36C26118R0214-0003002.pdf

VOLUME 1

INSPECTION & ASSESSMENT REPORT

ASBESTOS CONTAINING MATERIALS

and

LEAD BASED PAINTS

Facility:

BLDGS. 1, 1A, 1D, 7, 8, 15, 138, E, F, J

IOANNIS A. LOUGARIS V.A. MEDICAL CENTER

RENO, NEVADA

Prepared For:

V.A. SIERRA NEVADA HEALTH CARE SYSTEM

975 KIRMAN AVENUE

RENO, NV 89502-2597

ATTN: DAVID LUSCAVAGE, CIH, CSP

FACILITY INDUTRIAL HYGIENIST

Conducted and Prepared by:

Safety Environmental Laboratories and Consulting, Inc.

989 Yeager Parkway

P.O. Box 1848 Pelham, AL 35124

SELC Project # 2012-0853

Report Issued: April 23, 2014

Inspected/Reported By: Inspected/Reported By:

Elizabeth Hyde N. Glenn Ray, REM, REPA Project Manager Technical Director Lead Paint Inspector NV Asbestos Inspector # I-1639

Asbestos & LBP Inspection/Assessment Report April 23, 2014

IOANNIS A. LOUGARIS MEDICAL CENTER

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 PURPOSE

1.2 SCOPE OF SERVICES

1.3 SUMMARY OF FINDINGS

2.0 BACKGROUND INFORMATION

3.0 PROJECT AREA DESCRIPTION

4.0 INSPECTION METHODOLOGY

5.0 TESTING METHODOLOGY

6.0 SUSPECT MATERIALS

7.0 ASBESTOS INSPECTION & SAMPLING RESULTS

8.0 LEAD BASED PAINT TESTING & RESULTS

9.0 CONCLUSIONS & RECOMMENDATIONS

10.0 ASSUMPTIONS & LIMITATIONS

APPENDICES:

Appendix A SELC Inspector License & Laboratory Accreditation Appendix B Supplemental Testing for Asbestos by SELC – Bldgs. 1, 1D, 7, 8, 10 Asbestos Inspection Records by SELC – Bldgs. 15, 138, E, F, J Appendix C Lead Paint Testing Data by SELC – Organized by Bldgs.

Appendix D Lead Paint Testing Data by SELC – Printed by Chronological Order of Test Appendix E Select Representative Photographs of ACM & LBP

VOLUMES:

Volume 1 All items listed above.

Volume 2 Separate Database Reports for ACM & LBP Volume 3 Previous Major ACM Inspections Volume 4 Previous Limited / Project Specific Asbestos Testing 2009 - 2013 Volume 5 Separate Drawings for ACM & LBP Locations

SELC Project No.: 2012-0853 Page 1

1.0 INTRODUCTION

This report was prepared by Safety Environmental Laboratories & Consulting, Inc. (SELC) for the VA Sierra Nevada Health Care System to describe the procedures and findings of the Asbestos Containing Material (ACM) and Lead Based Paint (LBP) inspection services performed by SELC between August 2012 and January 2014. Those services addressed the following structures at the Ioannis A. Lougaris Medical Center: Buildings 1, 1A, 1D, 7, 8, 10, 15, 138, E, F, & J.

Results of the ACM & LBP inspections and records relied upon during those services are compiled into five volumes as follows:

Volume 1: This document contains a narrative summary of all the task that were performed by SELC; and describes the goals, methodologies, findings, recommendations, etc. It also contains new data generated during this contract – laboratory reports, summary tables, general photos, etc.

Volume 2: Contains hard copy prints of the ACM and LBP databases as developed using Access software.

Volume 3: Contains a hard copy of the three major historical (1992, 2002, 2010) ACM inspections/assessments provided by the VA and used, in part, by SELC to develop the current inspection report and databases.

Volume 4: Contains hard copies of the limited / project specific testing events that have occurred at the VAMC dating back to late 2009 / early 2010. These are records used, in part, by SELC to develop the current inspection report and databases.

Volume 5: Contains hard copies of the ACM and LBP location drawings.

1.1 PURPOSE

The primary purpose of this inspection project was to update the VAMC’s records related to ACM & LBP at Buildings 1, 1A, 1D, 7, 8, 10, 15, 138, E, F & J; and to compile current separate ACM & LBP databases and drawings for those buildings. Previous ACM inspections did not exist for Buildings 15, 138, E, F & J, so complete new inspections were required for those buildings. Previous LBP inspections did not exist for any of the buildings, so LBP testing was performed at each of those buildings.

1.2 SCOPE OF SERVICES

A basic summary of the services provided by SELC is presented below:

a) Review available records of ACM surveys, specific/limited material testing, abatement activities, and renovation projects. Rely upon those records to the extent reasonably feasible.

b) Conduct interviews of VAMC personnel familiar with previous ACM related activities, building maintenance operations, and renovation projects.

c) Conduct visual inspections of Buildings 1, 1A, 1D, 7, 8 & 10 to evaluate accuracy of the existing ACM records and assess the conditions of remaining ACM. Collect additional samples as needed to make appropriate determinations.

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d) Perform a thorough inspection of the interior and exterior of Buildings 15, 138, E, F & J for the purpose of identifying homogeneous building materials suspected to potentially contain asbestos.

e) Collect representative samples of each newly identified suspect homogenous building material and analyze all samples for asbestos content utilizing Polarized Light Microscopy and Dispersion Staining Techniques performed in accordance with EPA Bulk Analysis Method EPA/600/R-93/116 July 1993.

f) Visually inspect Buildings 1, 1A, 1D, 7, 8, 10, 15, 138, E, F & J for the purpose of identifying homogeneous building components with surfaces painted prior to 1978 – i.e. surfaces with paints potentially containing lead equal to or greater than 0.5% or

1.0 mg/cm².

g) Conduct random paint testing in each building using a portable XRF analyzer to establish a representative range of lead content on each major common building component.

h) Assess the condition identified ACM & LBP, and collect photographic documentation of general building conditions and specific ACM & LBP conditions. Present those photographs to the extent that they are needed to convey important information.

i) Prepare a main summary report, master databases, material location drawings, and compile all supporting data as outlined above in section 1.0 Introduction.

1.3 SUMMARY OF FINDINGS

A synopsis of the ACM and LBP identified by this inspection is presented below in tabular format. Reference sections 7.0 & 8.0 for detailed listings of ACM & LBP respectively.

ACM & LBP – BUILDING SUMMARY

BUILDING CONFIRMED

ACM (YES/NO)

SUSPECT /

PRESUMED

ACM (YES/NO)

CONFIRMED

LBP (YES/NO)

NOTES

BLDG. 1 YES YES YES

See section 6.1 for suspect / presumed conditions. Most readily accessible ACM has been removed.

ACM is known to be concealed inside chases and behind walls.

BLDG. 1A NO NO YES

Several bldg. components were determined to be coated with LBP in August 2012. However, most of the LBP has been removed but some is assumed to remain.

BLDG. 1D YES YES YES

See section 6.1 for suspect/presumed conditions. Also inconsistent results were obtained on mech room pipe insulation mastic testing.

BLDG. 7 YES NO YES

BLDG. 8 NO NO YES

BLDG. 10 YES YES YES

See section 6.1 for suspect/presumed conditions. Also inconsistent results were obtained on basement floor tile mastic testing.

BLDG. 15 NO NO NO

BLDG. 138 NO NO NO

BLDG. E NO NO NO

BLDG. F NO NO NO

BLDG. J NO NO NO

SELC Project No.: 2012-0853 Page 3

2.0 BACKGROUND INFORMATION ON PREVIOUS INSPECTIONS & DATA

One key task of this project was for SELC to compile and review records of previous ACM and LBP related activities associated with the subject buildings. Several sources of information related to ACM were relied upon during this project, but no significant records of previous LBP testing were identified. The primary reports/documents of record for major ACM inspections/surveys are as follows:

Final Report Date

Timeframe of Survey

Bldgs.

Included

Report Title & Firm Notes

Aug 1992 June 1992 1, 1A, 3, 5, A, B, C, T1, T2, T3

Facility Asbestos Survey Report by National Asbestos Consultants, Inc. – Oklahoma City, OK

Bldgs. 3, A, B, C, T1, T2, T3 are no longer on the VA site.

Several types of ACM identified at bldgs. 1 & 1A

June unknown unknown Asbestos Management Plan by Wise Consulting & Training – Reno, NV bldgs. addressed – unknown

This document was referenced in the 2010 management plan by Converse Consultants, but it was not furnished to SELC for review.

Jan 2002, Revised Feb 01, Oct 2001 – Dec 2001

1, 1A, 1D, 5, 7, 8, 10

Asbestos Re-Inspection and Assessment by Chung & Assocs, Inc. – Sacramento, CA and IHI Environmental – Sandy, Utah

ACM identified in all buildings except #5

Bldg. 5 in this survey appears to be Blockhouse #5 as indicated on site plan prepared by SELC

May 14, April 2009 – April 2010

1, 1A, 1D, 5, 7, 8, 10

Asbestos Management Plan by Converse Consultants – Reno, NV

This document addresses the same ACM as indicated by Chung/IHI in the 2002 report. It also list additional suspect materials as Assumed ACM (see additional discussion of those materials in section 6.1 of this report.

In addition to the documents listed above, SELC was furnished: various small/limited asbestos inspection reports for isolated areas; various reports/letters of suspect asbestos material analysis; and various reports/letters of abatement clearance inspections & air monitoring; and various reports/letters of area/ambient air monitoring for airborne fibers (PCM) and asbestos (TEM). The reports of limited inspections and suspect material analysis, spanning approximately Sept 02, 2009 – December 16, 2013, were helpful towards validating the results of the previous large surveys by retesting some the primary suspect building materials and by testing some other materials that may not have been addressed by the previous surveys. However, the air sampling and abatement clearance reports, spanning approximately June 30, 2006 – December 17, 2013, were not as useful because many of the reports indicated project name, date, and general area; but did not specifically state exactly what was removed and exactly where it was removed. As such most of the air monitoring and clearance records are not copied and transmitted with this report by SELC.

3.0 PROJECT AREA DESCRIPTION

The subject property includes several buildings split across two parcels lying east and west of Kirman Avenue on the north side of Burns Street. The primary healthcare buildings are located

SELC Project No.: 2012-0853 Page 4 on the west side of Kirman and they consist of Bldgs: 1, 1A, 1D, 4 (ER), 5 (Mental Health), 10, MRI, 12, Warehouse, Blockhouse 5, Blockhouse 10, Generator Bldg, and various Connectors.

Support structures located on the east side of Kirman consist of Bldgs: 7, 8, 15, 138, E, F, J, and a parking deck. Those buildings addressed by this asbestos and lead based paint survey are listed in the introduction part of this report as identified in the contract Statement of Work.

Buildings not addressed by this survey are indicated accordingly on the site plan included in Volume 5.

4.0 INSPECTION METHODOLOGY

4.1 ASBESTOS

Four of the most basic tasks of this project with regard to identification of ACM were: 1) organize and review records with respect to previously identified ACM, 2) interview VAMC personnel with knowledge of previously identified ACM locations and activities impacting those materials, 3) conduct additional inspections as needed to validate the recorded data, and 4) perform additional ACM surveys and sampling of suspect materials in buildings/areas that had not previously been surveyed or where additional data was needed.

As indicated in Section 2.0 of this report, ACM surveys have previously been performed at Buildings 1, 1A, !D, 7, 8, & 10; and therefore at those buildings the initial task was to carefully review existing records related to ACM testing and abatement activities. Also the VA has records of various limited suspect asbestos material testing that was generally performed in small areas for a specific work item or small renovation project. SELC reviewed and utilized those records spanning a period of September 2009 – December 2013.

This ACM inspection/survey and assessment was conducted through a series of three sites during the weeks of August 06-10, 2012, February 04-08, 2013, and January 13-17, 2014, by N.

Glenn Ray, a Nevada licensed asbestos inspector (# I-1639). See Appendix A for a copy of the inspector’s license. SELC’s investigations and material sampling were non-destructive and were conducted in a manner designed to provide general ACM information for database purposes.

Given that this report relied in part upon non-destructive sampling, and in part upon previous inspection records, and no specific renovation or demolition project scopes were investigated, these documents should not necessarily be considered compliant with NESHAP requirements for all future construction work going forward. However, the investigations of Buildings 15, 138, E, F & J should be considered comprehensive and NESHAP compliant because those surveys are recent and consist entirely of data generated by SELC through one inspector, and they covered all interior and exterior parts of those buildings which were constructed of relatively simple methods that do not need destructive sampling in order to view all of the building materials. Conversely, all of the report records comprised herein do appear to collectively represent investigations that would generally meet the requirements of the OSHA asbestos standards.

Following the review of VAMC records and interviews of VAMC staff, SELC‘s next step in the overall survey/inspection process was to visually inspect and evaluate the buildings for components/systems that may consist of materials suspected to potentially contain asbestos.

After those suspect materials were identified, sample collection locations were randomly selected. Then bulk samples were obtained and placed into individual containers for transportation to the laboratory. Each sample was assigned a unique number and each sample

SELC Project No.: 2012-0853 Page 5 description was recorded on an analysis request form that included a chain-of-custody signature block. Those numbers directly correspond with the numbers listed on the laboratory reports included in Appendix B of this Volume 1. Suspect asbestos material sample collection locations were recorded on building floor plans as indicated in Appendix B.

Each time suspect ACM was sampled; it was classified as either a friable or a non-friable material. Friable materials, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Friable ACM is potentially more hazardous than non-friable ACM because friable material can release airborne asbestos fibers more easily.

4.2 LEAD PAINT

The lead paint survey was generally conducted following guidelines published by HUD for “Target Housing” and “Child Occupied Facilities” (constructed prior to 1978). However, given that those guidelines do not apply to buildings dedicated to medical treatment of adults, SELC modified the process to meet the needs of the subject facility. This inspection addressed readily accessible coatings on major interior and exterior building materials that were installed prior to 1978 and are readily accessible to the public and most likely to be impacted by future renovations. Testing did not include every surface in every room. However, the testing did include all common pre-1978 painted components. As such, in areas where specific testing results were not obtained the results of other portions of the same building should be extrapolated.

A certified lead paint inspector/risk assessor from SELC used a Niton XLp-700-303 X-Ray Fluorescence (XRF) Analyzer, Serial # 21385, to measure the lead content of surface coatings on representative homogenous building components. A homogeneous component is a building material that is uniform in function, composition, texture, age, and generally appears consistent at various locations at the building. Although paint colors are recorded in the XRF data base, color is not a factor used to determine homogenous components; because colors can be changed by new coats of paint, while the underlying LBP remains in place thereby causing potential future problems with locating identified LBP.

5.0 TESTING METHODOLOGY

5.1 ASBESTOS

All bulk samples were analyzed at SELC by polarized light microscopy (PLM) utilizing dispersion staining techniques in accordance with EPA method EPA/600/R-93/116 July 1993. This type of analysis requires the analyst to take a portion of the bulk sample and treat it with an oil of specific refractive index. The prepared slide is then subjected to a variety of optical tests.

Percentages of the identified types of asbestos are determined by visual estimation. Even though this is a process of estimation, any material that contains greater than one percent of any type of fibrous asbestos is considered ACM and must be handled in accordance with applicable provisions of EPA, OSHA and state regulations if likely to be disturbed during maintenance, repair, renovation, or demolition operations.

SELC operates a laboratory, located at 989 Yeager Pkwy in Pelham, Alabama, that participates in the U.S. EPA approved National Voluntary Laboratory Accreditation Program (NVLAP) for asbestos identification by polarized light microscopy. SELC is rated proficient under NVLAP’s quality assurance program and our accreditation number is 200873-0. Please see appropriate

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Certificates in Appendix A.

5.2 LEAD PAINT

Paint testing was conducted using a portable x-ray fluorescence (XRF) instrument to measure the lead content of surface coatings on representative homogenous building components. SELC used a Niton XLp-700-303 XRF, Serial # 21385, in accordance with the manufactures recommendations.

6.0 SUSPECT MATERIALS

This section of the report provides information in general terms about the basic types of materials that were considered suspect (i.e. potential asbestos containing material and potential lead containing paint) and in some cases why certain types of materials were not considered suspect.

6.1 MATERIALS SUSPECTED TO CONTAIN ASBESTOS

Building materials suspected to potentially contain asbestos are those general types that have been included on lists published by the EPA as having at some point in history been manufactured with asbestos content by some companies. Also suspect materials include specific types of products known by the inspector through past experience to sometimes contain asbestos. It is important to note that a certified inspector does not have to sample and obtain analysis on every type of building material. The inspector can declare materials “non-suspect” that are visibly made of components historically known to be free of asbestos. Obvious materials that typically are not considered suspect include: wood, metal, concrete, standard clay brick, standard masonry blocks, standard masonry mortar, plastic, styrofoam, rubber, fiberglass, ceramic, foam rubber, cellular foam, processed wood/cellulose products, mineral wool, and pure vinyl products. Where some of those materials are mixed with other materials to produce a composition, then the end product may be suspect, e.g. vinyl composition floor tiles. Also where one type of suspect material is applied to another non-suspect material, then at least the suspect portion must be sampled or assumed/presumed to contain asbestos, e.g. mastic applied to fiberglass insulation.

This section does not attempt to list all suspect materials that were addressed during this inspection; for listings of the specific suspect materials that were sampled in a given building during this inspection refer to the respective Homogeneous Material Summary Tables presented in Appendix B of this report. This section also does not attempt to list all suspect materials that have been addressed by all previous inspections/surveys performed by other firms. Most of that information is presented in the respective reports contained in Volume 3 of this document; and much of it is no longer relevant because of extensive renovations and abatement. Rather, the materials listed below are those that were not adequately addressed by the previous major surveys or otherwise warranted special attention during this inspection.

One of the first/primary tasks for SELC was to address the issue of presumed/assumed ACMs listed by Converse in the most recent reinspection report (dated May 14, 2010), and to review spot/limited testing records to check for other ACM possibly identified since issuance of the 2010 reinspection report. As such the next portion of this report deals with those materials and any other noteworthy special conditions.

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Building 1 – Suspect ACM

Extensive renovation activity has occurred throughout this building over the past few years, including a major building wide HVAC upgrade project. According to information provided by the VA, those projects attempted to remove as much ACM as possible, but small amounts were left in various places. Based upon our review of relevant records it appears that the previous large scale surveys and re-inspections (as presented in Volume 3) dated 1992, 2002, & 2010 were primarily relied upon (at least initially) for identification of ACM to be removed during those jobs.

However, additional location specific information was obtained through small scale / limited ACM inspections during the projects as indicated by the Bldg. 1 records (2010 – 2013) presented in Volume 4.

During the last asbestos re-inspection, conducted in 2009/2010 by Converse Consultants, the following materials at Bldg. 1 were listed as suspect and “Assumed ACM” apparently due to lack of sufficient testing theretofore. However, supplemental testing records appear to indicate that most of them do not contain asbestos. See the limited area testing records (2010 – 2013) presented in Volume 4, and supplemental testing (2008 – 2010) presented in the Bldg 1 Section

- Appendix D, of the Converse report in Volume 3. Given that there is some degree of uncertainty concerning those materials and others, the following table is presented to discuss the issues.

Special Suspect Materials Building 1

Suspect Material

Description

Reported Locations

Notes Recommended Action

Drywall Joint Compound

Various This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report / Management Plan.

That report includes three samples of drywall and joint compound taken from the Compensation & Pension section of the 5th floor that were analyzed and none were found to contain asbestos. See report dated 01/07/10 in Appx. D of the Bldg. 1 section in the Converse report in Volume 3. No drywall testing was discovered in the limited reports presented in Volume 4. Based upon our inspection it appears that original construction of walls was predominately concrete, plaster, and hard tiles. Original ceilings appear to have been mostly plaster with some areas having sprayed acoustical/insulation material or glued acoustical tiles. Any existing drywall would likely represent added materials associated with relatively recent renovation projects or added wings/connectors, etc. As such, where drywalls are encountered they should not be considered homogenous with the 5th floor spot testing referenced above.

If drywall materials are discovered in areas of repair, renovation, or demolition work, they should be tested for asbestos.

If joint compounds or skim coats are found to contain asbestos treat the drywall as ACM in accordance with 29

CFR 1926.1101.

Wall Texture Various This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report / Management Plan.

No description or specific location of this material is provided.

There is no reference to wall texture in the pre-2010 reports and given the extensive amount of renovation in recent years it is unlikely that any old wall texture is still present. As such the only wall texture material, if any, is likely to be recently installed “knock-down” / “orange peel” drywall skim coat, which is unlikely to contain asbestos but should be tested prior to disturbance.

Same as above.

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Suspect Material

Description

Reported Locations

Notes Recommended Action

Cove Base & Mastic

Various This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. That report includes three samples of cove base mastic taken from the Compensation & Pension section of the 5th floor that were analyzed and none were found to contain asbestos. See report dated 01/07/10 in Appx. D of the Bldg. 1 section in the Converse report in Volume 3. SELC is not aware of any vinyl and rubber cove wall base products that contain asbestos, but the associated adhesives sometimes are ACM. Many years ago asphalt based wall bases did contain asbestos, but those products rarely still exist in buildings largely due to the fact that wall bases are changed each time floor finishes are changed.

Given that wall bases are typically changed each time flooring is replaced, and flooring is frequently replaced, often in small areas, wall base adhesives are often multi-layered and inconsistent throughout bldgs.

As such they should be tested prior to disturbance.

1’x1’ Ceiling Tile Mastic

Old Ground Floor Area 1-5 and Various Other Locations

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. One sample of a ceiling tile adhesive material from Bldg 1-C Room 440 was analyzed by Converse on 03/09/08 and reported to contain less than 1% asbestos. SELC collected one sample of a hard brown mastic used to adhere 1 foot square ceiling tiles to a wooden lattice located in the former 4th floor corridor just south of center of bldg. That ceiling system was located above a standard 2’ x 4’ lay in “T” grid system and below a plaster ceiling with sprayed ACM insulation/fireproofing. Two percent asbestos was detected by SELC in that sample of ceiling tile adhesive. Because of Converse’s previously reported result of less than 1% for the adhesive, SELC elected to analyze the sample by point counting and found that it contains less than 1% asbestos. As such the ceiling tile adhesive is not listed as ACM in this report. Furthermore, at the time this material was sampled, the area was being prepped for renovation to include removal of the ceiling as part of the ACM fireproofing abatement. Also it is our understanding that all other areas with this material had already been abated or would soon be abated in conjunction with the renovation work.

It is our understanding that this older ceiling system has been fully removed throughout Bldg 1, but if similar ceiling tile adhesive materials are encountered test them for asbestos content.

Ceramic Tile, Grout, Mortar, & Shower Pan Felt

Various The ceramic tile, grout, and mortar materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re- Inspection Report. Subsequent testing of those materials by Converse did not detect asbestos, but asbestos was found in some shower pan felts (see Volume 4). On 04/01/11 two samples of layered ceramic floor systems were collected by Converse; one sample at each of two showers in adjacent restrooms (former rooms 218A & 223B on former 2nd floor).

The bottom layer of felt in one of the samples was found to contain asbestos. Again on 05/04/11 that process was repeated in two more showers (former rooms 225B & 226B on former 2nd floor). Asbestos was detected in the bottom felt layer of both samples. Again on 05/03/2012 Converse collected ceramic tile system samples, this time from the 3rd floor, and none of the components were found to contain fibrous asbestos. It is possible / likely that this ACM felt is present below ceramic floor tile in other old showers in Bldg. 1.

SELC randomly collected one sample of ceramic tile, grout, and thin set from the basement below kitchen and no asbestos was detected (see Appx. B herein). It has been our experience

Sample old ceramic grouts, setting compounds, adhesives, and particularly asphaltic felts below old ceramic flooring in old shower locations prior to disturbance.

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Suspect Material

Description

Reported Locations

Notes Recommended Action that ceramic tiles/grouts/setting compounds do not normally contain fibrous asbestos, but occasionally non-fibrous / non-regulated tremolite is encountered.

Exterior Stucco

East Exterior Stairwells

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. On 12/15/10 three samples of exterior soffit plaster were analyzed by Converse and found to be free of asbestos (see Vol. 4). Also SELC collected and analyzed two samples of plaster/stucco on vertical exterior walls and no asbestos was detected. See sample nos. 1-1 & 1-2, report date 03/28/13, Vol. 1, Appx. B.

The soffit material and the vertical wall material may not be homogeneous.

If any additional exterior stucco is encountered sample and analyze the material prior to disturbance.

Structural Fireproofing

Various This material was listed as Assumed ACM in the May 2010 Asbestos Re-Inspection Report. However, subsequent testing of those materials has not detected asbestos. On 02/02/10 fireproofing in former rooms 390, 396 & 398 on former 3rd floor were found to be free of asbestos (see sample nos. FP-04, FP-05 & FP-06 in Appx. D of the Bldg. 1 section in the Converse report presented herewith in Volume 3). On 12/15/10 three samples of structural fireproofing were analyzed by Converse and found to be free of asbestos (see Vol. 4). Also a fireproofing sample from the Morgue on 07/21/11 was found to be free of asbestos (see Volume 4).

Apparently these structural fireproofing materials that are present at scattered locations are not homogeneous and are not representative of the original construction.

If any additional structural fireproofing is encountered sample and analyze the material prior to disturbance.

Roofing Various A series of Bldg. 1 roofing material samples were collected and analyzed in the Spring of 2008. The reports are dated 03/05, 03/14, 03/19, and 05/20. The roof was split into nine sections and none of the samples representing the main roofing membranes were found to contain asbestos. However, two of the samples representing coatings/cements /mastics used to seal around penetrations were found to contain asbestos. One of those samples was later point counted and reported to contain less than 1% asbestos. Much of the material tested was described as black felt, but the current roof appears to be a white rubber roof. Based upon the appearance of the current roofing and given that Converse did not list roofing as Assumed ACM in the May 2010 report, the ACM must not be present anymore.

None

Insulation / Fireproofing in Electrical Junction Boxes

Various In February and march 2012 a series of samples were collected from electrical junction boxes and insulation / fireproofing was reported to contain asbestos. According to the VAMC, that ACM was overspray associated with the sprayed ceiling ACM previously abated, but these boxes had been left in place during the abatement, and have subsequently been removed.

None

Stainless Steel Sink Undercoating

Various None of the previous reports mention coatings applied to underside of stainless steel sinks at Bldg. 1, although the 2002 Chung/IHI report does list them as suspect materials that were tested at Bldgs. 1D and 10. Given the common usage of stainless sinks it seems likely there are several in Bldg. 1.

However, the extensive renovations over the recent history have most likely replaced most of them with non-acm types.

SELC tested one older sink in the kitchen basement and found

When sinks are likely to be impacted by future renovation test the undercoatings prior to disturbance.

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Suspect Material

Description

Reported Locations

Notes Recommended Action that the coating does not contain asbestos (see Appx. B of this Volume 1).

End of Table

Numerous air monitoring / abatement clearance records dated from September 2008 – December 2013 indicate extensive ACM removal in areas throughout Building 1. Those records, combined with verbal information provided by VAMC personnel familiar with renovation and maintenance activities at Building 1, along with a review of “as built” drawing notes related to ACM, leads SELC to conclude that the overwhelming majority of all previously identified ACM have been removed from Building 1. Furthermore, given the VAMC’s active policies regarding proper identification and handling of ACM coupled with the long term renovation projects at Building 1 over the past several years, it is unlikely that any ACM associated with the common types of building materials have gone undiscovered. If there is any remaining ACM, beyond that identified in these documents, it likely exist only in small quantities, with two notable exceptions.

There is likely to be considerable amounts of ACM pipe insulation located inside wall cavities / chases, particularly along the perimeter walls. Also it is possible that some small amounts of ACM floor tile and/or ACM flooring mastic have been overlain with non-acm flooring products.

Building 1A – Suspect ACM

The most recent (prior to this report by SELC) major asbestos re-inspection report, dated May 2010, states that no ACM are present at Building 1A as a result of abatement conducted during renovation circa 2006/2007. Furthermore the building was scheduled to be renovated again in 2013/2014 including a total interior demolition.

Building 1”D” – Suspect ACM

Previous inspections appear to have adequately addressed the suspect materials in the building as observed by SELC, with the possible exception of white mastic/sealant applied to insulations on HVAC piping located primarily in air handler mechanical rooms and presumably as routed back to main equipment. Please see discussion in table below. Based upon our review of the historical renovation drawings, and abatement records coupled with our on-site observations it appears that essentially all of the previously identified ACM have been removed from the old ground (new 1st floor) and the old 3rd floor (new 4th floor). However, ACM floor tile and mastic remain in many of the old 1st, 2nd, & 4th floors (new 2nd, 3rd, & 5th floors).

During the last asbestos re-inspection, conducted in 2009/2010 by Converse Consultants, the following materials at Bldg. 1”D” were listed as suspect and “Assumed/Presumed ACM” apparently due to lack of sufficient testing theretofore. However, supplemental testing records appear to indicate that most of them do not contain asbestos. See the limited area testing records (2010 – 2013) presented in Volume 4, and supplemental testing (2008 – 2010) presented in the Bldg 1 Section - Appendix D, of the Converse report in Volume 3. Given that there is some degree of uncertainty concerning those materials the following table is presented to discuss the issues.

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Building 1”D”

Suspect Material

Description

Reported Locations

Notes Recommended Action

Drywall Joint Compound and Cove Base Mastic

Various These materials were listed as Presumed ACM by Converse in the Bldg 1D hazard assessment portion (Appx C) of the May 2010 Asbestos Re-Inspection Report / Management Plan.

However, they are not listed as “Assumed ACM” in the upfront summary section of that report which includes a February 2010 report of nine samples of the materials collected at various places throughout the old ground / new 1st floor and none were found to contain asbestos. Also somehow the May 2010 report includes a November 10, 2010 report of 12 more samples of those materials collected on the upper floors and again none were found to contain asbestos. Also another report dated Sept 02, 2009 (see Vol. 4) was found with one sample of drywall & joint compound collected at the old ground floor (new 1st floor) and it also contained no asbestos. Again, more negative samples of these materials were found in reports dated 04/25/12 and 10/24/12 (see Vol. 4). Our review of historical construction drawings and a comparison of existing conditions to older floor plans indicates that some alterations have occurred but most are relatively recent and should not have included the use of ACM. As such it appears that the drywall and wall base adhesives have been adequately tested.

None

Sheet Floor Covering

North End Of Former Ground Floor Corridor

GD119

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC has confirmed that this ACM has been removed, and the location is no longer a corridor per renovations of west side of old ground / new first floor that were in progress August 2012.

None

Ceramic Tile, Grout, & Mortar

Various Restrooms And Procedure Areas

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. It has been our experience that occasionally non-fibrous / non-regulated forms of tremolite are found in ceramic tiles and/or associated grouts and setting compounds; however, they are not normally considered suspect by most inspectors.

None

Exterior Stucco

Various Exterior Walls

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. Much of the exterior walls of this building have been concealed by the addition of other buildings: MRI to the north, Bldg. 4 ER to the west, and Mental Health to the south. SELC did collect one sample of what appears to be textured paint applied to concrete at the NW corner of Bldg. 1D, and no asbestos was detected in that sample (see Appx. B of this Vol. 1).

When future projects will likely impact the exterior walls analyze samples of any suspect texture or stucco materials prior to disturbance.

Roofing Roof This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. A September 20, 2011 report by Converse indicates that one sample of main field roofing materials and one sample of flashing materials were analyzed and the black felts in both were found to contain asbestos.

Treat roofing and flashing felts, and cements/sealants as ACM unless additional testing proves they do not contain asbestos.

White Mastic on Fiberglass Chilled Water Pipe Insulation

The 2002 Chung/IHI report list the mastic applied to duct insulation in the mechanical rooms as a suspect material that was found to be asbestos free, but does not list the mastic applied to the fiberglass HVAC pipe insulation. A January 08, 2013 report by Converse indicates three samples of pipe

When future projects will likely impact the older chilled water insulations analyze

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Building 1”D”

Suspect Material

Description

Reported Locations

Notes Recommended Action insulation were collected at 2nd floor chilled water pipes, and they were found to be asbestos free, but the lab report descriptions identify black foam and cream canvas – no white mastic. SELC tested an off-white mastic on an older looking section of fiberglass chilled water pipe insulation in the west side mechanical room on old first floor / new second floor and found it to contain 10% chrysotile. SELC also tested three samples of off-white, older looking, mastic on fiberglass chilled water pipe insulation in the east side mechanical room on the old 2nd floor / new 3rd floor and no asbestos was detected in those samples. There are clearly older and newer sections of fiberglass insulations in the mechanical rooms as some of the sections have a bright white mastic and also some sections have newer foam insulation. Most of the mastic materials in the mechanical rooms appear to be the newer bright white types, but that may not be the case with the overall pipe distribution, presumably routed from basement up to the mech rooms. The insulation mastics should be tested in the future samples of mastics

Building 7 – Suspect ACM

During the last asbestos re-inspection, conducted in 2009/2010 by Converse Consultants, the following materials at Bldg. 7 were listed as suspect and “Assumed/Presumed ACM” apparently due to lack of sufficient testing theretofore. As such SELC has reviewed testing records compiled since issuance of that report and conducted an investigation of the Assumed ACM as listed below.

Building 7

Suspect Material

Description

Reported Locations

Notes Recommended Action

Ceiling Drywall

Room 104 Utility Closet, Room 102 Bathroom & Shower

These materials were listed as Presumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. Our inspection of old room 104 / new # N224 revealed a 2’x4’ lay-in ceiling tile system with plastic faced gypsum board tiles which we do not consider suspect. They are simply gypsum board (no joint compound) and plastic/vinyl facing. Old room 102 / new # N223 has a 2’x4’ acoustical composition lay-in tile ceiling which was sampled by SELC and no asbestos was detected.

The shower area in room 102 has a plaster ceiling which was sampled by SELC and no asbestos was detected.

None

Cove Base and Mastic

Various These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. They were sampled by SELC and no asbestos was detected.

None

Ceramic Tile, Grout, & Mortar

Room 104 Utility Closet, These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC identified ceramic tiles in old rooms 102, 103, 104, 112, & 114 and

None

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Suspect Material

Description

Reported Locations

Notes Recommended Action

Room 102 Bathroom & Shower sampling of the tiles, grouts, and underlying mortars/plasters did not detect any asbestos.

Exterior Stucco on Concrete

Various Exterior Walls

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC sampled the exterior wall materials down to concrete, CMU blocks, and metal where it occurred (e.g. angle plates at loading dock).

The material appeared to largely consist of textured paint as evidenced by its presence over metal items at loading dock.

No asbestos was detected.

None

Roofing Roof This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC observed the roof to be a rubber membrane system which we do not consider to be suspect.

Building 8 – Suspect ACM

During the last asbestos re-inspection, conducted in 2009/2010 by Converse Consultants, the following materials at Bldg. 8 were listed as suspect and “Assumed/Presumed ACM” apparently due to lack of sufficient testing theretofore. As such SELC has reviewed testing records compiled since issuance of that report and conducted an investigation of the Assumed ACM as listed below. During that investigation some additional suspect materials were identified and sampled, as listed in Appendix B of this report (Vol. 1).

Building 8

Suspect Material

Description

Reported Locations

Notes Recommended Action

Interior Boiler Tank Insulation

Three Boiler Tanks (without external insulation) in Old Room G102

This material reported to be located in old room # G102 / new # N101 was listed as Presumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. Our inspection of that room revealed one deaerator tank and three boilers. The deaerator tank was found to be a 1999 vintage vessel with external insulation which is not suspect based on the 1973 & 1975 bans on asbestos insulating products; however SELC collected one QC sample and no asbestos was detected. The three package boilers were determined to be 1997 vintage.

We are not aware of any boiler water/steam tanks with internal insulation; however, package boilers of modern vintage normally include an unfaced fiberglass, mineral wool, or ceramic wool layer between an outer metal skin and the heavier steel plated firebox. We did observe beige/white preformed insulation blocks coated with a hand applied mud layer wrapped by canvas; all located behind stainless steel on the boiler economizer/exhaust sections. Again given the age of the materials one QC sample was collected and found to be asbestos free.

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Suspect Material

Description

Reported Locations

Notes Recommended Action

Cove Base and Mastic

Old Room G105 / New # N105

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. However, VAMC records indicate an abatement clearance on 11/30/11 for removal of previously identified ACM floor tile mastic in this room. It appears that the wall base was removed in conjunction with the flooring and as such no sampling was conducted.

None

Fire Rated Door

Old Room G106 / New Room N106

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. Based upon a drawing in the Converse report, apparently room 106 (chiller room) was configured differently in 2010 than at the time of this current inspection. As such, 5 doors are no longer present, and SELC collected a sample of the styrofoam filler (not truly a suspect matl.) located inside the double door between the boiler room and the chiller room. No asbestos was detected in that sample.

None

Ceramic Tile & Grout

Old Room G103 (Entry Alcove to New Room N104)

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC identified ceramic tiles at old room G104 (new room N104) and sampling did not detect any asbestos.

Exterior Stucco on Concrete

Various Exterior Walls

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC sampled the exterior wall materials down to concrete, CMU blocks, and metal where it occurred. The material appeared to largely consist of textured paint as evidenced by its presence over metal items. No asbestos was detected.

None

Roofing Roof This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC observed the roof to be a rubber membrane system which we do not consider to be suspect.

Building 10 – Suspect ACM

Previous inspections appear to have adequately addressed the suspect materials observed by SELC, with the possible exception of floor tile mastic on the basement level. However, during the last asbestos re-inspection, conducted in 2009/2010 by Converse Consultants, the following materials at Bldg. 10 were listed as suspect and “Assumed/Presumed ACM” apparently due to lack of sufficient testing theretofore. As such SELC has reviewed testing records compiled since issuance of that report and conducted an investigation of the Assumed ACM as listed below.

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Building 10

Suspect Material

Description

Reported Locations

Notes Recommended Action

Exterior & Entryway Wall Plaster / Stucco

Exterior Walls & Various Walls at Entrances

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC observed basic mortar mix type stucco / skim coat plaster, not normally considered a suspect material, at the reported locations. Two samples were collected for QA purposes and no asbestos was detected.

None

Cove Base and Mastic

Various These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC observed relatively modern vinyl and rubber wall bases, which as previously stated do not contain asbestos, as opposed to the old asphalt based acm types. Also the adhesives associated with those bases were observed to be the modern elastomeric type clear/beige/yellow materials as opposed to the older dark brown brittle acm types.

None

Ceiling Tile Mastic

Not Specified

This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report, but its location was not specified and SELC was not able to identify it.

None

Ceramic Tile, Grout, & Mortar

Patient Room bathrooms and Various Restrooms

These materials were listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. It has been our experience that occasionally non-fibrous / non-regulated forms of tremolite are found in ceramic tiles and/or associated grouts and setting compounds; however, they are not normally considered suspect by most inspectors.

None

Roofing Roof This material was listed as Assumed ACM by Converse in the May 2010 Asbestos Re-Inspection Report. SELC did not identify any testing associated with the Bldg. 10 roof.

If the roofing is not a rubber membrane, treat bituminous felts, flashing felts, cements, and sealants as ACM until testing proves they do not contain asbestos.

Building 15 – Suspect ACM

No previous inspections or limited testing records were identified for this Building 15. SELC conducted a thorough inspection of the interior and exterior of the building to identify materials normally considered suspect by SELC inspectors. A table listing all identified suspect homogeneous materials is presented herewith in Appendix B of Volume 1. Subsequent material testing did not detect any asbestos.

Building 138 – Suspect ACM

No previous inspections or limited testing records were identified for this Building 138. SELC conducted a thorough inspection of the interior and exterior of the building to identify materials normally considered suspect by SELC inspectors. A table listing all identified suspect homogeneous materials is presented herewith in Appendix B of Volume 1. Subsequent material testing did not detect any asbestos.

SELC Project No.: 2012-0853 Page 16

Building E – Suspect ACM

No previous inspections or limited testing records were identified for this Building E. SELC conducted a thorough inspection of the interior and exterior of the building to identify materials normally considered suspect by SELC inspectors. A table listing all identified suspect homogeneous materials is presented herewith in Appendix B of Volume 1. Subsequent material testing did not detect any asbestos.

Building F – Suspect ACM

No previous inspections or limited testing records were identified for this Building F. SELC conducted a thorough inspection of the interior and exterior of the building to identify materials normally considered suspect by SELC inspectors. A table listing all identified suspect homogeneous materials is presented herewith in Appendix B of Volume 1.