos type and content using PLM with dispersion staining in accordance with the following methods:

EPA EPA 600/R-93/116, “Method for the Determination of Asbestos in Bulk Building Materials” (July 1993).

EPA “Interim Method for the Determination of Asbestos in Bulk Insulation Samples” (40 CFR Part 763, Subpart F, Appendix A; May 27, 1982).

ASTM Draft “Standard Method of Testing for Asbestos Containing Materials by Polarized Light Microscopy” (ASTM Committee D22.05; January 14, 1988).

4.0 RESULTS

This section describes suspect materials that were found to be asbestos containing (Regulated ACM) or proven to be free of asbestos minerals (ACM-Free). [Refer to the bulk samples analysis report in Appendix B for specific sample composition; and, Appendix C for sampling locations drawing data.]

4.1 REGULATED ASBESTOS CONTAINING MATERIALS

ACMs are materials proven to contain at least 1% asbestos or greater. AHERA and NESHAP regulations distinguish between friable and nonfriable forms of ACM. A friable material is defined as one that can be “crumbled, pulverized, or reduced to powder by hand pressure when dry.”

Friability is an indication of a material’s ability to release asbestos fibers into the air. Regulated ACMs are defined by NESHAP as all friable ACM and non-friable ACM that may be disturbed by renovation or demolition.

PROVEN REGULATED ACM MATERIALS

The following homogeneous building materials & exposed soils tested from the Basement Level Interior of the VAMC Building 1 Structure were proven to contain greater than one percent (>1%) asbestos by laboratory analysis (for materials) or were proven to be asbestos fibers contaminated (for exposed soils) by local SRCAA regulatory guidance and are considered to be (Regulated ACM) requiring abatement prior to being impacted by building renovation:

Asbestos Contaminated Soils present exposed throughout the large east-side mechanical room area accessed from Room C005; exposed with the main steam piping entry area vault within Room C005A; exposed throughout the upper files storage Room A004B area; and, exposed behind the laundry shute within Room A005 are proven to be contaminated with

September 29, 2020 ACM - Page 4 Mountain Consulting Services chrysotile & amosite asbestos fibers. Asbestos contaminated soil is considered to be class I, friable, Thermal systems insulation (TSI) abatement work. Asbestos soil analysis only provides presence or non-presence results. Combined there is approximately 4,200 square feet (ft²) of exposed soils present in the basement of Building 1. It should be noted that SRCAA regulatory compliance requires that ACM-soils must to be removed under the guidance of a properly prepared Asbestos-Alternate Work Method (AWM). AWMs generally require that 6” of soils must be removed, that calculates to approximately 80 cubic yards of soils present.

Represented by Composite Soil Samples 20-058.5-A- 01, 02, 03, 82 & 83.

TSI “Aircel” Piping Run’s & Mudded Joint Pipe Fitting’s Insulations were visibly identified hidden running above suspended ceiling systems & feeding wet-walls throughout the Central Hallways System & above Rooms A002, A002A, A003, A005, A007, B001, B002, B004, B006, C002, C002A, C002B, C002C, Men’s Locker-Restroom C003 Area, Women’s Locker-Restroom C004 Area, C005, C005A, C005B, C005C & C007 are proven asbestos containing. The class I, friable, TSI aircel-piping-runs insulation contains 4-12% chrysotile asbestos; and, the class I, friable, TSI mudded-joint-pipe-fittings insulation contains 65-70% chrysotile asbestos. Combined there is approximately 3,000 linear feet of TSI piping runs & approximately 280 individual TSI mudded pipe fittings insulation materials present.

Represented by Bulk Samples 20-058.5-A-30, 31, 36, 37, 70 & 71. There is a moderately-high potential that additional hidden quantities of these materials could exist especially with wet-wall areas.

Off White w/Tan Streaks 12 VFT & Black Flooring Mastic Materials exposed or hidden under gray epoxy floor paint throughout the Central Hallways System and in Rooms A005, A006, A006C, B001, B002, B003, B004, B006, B005, Entry Hallway Area of B005A, B005E, B005E, B005F, B007, B009, B009A, B011, B016, B018, C005, C005A, C005C & C005D are asbestos containing. The class II non-friable miscellaneous VFTs are either Non-Detect (but contaminated w/asbestos black mastic) or contain <1-2% chrysotile asbestos; and, the class II, non-friable miscellaneous black mastic’s contain 4-8% chrysotile asbestos or are assumed asbestos containing. Combined there is approximately 10,300 ft² of these materials present.

Represented by Bulk Samples 20-058.5-A-04, 05, 06, 07, 08, 09, 62, 63, 78 & 79.

Dark Brown 9”x 9” VFT & Black Flooring Mastic Materials exposed in Storage Room A001 are asbestos containing. The class II non-friable, miscellaneous VFT contains 6-8% chrysotile asbestos; and, the class II, non-friable, miscellaneous black mastic was too thin to be analyzed (from collected VFT samples) but based upon multiple other black mastic samples analyzed with this project is being assumed asbestos containing. There is approximately 60 ft² of these materials present. Represented by Bulk Samples 20-058.5-A-74 & 75.

4.2 MATERIALS ASSUMED TO CONTAIN ASBESTOS

No homogeneous suspect building materials were ASSUMED to contain asbestos (without bulk testing) during this limited good-faith asbestos survey project.

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4.3 MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1%

No sampled building materials was proven to contain less than one percent (<1%) asbestos by laboratory analysis during this limited good-faith asbestos survey project.

4.4 NON-ACM MATERIALS IDENTIFIED

Microscopic examination of bulk material samples tested from the Basement Level Interior of the VAMC Building 1 Structure, did not detect the presence of asbestos minerals (ACM-Free):

Gray Epoxy Coating (on ACM-VFT in C005 area) (samples 08 & 09) 4” Gray Vinyl Cove Base (VCB) & White Mastic (C005 area) (samples 10 & 11) White Paper Backed F/G Piping Runs Insulation (throughout Bsmt) (samples 12 & 13) Red (Fire-Stop) Caulking Sealant (throughout Bsmt) (samples 14 & 15) 12”x 12” White Fiber Ceiling Tile (of C005D area) (samples 16 & 17) Brown Mastic Dots (of C005D, 12” ceiling tile) (samples 18 & 19) 2’x 4’ White Fiber Ceiling Tiles (of various types TO Bsmt) (samples 20, 21, 22, 23, 50 & 51) White Brush-Applied Bridging Sealant (on F/G piping ins; TO Bsmt) (samples 24 & 25) Sheetrock Wallboard Paneling Systems (sporadic throughout) (samples 26, 27, 46 & 47) Joint & Taping Compound Muds (of S/R systems TO) (sub-samples 26A, 27A, 46A, 47A, 68A & 69A) Gray Brush Applied Duct Sealant (on air ducting systems TO) (samples 28 & 29) Gray Mortar (of terracotta block type wall finish TO) (samples 32 & 33) Gray Concrete (of interior building area foundation) (samples 34 & 35) White 12”x 12” Vinyl Floor Tile & Yellow Mastic (of D008 hallway) (samples 38 & 39) Clear Blue Carpet Mastic (of Suite D008 area) (samples 40 & 41) 4” Dark Gray VCB & White Mastic (of Suite C008 area) (samples 42 & 43) 2’x 2’ White Fiber Ceiling Tile (of Suite D008 area) (samples 44 & 45) Gray Mortar (of RRs & Kitchen area ceramic floor tiling) (samples 48 & 49) Black Tar & Gold F/G Insulation System (of C002B&C walls) (samples 52 & 53) Gray Plaster Walls Skim coating (installed o/samples 52 & 53 ins.) (samples 54, 55 & 56) Gray Structural Fireproofing Insulation (of Suite C008 area ceilings) (samples 57, 58 & 59) Gray Caulking Sealant (of air-handler-unit frame joints TO) (samples 60 & 61) White 4” Ceramic Wall Tile & Gray Grout (of B016 area) (samples 64 & 65) Tan, Beige & Pink Pebble-Pattern Vinyl Sheet Flooring & Yellow Mastic (of B014 area)

(samples 66 & 67) Brown 4” VCB & White Mastic (of B014 area) (samples 68 & 69) Clear Gold Carpet Mastic (of A003 area) (samples 72 & 73) Tan & Beige 12”x 12” VFT & Yellow Mastic (of B014 area) (samples 76 & 77) Black Floor Mastic Dobbs (of elevated floor system mounting post bases in B005G area)

(samples 80 & 81)

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4.5 MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS

The following materials were assumed not to contain asbestos, based on manufacturers’ labels, age, appearance, or inspector’s expertise:

Wood components – framing, casement and cabinets.

Glass – exterior and interior.

Metal – structural support, ducting, doors and windows.

Fiberglass Insulation – unfaced w/walls and pipes.

5.0 CONCLUSIONS AND RECOMMENDATIONS

Our findings are based strictly on information obtained from our site observations during survey activities and from sample analysis. Consistent with our knowledge and understanding of environmental regulations, particularly as they apply to the potential liabilities associated with asbestos-containing building materials, we present the following conclusions and recommendations:

5.1 CONCLUSIONS

Mountain Consulting Identified Three (3) Class I, Friable, Thermal Systems Insulation type, Regulated Asbestos Containing Materials (Regulated ACMs) present within the Basement Level area within the VAMC Building 1 Structure, detailed as follows:

1) Approximately 4,200 ft² of Asbestos Fibers Contaminated Ground Soils (present throughout the east side large mechanical room accessed from Room C005; with the steam piping entry vault in Room C005A; with the files storage area in Room A004B; and, behind the Laundry Shute in Room A005 in the basement of Building 1). The presence of asbestos fibers with ground soils is generally attributed to contamination from past asbestos piping insulations removal, but once identified is considered to be regulated ACM material.

Unfortunately, exposed asbestos contaminated ground soils are not considered to be in a safe state (unless enclosed or encapsulated) and access to these areas should be limited to properly trained personnel;

2) Approximately 3,000 lf of Thermal Systems Insulation (TSI) - Preformed Piping Runs Insulation (present exposed hidden above suspended ceiling systems as well as hidden within wet-walls of restrooms, locker & kitchen areas with steam and domestic water supply piping systems located throughout the majority of the basement area interior of the Building 1 structure). This material is considered to be in fair to good intact condition, with minor areas impacted, abraded or missing; and

3) Approximately 280 ea. TSI - Mudded Joint Pipe Fittings Insulation (present exposed hidden above suspended ceiling systems as well as hidden within wet-walls of restrooms, locker & kitchen areas with steam and domestic water supply piping systems located throughout the majority of the basement area interior of the Building 1 structure). This material is considered to be in fair to good intact condition, with minor areas impacted, abraded or missing.

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Mountain Consulting Identified Three (3) Class II, Non-Friable, Miscellaneous type, Regulated Asbestos Containing Materials (Regulated ACMs) present within the Basement Level area within the VAMC Building 1 Structure, detailed as follows:

1-3) Combined Approx. 10,360 ft² of 12”x 12” VFT, 9”x 9” VFT & Black Flooring Mastic Materials (present exposed or hidden under gray epoxy floor paint throughout the Central Hallways System and in Rooms A001, A005, A006, A006C, B001, B002, B003, B004, B006, B005, Entry Hallway Area of B005A, B005E, B005E, B005F, B007, B009, B009A, B011, B016, B018, C005, C005A, C005C & C005D within the basement of Building 1). These regulated ACM materials are considered to be in fair to good conditions with minor areas impacted, abraded or missing.

In accordance with regulatory protocol, all suspect materials identified as, or assumed to be, asbestos containing must be managed as ACM until further sampling documents otherwise. The owner may refute, by additional point-count analysis, the ACM status of materials found to contain less than 10% asbestos. However, for materials such as vinyl tile and adhesive with concentrations between 1% and 10%, reanalysis by point counting typically does not decrease estimated concentrations enough to justify non-ACM classification.

5.2 RECOMMENDATIONS

Regulated Asbestos Containing Materials: Properly trained workers employed by a certified asbestos-abatement contractor may work on, remove, or dispose of the class I (friable) and class II (non-friable) asbestos containing materials using wet methods, appropriate work practices, and proper engineering controls. Workers need either 8 or 32 hours of training (depending on material type) and must be supervised by a competent person with 40 hours of training.

ACM-Free Materials: The materials proven not to contain asbestos (ACM-Free) require no further action in regard to asbestos regulations. These materials may be impacted without any specialized personnel training and disposed of in a landfill that accepts standard construction waste.

If any building materials not identified in this survey are uncovered during renovation or demolition operations, they must be considered to be asbestos containing until sampling and analysis proves otherwise. ACM must be handled in accordance with OSHA, WISHA, NESHAP, and local SRCAA regulations.

The building owner or tenant is required by OSHA / WISHA regulations to notify all maintenance and custodial workers of the presence and location of ACMs. Maintenance and custodial work during which employees will contact but not disturb asbestos shall be performed by workers with at least 2 hours of asbestos awareness training.

The Spokane Regional Clean Air Agency (SRCAA), the local building department, and the local fire department should be contacted regarding possible permit requirements.

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STATEMENT OF PROFESSIONALISM

Mountain Consulting Services hereby certifies that the Limited “Good-Faith” Asbestos Building Materials Survey conducted for the Basement Level Interior Area of the Building 1 Structure located on the VA Medical Center campus addressed at 4815 North Assembly Street in Spokane, Washington was conducted under modified protocols of 40 CFR 763.85. All policies and procedures described in 40 CFR 763 have been followed. All work and statements contained herein are certified true and correct to the best of Mountain Consulting’s ability.

Inspector: ______________________________ Date: September 29, 2020

Todd A. Lewis AHERA Building Inspector Certification: BIR20200820-01 Expiration: August 20, 2021

This report was prepared for the exclusive use by the Mann-Grandstaff Veteran Affairs Medical Center of Spokane, Washington and/or representatives thereof. It may be reproduced only in full and with the written permission of Mountain Consulting. The accuracy of this report is void unless the document remains unaltered and unabridged.

SECTION 3

LIMITED LEAD COATINGS SURVEY

L- LBP SURVEY

LEAD COATINGS SURVEY – TABLE OF CONTENTS

1.0 INTRODUCTION AND SITE DESCRIPTION

2.0 SCOPE OF WORK

2.1 Homogeneous Coatings

2.2 Bulk Sampling

2.3 TCLP Bulk Sampling

3.0 RESULTS

3.1 Lead Bulk Sampling Results

3.2 TCLP Bulk Sampling Results

4.0 RECOMMENDATIONS

5.0 HEALTH EFFECTS OF LEAD EXPOSURE

C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Coating & TCLP Sampling Analysis Reports

L-LBP SURVEY

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INTERIOR; MANN-GRANDSTAFF VA MEDICAL CENTER; SPOKANE, WA

LEAD COATINGS SURVEY REPORT

1.0 INTRODUCTION

Mann-Grandstaff Veteran Affairs Medical Center (VAMC) contracted Mountain Consulting Services (Mountain Consulting) to conduct a Limited “Good-Faith” Lead Coatings Survey for the Entire Basement Level Interior Area of the Building 1 Structure located on the VA Medical Center campus addressed at 4815 North Assembly Street in Spokane, Washington.

This survey project was conducted in good-faith to verify existing regulated lead containing paint film & glazed ceramic tile material coatings present throughout the basement level interior of the Building 1 structure located on the VAMC property. The Building 1 Basement Area interior included for survey is approximately 40,500 square feet (ft²) in size.

Mr. David A. Jones, Washington State Lead Risk Assessor; Certification 0567; Expiration February 16, 2022, conducted the field survey for this project on September 8th of 2020. [See Appendix A for inspector certifications and laboratory accreditations.]

2.0 SCOPE OF WORK

The tested coatings/materials were sampled in accordance with the requirements for lead based paint testing and due diligence notification as per Chapter 296-62, Washington Administrative Code (WAC), General Occupational Health Standards; Chapter 296-62-0721, Part I, WAC, Lead; Chapter 296-155, Safety Standard for Construction Work; 29 CFR 1926.62 OSHA Lead in Construction Work; and 29 CFR 1910.1025 OSHA Lead General Industry Standards.

The sampling included visual evaluation, classification and analysis of suspected lead coatings (Paint Films & Glazed Ceramic Tile Materials) present throughout the basement level interior of the VAMC Building 1 structure included for survey.

The sampling included the following tasks:

Visual survey and assessment of the location and condition of suspected coating(s).

Collection and analysis of bulk sample(s) from suspected coating(s).

Preparation of a report summarizing the identification and assessment of any LBP coatings.

2.1 HOMOGENEOUS COATINGS

Homogeneous coatings are those considered to be consistent throughout an area based on color, texture, and construction era. For the purpose of this survey, homogeneous coatings were delineated using the construction era, coating color, and coating location as the primary considerations.

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Coating appearance, texture, and analytical results may support assumptions about each coating(s) homogeneity.

2.2 BULK SAMPLING

Destructive bulk coatings sampling was conducted by Mountain Consulting for this project.

Mountain Consulting collected Twenty-One (21) Bulk Coating Samples (16 paint films & 5 glazed ceramic tile-block components) for this project. The bulk samples consisted of all the paint or glazed material that could be scrapped or removed from an area of approximately 2 to 4 square inches (in²) for each targeted suspect coating.

The samples were submitted following proper chain-of-custody procedures to EMSL Analytical in Cinnaminson, New Jersey, for analysis by methods SW846 3050B/7000B*. EMSL Analytical, Inc.

(phone 1-800-220-3675) is accredited by the American Industrial Hygiene Association. Their accreditation certificate is provided in Appendix A.

2.3 TCLP BULK SAMPLING

The Washington State Dangerous Waste Regulation (WAC 173-303) requires that renovation & demolition waste-streams must be treated as lead hazardous waste, until toxic characterization leeching procedure (TCLP) bulk waste-stream sampling proves otherwise. The Lead-TCLP characterization leachable threshold limit is 5 ppm.

Since this project is being conducted for good-faith knowledge purposes, Mountain Consulting collected Two (2) composite bulk building materials, Lead-TCLP waste-stream samples for this project to represent an area-wide renovation impacting scheme for the original building age of construction and for the eastern central remodeled area of the surveyed basement.

A representative TCLP sample consists of the collection of various components of a waste-stream generated by a renovation, demolition or abatement project in the same weight proportion as is found in the entire bulk of the waste. As such, a representative sample should contain a sample of all major items found in the proposed waste stream, in an approximate weight proportion.

The sampler must…