668-24-103 HAZ B3.pdf

Post Office Box 1446 • Auburn, Washington 98071-1446 • PHONE (253) 351-0677 • E-mail: fullertona@medtoxnw.com Website: www.medtoxnw.com

NS:\MTNW\ALLJOBS\9000-9999\9243\REPORT\Mann-Grandstaff Roof Project Letter Building 3 MTNW 9243.1 -.doc

May 12, 2025

Sofie O’Brien MA Architects, Inc.

385 Van Ness Avenue, Suite 110 Torrance, California 90501

Subject: Mann-Grandstaff Veterans Administration (VA) Roofing Project “Good Faith” Asbestos Investigation- Building 3

4815 North Assembly Street, Spokane, Washington Med-Tox Northwest Project No. 9139.1

Dear Ms. O’Brien, On April 24, 2025, Anthony Fullerton of Med-Tox Northwest (MTNW) visited the Mann- Grandstaff VA Medical Center located at 4815 North Assembly Street in Spokane, Washington to conduct asbestos sampling of the roof systems. This survey was completed as part of the Mann- Grandstaff VA Roofing Project under a contract with MA Architects for VA Project Number 668-24-103. MTNW was contracted to survey several buildings as part of this project (Building 1, Building 2, Building 3 and Building 31). This report focuses on the results of the sampling conducted at Building 3. The remaining buildings will be submitted in separate reports.

Building 3 is a support building. This building has two different roof levels. Both roof levels were sampled as part of the survey activities. On the day of the survey, Devin Dalcher, the COR for the VA escorted Mr. Fullerton to each of the areas to be sampled.

There are several different roof systems that will be impacted by the planned project. The following roof sections were identified and sampled at Building 3:

• Building 3, top roof (north end)- white membrane roofing over gypsum board, insulation board and built-up roofing on concrete decking. At area sampled, roofing is approximately 2” to 3” thick.

• Building 3, lower roof (south end)- white membrane roofing over gypsum board, insulation board and built-up roofing on concrete decking. At area sampled, roofing is approximately 2” to 3” thick.

MTNW sampled each section independent from one another. Core samples from each of the roof sections along with various sealants. MTNW collected the cores for the project and

Mann-Grandstaff VA Roofing Project- Building 3 May 12, 2025 Med-Tox Northwest Project No. 9243.1

S:\MTNW\ALLJOBS\9000-9999\9243\REPORT\Mann-Grandstaff Roof Project Letter Building 3 MTNW 9243.1 -.doc then patched the sample location and painted an orange circle around the repair for easy identification of the sample location.

Asbestos Bulk Sampling Summary

There were ten (10) samples collected from eight (8) homogeneous materials (HM) identified during the survey. The core samples collected from both roof levels were all determined to be negative for asbestos.

Samples were collected from the parapet flashing sealant, corrugated metal flashing sealant, gray vent sealant and white wall flashing sealant. There were two samples collected of the gray parapet flashing sealant. Both samples were determined to contain 2% Chrysotile asbestos. Sample 9243.1-3-051 was then re-analyzed by the more stringent EPA 400 Point Count Method. The sample was determined to contain 1.25% Chrysotile which is a regulated asbestos containing material.

The corrugated metal flashing sealant, gray vent sealant and white wall flashing sealant were determined to be negative for asbestos.

For a complete list of all samples collected, please refer to the attached Summary of Materials Sampled for Asbestos as they pertain to Building 3.

The purpose of the survey was to provide a “Good Faith Survey” (per Washington Administrative Code (WAC) 296-62-07721, (1)(c)(ii)) and to identify the materials stated above which may require removal and/or special handling before any demolition activities.

As required by 29 Code of Federal Regulations (CFR), WAC 296-62-077 and Spokane Regional Clean Air Agency (SRCAA), building inspectors certified under the Asbestos Hazard Emergency Response Act (AHERA) and employed by MTNW conducted the survey.

Med-Tox Northwest employs inspectors certified by an Environmental Protection Agency (EPA)-approved training provider to provide Asbestos Hazard Emergency Response Act (AHERA) building surveys, including renovation and demolition surveys. A copy of Mr.

Fullerton’s certificate is attached.

Table 1 provides a complete list of suspect materials determined greater than 1% asbestos as they pertain to Building 3.

May 12, 2025

S:\MTNW\ALLJOBS\9000-9999\9243\REPORT\Mann-Grandstaff Roof Project Letter Building 3 MTNW 9243.1 -.doc

Table 1. Summary of Asbestos-Containing Materials.

Material Location Friable Quantity

Building 3

Gray parapet flashing sealant (HM-32) North concrete wall between top roof and lower roof

No 30 LF

Note: This table is not to be used without the complete survey document including appendices for additional information.

Table 2 lists all suspect materials sampled that have been determined to be non-asbestos containing.

Table 2. Summary of Suspect Materials Determined Non-Asbestos Containing

Material Description Material Description

Building 3, top roof

Gypsum board over insulation board and built-up roofing (HM-30)

Building 3, lower roof

Gypsum board over insulation board and built-up roofing (HM-31)

Corrugated metal flashing sealant (HM-33) Gray vent sealant (HM-34)

White wall flashing sealant (HM-35) Note: This table is not to be used without the complete survey document including appendices for additional information.

Lead Containing Paint Summary

Lead was commonly used in most paint products until 1978, when it was banned from residential paints at concentrations greater than 600 parts per million (ppm); however, commercial applications with lead were still utilized and are still available. Lead is poisonous to the human body and presents a potential health hazard during any kind of disturbance (such as maintenance, including grinding, welding, and cutting) and if improperly disposed, where lead can enter drinking water supplies.

EPA defines lead-containing paint (LCP) as a concentration of 1.0 milligrams per centimeter squared (mg/cm2) or greater by X-Ray fluorescence (XRF) or 0.5 percent by weight (% wt.) or greater by total lead analysis; equivalent to 5,000 milligrams per kilogram (mg/kg). This EPA action level triggers requirements for protection of the environment, maintenance workers, and building occupants in child occupied facilities as defined by 40 CFR 745. Additionally, building components exceeding EPA lead levels may cause demolition waste streams to fail waste designation sampling performed for compliance with

WAC 173-303.

May 12, 2025

S:\MTNW\ALLJOBS\9000-9999\9243\REPORT\Mann-Grandstaff Roof Project Letter Building 3 MTNW 9243.1 -.doc

Occupational Safety and Health Administration (OSHA) and Washington Department of Occupational Safety and Health (DOSH) worker protection regulations have not defined a minimum concentration for regulating lead and has clarified that lead at any detectable concentration shall be considered regulated by 29 CFR 1926.62/WAC 296-155-176, Lead.

Paint sample results can be expressed in mg/kg (same as ppm), % wt. or mg/cm2 by area depending on the type of analytical methods used. Any positive result, regardless of the reporting method by the laboratory, will require compliance with 29 CFR 1926.62/WAC 296- 155-176.

Lead in Painted Surfaces

During the MTNW survey exterior painted surfaces that may potentially be impacted were tested for lead using bulk sample collection and chemical analysis. One paint chip sample was collected. Analytical results are provided in Table 3.

Table 4. Summary of Materials Sampled For Lead

Sample Number Location Component Substrate Color Result (% by wt.)

Building 3

9243.1-AF-05Pb Building 3 Wall Concrete Tan <0.0064 The Washington Department of Occupational Safety and Health (DOSH) worker protection regulations have stated that lead at any detectable concentration shall be considered regulated (Washington Administrative Code [WAC] 296-155-176, Lead.

Summary of Analysis

Asbestos-Containing Materials

A total of ten (10) bulk samples were analyzed by Polarized Light Microscopy (PLM) dispersion staining EPA Method 600/R-93/116 by Seattle Asbestos Test, LLC. (SAT). SAT is accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST), a division of the U.S. Department of Commerce. This accreditation does not constitute endorsement, but rather a finding of laboratory competence. The NVLAP participant number for SAT is

200768-0 (certification copies and analytical results are attached.

Lead-Based Paint

Bulk paint chip samples were submitted to EMSL Analytical, Inc. (EMSL), for analysis. One

(1) paint chip sample was analyzed for lead using atomic absorption spectroscopy (AAS) to determine the presence and percentage of lead. Procedures for analyzing metals are found in the ASTM International D-3335-78 and EPA Method Manual SW-846, Method 6010. (EMSL used SW 846 3050B*/7000B) an equivalent analytical method.

May 12, 2025

S:\MTNW\ALLJOBS\9000-9999\9243\REPORT\Mann-Grandstaff Roof Project Letter Building 3 MTNW 9243.1 -.doc

Analytical results for paint chip samples and EMSL Analytical, Inc., laboratory certification are attached.

Comments and Recommendations

Asbestos-Containing Materials

Med-Tox Northwest recommends, and state law requires, that all asbestos materials identified in Table 1 be removed prior to renovation or demolition.

We recommend that this survey report be placed on-site during renovation and/or selective demolition and copies provided to the contractor(s) bidding and performing work. DOSH, OSHA and SRCAA require that the report be on-site and available for review during the entire project duration.

1. The roof sections were sampled independently from one another. If additional materials are observed during the course of the project, they should be sampled by an AHERA inspector and analyzed by an accredited NVLAP laboratory.

This survey is not intended for use as abatement plans and/or specifications.

If you have any questions or require additional information, please call me at (253) 351- 0677.

Sincerely, Anthony Fullerton Senior Project Manager

Enclosures

Hazardous Building Materials Survey— Renovation Specific

Mann-Grandstaff VA Roofing Project

Building 3

May 2025 C-1 MA Architects

Table C-1. Summary of Materials Sampled for Asbestos

Sample Material Location AHERA Type HM Result

Building 3

9243.1-3-049 Gypsum board over insulation board and built-up roofing

B3 top roof Misc. 30 ND

9243.1-3-050 Gypsum board over insulation board and built-up roofing

B3 lower roof Misc. 31 ND

9243.1-3-051 Gray parapet flashing sealant

B3 Misc. 32 2% CHR

PC: 1.25% CHR

9243.1-3-052 Gray parapet flashing sealant

B3 Misc. 32 Layer 1: 2% CHR

Layer 2: 2% CHR

9243.1-3-053 Corrugated metal flashing sealant

B3 lower Misc. 33 ND

9243.1-3-054 Corrugated metal flashing sealant

B3 lower Misc. 33 ND

9243.1-3-055 Gray vent sealant B3 lower Misc. 34 ND

9243.1-3-056 Gray vent sealant B3 lower Misc. 34 ND

9243.1-3-057 White wall flashing sealant B3 Misc. 35 ND

9243.1-3-058 White wall flashing sealant B3 Misc. 35 ND

CHR = Chrysotile, HM = homogeneous material, Misc. = Miscellaneous, ND = None detect, PC = Point Count.

Photo 1: Building 3 top roof. The roofing is not asbestos containing.

Photo 2: Building 3 lower roof. The roofing is not asbestos containing.

Photo 3: Building 3 asbestos containing gray parapet flashing sealant.

Project Name:

Customer PO:

EMSL Sales Rep:

Reported:

Med-Tox Northwest [MEDT50]

PO Box 1446

Auburn, WA 98071

EMSL Analytical, Inc.

6340 Castleplace Drive, Indianapolis, IN, 46250

Telephone: 317.803.2997 Fax:317.803.3047 www.emsl.com

Anthony FullertonAttention:

(253) 351-0677 fullertona@medtoxnw.com Received: 04/30/2025 09:32

05/07/2025 15:06

Natalie Murphy

EMSL Order ID: 162554949

LIMS Reference ID: CD54949

EMSL Customer ID: MEDT50

9243.1

Analytical Results

Analyte Results RL Q DF Analysis Date

& AnalystWeight(g) Prep Date

& Tech

Analytical

MethodPrep Method

Client Sample ID: 92432.1-AF-01Pb/BUILDING 1, ROOF LEVEL 298, WALL, EIFS, TAN Date Sampled: 04/24/25

Matrix: Chips LIMS Reference ID: CD54949-01

1Lead 05/02/25 ET 05/02/25 CG<0.0092 % wt 0.0092 % wt SW-846 3050B SW 846-7000B0.1735

Sample Comments:

Client Sample ID: 92432.1-AF-02Pb/BUILDING 1, ROOF LEVEL 298, WALL, CONCRETE, TAN Date Sampled: 04/24/25

Matrix: Chips LIMS Reference ID: CD54949-02

1Lead 05/02/25 ET 05/02/25 CG<0.0066 % wt 0.0066 % wt SW-846 3050B SW 846-7000B0.2423

Sample Comments:

Client Sample ID: 92432.1-AF-03Pb/BUILDING 1, ROOF LEVEL 299, WALL, CONCRETE, TAN Date Sampled: 04/24/25

Matrix: Chips LIMS Reference ID: CD54949-03

1Lead 05/02/25 ET 05/02/25 CG<0.0064 % wt 0.0064 % wt SW-846 3050B SW 846-7000B0.2581

Sample Comments:

Client Sample ID: 92432.1-AF-04Pb/BUILDING 2, WALL, CONCRETE, TAN Date Sampled: 04/24/25

Matrix: Chips LIMS Reference ID: CD54949-04

1Lead 05/02/25 ET 05/02/25 CG<0.015 % wt 0.015 % wt SW-846 3050B SW 846-7000B0.106

Sample Comments:

Client Sample ID: 92432.1-AF-05Pb/BUILDING 3, WALL, CONCRETE, TAN Date Sampled: 04/24/25

Matrix: Chips LIMS Reference ID: CD54949-05

1Lead 05/02/25 ET 05/02/25 CG<0.0064 % wt 0.0064 % wt SW-846 3050B SW 846-7000B0.2597

Sample Comments:

[TOC_1]Sample Results[TOC]

EMSL Sales Rep:

Reported:

Med-Tox Northwest [MEDT50]

PO Box 1446

Auburn, WA 98071

EMSL Analytical, Inc.

6340 Castleplace Drive, Indianapolis, IN, 46250

Telephone: 317.803.2997 Fax:317.803.3047 www.emsl.com

Anthony FullertonAttention:

(253) 351-0677 fullertona@medtoxnw.com Received: 04/30/2025 09:32

05/07/2025 15:06

Natalie Murphy

EMSL Order ID: 162554949

LIMS Reference ID: CD54949

EMSL Customer ID: MEDT50

9243.1

CertificationsAnalyte

Certified Analyses included in this Report

SW 846-7000B in Chips

16-OHDOH,16-AIHA ELLAPLead

[TOC_1]Certified

Analyses[TOC]

List of Certifications

Code Description Number Expires

16-MO 10180Missouri Drinking Water 03/31/2026

16-NYDOH 12130New York Potable Water, Metals Solid and Hazardous Waste - Asbestos 04/01/2026

16-AIHA ELLAP 157245American Industrial Hygiene Association (AIHA LAP, LLC) - ELLAP 06/01/2025

16-AIHA IHLAP 157245American Industrial Hygiene Association (AIHA LAP, LLC) - IHLAP 06/01/2025

16-CA ELAP 2575California Metals in DW, Chemistry and Bulk Asbestos in Hazardous Waste 06/30/2025

16-A2LA Food 2845.11A2LA Food Microbiology 01/31/2026

16-A2LA Chemistry 2845.25A2LA Environmental and Chemistry 11/30/2025

16-IN Metals/Asbestos C-49-09Indiana Lead and Metals and Asbestos in Drinking Water 12/31/2026

16-OHDOH E10040Ohio - Lead in Paint Chips, Wipes, Soil and Air 05/03/2026

16-FLDOH E871170Florida Asbestos and Metals in Drinking Water, PCBs 06/30/2025

16-NJDEP IN002New Jersey Metals, Organics and Inorganics in DW PCBs 06/30/2025

16-IN Colilert/HPC M-49-06Indiana Colilert and HPC 12/31/2026

Please see the specific Field of Testing (FOT) on www.emsl.com <http://www.emsl.com> for a complete listing of parameters for which EMSL is certified.

[TOC_1]Certifications[TOC]

Notes and Definitions

Item Definition

(Dig) For metals analysis, sample was digested.

[2C] Reported from the second channel in dual column analysis.

DA Direct Analysis

DF Dilution Factor

MDL Method Detection Limit.

ND Analyte was NOT DETECTED at or above the detection limit.

NR Spike/Surrogate showed no recovery.

Q Qualifier

RCS Respirable Crystalline Silica

RL Reporting Limit

Wet Sample is not dry weight corrected.

Measurement of uncertainty and any applicable definitions of method modifications are available upon request. Per EPA NLLAP policy, sample results are not blank corrected.

[TOC_1]Qualifiers, Definitions and Disclaimer[TOC]

EMSL Sales Rep:

Reported:

Med-Tox Northwest [MEDT50]

PO Box 1446

Auburn, WA 98071

EMSL Analytical, Inc.

6340 Castleplace Drive, Indianapolis, IN, 46250

Telephone: 317.803.2997 Fax:317.803.3047 www.emsl.com

Anthony FullertonAttention:

(253) 351-0677 fullertona@medtoxnw.com Received: 04/30/2025 09:32

05/07/2025 15:06

Natalie Murphy

EMSL Order ID: 162554949

LIMS Reference ID: CD54949

EMSL Customer ID: MEDT50

9243.1

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received. Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. QC sample results are within quality control criteria and met method specifications unless otherwise noted. All results for soil samples are reported on a dry weight basis, unless otherwise noted.

Aleks Kuchenbrod Laboratory Manager or other approved signatory

Analysis following EMSL SOP for the Determination of Environmental Lead by FLAA. The laboratory has a reporting limit of 0.0064% by wt., based upon a minimum sample weight of

0.25g submitted to the lab, and is not responsible for any result or reporting limit provided in mg/cm2 since it is dependent upon an area value provided by non-lab personnel. A "<" (less than) result signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty and definitions of modifications are available upon request. Results in this report are not blank corrected unless specified.

Anthony L. Fullerton

AHERA Building Inspector

This is to certify that

4 hours of online refresher training as an

TSCA Title II, 40 CFR 763 (AHERA) to comply with the training requirements of has satisfactorily completed

194704 Certificate Number

Instructor:

EPA Provider # 1085

Aug 29, 2024 Date(s) of Training

Expires in 1 year.

N/AExam Score:

(if applicable)

Tracy Bockla

TERRACON TRAINING - FORMERLY ARGUS PACIFIC / 21905 64TH AVE W, SUITE 100 / MOUNTLAKE TERRACE, WASHINGTON 98043 / 206.285.3373 / EHS-TRAINING-TERRACON.COM

Certificate of Completion

STATE OF WASHINGTON

Department of Commerce

Lead-Based Paint Activities Program

Has fulfilled the certification requirements of

WAC 365-230

and has been certified to conduct lead based paint activities as a

Risk Assessor.

Certification # Issuance Date Expiration Date 0242 06/21/2023 04/03/2026

Anthony L Fullerton

AIHA Laboratory Accreditation Programs, LLC acknowledges that

EMSL Analytical, Inc.

6340 Castleplace Drive Indianapolis, IN 46250

Laboratory ID: LAP-157245 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation Programs (AIHA LAP), LLC accreditation to the ISO/IEC 17025:2017 international standard, General Requirements for the Competence of Testing and Calibration Laboratories in the following:

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE Accreditation Expires: June 01, 2025

ENVIRONMENTAL LEAD Accreditation Expires: June 01, 2025

ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: June 01, 2025

FOOD Accreditation Expires:

UNIQUE SCOPES Accreditation Expires:

Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:2017 and AIHA LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.

Revision21: 05/15/2023

Cheryl O Morton Managing Director, AIHA Laboratory Accreditation Programs, LLC

Date Issued: 06/01/2023

Effective: 05/15/2023 Revision: 9

AIHA Laboratory Accreditation Programs, LLC

SCOPE OF ACCREDITATION

EMSL Analytical, Inc. Laboratory ID: LAP-157245 6340 Castleplace Drive Indianapolis, IN 46250 Issue Date: 06/01/2023

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory's current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

The EPA recognizes the AIHA LAP, LLC ELLAP program as meeting the requirements of the National Lead Laboratory Accreditation Program (NLLAP) established under Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 and includes paint, soil and dust wipe analysis. Air and composited wipes analyses are not included as part of the NLLAP.

Environmental Lead Laboratory Accreditation Program (ELLAP)

Initial Accreditation Date: 09/01/2002

Component, parameter or characteristic tested Technology sub-type/Detector Method Method Description

(for internal methods only)

Airborne Dust AA NIOSH 7082 N/A

EPA SW-846 3050B N/A

EPA SW-846 3051A N/AAA

EPA SW-846 7000B N/A

EPA SW-846 3050B N/A

EPA SW-846 3051A N/A

Paint

ICP

EPA SW-846 6010D N/A

EPA SW-846 3050B N/A

EPA SW-846 3051A N/AAA

EPA SW-846 7000B N/A

EPA SW-846 3050B N/A

EPA SW-846 3051A N/A

Settled Dust by Wipe

ICP

EPA SW-846 6010D N/A

EPA SW-846 3050B N/A

EPA SW-846 3051A N/ASoil AA

EPA SW-846 7000B N/A

Effective: 05/15/2023 Revision: 9

Component, parameter or characteristic tested Technology sub-type/Detector Method Method Description

(for internal methods only)

EPA SW-846 3050B N/A

EPA SW-846 3051A N/AICP

EPA SW-846 6010D N/A

A complete listing of currently accredited ELLAP laboratories is available on the AIHA LAP, LLC website at:

http://www.aihaaccreditedlabs.org