Attachment 11 - Cheyenne VA - Asbestos Report.pdf

ASBESTOS REINSPECTION REPORT

LOCATION:

CHEYENNE VA MEDICAL CENTER

2360 E PERSHING BLVD.

CHEYENNE, WY 82001

CONTRACT NO.: 36C25923Q0452

INSPECTION DATES:

DECEMBER 4-6, 2023

CONTRACTOR:

CASTLE HILL ASSOCIATES, LLC

1197 FARNSWORTH – SUITE E

WATERVILLE, OH 43566

567-952-0212

CHEYENNE VA MEDICAL CENTER - CHEYENNE, VA

DECEMBER 2023

TABLE OF CONTENTS

1.0 ASBESTOS INSPECTION REPORT

• Table 1 – List of Acronyms

• Table 2 - Removal Priority Protocols

2.0 APPENDICES

Appendix A – Asbestos Sampling Data 2018

Appendix B – Asbestos Quantities, Assessments, & Remediation Cost Estimate

Appendix C – Photographs Asbestos Materials

Appendix D – Asbestos Laboratory Reports

Appendix E - Inspector Certifications

Appendix F – Asbestos Material Locations & Sample Location Drawings

Appendix G – O&M Plan (Operations & Maintenance)

DECEMBER 2023

1.0 EXECUTIVE SUMMARY

On December 4-6, 2023, Castle Hill Associates, LLC was contracted by the US Department of Veterans Affairs (VA) to perform asbestos re-inspections of 15 buildings on the site of the Cheyenne VA Medical Center in Cheyenne, VA. The survey was performed as part of the VA Contract Number 36C25923Q0452. The buildings that were surveyed as part of this project included:

Building Number

Building Name/Description

ASBESTOS

PRESENT?

1 Main Hospital Yes 1-CA Main Hospital – Clinical Addition No 1-CX Main Hospital – Physical Therapy No

4 Offices – Fiscal and AM&M Yes 5 Office – Human Resources Yes 6 Former Quarters/Offices Yes 7 Former Quarters/Offices Yes 8 Offices Yes

11 Engineering & Shops Yes 12 Supply Warehouse No 13 Boiler Plant Yes 18 Garage No 19 Storage-Grounds Yes 20 Storage Garages Yes 23 Grounds Shop No 25 Garage Yes 26 Garage Yes

The inspection was conducted by Brett Brumbaugh and Samuel Ansara. The project manager was Mr.

Brumbaugh who has been conducting asbestos surveys, sampling, and consulting work since 1987.

Sam Ansara has been conducting asbestos surveys, sampling, and consulting work since 1989. There was a previous asbestos reinspection/sampling conducted at the facility in 2013 and 2018. These previous inspections were reviewed by Castle Hill prior to this inspection and incorporated into this report. There were no limitations or exceptions to the PWS for the surveys conducted. Roofing materials were not tested and must be assumed to be present on all buildings until tested prior to future renovations.

All accessible functional areas in the facilities were surveyed. All previous asbestos survey information and sampling conducted at the facilities were evaluated and incorporated into this survey. All confirmed asbestos-containing materials were verified. This report can be incorporated into the facility’s management plan for asbestos-containing materials.

2.0 STATE AND LOCAL REGULATIONS

The State of Wyoming asbestos licensing regulations are similar to the Federal regulations. State asbestos regulations include requirements for licensing and certification of personnel who will perform asbestos-related work activities. All personnel who engage in asbestos-related activities must comply with the state licensing/certification requirements as well as with all Federal requirements.

3.0 SUMMARY OF FINDINGS

3.1 Asbestos-Containing Building Materials

The following is a summary of the asbestos containing materials, locations, quantities of materials in each inspected building for this project:

Building 1 – Main Hospital

Asbestos Containing Materials Locations Quantity Contaminated soil with pipe insulation debris

Crawl Spaces under building 37,500 sf

Pipe insulation CL-02C hallway, pipe chases by CL-04 and CL-17, C1-102, D1-36A closet, D1-47, D1-50G, D1-50J

68 lf

Hard ceiling plaster C1-92 Entry & C1-95 Lobby 1,440 sf

9” floor tile D1-36A closet, D1-15 storage, D1-41 80 sf

Ebony cement countertops & shelves D1-53 Dental Lab 90 sf

Drywall joint compound Attic 4-OL & 4-OK divider wall 628 sf

Black tar on FG Duct Insulation D1-15, N. basement Crawl 560 sf

Cove base mastic (brown cove base) D2-38 80 lf

Building 1-CA Clinical Addition

No asbestos containing materials identified in building.

Building 1-CX Physical Therapy Addition

Building 4 – Offices (Fiscal and AM&M)

Contaminated soil under concrete cap Crawl Spaces 2,860 sf

Pipe insulation Basement Storage Rooms B1, B2, and B4 415 lf

Skim coating on concrete walls Basement rooms B1, B1A, B2, B3, B4 and

1,440 sf

Hard ceiling & wall plaster

1st & 2nd floor rooms 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, S1F1, 200, 201, 203, S1F2

11,220 sf

Building 5 – Offices (Human Resources)

Transite cement sheets Basement furnace room B1 16 sf

Drywall joint compound First floor rooms 101, 102, 103, 104, 105, 106, 107, 108, C1, C2, S1F1

4,160 sf

Building 6 – Offices (former quarters)

Contaminated soil under concrete cap 2 Crawl Spaces 776 sf

Pipe insulation Basement Storage Room 001 20 lf

Building 7 – Offices (former quarters)

Hard ceiling & wall plaster Basement, 1st & 2nd floor rooms B01, B02, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, S1F2, 201

3,430 sf

Linoleum sheet flooring Kitchen 104 168 sf

Building 8 – Offices (former quarters)

9” floor tile Basement Storage B01 80 sf

Drywall joint compound 1st floor entry 100 846 sf

Building 11 – Engineering and Shops

Pipe insulation (remaining stubs in sleeves) Elect. shop 103 (S.W. corner) 2 lf

Hard ceiling plaster Paint shops 105, 106, 107, and closet

770 sf

Glue pods for non-ACM 12” ceiling tiles (above 2x4 lay-in ceiling tile)

2nd floor offices 212 and 212A 384 sf

Building 12 – Supply Warehouse

Building 13 – Boiler Plant

Pipe insulation Tunnel under driveway to Building 11 90 lf

Skim coating on concrete walls Basement Room B-107 320 sf

Building 18 – Garage

Building 19 – Storage/Grounds

Window Glazing/Putty Metal Windows 4 windows

Building 20 – Storage Garages

Window Caulking Metal Windows 10 windows

Building 23 – Grounds Shop

Building 25 –Garage

Window Caulking Metal Windows 1 window

Building 26 –Garage

Window Caulking Metal Windows 2 windows

Building 42 – Storage Building

Building 45 – VBA Veterans Benefits

4.0 Explanation of Assessment of Asbestos Containing Materials

Re-inspection protocol is based on the Asbestos Hazard Emergency Response Act (AHERA), Environmental Protection Act’s (EPA’s) revised Asbestos Model Accreditation Plan (MAP) mandated by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA), and the Department of Veterans Affairs (VA) Directive 7700. The tabular listing included in this report contains Building Number, Floor, Room Number, Material Category (i.e., TSI, SM or MM), Material Type, quantity, a numerical priority ranking, condition, potential for damage, potential for human exposure, drawing number, hazard ranking, recommended response action and associated cost estimate for implementation of those response actions.

The material assessment categories of the ACM identified in the building is formatted in the following order for the summary tables enclosed in this report:

• Material Category - Surfacing Material (SUR); Thermal System Insulation (TSI); Miscellaneous (MM)

• Material Type - Friable (F); Non-Fable (NF)

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

• Recommended Response Action - 1 through 7

Material category is the type of material such as surfacing material (SUR), thermal system insulation (TSI), and miscellaneous (MM)

• Surfacing Material (SUR) - Surfacing ACM means surfacing material that is ACM. Surfacing material means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

• Thermal System Insulation (TSI) - Thermal system insulation ACM means thermal system insulation that is ACM. Thermal system insulation means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

• Miscellaneous (MM) - Miscellaneous ACM means miscellaneous material that is ACM Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

Material type refers to the hardness of a material to be crumbled, pulverized, or reduced to powder by hand pressure as friable (F), and includes previously non-friable (NF) material after such previously non-friable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

Seven Assessment Categories defined in the AHERA regulation, one of which must be assigned to each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI during the inspection/re-inspection.

1. Damaged or significantly damaged TSI ACBM - Damaged or significantly damaged thermal system insulation ACM means thermal system insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation equipment where the insulation has lost its structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by occasional punctures, gouges or other signs of physical injury to ACM; occasional water damage on the protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris originating from the ACBM in question may also indicate damage.

2. Damaged friable surfacing ACBM - Damaged friable surfacing ACM means friable surfacing ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or which has delaminated such that its bond to the substrate (adhesion) is inadequate, or which, for any other reason, lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

3. Significantly damaged friable surfacing ACBM - Significantly damaged friable surfacing ACM means damaged friable surfacing ACM in a functional space where the damage is extensive and severe.

4. Damaged or significantly damaged friable miscellaneous ACBM - Damaged friable miscellaneous ACM means friable miscellaneous ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

5. ACBM with Potential for Damage - Potential damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

6. ACBM with potential for significant damaged - Potential significant damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become significantly damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

7. Any remaining friable ACBM or Friable Suspected ACBM

5.0 EXPLANATION OF REMEDIATION COST ESTIMATES

All remediation cost (removal and repair) estimates are based upon RS Means data. Since RS Means does not account for work in a VA Medical Center, all cost estimates are adjusted to reflect the VA specific requirements for abatement. In addition, the cost estimates reflect the quantity and location of the asbestos materials. For example, abatement work in crawl spaces is expected to be much more costly than work in more accessible areas of building. Also, the costs for each material in each building are intended to be for “stand alone” projects and the combination of areas for removal will reduce the costs due to an economy of scale.

6.0 CONCLUSION/RECOMMENDATIONS

An operations and maintenance (O&M) program has been developed by the VAMC specifically for the positively identified ACBM in the facilities. Any renovation/demolition work which may impact these positive materials should be conducted in accordance with the O&M program and all applicable Federal, state, and local regulations by appropriately trained and VA-approved personnel and contractors. Since demolition was not performed as part of the inspection work at the facilities, certain areas such as pipe chases and areas above fixed permanent ceilings, fire-door interiors, and vault/safe wall and door linings were not inspected or tested. Prior to renovation and alteration work which could impact these areas, Castle Hill recommends that exploratory demolition be performed and a qualified inspector be utilized to examine the areas and collect samples as needed. Castle Hill recommends sampling of roofing materials and electrical components (not specifically examined as part of this survey) if renovation activities are planned which may disturb these materials.

Inspector Signature:

Brett L. Brumbaugh, REPA, CESCO

Asbestos Bldg. Inspector & Management Planner

Samuel D. Ansara

TABLE 1

LIST OF ACRONYMS

ACBM Asbestos Containing Building Material ACM Asbestos Containing Material AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association CAA Clean Air Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency HazCom Hazard Communication HEPA High Efficiency Particulate Air Filter HVAC Heating, Ventilation, and Air Conditioning MISC Miscellaneous Asbestos Containing Material NESHAP National Emission Standards for Hazardous Air Pollutants NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology NOB Non-friable Organically Bound NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PAT AIHA Proficiency Analytical Testing Program PCM Phase Contrast Microscopy PEL Permissible Exposure Limit PLM Polarized Light Microscopy TEM Transmission Electron Microscopy TSCA Toxic Substances Control Act TSI Thermal Systems Insulation Castle Hill Castle Hill Associates, LLC VA United States Department of Veterans Affairs VAMC VA Medical Center XRD X-Ray Diffraction

TABLE 2

ASBESTOS REMOVAL PRIORITY PROTOCOLS

HAZARD

RANK

REMOVAL

PRIORITY

AHERA

CATEGORY

RESPONSE ACTION

RECOMMENDATION

7 1 Significantly Damaged

Evacuate or isolate the area.

Remove or repair if feasible. O&M for all friable ACM.

6 2 Damaged with potential for significant damage

Evacuate or isolate the area.

Remove, encapsulate, or repair if feasible. O&M for all friable ACM.

5 3 Damaged with potential for damage

Remove, encapsulate, or repair.

O&M for all friable ACM.

4 4 Damaged Remove, encapsulate, or repair.

O&M for all friable ACM.

3 5 Potential for significant damage

Take steps to reduce potential for damage. O&M for all friable ACM.

2 6 Potential for damage O&M for all friable ACM.

1 7 No problem O&M for all friable ACM.

APPENDIX A

ASBESTOS BULK SAMPLING DATA

NOVEMBER 2018

ASBESTOS BULK SAMPLING INFORMATION

Facility: Cheyenne VA Medical Center – Cheyenne, VA Building: 1 Sampling Date: November 5, 2018 Analysis Date: November 12, 2018 Laboratory: EMLab P&K – Marlton, NJ Accreditation: NVLAP Asbestos Bulk Accredited Laboratory # 200844-0 Sampler: Brett Brumbaugh Certification: EPA Accredited Asbestos Inspector/Management Planner

PLM Laboratory Analysis Result

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1 Asphalt tar paper under slate shingle Attic No asbestos detected

2a 9” tan vinyl floor tile D2-38 mechanical room No asbestos detected

2b Black tar paper under tile “” No asbestos detected

2c Yellow mastic under tar paper “” No asbestos detected

3a 9” green floor tile D1-36 conf. room closet 4% Chrysotile Asbestos

3b Black mastic “” No asbestos detected

4a 9” tan floor tile D1-15 food storage room 6% Chrysotile Asbestos

4b Black mastic “” No asbestos detected

C3 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos

C4 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos

C6 Pipe insulation debris in soil Crawl space 30% Chrysotile Asbestos

C7 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos

C8 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos

EPA Definition of an asbestos containing material: Greater than 1% asbestos

ASBESTOS BULK SAMPLING INFORMATION

Facility: Cheyenne VA Medical Center – Cheyenne, VA Building: 1 Sampling Date: November 5, 2018 Analysis Date: November 21, 2018 Laboratory: EMLab P&K – Arvada, CO Accreditation: NVLAP Asbestos Bulk Accredited Laboratory # 500053-0 Sampler: Brett Brumbaugh Certification: EPA Accredited Asbestos Inspector/Management Planner

PLM Point Count Laboratory Analysis Result (CARB 435)

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

C1 Loose soil in crawl space Crawl space 1-A No Asbestos Detected

C2 Loose soil in crawl space Crawl space 1 <0.25% Chrysotile Asbestos

C5 Loose soil in crawl space Crawl space 1-B No Asbestos Detected

APPENDIX B

Asbestos Quantities, Assessments, & Remediation Cost Estimates

APPENDIX C

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 1

Photo 1-1

Pipe insulation debris in crawl space on loose soil

Photo 1-2

Photo 1-3

Photo 1-4

Photo 1-5

Ebony cement lab table tops and shelves in Dental Lab D1-

Photo 1-6

9” tan floor tile in Canteen storage room D1-15

Photo 1-7

9” green floor tile in conference room closet D1-36

Photo 1-8

Pipe insulation in basement

Photo 1-9

Hard plaster ceiling in Cowboy Building Lobby

Photo 1-10

Drywall joint compound in Attic

BUILDING 4

Photo 4-1 storage rooms

Photo 4-2

Asbestos debris in crawl space under concrete cap

Photo 4-3

Skim coat on concrete walls in basement

Photo 4-4

Hard plaster on ceilings and walls

BUILDING 5

Photo 5-1

Transite cement sheets above furnace in basement storage room B1

Photo 5-2

Drywall joint compound on 1st floor

BUILDING 6

Photo 6-1 storage room 001

Photo 6-2

BUILDING 7

Photo 7-1

Linoleum sheet flooring in kitchen/break room

Photo 7-2

Hard plaster on walls and ceilings

BUILDING 8

Photo 8-1

9” floor tile in basement storage room B01

Photo 8-2 entry

BUILDING 11

Photo 11-1

Pipe iinsulation in electrical shop

Photo 11-2 Hard ceiling plaster

Photo 11-3 Glue pods for 12” ceiling tile

BUILDING 13

Photo 13-1

Steam pipe insulation in tunnel from basement to

Building 11 under driveway

Photo 13-2

Skim coating on concrete walls in basement storage

BUILDING 19

Photo 19-1

Window glazing/putty on metal windows

BUILDINGS 20, 25, AND 26

Photo 1

Window frame caulking on

Photo 2

Photo 3

APPENDIX D

ASBESTOS LABORATORY REPORTS

APPENDIX E

INSPECTOR CERTIFICATIONS

APPENDIX F

ASBESTOS MATERIAL LOCATIONS & SAMPLE LOCATION

DRAWINGS

APPENDIX G

O&M PLAN

(OPERATIONS & MAINTENANCE)

ASBESTOS O&M PLAN

NOVEMBER 2018

ASBESTOS O&M PLAN

Page 1 of

4.0 Explanation of Assessment of Asbestos Containing Materials

Re-inspection protocol is based on the Asbestos Hazard Emergency Response Act (AHERA), Environmental Protection Act’s (EPA’s) revised Asbestos Model Accreditation Plan (MAP) mandated by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA), and the Department of Veterans Affairs (VA) Directive 7700. The tabular listing included in this report contains Building Number, Floor, Room Number, Material Category (i.e., TSI, SM or MM), Material Type, quantity, a numerical priority ranking, condition, potential for damage, potential for human exposure, drawing number, hazard ranking, recommended response action and associated cost estimate for implementation of those response actions.

The material assessment categories of the ACM identified in the building is formatted in the following order for the summary tables enclosed in this report:

• Material Category - Surfacing Material (SUR); Thermal System Insulation (TSI); Miscellaneous (MM)

• Material Type - Friable (F); Non-Fable (NF)

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Recommended Response Action - 1 through 7

Material category is the type of material such as surfacing material (SUR), thermal system insulation (TSI), and miscellaneous (MM)

• Surfacing Material (SUR) - Surfacing ACM means surfacing material that is ACM. Surfacing material means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

• Thermal System Insulation (TSI) - Thermal system insulation ACM means thermal system insulation that is ACM. Thermal system insulation means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

• Miscellaneous (MM) - Miscellaneous ACM means miscellaneous material that is ACM Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

Material type refers to the hardness of a material to be crumbled, pulverized, or reduced to powder by hand pressure as friable (F), and includes previously non-friable (NF) material after such previously non-friable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

Seven Assessment Categories defined in the AHERA regulation, one of which must be assigned to each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI during the inspection/re-inspection.

1. Damaged or significantly damaged TSI ACBM - Damaged or significantly damaged thermal system insulation ACM means thermal system insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation equipment where the insulation has lost its structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by occasional punctures, gouges or other signs of physical injury to ACM; occasional water damage on the protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris originating from the ACBM in question may also indicate damage.

2. Damaged friable surfacing ACBM - Damaged friable surfacing ACM means friable surfacing ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or which has delaminated such that its bond to the substrate (adhesion) is inadequate, or which, for any other reason, lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

3. Significantly damaged friable surfacing ACBM - Significantly damaged friable surfacing ACM means damaged friable surfacing ACM in a functional space where the damage is extensive and severe.

4. Damaged or significantly damaged friable miscellaneous ACBM - Damaged friable miscellaneous ACM means friable miscellaneous ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

5. ACBM with Potential for Damage - Potential damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

6. ACBM with potential for significant damaged - Potential significant damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become significantly damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

7. Any remaining friable ACBM or Friable Suspected ACBM

5.0 EXPLANATION OF REMEDIATION COST ESTIMATES

All remediation cost (removal and repair) estimates are based upon RS Means data. Since RS Means does not account for work in a VA Medical Center, all cost estimates are adjusted to reflect the VA specific requirements for abatement. In addition, the cost estimates reflect the quantity and location of the asbestos materials. For example, abatement work in crawl spaces is expected to be much more costly than work in more accessible areas of building. Also, the costs for each material in each building are intended to be for “stand alone” projects and the combination of areas for removal will reduce the costs due to an economy of scale.

6.0 CONCLUSION/RECOMMENDATIONS

An operations and maintenance (O&M) program has been developed by the VAMC specifically for the positively identified ACBM in the facilities. Any renovation/demolition work which may impact these positive materials should be conducted in accordance with the O&M program and all applicable Federal, state, and local regulations by appropriately trained and VA-approved personnel and contractors. Since demolition was not performed as part of the inspection work at the facilities, certain areas such as pipe chases and areas above fixed permanent ceilings, fire-door interiors, and vault/safe wall and door linings were not inspected or tested. Prior to renovation and alteration work which could impact these areas, Castle Hill recommends that exploratory demolition be performed and a qualified inspector be utilized to examine the areas and collect samples as needed. Castle Hill recommends sampling of roofing materials and electrical components (not specifically examined as part of this survey) if renovation activities are planned which may disturb these materials.

Brett L. Brumbaugh, REPA, CESCO

TABLE 1

LIST OF ACRONYMS

ACBM Asbestos Containing Building Material ACM Asbestos Containing Material AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association CAA Clean Air Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency HazCom Hazard Communication HEPA High Efficiency Particulate Air Filter HVAC Heating, Ventilation, and Air Conditioning MISC Miscellaneous Asbestos Containing Material NESHAP National Emission Standards for Hazardous Air Pollutants NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology NOB Non-friable Organically Bound NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PAT AIHA Proficiency Analytical Testing Program PCM Phase Contrast Microscopy PEL Permissible Exposure Limit PLM Polarized Light Microscopy TEM Transmission Electron Microscopy TSCA Toxic Substances Control Act TSI Thermal Systems Insulation Castle Hill Castle Hill Associates, LLC VA United States Department of Veterans Affairs VAMC VA Medical Center XRD X-Ray Diffraction

TABLE 2

ASBESTOS REMOVAL PRIORITY PROTOCOLS

HAZARD

RANK

REMOVAL

PRIORITY

AHERA

CATEGORY

RESPONSE ACTION

RECOMMENDATION

7 1 Significantly Damaged

Evacuate or isolate the area.

Remove or repair if feasible. O&M for all friable ACM.

6 2 Damaged with potential for significant damage

Evacuate or isolate the area.

Remove, encapsulate, or repair if feasible. O&M for all friable ACM.

5 3 Damaged with potential for damage

Remove, encapsulate, or repair.

O&M for all friable ACM.

4 4 Damaged Remove, encapsulate, or repair.

O&M for all friable ACM.

3 5 Potential for significant damage Take steps to reduce potential for damage. O&M for all friable ACM.

2 6 Potential for damage O&M for all friable ACM.

1 7 No problem O&M for all friable ACM.

DECEMBER 2023

APPENDIX A

ASBESTOS BULK SAMPLING DATA

DECEMBER 2023

ASBESTOS BULK SAMPLING INFORMATION

Facility: Cheyenne VA Medical Center – Cheyenne, VA Building: 1 Sampling Date: November 5, 2018 Analysis Date: November 12, 2018 Laboratory: EMLab P&K – Marlton, NJ Accreditation: NVLAP Asbestos Bulk Accredited Laboratory # 200844-0 Sampler: Brett Brumbaugh Certification: EPA Accredited Asbestos Inspector/Management Planner

PLM Laboratory Analysis Result

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1 Asphalt tar paper under slate shingle Attic No asbestos detected

2a 9” tan vinyl floor tile D2-38 mechanical room No asbestos detected

2b Black tar paper under tile “” No asbestos detected

2c Yellow mastic under tar paper “” No asbestos detected

3a 9” green floor tile D1-36 conf. room closet 4% Chrysotile Asbestos

3b Black mastic “” No asbestos detected

4a 9” tan floor tile D1-15 food storage room 6% Chrysotile Asbestos

4b Black mastic “” No asbestos detected

C3 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos

C4 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos

C6 Pipe insulation debris in soil Crawl space 30% Chrysotile Asbestos

C7 Pipe insulation debris in soil Crawl space 45% Chrysotile Asbestos

C8 Pipe insulation debris in soil Crawl space 40% Chrysotile Asbestos

Facility:

Building:

Sampling Date:

Analysis Date:

Laboratory:

Accreditation:

Sampler:

Certification:

CHEYENNE VA MEDICAL CENTER - CHEYENNE, VA

ASBESTOS REINSPECTION REPORT

DECEMBER 2023

ASBESTOS BULK SAMPLING INFORMATION

Cheyenne VA Medical Center – Cheyenne, VA Bldg. 1 November 5, 2018 November 21, 2018 EMLab P&K – Arvada, CO NVLAP Asbestos Bulk Accredited Laboratory # 500053-0 Brett Brumbaugh EPA Accredited Asbestos Inspector/Management Planner

PLM Point Count Laboratory Analysis Result (CARB 435)

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

C1 Loose soil in crawl space Crawl space 1-A No Asbestos Detected

C2 Loose soil in crawl space Crawl space 1 <0.25% Chrysotile Asbestos

C5 Loose soil in crawl space Crawl space 1-B No Asbestos Detected

DECEMBER 2023

APPENDIX B

Asbestos Quantities, Assessments, & Remediation Cost Estimates

Cheyenne VAMC - Cheyenne, WY Building 1

Asbestos Assessments and Cost Estimates December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment

Recommendation Removal Priority

Repair Cost Estimate

Removal Cost Estimate

Contaminated soil from pipe insulation debris Crawl Spaces 35,500 sf TSI Friable 7 Isolate crawl spaces and place signs at all entrances. Require PPE for entrance to crawl. Encapsulate soil or remove.

1 $220,000 $916,000

Pipe insulation CL-02C hallway, pipe chases by CL-04 and CL- 17, C1-102, D1-36A closet, D1-47, D1-50G, D1- 50J

68 lf TSI Friable 2 O&M; Remove at renovation or demolition 6 No damage $6,500

Hard ceiling plaster C1-92 Entry 1,440 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $96,000

9” floor tile D1-36A closet, D1-15 storage, D1-41 80 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $3,200

Ebony cement countertops & shelves D1-53 Dental Lab 90 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $3,800

Drywall joint compound Attic 4-OL & 4-OK divider wall 628 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $8,200

Black tar on FG Duct Insulation D1-15, N. basement Crawl 560 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $22,500

Cove base mastic (brown cove base) D2-38 80 lf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $4,500

Building 4

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Contaminated soil under concrete cap Crawl Spaces 2,860 sf TSI Non-friable 1 O&M; Remove at demolition 7 No damage $94,000

Pipe insulation Basement Storage Rooms B1, B2, and B4 415 lf TSI Friable 2 O&M; Remove at renovation or demolition 6 No damage $22,000

Skim coating on concrete walls Basement rooms B1, B1A, B2, B3, B4 and

1,440 sf SURFACING Non-friable 1

O&M; Remove at renovation or demolition 7 No damage $26,000

Hard ceiling & wall plaster

1st & 2nd floor rooms 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 114, 115, S1F1, 200, 201, 203, S1F2

11,220 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $132,000

Building 5

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Transite cement sheets Basement furnace room B1 16 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $3,200

Drywall joint compound First floor rooms 101, 102, 103, 104, 105, 106, 107, 108, C1, C2, S1F1 4,160 sf MISC Non-friable 2

O&M; Remove at renovation

6 No damage $28,000

Building 6

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Contaminated soil under concrete cap 2 Crawl Spaces 776 sf TSI Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $58,000

Pipe insulation Basement Storage Room 001 20 lf TSI Friable 4 O&M; Remove at renovation

4 No damage $3,750

Building 7

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Hard ceiling & wall plaster

Basement, 1st & 2nd floor rooms B01, B02, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, S1F2, 201

3,430 sf SURFACING Non-friable 2 O&M; Remove at renovation or demolition 6 No Damage $62,000

Linoleum sheet flooring Kitchen 104 168 sf MISC Non-friable 1 O&M; Remove at renovation

7 No Damage $3,200

Building 8

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

9” floor tile Basement Storage B01 80 sf MISC Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $3,000

Drywall joint compound 1st floor entry 100 846 sf MISC Non-friable 2 O&M; Remove at renovation or demolition 6 No damage $8,460

Building 11

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Pipe insulation (remaining stubs in sleeves) Elect. shop 103 (S.W. corner) 2 lf TSI Friable 1 O&M; Remove at renovation or demolition 7 No damage $2,500

Hard ceiling plaster Paint shops 105, 106, 107, and closet 214 770 sf SURFACING Non-friable 1 O&M; Remove at renovation or demolition 7 No damage $9,500

Glue pods for non-ACM 12” ceiling tiles (above 2x4 lay-in ceiling tile) 2nd floor offices 212 and 212A 384 sf MISC Non-friable 1

O&M; Remove at renovation or

7 No damage $7,200

Building 13

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Pipe insulation Tunnel under driveway to Building

90 lf TSI Friable 2

Restrict access to tunnel with proper

PPE; O&M until removal at renovation or demolition

6 No damage $32,000

Skim coating on concrete walls Basement Room B-107 320 sf SURFACING Non-friable 2 O&M; Remove at renovation or

6 No damage $8,200

Building 19

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window Glazing/Putty Metal windows 4 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $4,000

Building 20

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Metal windows 10 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $5,000

Building 25

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Metal windows 1 window MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $2,500

Building 26

Asbestos Assessments and Cost Estimates

December 2023

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation Removal Priority

Repair Cost

Estimate

Removal

Cost

Estimate

Window caulking Metal windows 2 windows MISC Non-friable 1 O&M; Remove at renovation or

7 No damage $2,500

DECEMBER 2023

APPENDIX C

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 1

Photo 1-1 Pipe insulation debris in crawl space on loose soil

Photo 1-2 Pipe insulation debris in crawl space on loose soil

Photo 1-3 Pipe insulation debris in crawl space on loose soil

Photo 1-4

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 1

Photo 1-5 Ebony cement lab table tops and shelves in Dental Lab D1-

Photo 1-6 9” tan floor tile in Canteen storage room D1-15

Photo 1-7 9” green floor tile in conference room closet D1-36

Photo 1-8

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 1

Photo 1-9 Hard plaster ceiling in

Cowboy Building Lobby

Photo 1-10

Attic

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 4

Photo 4-1 Pipe insulation in basement storage rooms

Photo 4-2 Asbestos debris in crawl space under concrete cap

Photo 4-3 Skim coat on concrete walls in basement

Photo 4-4 Hard plaster on ceilings and walls

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 5

Photo 5-1 Transite cement sheets above furnace in basement storage room B1

Photo 5-2 Drywall joint compound on 1st floor

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 6

Photo 6-1 Pipe insulation in basement storage room 001

Photo 6-2

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 7

Photo 7-1 Linoleum sheet flooring in kitchen/break room

Photo 7-2 Hard plaster on walls and ceilings

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 8

Photo 8-1 9” floor tile in basement storage room B01

Photo 8-2 entry

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 11

Photo 11-1 Pipe iinsulation in electrical shop

Photo 11-2 Hard ceiling plaster

Photo 11-3 Glue pods for 12” ceiling tile

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 13

Photo 13-1 Steam pipe insulation in tunnel from basement to

Building 11 under driveway

Photo 13-2 Skim coating on concrete walls in basement storage

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDING 19

Photo 19-1 Window glazing/putty on

DECEMBER 2023

PHOTOGRAPHS OF ASBESTOS MATERIALS

BUILDINGS 20, 25, AND 26

Photo 1 Window frame caulking on metal windows

Photo 2 Window frame caulking on metal windows

Photo 3

DECEMBER 2023

APPENDIX D

ASBESTOS LABORATORY REPORTS

Approved by:

Approved Signatory Balu Krishnan

Report for:

Mr. Brett Brumbaugh, REPA Castle Hill Associates PO Box 283 Waterville, OH 43566

Regarding: Project: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

EML ID: 2038295

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the items tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 11-12-2018

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267)

EMLab ID: 2038295, Page 1 of 4EMLab P&K, LLC

EMLab P&K 3000 Lincoln Drive East, Suite A, Marlton, NJ 08053

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Total Samples Submitted: 9 Total Samples Analyzed: 9

Total Samples with Layer Asbestos Content > 1%: 7

Location: 1, Roofing Felt Lab ID-Version‡: 9619113-1

Sample Layers Asbestos Content Black Roofing Felt ND

Composite Non-Asbestos Content: 50% Cellulose Sample Composite Homogeneity: Good

Location: 2, Floor Tile & Mastic Lab ID-Version‡: 9619114-1

Sample Layers Asbestos Content Tan Floor Tile ND

Brown/Black Felt Padding ND Yellow Mastic ND

Composite Non-Asbestos Content: 70% Cellulose Sample Composite Homogeneity: Good

Location: 3, Floor Tile Lab ID-Version‡: 9619115-1

Sample Layers Asbestos Content Green Floor Tile 4% Chrysotile

Black Mastic ND Composite Non-Asbestos Content: 2% Cellulose Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 2 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Location: 4, Floor Tile Lab ID-Version‡: 9619116-1

Sample Layers Asbestos Content Cream Floor Tile 6% Chrysotile

Black Mastic ND Sample Composite Homogeneity: Good

Location: C3, Debris in Crawl Lab ID-Version‡: 9619117-1

Sample Layers Asbestos Content White Insulation 45% Chrysotile

Peach Rock & Stick ND Composite Non-Asbestos Content: 25% Cellulose

20% Mineral Wool Sample Composite Homogeneity: Good

Location: C4, Debris in Crawl Lab ID-Version‡: 9619118-1

Sample Layers Asbestos Content Off-White Fibrous Material 40% Chrysotile

Composite Non-Asbestos Content: 50% Mineral Wool 2% Cellulose

Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 3 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 Fax (856) 334-1040 www.emlab.com Client: Castle Hill Associates C/O: Mr. Brett Brumbaugh, REPA Re: Cheyenne VAMC - Cheyenne, WY; Asbestos Reinspection

Date of Sampling: 11-06-2018 Date of Receipt: 11-07-2018 Date of Report: 11-12-2018

ASBESTOS PLM REPORT

Location: C6, Debris in Crawl Lab ID-Version‡: 9619119-1

Sample Layers Asbestos Content Beige Wrap Insulation 30% Chrysotile

Composite Non-Asbestos Content: 5% Cellulose Sample Composite Homogeneity: Good

Location: C7, Debris in Crawl Lab ID-Version‡: 9619120-1

Sample Layers Asbestos Content Off-White Fibrous Material 45% Chrysotile

Composite Non-Asbestos Content: 40% Mineral Wool 2% Cellulose

Sample Composite Homogeneity: Good

Location: C8, Debris in Crawl Lab ID-Version‡: 9619121-1

Sample Layers Asbestos Content White Insulation 40% Chrysotile

Composite Non-Asbestos Content: 50% Mineral Wool 3% Cellulose

Sample Composite Homogeneity: Good

EMLab ID: 2038295, Page 4 of 4EMLab P&K, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The report must not be used by the client to claim product certification, approval, or endorsement by any agency of the federal government. EMLab P&K reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

Approved by:

Technical Manager Noah Lazarte

Report for:

Mr. Brett Brumbaugh, REPA Castle Hill Associates PO Box 283 Waterville, OH 43566

Regarding: Project: Cheyenne VAMC- Cheyenne, WY; Asbestos Reinspection

EML ID: 2041579

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. Due to the nature of the analyses performed, field blank correction of results is not applied. The results relate only to the items tested.

EMLab P&K ("the Company") shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results.