Attachment 20 - Asbestos Report.pdf

ASBESTOS CONTAINING MATERIALS

2014 THREE-YEAR RE-INSPECTION AND

ASSESSMENT REPORT

BUILDINGS 1, 2, 3, 4, 5, 6, 7, 8, 12, 15, 17, 18, 39, 40, 41, 46

VA MEDICAL CENTER

3701 PELHAM LOOP ROAD EAST

TUSCALOOSA, AL 35404

Prepared For:

DEPARTMENT OF VETERAN AFFAIRS

VAMC

3701 PELHAM LOOP ROAD EAST

ATTN: MARK VERSACE

Conducted and Prepared by:

Safety Environmental Laboratories and Consulting, Inc.

989 Yeager Parkway Pelham, AL 35124

SELC Project # 2014-1108

Report Narrative Issued: August 29, 2014

Inspected/Reported By: Reviewed By:

Elizabeth Hyde N. Glenn Ray, REM, REPA Project Manager/ Technical Director Environmental Specialist/Asbestos Inspector

ASBESTOS CONTAINING MATERIALS

2014 THREE-YEAR RE-INSPECTION AND ASSESSMENT REPORT

BUILDINGS 1, 2, 3, 4, 5, 6, 7, 8, 12, 15, 17, 18, 39, 40, 41, 46

VA MEDICAL CENTER

TABLE OF CONTENTS

1.0 INTRODUCTION 1

2.0 PURPOSE AND SCOPE OF SERVICES 1

3.0 REGULATIONS, STANDARDS & GUIDELINES 2

4.0 PROJECT AREA DESCRIPTION 3

5.0 RE-INSPECTION METHODOLOGY 4

6.0 ANALYTICAL METHODOLOGY 6

7.0 SUSPECT MATERIALS 6

8.0 ASBESTOS RE-INSPECTION AND SAMPLING RESULTS 6

8.1 Friable ACM 7

8.2 Non-Friable ACM 7

9.0 CONCLUSIONS AND RECOMMENDATIONS 8

10.0 ASSUMPTIONS AND LIMITATIONS 10

APPENDICES:

Appendix A Building 1 Re-inspection Documentation A-1 – Annual Asbestos Re-inspection Documentation A-2 – Homogeneous Area / Sample Summary Table A-3 – Sample/ACM Location Plans A-4 – PLM Laboratory Reports A-5 – Photographic Documentation A-6 – Estimated Asbestos Abatement Costs A-7 – Additional VAMC Supplied Notes/Information (if provided)

Please note that format “X”-1 through “X”-7 will be continued for each building in the appendices below, with the exception of Appendix Q.

Appendix B Building 2 Re-inspection Documentation Appendix C Building 3 Re-inspection Documentation Appendix D Building 4 Re-inspection Documentation Appendix E Building 5 Re-inspection Documentation Appendix F Building 6 Re-inspection Documentation

Appendix G Building 7 Re-inspection Documentation Appendix H Building 8 Re-inspection Documentation Appendix I Building 12 Re-inspection Documentation Appendix J Building 15 Re-inspection Documentation Appendix K Building 17 Re-inspection Documentation Appendix L Building 18 Re-inspection Documentation Appendix M Building 39 Re-inspection Documentation Appendix N Building 40 Re-inspection Documentation Appendix O Building 41 Re-inspection Documentation Appendix P Building 46 Re-inspection Documentation Appendix Q Inspector and Laboratory Certifications

2014 Three-Year Re-Inspection and Assessment Report August 29, 2014 Buildings 1, 2, 3, 4, 5, 6, 7, 8, 12, 15, 17, 18, 39, 40, 41, 46 VAMC Tuscaloosa – Tuscaloosa, Alabama

SELC Project No: 2014-1108 Page 1

1.0 INTRODUCTION

Safety Environmental Laboratories & Consulting, Inc. (SELC) was employed by the Department of Veterans Affairs to provide an “Asbestos Three-Year Re-Inspection and Assessment” for 16 buildings at the VAMC Tuscaloosa campus located at 3701 Pelham Loop Road East in Tuscaloosa, Alabama. The services required to conduct the “2014 Asbestos Three-Year Re- Inspection and Assessment” (referred to herein as the “2014 re-inspection”) and prepare the associated documentation are described in the respective sections of this report.

This 2014 Asbestos Three-Year Re-Inspection and Assessment Report is specifically prepared as an update to previous inspections and re-inspections conducted at the 16 subject buildings on the VAMC Tuscaloosa campus, and to assess the condition of identified asbestos containing materials (ACM). These previous reports include (1) an initial 1991 inspection performed by CAPE Environmental (referred to as 1991 or CAPE report), (2) a 2002 report prepared by Southeast Consulting and Occupational Management, Inc. (referred to as the 2002 report or the “Buckalew” report), and (3) re-inspection reports prepared by SELC in 2008 and 2009 (referred to respectively as the 2008 report and 2009 report). All except one of the 16 subject buildings were inspected or re-inspected during one or more of the above-reference projects. No initial inspection (or re-inspection) information was available for Building 17.

SELC has confirmed to the extent practical, the presence or non-presence of those building materials previously identified in the above-referenced reports. During this 2014 re-inspection, SELC identified some additional ACM that were not listed in the previous reports. Also, in a precautionary effort to provide a measure of safety, other materials were assumed by SELC to be ACM, either based on the presence of similar building materials on similarly constructed buildings or due to certain inconsistencies between various records. The Annual Asbestos Re- Inspection Documents, drawings / floor plans, and other information provided in the appendices of this report provide the descriptions and locations of all confirmed ACM and assumed ACM still present at the subject VAMC. Condition of the identified ACMs is provided on the Annual Asbestos Re-Inspection Documents. An appendix has been prepared for each building and contains all pertinent information related to ACM present in each building, including all Annual Asbestos Re-Inspection Documents, ACM sample/location plans, homogeneous area / sample summary tables, laboratory reports, photographic documentation, estimated asbestos abatement costs, and VAMC provided supplemental data used in the field (if provided).

General recommendations are also presented for the handling of the ACM based upon their condition and potential for disturbance by routine operations, repair, renovation, or demolition activities.

2.0 PURPOSE AND SCOPE OF SERVICE

The purpose of this “2014 Asbestos Three-Year Re-Inspection and Assessment" was basically to review existing asbestos inspection and re-inspection/assessment information, and update the most current version of the existing asbestos re-inspection documentation. A summary of the services to be provided by SELC is presented below:

Review available records of previous ACM inspections and re-inspections, limited material testing, and VAMC ACM removal activity notes and documentation. According to the contracted scope of work the inspector is required to review the afore-referenced 1991, 2002, 2008, and 2009 reports. A 2005 report and a 2010 report also exist but were

SELC Project No: 2014-1108 Page 2 not available for review. Please note that information related to known locations of previous asbestos abatement, particularly of flooring materials, were provided to and reviewed by SELC, and incorporated into this re-inspection.

Perform a visual inspection of the previously identified ACM to collect information on the ACM conditions. Inspect all friable ACM and non-friable ACM for damaged or deterioration and record findings. Specifically, conditions and modifications from the 1991, 2002, and 2009 reports are to be recorded on an Annual Asbestos Re-inspection Document, which was provided by the VAMC.

Collect and analyze suspect ACM bulk samples from various locations throughout the subject buildings to support already collected information or identified new potential ACMs.

Identify management and/or mitigation options for areas identified as ACM. Please note that these options are provided on the Annual Asbestos Re-inspection Documents.

Management and/or mitigation options are generally discussed in the text of this report.

Provide estimated abatement costs.

Provide labels to adhere to otherwise unmarked ACM.

Compile a report (contained herein) which describes the re-inspection process, presents all findings, sampling and analytical results, and generally identifies ACM locations and approximate quantities in accordance with “Communication of Hazards” requirements pursuant to 29 CFR 1926.1101(k). This report includes several appendices which contain important information that may be essential to proper understanding of the data summarized in the narrative sections.

3.0 REGULATIONS, STANDARDS & GUIDELINES

This section of the report provides basic information on some of the key criteria applicable to the 2014 re-inspection performed by SELC; as well as regulatory obligations applicable to building owners and contractors involved in operations impacting ACM. The information below is presented in a very general nature and is not a complete representation of all regulatory criteria;

Any key parties, that will be involved in repair, renovation, or demolition projects that impact ACM, and whom are not knowledgeable of the associated asbestos regulatory requirements, should consult with the regulatory authorities mentioned herein and/or an asbestos abatement professional such as a certified asbestos project designer, before proceeding with any repair, renovation, or demolition operations that might disturb the ACM.

The National Emissions Standards for Hazardous Air Pollutants (NESHAP) requires the Owner or Operator of a facility to determine the presence or non-presence of asbestos containing materials via a “thorough inspection” prior to conducting renovation or demolition activities. The NESHAP Standard for asbestos (40 CFR Part 61 Sub-part M) is applicable to all types of facilities, regardless of construction date, except single family dwellings or multi-family dwellings with four or fewer units, unless those dwellings are being renovated or demolished for commercial purposes. NESHAP requires the use of controlled wet procedures for removal of asbestos materials that are or will become friable during renovation or demolition. The removal procedure must prevent visible emissions and must occur before renovation or demolition activities impact those materials. Presentation of this report and/or a pertinent summary thereof to all parties potentially performing activities that will contact or disturb identified ACM at the

SELC Project No: 2014-1108 Page 3 subject project area will complete the Owner/Operator discovery and communication requirements pursuant to NESHAP. Removal, handling and disposal of certain ACM (if identified herein) must be provided in accordance with NESHAP as locally administrated and enforced by the Alabama Department of Environmental Management (ADEM). Renovation projects involving ACM and all demolition projects, regardless of ACM, require advance notification to ADEM.

Alabama’s asbestos regulations that are relevant to renovation and demolition are essentially the same as the federal NESHAP.

On October 11, 1994, OSHA’s current construction industry regulation (29 CFR Part 1926.1101) for asbestos became effective. That regulation known as the Asbestos Construction Standard is related to asbestos exposure in construction, renovation, demolition, and building repair work places. Building owners are required, pursuant to section (k) “Communication of Hazards” of the Standard, to notify employees, tenants and prospective employers (e.g. construction bidders) of the description, locations and quantities of ACM in their buildings. Suspect materials installed no later than 1980 must be assumed to contain asbestos unless inspected and analyzed using “AHERA” protocol. The OSHA Standard applies by law to work performed by private sector employers / contractors, regardless of the type of facility or building owner. The OSHA Asbestos Standard does not directly apply to work performed by employees of state, county and municipal agencies in states without state-run OSHA programs (e.g. Alabama); however, since December 2000 the provisions of the Standard were made binding on state and local entities, via the EPA’s Asbestos Worker Protection Rule (40 CFR 763 Subpart G). Also most federal agencies have adopted the OSHA Standard for operations performed by their employees. Presentation of this report or pertinent information derived from it, to all parties that will potentially work in contact with the identified ACM described herein, will complete the Owner/Operator’s initial discovery and communications requirements pursuant to the OSHA Standard. Removal, handling and disposal of ACM (if identified herein) must be provided in accordance with the OSHA Standard, which is enforced by the Birmingham branch office of OSHA.

On November 28, 1992, a law became effective which extended the EPA’s Model Accreditation Plan (MAP), originally applicable only to schools, to all public and commercial buildings.

Currently the rule extends the accreditation requirements of MAP to persons performing asbestos work (inspectors, project designers, abatement supervisors and workers) in public and commercial buildings, but does not extend the other aspects of the AHERA asbestos rules for schools. This inspection was conducted using EPA/MAP accredited personnel. Accreditation in Alabama is provided by the University of Alabama’s Safe State Environmental Program. Refer to Appendix Q for copies of the inspector’s Safe State accreditation certificate.

4.0 PROJECT AREA DESCRIPTION

This section of the report contains a basic description of the 16 subject structures on the VAMC Tuscaloosa, AL campus, and is presented in part, to demonstrate that SELC has a good understanding about the construction history of the subject facility; and therefore the Inspector possessed the basic knowledge needed to recognize previously identified homogeneous areas, and to establish homogeneous areas, at least with respect to the approximate age of the various building materials. The information provided in Section 4.0 also references any known, large-scale improvement and/or renovation projects that have reportedly occurred at the 16 subject structures.

SELC understands the VAMC Tuscaloosa campus was initially constructed in the early 1930s.

Buildings 1, 2, 3, 4, 5, 6, 7, 8, 12, 15, 17, and 18 were reportedly constructed between 1931 and 1936. Buildings 39, 40, and 41 were reportedly constructed in 1944. Building 46 was reportedly

SELC Project No: 2014-1108 Page 4 constructed in 1963.

Please note that most of the subject structures are brick-faced buildings that are supported by wood, concrete, and metal structural supports. Most buildings have pitched, slate roofs on the original structure, with flat roofs on additions. Buildings 1, 2, 3, 4, 5, 39, 40, and 46 reportedly have new slate roofs that have been replaced within the last several years. At some of these structures, ACM roof tars were abated. This information is noted on respective Annual Asbestos Re-Inspection Documents included as Appendix “X”-1.

Generally, interior wall finishes in the 16 subject structures include, but are not limited to, plaster, gypsum board, concrete masonry units, glazed clay tiles, and concrete. Original ceilings are plaster; however most plaster ceilings are covered by lay-in ceiling tile systems. Flooring throughout the structures include, but are not limited to, vinyl composition floor tiles, vinyl sheet flooring, carpet, Centiva laminate flooring products, hardwood, ceramic tile, and concrete.

Piping systems in the subject structures are insulated with various types of insulating materials.

According to a review of previous asbestos reports, old steam pipe insulation was reported to be asbestos-containing “magnesia”-type insulation. Old domestic water piping was reportedly insulated with asbestos-containing “cardboard”-like insulation or air cell insulations. According to on-site engineers and maintenance personnel, since 1991, piping system insulations have been removed as part of asbestos abatement projects or general property improvement projects.

However, this information is very general in nature and exact locations of abatement of piping systems could not be verified in all buildings. During this inspection, typical insulating materials observed on piping systems included kraft-faced fiberglass or hard foam insulation, hard mud insulation, what appeared to be pre-formed, calcium silicate type insulations, and mineral wool insulation. Piping systems in crawlspaces were typically covered with metal-jacketing. When encountered, SELC noted on the respective Annual Asbestos Re-Inspection Documents locations of previously identified asbestos containing pipe insulations. However, it is likely that old, ACM piping insulation remains in the subject structures in typically inaccessible areas, such as crawlspaces, wall and ceiling cavities, etc.

According to VAMC personnel, all ACM has been removed from the Building 3 boiler plant as part of a recently completed boiler replacement project.

5.0 RE-INSPECTION METHODOLOGY

The field work portion of the 2014 re-inspection was conducted in July 2014 by Elizabeth Hyde, a University of Alabama Safe State Environmental Program certified asbestos inspector. See Appendix Q for the inspector's accreditation certificate.

SELC‘s first step in the overall survey/inspection process was to review the afore-referenced inspection and re-inspection reports provided by the VAMC. According to a review of these reports, it appears that homogeneous areas initially identified in 1991 by CAPE were re-inspected by Buckalew in 2002. Buckalew also identified additional homogeneous areas during their 2002 inspection. SELC’s 2008 and 2009 re-inspections addressed those homogeneous areas identified in 1991 and 2002. SELC compiled this information, and primarily addressed these previously identified ACMs. Please note that, as copies of the above-referenced previous reports are on-file with the VAMC, they are not included as attachments to this 2014 Three-Year Asbestos Re-Inspection and Assessment Report.

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During this re-inspection, if a homogeneous area was determined by the previous consultants to be non-ACM and/or if an ACM homogeneous area was listed as having been removed in a previous inspection/re-inspection report or in VAMC provided general notes/information, this material was typically removed from consideration during this re-inspection. For example, if floor tile in a particular area was removed and noted as such in the 2002, 2008, or 2009 re-inspection or in VAMC provided notes, an Annual Asbestos Re-Inspection Document was not completed for this homogeneous area. However, please note that a listing of all homogeneous areas, either previously identified by others or identified by SELC during this 2014 re-inspection, is provided as the first page of Appendix “X”-1 for the benefit of the user of this report. This list indicates if a homogeneous area was non-ACM or NAD (no asbestos detected) or has been removed.

Following the review of the previous inspection and re-inspection reports, SELC began the visual and physical portion of this re-inspection and assessment by visiting the spaces listed in the previous reports. Generally, if the reported ACM was identifiable, no sampling was conducted. However, in some cases the reported ACM may have been sampled, for example, to verify extent of an ACM or address inconsistencies in previous reports. After confirming the presence or non-presence of reported ACMs, limited visual inspection was conducted within the subject buildings to determine if other (previously unreported) suspect materials were present.

Please note that samples collected to confirm/verify the presence or absence of an existing homogeneous area were considered to be part that that homogeneous area, i.e., a new homogeneous # was not assigned. However, if a new suspect ACM was identified and sampled, SELC assigned a new homogeneous area number. Please refer to Appendices “X”-1 and “X”-2 for these assignments.

After 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 those sample numbers directly correspond with the numbers listed on the laboratory reports included in the appendices. Also the sample numbers were recorded on copies of floor plans provided by the VAMC. Refer to Appendix “X”-3 for drawings that depict sample locations as well as general locations of confirmed ACM.

As previously stated, it does not appear that an initial asbestos inspection has been conducted at Building 17. The performance of a comprehensive, initial asbestos inspection would require additional time and sampling that is beyond the scope of this re-inspection. SELC did collect a sample of a suspect flooring material in Building 17 that was of concern to the Client. Otherwise, only a visual assessment of Building 17 was performed during re-inspection activities. SELC has provide photographic documentation of suspect ACM building materials present in Building 17 (see Appendix K-5). However, not all suspect ACM in Building 17 are represented in the attached photograph log. SELC has provided the VAMC with a proposal for an asbestos inspection of Building 17.

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.

Note! The sampling conducted by SELC during this re-inspection was limited in nature. Also SELC did not conduct TEM analysis on negative non-friable organically bound (NOB) materials.

This report is compiled for the VAMC’s material tracking, hazard awareness, long term planning, and general information purposes.

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6.0 ANALYTICAL METHODOLOGY

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 Parkway 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 Certificate in Appendix Q.

7.0 SUSPECT MATERIALS

Individual building tables that list all samples collected by SELC during this re-inspection are presented as Appendix “X”-2. That table provides detailed descriptions of each material along with the corresponding sample numbers, basic sample locations, asbestos content, and other information. The following is a more general list of basic types of building materials identified by SELC during the 2014 re-inspection that were suspected to potentially contain asbestos. The materials are grouped into categories according to general types as set forth in AHERA, 40 CFR 763.

Surfacing Materials (decorative, acoustical, thermal, or fire resistant products that are typically site batched and sprayed or troweled onto a building component)

Sprayed insulation

Thermal System Insulation (HVAC & plumbing system insulations)

Pipe fitting insulation mud Pre-formed pipe insulations

Miscellaneous Material

Mastic applied to pipe insulations & HVAC duct insulations Vinyl composition floor tiles Vinyl surfaced sheet flooring Flooring adhesive/mastic Ceiling tile adhesives

8.0 ASBESTOS RE-INSPECTION AND SAMPLING RESULTS

Given the number of buildings (16) included in this re-inspection, and the large quantity of information related to each building, SELC has created a comprehensive appendix for each building that presents the findings of this re-inspection. Each Appendix includes; the completed Annual Asbestos Re-Inspection Documents (included in Appendix “X”-1) for each homogeneous

SELC Project No: 2014-1108 Page 7 area; a homogeneous area / sample summary table (Appendix “X”-2); sample and ACM locations plans (Appendix “X”-3); laboratory data sheets (Appendix “X”-4) for samples collected;

photographic documentation of various existing and newly identified ACM (Appendix “X”-5); an Estimated Asbestos Abatement Cost table (Appendix “X”-6), and additional VAMC Supplied Notes/Information (Appendix “X”-7). Please note that the Annual Asbestos Re-Inspection Documents include previously existing homogeneous areas, and new homogeneous area identified by SELC during this re-inspection.

As previously stated, it does not appear that an initial asbestos inspection has been conducted at Building 17. The performance of a comprehensive, initial asbestos inspection would require additional time and sampling that is beyond the scope of this re-inspection. SELC did collect one sample of a suspect flooring material in Building 17 that was of concern to the Client.

Otherwise, only a visual assessment of Building 17 was performed during re-inspection activities. SELC has provide photographic documentation of suspect ACM building materials present in Building 17 (see Appendix K-5). However, not all suspect ACM in Building 17 are represented in the attached photograph log. Suspect ACM present in Building 17 includes, but is not limited to, other vinyl composition floor tiles and mastics, pipe insulations and mastics, HVAC insulations and mastics window frame caulking, ceiling tiles, gypsum board and joint compound, roofing materials, and down spout tar.

SELC collected 75 bulk samples of suspect materials within the subject structures during the conduct of this re-inspection. All of those samples were analyzed per the EPA’s standard PLM method. A narrative description of new homogeneous areas, including all "Friable ACM" and "Non-Friable ACM" identified during this re-inspection is given below, if applicable. Additional information about each ACM is presented in the building specific appendix.

8.1 Friable ACM

All ACM identified during this re-inspection were classified as either friable or non-friable based upon their potential to be crumbled, pulverized or reduced to powder by hand pressure when dry. The following is a list of those newly identified ACM that can be crumbled, pulverized or reduced to powder by hand pressure when dry (i.e. friable):

ACM pipe fitting insulation – Buildings 3, 39, 40 ACM pipe insulation – Buildings 3, 39, 40 ACM HVAC Duct seam tape – Building 4

8.2 Non-Friable ACM

Based upon physical inspections the following newly identified ACM were classified as non-friable:

ACM 12” Vinyl composition floor tiles – Building 1 ACM Flooring mastics (generally black in color) – Buildings 1, 3, 4, 17, 40 ACM Vinyl sheet flooring – Building 6 ACM Adhesive/glue dots used to secure ceiling tile to plaster ceilings – Building 1 ACM Mastic on non-ACM pipe fitting insulations – Buildings 3, 4 ACM Exterior window frame caulk (See Note #1 below) – Buildings 6, 8, 15

Note #1: While not tested at every structure, it is likely that ACM exterior window frame caulk is present at any building with original wood windows. This includes buildings at

SELC Project No: 2014-1108 Page 8 which original windows remain present, but are encased with factory coated metal employed to reduce potential lead exposure hazards. It would be prudent to test window frame caulk on what are presumably old/original windows prior to any planned window removal project or activities that might impact this material.

9.0 CONCLUSIONS AND RECOMMENDATIONS

Generally, most of the re-inspected or newly identified ACMs can be managed in place in accordance with the VAMC asbestos operations and maintenance (O&M) program. Information presented in this report should be incorporated into the existing asbestos operations and maintenance program. Specific areas at which either (1) damaged ACM are present or (2) the presence of newly identified ACM with potential for significant damage should be noted by on-site safety and maintenance personnel, are listed below. Please note that the list provided below in Section 9.0 does not include all ACMs on-site. Please refer to Appendix “X”-1 for information related to all homogeneous areas/ACMs that should be properly managed/addressed.

Building 1

ACM Pipe insulation (HA 36/37, ~ 20 linear feet) present above ceiling tile in Room 235 ACM Pipe insulation (HA 36/37, ~ 5 linear feet) present above ceiling tile in Room 207

Building 3

ACM Pipe insulation (HA 35, ~ 10 linear feet) in Rooms 12 and 12A ACM Mastic on non-ACM pipe insulation (HA 44) on 2 fittings in Room 12, and ~ 10 fittings in Room 4

Building 4 ACM Flexible duct connector (HA 13 – 1 duct connector) in mechanical room 9 ACM Adhesive/glue dots (HA 19B) on plaster ceilings of first floor and mezzanine. Most are covered with non-ACM 1’ x 1’ ceiling tile ACM HVAC duct seam tape (HA 20) ACM Mastic over non-ACM pipe fitting insulation (HA 22) on ~ 6 fittings of roof drain piping in Room 7C

Building 5 ACM Pipe insulation (HA 23) observed on piping in Room 105 and Closet 207A ACM Mastic on non-ACM pipe insulation (HA 44) on 2 fittings in Room 12, and ~ 10 fittings in Room 4

Building 6 ACM Down spout tar (HA 07) ACM Exterior window frame caulk (HA 12)

Building 8

ACM Pipe insulation (HA 11) observed in crawlspace ACM Pipe insulation (HA 12) observed in attic ACM Exterior window frame caulk (HA 13)

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Building 15 ACM Exterior window frame caulk (HA 12)

Building 17

ACM Mastic below non-ACM VCT (HA 01) in Rooms 4A and 4B

Building 39 ACM Pipe insulation (HA 38) exposed in basement stairwells ACM Pipe fitting insulation (HA 39 and 40) exposed in basement stairwells

Building 40

ACM 12” VCT and mastic (HA 03). Please note that, while not a newly identified ACM, HA 03 is noteworthy as this ACM is present in areas of the daycare. This ACM is in good to fair condition in most locations, however is in fair to poor condition in Room 1 of the daycare. Until abated, this ACM (and the condition thereof) should be closely monitoring as it is in a child-occupied area.

ACM Flexible duct connector (HA 19) in Room 110F-1 ACM Pipe insulation (HA 23) observed on two pipes above ceiling tiles in Room 110F ACM mastic below non-ACM 12” VCT (HA 31) in daycare room 14. Please note that this material is in good to fair condition. Until abated, this ACM (and the condition thereof) should be closely monitoring as it is in a child-occupied area.

ACM Pipe insulation (HA 34) exposed in basement stairwells ACM Pipe fitting insulation (HA 35) exposed in basement stairwells

The EPA and OSHA regulations address various types of ACM differently and all of the associated regulatory issues including disposal for each type are too complex to effectively discuss in this report format. Certain types of ACM must be removed by ADEM/EPA certified abatement personnel prior to renovation or demolition operations that will disturb them.

However, other types of ACM can remain in place during renovation or demolition, depending upon the condition of the ACM and the nature of the construction activities, more specifically, the forces that will act upon the ACM. Regardless, all waste that contains ACM should be disposed of in a landfill that is permitted by ADEM to receive ACM. As such, SELC often recommends the complete removal and disposal of all ACM from buildings prior to any renovation or demolition operations. However, it is important to note that this is not necessarily required and cost savings may potentially be achieved by other approaches. Guidance on various options can be obtained from the aforementioned regulatory agencies and/or qualified abatement professionals such as a certified asbestos project designer employed by SELC or another qualified firm.

Renovation projects at regulated facilities, involving at least 160 square feet or 260 linear feet of regulated ACM (RACM), and all demolition projects (regardless of ACM presence), require NESHAP notification, which given this project's location must be filed with the Montgomery office of ADEM at least ten working days prior to activities that would disturb the ACM. Removal of NESHAP regulated ACM must be performed by “Alabama Safe State” accredited asbestos abatement personnel employed by an ADEM licensed asbestos abatement contractor.

The foregoing paragraph relates primarily to the EPA’s NESHAP asbestos standard 40 CFR 61 Subpart M. ACM handling is also regulated by OSHA which has a much more complex regulation that is too involved to summarize herein. Any handling of any type of ACM must be conducted in accordance with the OSHA standard by persons trained for the appropriate class of work as outlined by the standard. It is important to note that OSHA regulates all types of ACM handling activities, regardless of the NESHAP status, and all firms and their employees

SELC Project No: 2014-1108 Page 10 working on project sites where they will come into contact with ACM must comply with the OSHA Asbestos Standard 29 CFR 1926.1101, which will at a minimum involve specific worker training and worker protection procedures. Furthermore, owners of dwellings that contain ACM, must inform all prospective contractors/employers about the ACM descriptions, locations, and quantities, before those firms bid on or conduct repair, renovation, or demolition work.

10.0 ASSUMPTIONS AND LIMITATIONS

As previously stated this 2014 Three-Year Re-Inspection and Assessment was conducted to update data presented in the afore-referenced, previous inspection and re-inspection reports.

SELC has done that and additionally has reviewed other VACM information/notes and conducted various spot checks. Although considerable ACM information was generated during this 2014 re-inspection, it must be understood that areas inspected by SELC were limited to those needed to verify the presence or non-presence of the ACM listed in the previous inspection and re-inspection reports. In addition, the sampling conducted by SELC during this re-inspection was limited in nature. Also, SELC did not conduct TEM analysis on negative NOB materials. Although SELC made every attempt to identify ACM in the subject structures, it is reasonable to assume that many of the ACMs identified herein were homogeneously installed throughout several buildings of similar construction date, and may be located in spaces other than the specific examples listed herein. This report is compiled for the VAMC’s material tracking, hazard awareness, long term planning, and general information purposes.

The performance of a comprehensive, initial asbestos inspection of Building 17 would require additional time and sampling that is beyond the scope of this re-inspection. Therefore, only a visual assessment of Building 17 was performed during re-inspection activities.

End of report narrative.

APPENDIX A

BUILDING 1

MAIN BUILDING

INCLUDED IN APPENDIX A:

A‐1 – Annual Asbestos Re‐inspection Documentation

A‐2 – Homogeneous Area / Sample Summary Table

A‐3 – Sample/ACM Location Plans

A‐4 – PLM Laboratory Reports

A‐5 – Photographic Documentation

A‐6 – Estimated Asbestos Abatement Costs

A‐7 – Additional VAMC Supplied Notes/Information

APPENDIX A‐1

Annual Asbestos Re‐inspection

Documentation

BUILDING 1 HOMOGENEOUS AREA LIST

HA 01 = 12” X 12” FLOOR TILE (OFF‐WHITE WITH GREY AND BLUE) ‐ NAD

HA 02 = 12” X 12” FLOOR TILE (MULTI‐BROWN)

HA 03 = LINOLEUM (BLUE) ‐ REMOVED

HA 04 = 9” X 9” FLOOR TILE (OFF‐WHITE)

HA 05 = 12” X 12” FLOOR TILE (OFF‐WHITE WITH BROWN)

HA 06 = 12” X12” FLOOR TILE (GREY WITH BROWN) ‐ NAD

HA 07 = 12” X 12” FLOOR TILE (OFF‐WHITE WITH GREEN) ‐ REMOVED

HA 08 = 9” X 9” FLOOR TILE (BURGUNDY AND BLACK ALTERNATING) ‐ REMOVED

HA 09 = 9” X 9” FLOOR TILE (LIGHT BROWN)

HA 10 = 9” X 9” FLOOR TILE (YELLOW AND BLUE ALTERNATING) – NAD/REMOVED

HA 11 = 12” X 12” FLOOR TILE (WHITE) – NAD

HA 12 = 9” X 9” FLOOR TILE (BLACK)

HA 13 = 9” X 9” FLOOR TILE (YELLOW AND GREEN) – NAD / REMOVED

HA 14 = 9” X 9” FLOOR TILE (MULTI – WHITE) ‐ REMOVED

HA 15 = LINOLEUM (YELLOW)

HA 16 = 12” X 12” FLOOR TILE (OFF‐WHITE WITH BLUE)

HA 17 = 12” X 12” FLOOR TILE (BROWN WITH DARK BROWN) ‐ REMOVED

HA 18 = 12” X 12” FLOOR TILE (MULTI – LIGHT BROWN) ‐ REMOVED

HA 19 = 12” X 12” FLOOR TILE (GREEN WITH DARK GREEN) ‐ REMOVED

HA 20 = 9” X 9” FLOOR TILE (WHITE WITH BLACK SPOTTED)

HA 21 = 12” X 12” FLOOR TILE (WHITE WITH BLACK) ‐ REMOVED

HA 22 = FLEX DUCT CONNECTORS

HA 23 = CEILING TILE, 2’ X 2’ GROOVE AND PINHOLE (OLD) – NAD

HA 24 = CEILING TILE, 2’ X 2’ GROOVE AND PINHOLE (NEW) – NAD

HA 25 = CEILING TILE, 2’ X 2’ GREY – NAD

HA 26 = CEILING TILE, 2’ X 2’ WHITE – NAD

HA 27 = CEILING TILE, 2’ X 2’ PINHOLE ‐ NAD

HA 28 = CEILING TILE, 2’ X 2’ GROOVE – NAD

HA 29 = CEILING TILE, 2’ X 2’ SHALLOW GROOVE ‐ NAD

HA 30 = CEILING TILE, 2’ X 4’ GROOVE AND PINHOLE (NEW) – NAD

HA 31 = CEILING TILE, 2’ X 2’ GREY WITH WHITE SPOTTED – NAD

HA 32 = PLASTER, SMOOTH (ORIGINAL WALLS AND CEILINGS) – NAD

HA 33 = LAB TABLE TOPS – NAD

HA 34 = ????

HA 35 = PIPE INSULATION – FOAM GLASS – NAD

HA 36 = PIPE INSULATION – MAGNESIA TYPE – STEAM SYSTEM PIPING

HA 37 = PIPE INSULATION – CARDBOARD TYPE – DOMESTIC WATER SYSTEM PIPING

HA 38 = DUCT INSULATION – NAD

HA 39 = PIPE FITTING INSULATION ON FIBERGLASS RUNS ‐ REMOVED

HA 40 = WALLBOARD/GYPSUM BOARD ‐ NAD

HA 41 = 9” X 9” FLOOR TILE (BURGUNDY AND BROWN ALTERNATING) ‐ REMOVED

HA 42 = 12” X 12” FLOOR TILE (OLIVE GREEN) – NAD

HA 43A = ROOFING TAR (BUILT UP ROOFING) ‐ NAD

HA 43B = ROOFING TAR (TRIM BELOW SHINGLES) ‐ REMOVED

HA 44 = DOWNSPOUT TAR AT JOINTS ‐ REMOVED

HA 45 = ROOFING FELT – NAD

HA 46 = ROOFING TAR (PARAPET)

HA 47 = UNKNOWN

HA 48 = EXPANSION JOINT MATERIAL ON EXTERIOR OF BUILDING – NAD

HA 49 = SPRAY‐APPLIED FIREPROOFING MATERIAL ‐ NAD

HA 50 = TANK INSULATION – NAD

BUILDING 1 HOMOGENEOUS AREA LIST (continued)

HA 51/52 = 12” X 12” FLOOR TILE (OFF‐WHITE WITH TAN SPECKS) AND MASTIC

HA 53 = UNKNOWN

HA 54 = 12” x 12” FLOOR TILE (OFF‐WHITE WITH GREY AND BROWN) AND MASTC – REMOVED HA 55 = 12” X 12” VINYL COMPOSITION FLOOR TILE (OFF‐WHITE) AND BLACK MASTIC, BELOW CARPET

HA 56 = ADHESIVE/GLUE DOTS ON PLASTER CEILINGS

HA 57 = 12” X 12” VINYL COMPOSITION FLOOR TILE (OFF‐WHITE WITH GREEN STREAKS) AND

CREAM/BROWN MASTIC

HA 58 = FIBERBOARD PANEL ON MECHANICAL PENTHOUSE ROOF

HA = HOMOGENEOUS AREA

HA = ASBESTOS CONTAINING MATERIAL

NAD = NO ASBESTOS DETECTED

HA (ITALICIZED) = IDENTIFIED BY SELC DURING 2014 RE‐INSPECTION. OTHER HOMOGENEOUS AREAS

IDENTIFIED DURING PREVIOUS RE‐INSPECTIONS/INSPECTIONS BY OTHER CONSULTANTS.

Tuscaloosa VA Medical Center Annual Asbestos Re-Inspection Documentation

Physical Assessment (check all that apply) Damaged or significantly damaged TSI, ACM or ACE Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE X ACM or ACE with potential for damage ACM or ACE with potential for significant damage Any remaining friable ACM or ACE No asbestos detected

Classification of Hazard Potential (circle one)

Hazard Rank ACM Condition ACM Disturbance Potential

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage 2 Good Potential for Damage 1 Good Low Potential for Damage

Current Inspection Comments/Condition if Changed: Good to fair condition. Present in Elevator P-5 (~50 ft2), Room 41S (~ 120 ft2 - see photograph 1), Room 270 (see photograph 7, ~80 ft2). Also present below carpet in Room 42C (~ 100 ft2). Not present in Corridors 49, 51-52, 163A & B, corridor 120 - now have Centiva flooring or carpet over concrete. Carpet over concrete in Rooms 335 & 337 (former rooms 302 and 360, respectively).

2009 Inspection Note: Elevators P-1 and P-2 abated/replaced ACM with new vinyl sheet flooring. Room 270A and P-5 - fair to poor condition. Rooms 42C, 335, and 337 - have carpet over tile. No mention of 302, 352, 360. All ACM or ACE with potential for damage. Room 335 assigned HA 14 in 1991/2002 inspections. Room 337 assigned HA 19 in 1991/2002 inspections.

2002 Inspection Note: ACM/ACE with potential for damage. Elevators P-1, P-2, P-5, Rooms 42C, 270A, 302, 352, 360. Good condition. Please note Room 303 changed to HA #54.

1991 Inspection Note: ACM/ACE with potential for damage. Rooms 42C, and connecting corridors 49, and 51-52, Rooms 163A, 163B and connecting corridor 120, Rooms 302-303 & 360

Recommendation Response Action (circle applicable actions) O&M Remove/Enclose/Encapsulate Evacuate/Restrict

Explain: Manage in place until impacted by planned renovations or repair activities. Abate prior to or as part of planned renovation or repair activities.

Building #: 1 Homogeneous Area #: 02 Date: 7/22/14 Description: Floor tile, 12” x 12” (Multi-brown) & mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE ACM or ACE with potential for damage ACM or ACE with potential for significant damage Any remaining friable ACM or ACE X No asbestos detected

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Removed and replaced with thick rubber/vinyl in stairwells

2009 Inspection Note: Says all abated / no longer asbestos, but corner of bottom stair at landings 133 and 401A needs repair (trip hazard). In 2008, SELC referenced 302, 305, 355, 367, 401A and 406.

But there was no mention of 322, 334, 341, or 418.

2002 Inspection Note: ACM/ACE with potential for damage, Stairways landings 29, 38, 41, 123, 133, 138, 230, 237, 241, 322, 334, 341, and 418 with connecting stairs. Good condition.

1991 Inspection Note: ACM/ACE with potential for damage, Stairways 29, 38, 41, 123, 133, 138, 230, 237, 241, 322, 334, 341, 418.

Recommendation Response Action (circle applicable actions) O&M Remove/Enclose/Encapsulate Evacuate/Restrict

Explain: N/A

Building #: 1 Homogeneous Area #: 03 Date: 7/21 & 22/14 Description: Linoleum (blue) Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE X ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Fair condition. Approximately 2’ x 1.5’ area of HA 04 present in Room 47 (see photograph 2). Rest of flooring in Room 47 is newer VCT.

2009 Inspection Note: N/A

2002 Inspection Note: Abated, per 2002 report.

1991 Inspection Note: ACM/ACE with potential for damage. Room 47 (130 SF)

Explain: Manage in place until impacted by planned renovations or repair activities. Abate prior to or as part of planned renovation or repair activities.

Building #: 1 Homogeneous Area #: 04 Date: 7/22/14 Description: 9” x 9” Floor tile (off-white) and mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE X ACM or ACE with potential for damage ACM or ACE with potential for significant damage Any remaining friable ACM or ACE No asbestos detected

Classification of Hazard Potential (circle one)

Hazard Rank ACM Condition ACM Disturbance Potential

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Good to poor condition. Observed in Room 1 (~only 25 ft2 on floor surface – rest (450 ft2) on elevated floor), Room 37A (~ 60 ft2 - see Sample B1- 6.), and Room 41R (~ 150 ft2).

2009 Inspection Note: No comment with regard to Room 1. Second floor - appears to be 2002’s HA # 51/52. See sheet for 51/52.

2002 Inspection Note: No comment with regard to Room 1. Second floor - appears to be 2002’s HA # 51/52. See sheet for 51/52.

1991 Inspection Note: ACM/ACE with potential for damage – Room 1 (25 SF) / Majority of 2nd floor

(13,555 SF)

Recommendation Response Action (circle applicable actions) O&M Remove/Enclose/Encapsulate Evacuate/Restrict

Explain: Manage in place until impacted by planned renovations or repair activities. Abate prior to or as part of planned renovation or repair activities.

Building #: 1 Homogeneous Area #: 05 Date: 7/21&22/14 Description: 12” x 12” Floor tile (off-white with brown) and mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Carpet over concrete in Room 35 D (mail room)

2009 Inspection Note: No comment/information

2002 Inspection Note: No comment/information

1991 Inspection Note: ACM – Room 35 D (140 sf)

Explain: N/A

Building #: 1 Homogeneous Area #: 07 Date: 7/22/14 Description: 12” x 12” Floor tile (off-white with green) and mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: N/A - Now has beige rubber/vinyl

2002 Inspection Note: Removed, from Room 137, per 2002 report.

1991 Inspection Note: ACM – Room 137 (100 sf)

Explain: N/A

Building #: 1 Homogeneous Area #: 08 Date: 7/22/14 Description: 9” x 9” Floor tile (burgundy & black alternating) & mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE X ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: ACM or ACE with potential for damage. Good condition. Present in Room 127 (~ 40 ft2). Rooms 101, 101A now finished with new stone tile.

1991 Inspection Note: No asbestos detected. Rooms 101, 101A, and 127

Explain: Manage in place until impacted by planned renovations or repair activities. Abate prior to or

Building #: 1 Homogeneous Area #: 09 Date: 7/22/14 Description: 9” x 9” Floor tile (light brown) Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Centiva flooring now present in corridors 162 and 164. Carpet over concrete in Rooms 129-132.

2002 Inspection Note: Removed from Rooms 129-132, per 2002 report. No comment related to corridors 162 or 164

1991 Inspection Note: NO ASBESTOS DETECTED – 129-132 and corridors 162 and 164

Explain: N/A

Building #: 1 Homogeneous Area #: 10 Date: 7/22/14 Description: 9” x 9” Floor tile (yellow and blue alternating) & mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE X ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Approximately 12 ft2 in Room 111A – poor condition. Other tile in 111A is ceramic. Removed from Rooms 110, 407, 424, 427, 428.

2009 Inspection Note: No reference to Rooms 410, 414, 416. 2008 referenced Room 427 as abated.

Rooms 407 and 424 - good condition. Room 428 carpeted. Previous reports indicated that HA 20 is present in Rooms 407 and 428. ACM or ACE with potential for damage.

2002 Inspection Note: ACM/ACE with potential for damage. Rooms 410, 414, 416, and 424. Fair condition. Removed from Room 110, per 2002 report.

1991 Inspection Note: ACM/ACE with potential for damage. Rooms 110, 414 and 416

Explain: In poor condition. Maintain in place until practical to remove or encapsulate.

Building #: 1 Homogeneous Area #: 12 Date: 7/21 & 22/14 Description: 9” x 9” Floor tile (black and white streaks) & mastic Inspector: E. Hyde

Damaged friable surfacing ACM or ACM Significantly damaged friable surfacing ACM or ACE Damaged or significantly damaged friable miscellaneous ACM or ACE ACM or ACE with potential for damage ACM or ACE with potential for significant damage

7 Significantly Damaged Any 6 Damaged Potential for Significant Damage 5 Damaged Potential for Damage 4 Damaged Low Potential for Damage 3 Good Significant Potential for Damage

Current Inspection Comments/Condition if Changed: Carpet over concrete present in…