Environmental Narrative.pdf

VA PROJECT NUMBER

PROJECT NAME

549-21-700 EHRM Infrastructure Upgrades – Dallas, TX

SUBMITTAL Final Bid Documents SUBJECT Environmental Design Narrative

Environmental 1

1.0 Project Overview and Background

Riverfront Safety & Health, LC (Riverfront), a Service-Disabled Veteran Owned Small Business, has provided a limited mold, asbestos & lead identification field survey and abatement plan in support of the Final Bid Documents phase for the EHRM Infrastructure Upgrades Project (VA Project 549-21-700) proposed at the North Texas VA Medical Center in Dallas, Texas (The Project). The initial limited asbestos and lead inspection was performed by RSH personnel using project SOW documents as a basis for proposed work along with a generalized understanding of proposed data system distributions within buildings. Asbestos reports from the 2014 3-Year Reassessment and Update and the 2015 Lead-Based Paint Survey reports for the campus, both performed by Micro Air of Texas, Inc., were used as a baseline for The Project where possible. All work was performed under the direct supervision of a Certified Industrial Hygienist (CIH), Mr. Justin R. Rhyneer, to ensure standard EPA-NESHAP/AHERA/OSHA field inspection and sampling methods were employed for representative project inspection. Principal contacts for this project were Tanisha Jackson of the VA Medical Center and Noah Medley from Spur-Design. In addition to this initial inspection, a follow-up field investigation was carried out after the TR schedule had been completed. The focus of this second field investigation was constrained to in scope TR’s as well as areas inaccessible during the initial field visit.

The federal National Emission Standard for Asbestos (NESHAP), the VA asbestos design guide and asbestos program directive, and the Texas Asbestos Health Protection Act (TAHPA) all require that prior to any demolition or renovation activity in a building, a thorough inspection of the affected facility or part of the facility where the demolition or renovation operation will occur, must be performed for the presence of asbestos, including Category I and Category II non-friable asbestos-containing material (ACM). Additionally, TAHPA requires that a minimum of three samples be collected from each homogeneous sampling area (material type) identified in the building. The area to be renovated or demolished and adjacent areas which could possibly be disturbed by The Project must be inspected and sampled as applicable prior to renovations or demolition. While the VANTHCS, as a federal facility, is not subject to the TAHPA regulation, RSH representatives collected bulk samples in accordance with TAHPA and AHERA protocols. RSH performed onsite building inspections to identify the presence, location, quantity, and condition of all asbestos containing materials and lead bearing building components present within the pathways of The Project which may be impacted during the execution of work. Currently, RSH understands the scope of work to be as follows:

A/E Part One Services (also known as Design Phase) for this design project includes site visits, field investigation, studies, and user interviews to prepare drawings, specifications and cost estimates for all facets of work and disciplines/trades to facilitate a construction project to upgrade the facility infrastructure to support the new Electronic Health Record Modernization (EHRM) system in accordance with VA OEHRM Site Infrastructure Requirements (provided by VHA). The project shall include, but is not limited to, upgrading facility fiber throughout the buildings to each IT closet, provide a redundant fiber run throughout the facility to each IT closet, provide redundant fiber mains to the demarcation room from the provider point, design or remodel one hundred twenty six IT closets throughout the facility, at specified locations adhering to the EHRM guidelines outlined in attachments, upgrade facility HVAC and electrical distribution as required, physical security assessment and upgrades and hazardous material abatement.

The buildings in scope are Buildings 1, 2, 2J, 3, 5, 6, 7, 8, 9, 11, 13, 43, 44, 45, 60, 69, 70, 71, 72, 74, 75, 77, 79, 80, 81, 82, 87, TT46, TT47, TT48, TT49, TT50, TT51, TT52, TT54, TT55, and 3 buildings at Herzog.

2.0 Preliminary Assessment & Records Review

Originally, historical asbestos records were provided regarding known asbestos containing building materials at the VA campus for the buildings within The Project scope except buildings 12, 69, 80 - 82, and TT’s 46 - 49, 50 - 52, 54, and 55. Initially, no lead records were provided for any buildings within scope. Building 12 was later removed from The Project scope and buildings 87 and TT55 were added to scope. The missing records were requested, and historical asbestos records have now been received for all buildings except 80 - 82, and TT55. Lead records have been received for all buildings except buildings 79 – 82, and TT55. Unfortunately, RSH didn’t have access to all the historical documents before the initial site visit and was well into the survey, 549-21-700 EHRM Infrastructure Upgrades – Dallas, TX

Environmental 2 when a chance meeting between Justin Rhyneer and the Dallas site’s IH, Natalie Marjasovs, allowed RSH to obtain most of the missing files. Proper channels were used to obtain documents, meaning RSH contacted Spur with the request, which was then passed up to the VA’s COR, Tanisha Jackson. A thorough inspection, sampling, and assessment effort was performed to identify asbestos and lead containing building materials likely to be impacted by The Project. The historical records were used as a guide to assist in the inspection and design process. Field conditions were observed to verify the current validity and accuracy of the information within the reports provided. Any new suspect asbestos containing materials encountered were also assessed as to their potential to be impacted by The Project and sampled accordingly. Additionally, no information on historic or current mold conditions was provided. These assessments were also supplemented with an onsite inspection. A building-by-building summary of the provided asbestos records and future lead and mold inspection efforts needed at each building can be found in Appendix A: Historic Records Summary.

3.0 Initial RSH Asbestos Investigation Findings

Justin Rhyneer, Cody Dey, Charles Davis, and Eric Colombo performed an initial asbestos site survey in late January 2024. Each inspector carries the necessary EPA Asbestos Building Inspector certifications required by law and/or by The Contract Documents and was performed in accordance with all applicable local, State, and Federal regulations pertaining to asbestos building inspections. The RSH personnel are accredited under the Asbestos Hazard Emergency Response Act (AHERA), U.S. Environmental Protection Agency Model Accreditation Program for Asbestos Building Inspectors. 239 suspect asbestos bulk samples were collected during this initial visit to the station. Sampling locations were chosen to be representative of the accessible materials and collected randomly from all accessible areas of the buildings where material was available without destructive collection procedures.

Practical precautions were used in collecting samples to ensure the safety of all personnel. All samples were safely collected, placed in sealed containers, and transferred with a written chain-of-custody, to EMSL Analytical Inc., an AIHA & NVLAP accredited laboratory, for analysis. All samples were analyzed using polarized light microscopy (PLM) analysis with dispersion staining (DS) according to U.S. Environmental Protection Agency (EPA) Method 600 IR-93/116 which is presently recommended by the EPA. Reference Table-1 of the supporting documents for a more detailed summary of sampling efforts. Asbestos Containing Materials are defined by EPA as having greater than 1% asbestos as measured by PLM methods. Results reported as None Detected should be interpreted as having no asbestos observed within the limits of the analysis method. The suspect materials sampled were noted to be in fair to good condition. RSH was on station from January 13, 2024, through January 26, 2024.

Of the 239 samples collected, 7 revealed >1% asbestos content. Refer to Table 1 for the asbestos bulk sampling log and Appendix B for laboratory results and chain of custody forms.

This initial field investigation was carried out with the following limitations and assumptions:

1. At the time of this initial field investigation, the TR schedule for this project was not finalized. As such, sampling efforts and the visual inspection were focused solely on building envelopes. TR’s. closets, and other related areas were not looked at for this initial effort.

2. Large portions of some buildings were not accessible due to lack of a key or escort as part of this initial visit. These buildings were later accessed as part of RSH’s second field investigation.

3. Buildings 1 and 2 have large quantities of historic pipe insulation present throughout corridors and rooms.

This pipe insulation was visually inspected to the best of RSH’s ability in corridors and in-scope rooms.

Unless otherwise indicated on the Environmental drawing set, this pipe insulation is considered to be in good condition. Caution should be exercised anytime work is being performed near this pipe insulation in corridors and rooms. Damaged asbestos pipe insulation was observed on levels 2, 3, and 9 in Building 2.

As a general rule, historic records provided by the VA were accurate in regard to pipe insulation locations.

Outside of corridors and TR’s, historic records were used to identify the presence of asbestos pipe insulation.

4.0 Follow-up RSH Asbestos Investigation Findings

Charles Davis and Jamison Bear performed the follow-up asbestos site survey in mid to late August 2024 to inspect ninety proposed or existing Telecommunications Rooms (TR). Each member of the team carried the necessary EPA Asbestos Building Inspector certifications required by law and/or by The Contract Documents and were performed in accordance with all applicable local, State, and Federal regulations pertaining to asbestos building

549-21-700 EHRM Infrastructure Upgrades – Dallas, TX

Environmental 3 inspections. The RSH personnel are accredited under the Asbestos Hazard Emergency Response Act (AHERA), U.S. Environmental Protection Agency Model Accreditation Program for Asbestos Building Inspectors. 961 suspect asbestos bulk samples were collected during the follow-up visit to the station. Sampling locations were chosen to be representative of the accessible materials and collected randomly from all accessible areas of the buildings where the material was available without destructive collection procedures. Practical precautions were used in collecting samples to ensure the safety of all personnel. All samples were safely collected, placed in sealed containers, and transferred with a written chain-of-custody, to EMSL Analytical Inc., an AIHA & NVLAP accredited laboratory, for analysis. All samples were analyzed using polarized light microscopy (PLM) analysis with dispersion staining (DS) according to U.S. Environmental Protection Agency (EPA) Method 600 IR-93/116 which is presently recommended by the EPA. Reference Table 1 of the supporting documents for a more detailed summary of sampling efforts. Asbestos Containing Materials are defined by EPA as having greater than 1% asbestos as measured by PLM methods. Results reported as None Detected should be interpreted as having no asbestos observed within the limits of the analysis method.

Of the 961 samples collected, 18 revealed >1% asbestos content. Refer to Table 1 for the asbestos bulk sampling log and Appendix B for laboratory results and chain of custody forms.

This second field investigation was carried out with the following limitations and assumptions:

1. At the time of the second field investigation, RSH was informed by Spur that the TR schedule was unlikely to change going forward. All investigation efforts for the second field investigation were focused on the Telecom Rooms, closets, and other related areas, as well as a few buildings with limited access during the initial field investigation.

2. During the 95% Construction Documents submittal phase, a total of four telecommunication rooms were changed in Buildings 1, 6, TT50, and TT55 from those previously established during earlier design phases. As these rooms were added after both of RSH’s field investigation efforts, the exact makeup of these rooms is unknown. RSH has provided abatement plans for these four rooms based on historical records as well as photographs provided by Spur. All abatement in these rooms is based solely on historical records and thus, items called out for abatement may have been removed previously. It should also be noted that, during the course of construction, stop work immediately and report to COR if additional suspect materials are found within: Building 1 Room 600D, Building 6 Room 102B, Building TT50 Room 106, and Building TT55 Room 105

5.0 RSH Lead Investigation Findings

Verification of the presence of lead-based paint and other materials potentially exhibiting elevated lead levels was performed using standard XRF direct reading instruments and was performed in accordance with all applicable local, State and Federal regulations pertaining to lead building inspections. Charles Davis and Eric Columbo are EPA accredited lead risk assessors and/or inspectors.

Per both HUD Lead-Based Paint Interim Guidelines for Hazard Identification and EPA 40 CFR Part 744, Environmental Protection Agency Lead-based Paint in Target Housing and Child-Occupied Facilities, the definition of lead-based paint is paint which has a lead content of 5000 mg/kg (0.5% by weight) or greater, or 1.0 milligrams per square centimeter (mg/cm2) surface area. Texas Environmental Lead Reduction Rules (TELRR) define lead-based paint as “paint or surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter or more than 0.5% by weight”, and this applies to Target Housing and Child-Occupied Facilities. Both the HUD Guidelines and the TELRR define “Target Housing” as “any housing constructed prior to 1978, except housing for the elderly or persons with disabilities (unless any child who is six years of age or younger resides or is expected to reside in such housing) or any zero-bedroom dwelling”. These regulations define a “Child-Occupied Facility” as “a building or part of a building constructed before 1978, including but not limited to, a day-care center, preschool, or kindergarten classroom, that is visited regularly by the same child, six years of age or younger, at least two days in any calendar week if the visits are for at least three hours each day and 60 hours each year”. At this time, the above referenced HUD and TELRR regulations do not apply to the buildings inspected in this survey because it does not meet either definition of “Target Housing” or “Child-Occupied Facility.”

Currently, no federal or state regulations require the abatement of lead-based paint in buildings which are not considered to be Target Housing or Child-Occupied Facilities. However, state and federal disposal requirements apply to all demolished structures that include lead-based paint components. If structural building components that

549-21-700 EHRM Infrastructure Upgrades – Dallas, TX

Environmental 4 have lead-based paint are going to be demolished, the paint from these substrates should undergo further testing prior to disposal for leachable lead (Toxicity Characteristic Leaching Procedure (TCLP) analysis), which will determine whether any hazardous waste disposal requirements apply. This should be performed by the contractor that is responsible for demolition and disposal of demolished building materials.

It should be noted that the OSHA Construction Industry Standard, 29 CFR, 1926.62 does apply to any employee involved with demolition / renovation work that might occur in the above building. The Construction Industry Standard regulates occupational exposures to airborne lead, which includes demolition or salvage of structures where lead or materials containing lead are present, and any amount of lead present in painted surfaces, including those which fall below the above definition of lead-based paint, could result in regulated occupational exposures and should therefore be monitored according to OSHA 1926.62 whenever they are disturbed in a manner that could result in exposure to airborne lead particulates. It is the responsibility of the employer to comply with 29 CFR, 1926.62 to protect the safety and health of employees involved in the demolition or renovation of the above structure. According to OSHA, the Permissible Exposure Limit (PEL) for lead is 50 micrograms per cubic meter (μg/m3) (8-hour Time Weighted Average (TWA)) with an action limit of 30 μg/m3 8-hour TWA.

The lead investigation revealed several building components exhibiting elevated lead levels. As stated previously, historical lead records weren’t received until after the initial site visit. Therefore, many surfaces were retested. In comparison, the data generated during this site visit verifies the data found in historical records. A building-by-building summary of lead trends compiled from historical records and the initial site investigation is provided below.

Note that the data below is from targeted lead inspections and may not list all items containing elevated lead levels within buildings. Furthermore, only building components thought likely to be impacted by The Project were listed.

Reference Table 2 for the specific data generated during the initial investigation. It should be noted that due to accessibility issues roof decks and metal structural components are presumed to be positive for lead in buildings that pre-date 1978.

In general, lead issues are known to exist within the following Buildings or areas:

1. Building 1 – Widespread lead issues exist throughout all of Building 1. All plaster walls throughout Building 1 have an associated lead-based paint. As such, all jack locations are to be reused within Building 1 to avoid disturbing this lead-based paint. Any work likely to penetrate or otherwise disturb any plaster surfaces throughout Building 1 must be performed by a licensed abatement contractor. Other lead issues also exist within Building 1 but should not be impacted by The Project. Refer to H-series drawings for specifics.

2. Building 2 – Wooden building components throughout the entirety of Building 2 are presumed to have lead-based paint. Any work likely to impact wooden window frames, door frames, or other materials must be performed by a licensed abatement contractor. These materials should not be impacted by The Project.

3. Building 2J – Building 2J was constructed post-1978, meaning that lead-based paint is generally not an issue. However, Building 2J houses multiple imaging spaces. These spaces tend to have lead backing behind drywall and thus jack locations throughout Building 2J should be reused.

4. Building 3 – Lead-based paint has been identified on plaster and concrete throughout Building 3. Plaster ceilings and concrete ceiling decks will require abatement as part of The Project.

5. Building 6 – Lead-based paint has been identified on plaster ceilings and walls throughout Building 6. This material will require abatement as part of The Project.

6. Building 7 – Wooden building components throughout the entirety of Building 7 are presumed to have lead-

7. Building 8 – Lead-based paint has been identified on plaster ceilings and walls throughout Building 6. This material will require abatement as part of The Project.

549-21-700 EHRM Infrastructure Upgrades – Dallas, TX

Environmental 5

8. Building 9 – Wooden building components throughout the entirety of Building 9 are presumed to have lead-

9. Various components throughout other in-scope buildings have or are presumed to have lead-based paint.

As a rule, these items should not be impacted by work for The Project. These materials should be protected as necessary and any work likely to impact them is required to be performed by a licensed abatement contractor. Refer to Environmental drawing set for specific items.

6.0 Mold Investigation Findings

An inspection targeting visible mold growth was also performed alongside the lead and asbestos surveys in support of The Project design. Currently, no licensing requirements exist for performing mold inspections.

However, Justin Rhyneer is a Certified Industrial Hygienist, and the team, as a whole, has decades of experience assisting clients with mold related issues.

No suspect visible mold growth was observed in any buildings investigated during the site investigation.

Inspectors did note water damage in the basement corridor of Building 3. RSH had very limited access to areas in the building, so it is unknown if this is part of a larger issue or just a localized event as heavy rains were affecting the area. No suspect mold growth was observed at the location. However, water staining was observed on ceiling tiles, and water damage to floors and walls, indicating this is an ongoing problem, at least at this specific location.

7.0 RSH Asbestos, Lead, and Mold Field Investigation Summary

• While the historical records provided by the VA were both accurate and helpful, RSH was able to identify new materials throughout the project scope of work areas that were previously unidentified. These materials include floor tiles, mastic, and soil debris. Review of the historic asbestos documents indicates that the largest scope of asbestos remediation will most likely be necessary at Buildings 1, 2, 3, 5, 6, 8, 9, 11, 13, 43, 44, and the Main and Motor Pool Buildings at the Herzog campus. These buildings all have the distinction of being constructed prior to 1978. Building 7 seems to be an exception to this trend, which makes sense as it received a gut renovation in 2003. Project buildings constructed after 1978 are largely devoid of asbestos-containing materials and the asbestos-containing materials that are present should be able to be protected in place for the most part.

• It is presumed that an asbestos-containing black vapor barrier mastic exists on the interior side of all exterior walls at all buildings within Project scope regardless of age with the exception of the TT trailers, which are of a different type of construction. Furthermore, it is also presumed that an asbestos-containing waterproofing exists below grade on the exterior side of these walls as well. A licensed Abatement Contractor will be required to perform any needed penetrations through exterior walls of the buildings.

These penetrations are typically needed by Electrical, Mechanical, Plumbing, and Telecommunications Contractors to route conduits or ducts between buildings or to equipment such as HVAC condensers.

• It is presumed that asbestos-containing roofing materials exist on all roofing components. These materials are typically not sampled during asbestos inspections as this tends to void any warranties on the installed materials. Any impacts or penetrations to these materials will require abatement by a licensed Abatement Contractor. These penetrations are typically needed by Electrical, Mechanical, Plumbing, and Telecommunications Contractors to route conduits or ducts between areas within buildings to equipment such as HVAC condensers.

• All doors being impacted by The Project are presumed to be asbestos-containing fire doors and will require abatement by a licensed Abatement Contractor.

• Buildings 1 and 2 specifically have large quantities of asbestos pipe insulation. This insulation, unless otherwise noted on the Environmental drawing set, is in good condition. This pipe insulation, where it is likely to be impacted, will require abatement by a licensed abatement contractor. Additionally, multiple areas throughout Building 2 have damaged or severely damaged pipe insulation; these areas will require abatement to make these areas safe for future above-ceiling work.

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Environmental 6

• All crawlspaces throughout in-scope buildings are presumed to be contaminated with asbestos debris.

This crawlspace soil will not be impacted by work related to The Project in most buildings unless otherwise noted on the Environmental drawing set. Any work likely to impact these crawlspaces must be performed by a licensed abatement contractor.

• Where new building penetrations are necessary for interbuilding fiber lines, asbestos containing waterproofing tar is presumed present within wall voids. Any penetrations into or through these wall voids must be performed by a licensed abatement within a negative pressure enclosure.

• Several components exhibiting elevated lead levels either in paint or ceramic glazings were discovered or highlighted within historical documents. Generally, these materials will not be impacted and will be able to be protected in place. An Abatement Contractor will be required to provide penetrations through interior walls and attachment points for the routing of conduits, ducts, and cable ways/trays. As expected, it is pre-1978 construction that requires the most abatement. Buildings 1, 2, 3, 5, 6, 7, 8, 9, 9, 11, 13, 43, 44, and the Main and Motor Pool Buildings at the Herzog campus will require some abatement to provide penetrations and attachment points. Paint stabilization is a definite requirement at Building 13. Buildings that exhibited lead past the 1978 construction date exhibited it as lead-based glazing in ceramic wall tiles.

It is not likely that these materials will be impacted by The Project.

• At the time of this submittal, it does not appear that mold will be a driver for this project. As noted above, material staining due to water infiltration was noted during the initial site visit.

In closing, Riverfront appreciates the opportunity to assist with this project. It is our intent that this information will assist with project development at this phase. Please feel free to contact us with any questions or concerns.

Sincerely, March 10, 2025 Justin R. Rhyneer, CIH Date Principal

Table 1: Asbestos Bulk Sampling Data Log Table 2: XRF Data Log Appendix A: Historical Records Summary Appendix B: Laboratory Chains of Custody and Results Appendix C: Professional Certifications