5 SOW Attachment Asbestos Report - JAHVA ED-203.pdf

Limited Asbestos Survey

Performed at:

James A. Haley VA Hospital Tampa

“Replace AHU ED-203”

13000 Bruce C Downs Blvd

Tampa, FL 33612

Report Prepared For:

AESUS Group

1050 E. Southern Ave, Suite #5

Tempe, AZ 85282

Report Prepared By:

OHC Environmental Engineering, Inc.

101 South Hoover Blvd, Suite 101

Tampa, FL 33609

OHC Project #220113-AS

September 7, 2022

JAHVA Replace AHU ED-203

Asbestos NESHAP Survey

OHC Project No. 220113-AS

PROJECT INFORMATION

OHC PROJECT NO. 220113-AS

CLIENT NAME: AESUS Group

CLIENT CONTACT: David Combs

PROJECT LOCATION: 13000 Bruce C Downs Blvd.

Tampa, FL 33612

SERVICES PERFORMED: Asbestos Pre-Renovation Survey

DATES OF SERVICES: August 17, 2022

CONSULTING FIRM: OHC Environmental Engineering, Inc.

101 South Hoover Blvd, Suite 101

Tampa, FL 33609

SURVEYOR: Nick Foster

OHC PROJECT MANAGER:

Cristina Rushing, MPH, CPH

LICENSED CONSULTANT:

James F. Rizk, CIH

FLAC #IA0000022

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 EXECUTIVE SUMMARY

3.0 PROJECT SCOPE

4.0 ASBESTOS SURVEY

4.1 Asbestos Survey Results

4.2 Asbestos Sampling Methods

4.3 Regulatory Requirements

4.4 Statutory Requirements

5.0 OBSERVATIONS

6.0 CONCLUSIONS

7.0 LIMITATIONS

8.0 DOCUMENT CONTENT

APPENDIX A: Asbestos Sampling Locations

APPENDIX B: Site & Asbestos Sampling Photographs

APPENDIX C: Laboratory Results for Asbestos Samples

APPENDIX D: Consultant & Laboratory Credentials

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1.0 INTRODUCTION

OHC Environmental Engineering, Inc., (OHC), was contracted by AESUS to perform an

Asbestos Survey in compliance with the National Emission Standard for Hazardous Air

Pollutants (NESHAP) regulation for asbestos (40 CFR 61, Subpart M). These services were conducted for the upcoming replacement of the air handler unit (AHU) servicing ED-203.

A representative from OHC and certified AHERA Building Inspector, Mr. Nick Foster, visited the site on August 17th of 2022, to perform these services.

2.0 EXECUTIVE SUMMARY

Based on the results of the Polarized Light Microscopy (PLM) laboratory analysis, asbestos-containing materials (ACM) are not present within the scope of the survey.

3.0 PROJECT SCOPE

The project scope includes the replacement of Air Handler Unit ED-203 and associated ductwork supplying the emergency department in building 1. The A/H unit is located on the roof which was easily accessible from inside the building. Although the roof will be disturbed during this process, the roofing system is a new roof and disturbing may invalidate the warranty of the roof. Therefore, no roofing samples were collected. The ductwork is located in the hallway of the building, in which the sampling events required setting up mini containments in the hallway for infection control following ICRA.

4.0 ASBESTOS SURVEY

The Environmental Protection Agency defines asbestos-containing material (ACM) as any material or product that contains more than one percent (1%) asbestos. Based on the laboratory analysis of the samples collected, ACM does not exist within the scope of this survey.

4.1 Asbestos Survey Results

The table below summarizes the samples of suspect ACM collected from the site and describes the homogenous sampling area (HSA), sample ID, sample location, material description, quantity, condition, friability, and the laboratory analytical result. Please refer to the Appendices at the end of this report for photographs of the materials sampled and official laboratory analytical results.

LEGEND:

▪ NAD = No Asbestos Detected

▪ ### = the material contains asbestos and requires compliance with NESHAP and OSHA

▪ HSA-AC indicates the samples were collected from inside the AHU

▪ HSA-F1 indicates the samples were collected from the 1st floor hallway

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TABLE 1: MATERIALS SAMPLED FOR ASBESTOS

HSA Sample ID Sample Location Material Description

Quantity, Condition, Friability

Lab

Results

AC-1

113-AC1A

AC Unit on exterior roof vibration dampeners E side on floor

Black Mastic on

Vibration Dampers

6 Dampers

Good

Non-Friable

NAD 113-AC1B

AC Unit on exterior roof vibration dampeners E side on floor

113-AC1C

AC Unit on exterior roof vibration dampeners W side on floor

AC-2

113-AC2A

Exterior metal joints of W side of

AC units White Sealant on Exterior

Metal Joints

30 LF

Good

Non-Friable

NAD

113-AC2B

Blower motor, 4th compartment

South

AC-3

113-AC3A

Exterior A/C unit top metal joints

West side Gray Sealant on Metal

Joints

30 LF

Good

Non-Friable

NAD

113-AC3B

Inside unit 4th compartment blower motor

AC-4

113-AC4A

Exterior A/C unit vertical metal joints East Side Course Gray Sealant

Along Vertical Metal

Joints

260 LF

Good

Non-Friable

NAD 113-AC4B

Exterior A/C unit vertical metal joints West Side

113-AC4C

Exterior A/C unit vertical metal joints South Side

AC-5 113-AC5A

Inside A/C Compartment 3rd door

South Black Vibration Damper

20 LF

Good

Non-Friable

NAD

AC-6 113-AC6A

Inside A/C Compartment 3rd door

South

Gray Caulking on Metal

Joints

1 SF

Good

Non-Friable

NAD

AC-7 113-AC7A Inside 5th compartment door South Silver Mastic on Supply

Ducts Below

15 LF

Good

Non-Friable

NAD

F1-1

F1-1A F1 Hall and Nurses Station Area

White Mastic over Silver

Wrap Duct Insulation with Pink Fiberglass

100 LF

Good

Non-Friable

NAD

F1-1B F1 Hall and Nurses Station Area

F1-1C F1 Hall and Nurses Station Area

F1-1D F1 Hall and Nurses Station Area

F1-1E F1 Hall and Nurses Station Area

F1-2

F1-2A F1 Hall and Nurses Station Area

Silver Mastic on Metal

Ducts Underneath

Insulation

100 LF

Good

Non-Friable

NAD

F1-2B F1 Hall and Nurses Station Area

F1-2C F1 Hall and Nurses Station Area

F1-2D F1 Hall and Nurses Station Area

F1-2E F1 Hall and Nurses Station Area

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4.2 Asbestos Sampling Methods

Asbestos sampling was conducted in accordance with NESHAP (40 CFR 61, Subpart

M) protocol for the commencement of demolition/renovation activities. The surveyor conducted a visual inspection of every safe and reasonably accessible room and space of the building. Materials sampled were grouped into Homogenous Sampling Areas

(HSA) based on the texture, color, use, age, condition, and every other visual appearance to identify suspect ACM. Materials containing asbestos are grouped into the following categories:

• Regulated ACM (RACM): Refers to friable manufactured ACM or a

Category I non-friable ACM that has become friable; or a Category I Non-

Friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading; or a Category II Non-Friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

• Category I Non-Friable ACM: Refers to asbestos containing packing, gaskets, resilient floor coverings (including mastics), and asphalt roofing products containing more than 1% asbestos.

• Category II Non-Friable ACM: Refers to any material that is not a

Category I Non-Friable ACM that contains greater than 1% asbestos.

Bulk samples of all friable and non-friable suspect ACM were collected, as well as a representative number of samples from each homogeneous area following the EPA's simplified random sampling method (EPA560/585-030a). Good Industrial Hygiene practices were followed when collecting bulk samples in order to minimize fiber release. Every precaution was taken to prevent asbestos exposure to the surveyor, the building occupants, and the public. All sample locations were logged with an appropriate description and the locations were marked on any available drawings. A unique sequential numbering system was used to identify each area. Each bulk sample was placed in a labeled bag, which was immediately marked with its sample number.

Strict Chain-of-Custody protocols were followed and signed by the receiving laboratory personnel who handled the samples. The samples were analyzed via polarized light microscopy (PLM) by an AIHA and NVLAP accredited laboratory.

4.3 Regulatory Requirements

Demolition: According to NESHAP, 40CFR61 Subpart M, demolition is defined as the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility.

The final NESHAP Rule provides classification for regulated asbestos containing material as follows:

• Friable asbestos material;

• Category I non-friable ACM that has become friable;

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• Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or

• Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by forces expected to act upon the material in the course of demolition or renovation operations.

If the total asbestos content is determined to be trace to 10%, the owner must either assume that the material contains greater than 1% asbestos and treat the material as regulated asbestos-containing material (RACM) or have the material verified/quantified by point counting. If after point counting, the material is quantified as 1% or less, it is not regulated by the NESHAP. The Occupational

Safety and Health Administration (OSHA) considers material that contains any amount of asbestos as asbestos-containing and requires compliance with OSHA regulations. The demolition of a structure with materials present that contain any amount of asbestos is considered by OSHA as an asbestos abatement, and all applicable OSHA rules must be complied with during the demolition.

Notification: Notification is required to the local regulatory agency:

1. Ten (10) working days prior to a demolition.

2. Ten (10) working days prior to a renovation operation, if the amount of asbestos material removed or impacted is greater than 160 SF on all building components (i.e. floor tile, mastic, GWBS, etc.) or 260 LF on pipes.

3. One (1) day prior to demolition, if the building has been condemned and is structurally unsound as determined by the appropriate agency.

Notification must be sent by certified mail with return receipt or hand delivered to the Florida Department of Environmental Protection. The demolition contractor must wait ten (10) working days (Monday – Friday) from the postmarked date of mailing or the date of hand delivery to commencement of demolition. Any change to the start date of the demolition requires notification to the agency by phone, followed by a written revision to the Notification Form.

4.4 Statutory Requirements

The regulatory agency responsible for the oversight of the rules pertaining to asbestos-containing building materials (ACBM) is the Environmental Protection Agency

(EPA). The regulations state that prior to demolition or renovation a facility survey must be conducted in accordance to section 40 CFR 61-M National Emission

Standards for Hazardous Air Pollutants; Asbestos NESHAP Revisions, Final Rule.

Enforcement of these rules was passed on to the states. In the State of Florida, they are enforced by the Department of Environmental Protection (DEP). Some counties have developed an enforcement division to carry out the responsibilities of the DEP and have developed environmental and asbestos ordinances with which compliance is required.

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5.0 OBSERVATIONS

• No remarkable observations noted.

6.0 CONCLUSIONS

Based on the results of the PLM analysis, ACM is not present in the future replacement of

Air Handler Unit ED-203 and associated ductwork. Therefore, these materials do not require removal and can be demolished and disposed of as construction waste.

7.0 LIMITATIONS

The materials sampled in this survey were subject to accessibility. This survey is limited to the future renovation scope, as specified by the provided demolition plans. The building was occupied at the time of the assessment, but sampling was performed during non-peak hours. OHC warrants that the investigations and methodology reflect the prevailing standard of work practices in the environmental consulting field. If it is expected that materials outside the scope of this survey are to be disturbed, they must be presumed ACM until the materials can be analyzed by an accredited asbestos building inspector.

8.0 DOCUMENT CONTENT

This document had been made for the exclusive use by AESUS and the Tampa VA. The knowledge of the consultant is based upon current information and research. If local knowledge indicates error, omissions, or inaccuracy, please notify the consultant.

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APPENDIX A

ASBESTOS SAMPLING LOCATIONS

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APPENDIX B

PHOTOGRAPHS OF MATERIALS

SAMPLED FOR ASBESTOS

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113-AC1A Black Mastic on Vibration Dampers [NAD]

113-AC2A White Sealant on Exterior Metal Joints [NAD]

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113-AC3A Gray Sealant on Metal Joints [NAD]

113-AC4A Course Gray Sealant Along Vertical Metal Joints [NAD]

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113-AC5A Black Vibration Damper [NAD]

113-AC6A Gray Caulking on Metal Joints [NAD]

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113-AC6A Silver Mastic on Supply Ducts Below [NAD]

F1-1A White Mastic over Silver Wrap Duct Insulation with Pink Fiberglass [NAD]

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F1-2A Silver Mastic on Metal Ducts Underneath Insulation [NAD]

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APPENDIX C

LABORATORY RESULTS

FOR ASBESTOS SAMPLES

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APPENDIX D

CONSULTANT & LABORATORY

CREDENTIALS

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JAHVA Replace AHU ED-203

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