S02 St Cloud VAHCS - West Steam Main Asbestos Survey Report.pdf

Prepared for:

Anderson Engineering of Minnesota, L.L.C.

January 5, 2024

Asbestos Inspection Report St. Cloud VA Health Care System – West Steam Line Project St. Cloud, Minnesota

Landmark Environmental, LLC 9555 James Avenue South – Suite 262 | Bloomington, MN 55431 | Phone: 952-295-9400 | www.landmarkenv.com

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Asbestos Inspection Report

St. Cloud Veterans Affairs Health Care System

Replace/Add Steam Mains West Side Campus Project St. Cloud, Minnesota

1.0 Executive Summary

2.0 Introduction

3.0 Sampling Methods and Analysis

4.0 Asbestos-Containing Material Assessment

5.0 Findings

6.0 Recommendations

Appendices

Appendix A Certificates

Appendix B Building Diagram and Laboratory Report

Appendix C Asbestos-Containing Materials Physical Assessment

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1.0 Executive Summary

Landmark Environmental, LLC (Landmark) was retained by Anderson Engineering of

Minnesota, L.L.C. (Client) to complete an asbestos survey (Survey) as part of a renovation project at the St. Cloud Veterans Affairs (VA) Health Care System (VAHCS) located in

St. Cloud, Minnesota (the Property). The Survey was conducted in the western portion of the tunnel system as part of the Replace/Add Steam Mains West Side Campus – St. Cloud

VAHCS project (the Project). Tunnels and building crawlspaces between manhole 21 and

Building 51 were included in the Survey. In the crawlspaces of the buildings, approximately 20 feet on either side of the main steam lines were included in the Survey.

A diagram of the locations included in the Survey has been included in this report.

Castle Hill Associates, LLC conducted an asbestos reinspection of the full campus, including tunnels and crawlspaces, in 2019. The results of the reinspection were released in a report titled “Asbestos Reinspection Report 2019” which was dated November 4-6, 2019 and July 13, 2020 (the Reinspection Report). The findings of this Reinspection

Report were used in Landmark’s Survey Report.

A summary of the Survey results are as follows:

Landmark collected 7 bulk asbestos samples as part of the Survey. The contracted laboratory, EMSL Analytical, Inc. (EMSL), analyzed all 7 samples submitted for analysis.

Based on the Reinspection Report, suspect building materials found to contain asbestos include: contaminated soil. Asbestos-containing material (ACM) should not be cut, drilled, sanded or disturbed.

No suspect building materials were assumed to contain asbestos during the Survey.

Electrical wiring and panels were not sampled for asbestos. Landmark does not perform bulk sampling of electrical equipment unless it has been shut down and tagged by a licensed electrician.

This Survey identifies asbestos materials as they existed on the day of the survey at the

Property. Conditions may change over time.

This Survey should not be used as a bidding document. The ACM quantities provided are estimates and must be verified by the bidding contractors. Landmark recommends using a licensed asbestos project designer to design and bid all projects.

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2.0 Introduction

Landmark completed an asbestos survey report (Report) at the Property. The procedures used for this Survey and assessment comply with the Environmental Protection Agency

(EPA), Occupational Safety and Health Administration (OSHA), Minnesota Department of Health (MDH), and Minnesota Pollution Control Agency (MPCA) asbestos standards.

2.1 Purpose

Landmark was retained by the Client to complete the Survey and Report to identify

ACM, and quantities of ACM in the Project area prior to commencing with a scheduled renovation project.

2.2 Survey Approach

The Survey and assessment, consisting of identifying, sampling, assessing, and quantifying suspect ACM within the Project work area, was conducted on December 22, 2023.

2.3 Assumptions, Limitations and Exceptions

The findings and recommendations in this Report are subject to the following assumptions, limitations, and/or exceptions:

• Based on the Project scope of work, a destructive survey was not conducted. No attempt was made to locate materials inside walls, doors, ducts, and other areas that would require destructive entry. The possibility exists that suspect materials may be present in these locations. Materials observed, or suspected in these areas, were assumed to be ACM if sampling was not feasible.

• Electrical wiring and panels were not sampled for asbestos. Landmark does not perform bulk sampling of electrical equipment unless it has been shut down and tagged by a licensed electrician.

• This Survey identifies materials as they existed on the day of the survey. Conditions may change over time.

2.4 Qualifications

The Survey was conducted by Mark Meier and Cheyenne Neess, accredited asbestos building inspectors with Landmark. A photocopy of the inspector’s MDH certification is included in Appendix A.

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Asbestos sample analysis for this project was conducted by EMSL located in New Hope, Minnesota. EMSL is accredited by the National Voluntary Accreditation Program

(NVLAP lab code 200019-0).

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3.0 Sampling Methods and Analysis

3.1 Bulk Asbestos Sampling

Building diagrams were utilized to divide the Survey areas into functional spaces for the purposes of describing sampling locations. The building diagram with sample locations has been included in Appendix B.

Similar systems and materials were grouped into “homogeneous areas of building materials” (homogeneous materials). Homogeneous materials often exist in more than one functional space within the Property building. Each homogeneous material was assigned a discrete number; the homogeneous material number is indicated in the first number of the sample name. Multiple samples of each homogeneous material were taken in accordance with the EPA-Asbestos Hazard Emergency Response Act (AHERA) guidelines using a random sampling procedure. These multiple samples were designated

“A, B, C,” etc. for each homogenous material, as indicated in the sample name. The sample locations and sample descriptions are shown on the building diagram and the asbestos laboratory report in Appendix B.

Samples were collected by carefully removing a small representative sample of the suspect material and sealing it in a plastic bag.

3.2 Bulk Asbestos Analysis

Landmark collected 7 bulk asbestos samples as part of the Survey. EMSL, analyzed all 7 samples submitted for analysis. Laboratory results are presented in the attached report in

Appendix B.

The bulk samples were analyzed by polarized light microscopy (PLM) with dispersion staining, EPA method 600/R-93/116 and EPA method 600/M4-82-020. Quantity determinations are made by visual estimation. For each homogeneous material, once a positive sample was identified, the remaining samples were not analyzed.

EPA National Emission Standards for Hazardous Air Pollutants (NESHAP)-Rule 40 CFR

Part 61 states that samples found to contain less than 10% asbestos by visual estimation may be further quantified by point count analysis.

The Asbestos rule states that all multi-layer systems, except for wall systems where joint compound was used only at the joints and nail holes, must be analyzed as separate materials. If any layer contains greater than one percent asbestos, that layer must be treated as asbestos-containing. This requires all layers in a multi-layered system to be

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Asbestos samples will be held for 30 days after the date of this report.

3.3 Chain of Custody Procedures

To ensure that samples collected in the field are neither lost nor their identity misidentified, all samples, from the point of collection to receipt in the laboratory, proceeds as follows. Each sample is first assigned a unique and distinct sampling number. After a sample is placed into a plastic bag, that unique number is assigned to that bag. This same number is documented on the laboratory’s chain of custody. The inspector signs each chain of custody before delivering to the lab. Upon receipt of the samples, the lab analyst verifies that each sample matches the corresponding chain of custody number and signs and dates the chain of custody. After analysis, the analyst generates a report that includes the sample results and the project chain of custody forms.

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4.0 Asbestos-Containing Material Assessment

In each functional space, each homogeneous material was quantified and assessed for friability (i.e. material can be crumbled, pulverized, or reduced to powder by hand pressure when dry). Suspect ACM was then assessed as to their condition and potential for disturbance. This information was recorded on the asbestos physical assessment shown in Appendix C. The model for this system is described in the EPA Draft

Curriculum for Training Building Inspectors.

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5.0 Findings

5.1 Summary of Asbestos-Containing Materials

Suspect homogeneous material found to contain asbestos and their sample numbers include:

Thermal Insulation

Contaminated soil in Building 49 (Castle Hill Sample S-11, S-12, S-13, S-14).

Contaminated soil in Building 50 (Castle Hill Sample S-15, S-16, S-17).

Contaminated soil in Building 51 (Castle Hill Sample S-18, S-19, S-20).

Contaminated soil in Manhole 21 to Building 48 Tunnel (Castle Hill Sample S-9).

Contaminated soil in Building 48-49 Tunnel (Castle Hill Sample S-10).

Surfacing Material – None Observed

Miscellaneous Materials - None Observed

Assumed Materials – None Observed

5.2 Summary of Non-Asbestos-Containing Materials

Suspect ACM is considered negative for asbestos when all samples of the material are found to contain one percent or less asbestos. Suspect homogeneous material found to be negative includes:

1. Black tar on wall (Landmark Sample 1).

2. Red firestop putty (Landmark Sample 2).

3. Hard fitting on fiberglass (Landmark Sample 3).*

4. Mud on pipe hanger (Landmark Sample 4).*

5. Black tar on wall (Landmark Sample 5).

6. Tar expansion joint (Landmark Sample 6).

7. Tar expansion joint (Landmark Sample 7).

*-confirmation bulk samples of materials previously sampled and found negative.

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6.0 Recommendations

Based on the Survey and assessment results, as well as the proposed future use of the

Property building, the following recommendations for each ACM are summarized below.

Description Total Estimated

Thermal System Insulation

Contaminated soil (Crawlspace Building 49) 16,625 sf

Contaminated soil (Crawlspace Building 50) 9,500 sf

Contaminated soil (Crawlspace Building 51) 16,625 sf

Contaminated soil (Tunnel Manhole 21 to Building 48) 980 sf

Contaminated soil (Tunnel Building 48-49 Tunnel) 935 sf

Surfacing Material None observed

Miscellaneous Materials None observed

Assumed Materials None observed

A certified asbestos abatement contractor must remove identified and assumed asbestos containing materials prior to renovation or demolition activities in accordance with the applicable state and federal regulatory requirements. Non-asbestos certified persons or companies are prohibited from disturbing, removing, or rending the material friable.

Access to the tunnels and crawlspaces with contaminated soil shall be limited to properly trained individuals.

If untested material(s) are discovered during renovation or demolition activities, stop work, and assume the material(s) contains asbestos or have the material(s) tested to determine the asbestos content.

No attempt was made to locate materials inside walls, doors, ducts, and other areas that would require destructive entry. If any newly discovered suspect material is found during asbestos abatement or building demolition, work should stop until the material can be sampled to determine asbestos content, or assumed to contain asbestos and abated by a licensed asbestos abatement contractor.

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Electrical wiring and panels were not sampled and should be assumed to contain asbestos. Landmark does not perform bulk sampling of electrical equipment unless it has been shut down and tagged by a licensed electrician.

This Survey identifies asbestos as they existed on the day of the survey at the Property.

Conditions may change over time.

This Survey should not be used as a bidding document. The ACM quantities provided are estimates and must be verified by the bidding contractors.

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7.0 Signatures of Environmental Professional(s)

We declare that, to the best of our professional knowledge and belief, the Survey referenced by this report, and the report itself, were conducted in accordance with intent of the EPA, MPCA, MDH, AHERA regulations to the best of my ability and knowledge.

Mark Meier, Asbestos Building Inspector

(AI-3893)

Eric Gabrielson, Vice President

Appendices

Appendix A

Appendix B

EMSL Analytical, Inc.

3410 Winnetka Avenue North New Hope, MN 55427

Tel/Fax: (763) 449-4922 / (763) 449-4924 http://www.EMSL.com / minneapolislab@emsl.com

352311372EMSL Order:

Customer ID: LMEN42

Customer PO:

Project ID:

Attention: Phone:Mark Meier (952) 666-2422

Fax:Landmark Environmental, LLC (952) 887-9605

Received Date:9555 James Avenue South – Suite 262 12/22/2023 2:10 PM

Analysis Date:Bloomington, MN 55431 12/27/2023

Collected Date: 12/22/2023

Project: STCVA Steam Tunnel

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

352311372-0001

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous by manhole 21 -

Black Tar on Wall

352311372-0002

None DetectedNon-fibrous (Other)90%Glass10%Red

Fibrous

Homogeneous

CS 48 - Red Fire Stop

Putty

352311372-0003

None DetectedNon-fibrous (Other)70%Cellulose

Min. Wool

15%

15%

Beige

Fibrous

Homogeneous

CS 49 - Hard Fitting on Fiberglass

352311372-0004

None DetectedNon-fibrous (Other)75%Cellulose

Min. Wool

10%

15%

Beige

Fibrous

Homogeneous

CS 49 - Mud on pipe hanger

352311372-0005

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Past Tunnel 49 -

Black Tar

352311372-0006

None DetectedNon-fibrous (Other)30%Cellulose70%Black

Fibrous

Homogeneous

Past 49 in tunnel - Tar

Expansion Joint

352311372-0007

None DetectedNon-fibrous (Other)40%Cellulose60%Black

Fibrous

Homogeneous

Tunnel 50 To 51 - Blk

Tar Exp. Joint

Analyst(s)

Louis Miller (7) Rachel Travis, Laboratory Manager or Other Approved Signatory

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

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. New Hope, MN NVLAP Lab Code 200019-0; Colorado AL-24478

Initial report from: 12/27/2023 16:25:51

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 12/27/2023 3:25 PM

OrderID: 352311372

OrderID: 352311372

Asbestos Bulk Sample LocationX

Appendix C

1/4/2024 ST. CLOUD VAHCS

WEST MAIN STEAM LINE PROJECT

ASBESTOS-CONTAINING MATERIAL ASSESSMENT DATABASE

Floor

Functional

Space Location Type Description Quantity

Height

(Feet) Condition

Disturbance

Potential

Homog.

Material

Tunnel 1

Manhole 21 to

Building 48 MISC Contaminated soil 980 sf G L

Previously

Sampled

Crawlspace 2 Building 48

No ACM Observed in Landmark's or Prior

Surveys

Tunnel 3

Building 48 to

Building 49 MISC Contaminated soil 935 sf G L

Previously

Sampled

Crawlspace 4 Building 49 MISC Contaminated soil 16,625 sf G L

Previously

Sampled

Tunnel 5

Building 49 to

Building 50 MISC

No ACM Observed in Landmark's or Prior

Surveys

Crawlspace 6 Building 50 MISC Contaminated soil 9,500 sf G L

Previously

Sampled

Tunnel 7

Building 50 to

Building 51 MISC

No ACM Observed in Landmark's or Prior

Surveys

Type: TSI=Thermal System Insulation SURF=Surfacing Materials MISC=Misc.

Quantity: CF=Cubic Ft LF=Linear Ft SF=Square Ft Condition: G=Good F=Fair P=Poor Dist. Pot.: L=Low M=Medium H=High