ACM and LeadReports.pdf

VAMC Alexandria, Building 3, Replace Roof and HVAC DEC Project No. 2020.011

PRE-RENOVATION SURVEY FOR ASBESTOS

BUILDING 3, REPLACE ROOF AND HVAC

VAMC ALEXANDRIA

ALEXANDRIA, LOUISIANA

Prepared for:

TOLAND MIZELL MOLNAR

590 MEANS STREET NW, SUITE 200

ATLANTA, GA 30318

Report Date:

April 21, 2020

Prepared by:

MICHAEL F. DURBIN, CIH

LDEQ ASBESTOS INSPECTOR: AI# 138242, ACCREDITATION No. JI138242 (EXPIRES

1/27/2021)

DURBIN ENVIRONMENTAL CONSULTANTS, INC.

2201 POTOMAC PLACE

LAWRENCEVILLE, GA 30043

(678) 482-9917

Page AppE - 3

TABLE OF CONTENTS

PAGE

1. INTRODUCTION 3

2. DISCUSSION AND RESULTS 3

a. Asbestos

b. Lead in Paint

c. PCBs/Fluorescent Lights

3. METHODOLOGY 6

Asbestos Sampling Protocol Lead in Paint Sampling Protocol

4. OBSERVATIONS/CONCLUSIONS 8

5. RECOMMENDATIONS 9

6. REFERENCES 10

APPENDIX

A. Asbestos Bulk Sampling Summary followed by the Laboratory Report and Representative Photographs of Suspect Asbestos Containing Materials

B. Lead in Paint Summary followed by the Laboratory Report and Representative Photographs

C. Asbestos Inspector Accreditation Certification and Laboratory Accreditation

Page AppE - 4

1. INTRODUCTION

Durbin Environmental Consultants, Inc. (DEC) was retained by Toland Mizell Molnar, to conduct a pre-renovation survey for suspect asbestos containing materials at the VA Medical Center (VAMC), Alexandria, Louisiana, in support of the Building 3, Replace Roof and HVAC Project, Alexandria, Louisiana. Michael F. Durbin, CIH of Durbin Environmental Consultants, Inc., conducted the suspect asbestos containing material assessment on March 12, 2020. Mr.

Durbin is currently accredited as an asbestos inspector through an Environmental Protection Agency (EPA) approved training provider (State of Louisiana Department of Environmental Quality (AI# 138242, ACCREDITATION No. JI138242 (EXPIRES 1/27/2021).

Bulk sample analysis for suspect asbestos containing materials and paint chip sample analysis was performed by SanAir Technologies Laboratory, 1551 Oakbridge Drive, Suite B, Powhatan, VA 23139. SanAir is accredited for asbestos fiber analysis through participation in the National Institute of Standards and Technology (NIST) National Voluntary Laboratory Accreditation Program (NVLAP) and is assigned NVLAP Lab Code 200870-0. San Air utilized the analytical method: EPA/600/R-93/116: "Method for the Determination of Asbestos in Bulk Building Materials” (polarized light microscopy in conjunction with dispersion staining).

SanAir analyzed the paint chip samples by Atomic Absorption Spectrophotometer, Flame, following the EPA Method SW846/M3050B/7000B. SanAir is accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program and is a participant in the Environmental Microbiology & Lead Proficiency Analytical Testing Program (EMPAT) and is assigned Lab Number 162952. SanAir is an approved laboratory by the State of Louisiana, Department of Environmental Quality, Certificate Number 05088, Expiration June 30, 2020.

2. DISCUSSION AND RESULTS

a. Building 3 - Asbestos

The asbestos survey was conducted in accordance with the sampling protocol established in the Environmental Protection Agency’s Asbestos Hazard Emergency Response Act (AHERA 40 CFR, Part 763) and the State of Louisiana Asbestos Regulations for the materials included in this specific project. The following provides general information and summarizes the potential impact of asbestos containing material during this scheduled renovation project.

Bulk samples were collected from the following suspect asbestos containing roofing materials during this survey:

1. Medium Pressure Steam Paper Wrapped Pipe Insulation (HM #1)

2. Low Pressure Steam Paper Wrapped Pipe Insulation (HM #2)

3. Hot Water Supply Paper Wrapped Pipe Insulation (HM #3)

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4. Cold Water Paper Wrapped Pipe Insulation (HM #4)

5. Condensate Return Paper Wrapped Pipe Insulation (HM #5)

6. Brown Paper Wrapped Pipe Insulation with Metal Bands (HM #6)

7. Foil Wrapped Duct Insulation (HM #7)

8. Foil Wrapped Duct Insulation with Black Mastic (HM #8)

9. Paper Wrapped Duct Insulation (HM #9)

10. Beige Paper Like Duct Tape on Seams of Metal Duct (HM #10)

11. Saddle Block Pipe Insulation – Foam Glass or White Friable (HM #11)

12. Hard Mudded Pipe Fitting Insulation (HM #12)

13. 2’ X 4’ Ceiling Tile, Long Fissures & Holes (HM #13)

14. 2’ X 2’ Ceiling Tile, Gouges/Mars & Pinholes (HM #14)

15. 2’ X 4’ Ceiling Tile, Small Gouges & Holes (HM #15)

16. 12” x 12” Ceiling Tile, Large Holes with Glue Dots (HM #16)

17. 2’ X 2’ Ceiling Tile, Mottled Texture (HM #17)

18. Black Felt Layer Under Red Clay Roof Tiles (HM #18)

19. Plaster Material (HM #19)

20. Red Fire Safe Material (HM #20)

The following collected bulk sample materials contained asbestos by Polarized Light Microscopy (PLM) (reference Appendix A for the Asbestos Bulk Sampling Summary followed by the Laboratory Report and Representative Photographs of Suspect Asbestos Containing Materials).

1. Saddle Block Pipe Insulation – Foam Glass or White Friable (HM #11)

2. 12” x 12” Ceiling Tile, Large Holes with Glue Dots (HM #16)

Reference Appendix A for the Asbestos Bulk Sampling Summary followed by the Laboratory Report and Representative Photographs of Suspect Asbestos Containing Materials). Note: Floor covering and associated mastics, glues and adhesives and radiator heat shields (Transite-type) shall be assumed to contain asbestos, but are not scheduled for disturbance as part of this project.

b. Building 3 - Lead

Representative paint chip samples were collected from the following locations:

1. Green Paint on Plaster Wall, Building 3, Basement (Sample # 3-PC-01); 0.887% lead by weight

2. Black Paint on Concrete Wall, Building 3, Basement (Sample # 3-PC-02); 5.752% lead by weight

3. Beige Paint on Plaster Wall, Building 3, 1st Floor Room 104 (Sample # 3-PC-03); 0.720% lead by weight

4. Green Paint on Plaster Ceiling, Building 3, 2nd Floor Room 217A (Sample # 3-PC-04);

1.238% lead by weight

5. Beige Paint on Plaster Ceiling, Building 3, 2nd Floor Room 223 (Sample # 3-PC-05); 2.647% lead by weight

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6. Beige Paint on Plaster Ceiling, Building 3, 3rd Floor Room 303 (Sample # 3-PC-06); 0.872% lead by weight

All six (6) of the representative paint chip samples taken from painted surfaces in Building 3, in areas that will be impacted by the scheduled renovation project, had detectable levels of lead above the EPA/HUD definition of Lead Based Paint (LBP) which is a painted surface or component that contains lead equal to or in excess of 0.5% by weight via Flame Atomic Absorption Spectrophotometer (AAS) analysis.

Disturbance to any painted item/surface/component shall be done in compliance with the OSHA Construction Industry Standard for Lead (29 CFR 1926.62). The Occupational Safety and Health Administration (OSHA) Construction Industry Standard for Lead (29 CFR 1926.62) does not reference the HUD definition for LBP. If detectable levels of lead are identified in any painted surface, paint disturbance will fall under the OSHA Lead Standard. OSHA 29 CFR

1926.62 requires employers to perform exposure monitoring for employees whose tasks disturb or potentially disturb lead. The Contractor shall assume that all painted surfaces, ceramic tiles and yellow block walls may contain detectable levels of lead for purposes of this project and demonstrate through personal air sampling that airborne lead levels will not exceed 30 micrograms (µg) lead per cubic meter (m3) of air determined as an 8-hour time-weighted average (TWA), for each representative task and trade that disturbs painted surfaces.

c. Building 3 - PCBs/Fluorescent Lights

The specific construction date of the VAMC Alexandria, Building 3, is unknown, but is reportedly circa 1940s - 1950’s. Substantial renovation has occurred in these specific area as evidenced by relatively new construction products. All ballasts installed or manufactured prior to 1978, shall be assumed to contain PCBs unless specifically labeled as having no PCBs.

All known or assumed PCB ballasts, capacitors or other PCB articles shall be handled in accordance with 40 CFR Part 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions and State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

All batteries, mercury-containing equipment and bulbs shall be handled in accordance with 40 CFR Part 273 Standards for Universal Waste Management and State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

Refrigerants shall be disposed on in accordance with Section 608 of the Clean Air Act (EPA Refrigerant and Recycling Rule and 40 CFR Part 82 Protection of Stratospheric Ozone) in addition to the State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

Fluorescent lights and high intensity discharge bulbs (HID) and other mercury-containing bulbs are regulated under the Resource Conservation and Recovery Act (RCRA) Universal Waste Rule (UWR) and Subtitle C hazardous waste regulations and the State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1). Accordingly, all bulbs shall be disposed of or recycled in accordance with the current policy of the VA Medical Center, Alexandria, Louisiana.

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3. METHODOLOGY

Asbestos Sampling Protocol

The inspector sampled all suspect ACM in accessible areas. In order for a group of homogeneous materials to be considered as non-asbestos containing, all samples from that specific homogeneous material must be analyzed and determined to be non-asbestos containing or less than or equal to 1% asbestos.

Representative, randomly selected samples were collected from each homogeneous area of suspect asbestos-containing material. For purposes of this report, the homogeneous area is physically defined as all material with the same visual appearance, texture and hardness.

The minimum number of samples collected for each homogeneous area (or material), if present, is as follows:

1. Friable Spray-applied or Trowel-applied Material

a. Less than or equal to 1000 square feet (S.F.) = 3 samples

b. Greater than 1000 S.F. and less than or equal to 5000 S.F. = 5 samples.

c. Greater than 5000 S. F. = 7 samples

2. Pipe and Duct Insulation

Three samples per homogeneous area of insulation were taken unless it was a confirmation sample.

3. Elbows, Valves, Fittings and Connection Mud

Three representative samples were taken from each representative type of insulated elbow, valve, fitting and connecting mud unless it was a confirmation sample.

4. Boiler, Tanks and Furnaces

A minimum of 3 samples per unit was collected.

5. Patchwork Patchwork is defined as a patch or repair to existing material based on the following quantities:

a. Surfacing material patches are limited to a maximum of 6 S. F.

b. Pipe and duct insulation patches are limited to a maximum of 6 L. F. or 6

S. F.

c. Boiler, tanks and furnace patches are limited to 6 S.F. maximum.

Page AppE - 8

If the patchwork exceeded the limits prescribed above, the sampling protocol resorted back to the homogeneous area descriptions in items 1-4. If a material qualifies as patchwork, a single sample was collected per patch.

6. Ceiling or Acoustical Tile

a. Minimum of 3 Samples

7. Miscellaneous Friable Material (INCLUDED DRYWALL & JOINT

COMPOUND)

a. 3 Samples

8. Non-friable Material

Non-friable materials for purposes of this survey would include material such as floor tiles and mastic/adhesive, linoleum floor covering, interior/exterior caulks, flooring felt (if still under floor tile), roofing materials, miscellaneous cementitious material such as wall or ceiling panels, caulking or sealant, or window glazing.

a. Minimum of 2 samples

Lead-Based Paint (LBP) Sampling Protocol

Paint chips containing lead concentrations at or above 0.5 percent by weight are considered positive for lead, based on EPA and Department of Housing and Urban Development (HUD) guidelines for Target Housing and Child Occupied Facilities.

The inspector collected paint chip samples from representative surfaces and components likely to be impacted by any renovation project and compared them against the HUD definition for Lead- Based Paint (LBP) of 0.5 % by weight. Individual sample results are presented in tabular form in Appendix B.

The Occupational Safety and Health Administration (OSHA) Construction Industry Standard for Lead (29 CFR 1926.62) does not reference the HUD definition for LBP. If detectable levels of lead are identified in any painted surface, paint disturbance will fall under the OSHA Lead Standard. OSHA 29 CFR 1926.62 requires employers to perform exposure monitoring for employees whose tasks disturb or potentially disturb lead. The data contained in this survey report should be provided to the Contractor, prior to the Contractor submitting bids for maintenance, renovation or demolition work. The Contractor shall assume that all painted surfaces may contain detectable levels of lead for purposes of this project and demonstrate through personal air sampling that airborne lead levels will not exceed 30 micrograms (µg) lead per cubic meter (m3) of air determined as an 8-hour time-weighted average (TWA), for each representative task and trade that disturbs painted surfaces.

Page AppE - 9

4. OBSERVATIONS/CONCLUSIONS

Building 3 - Asbestos

The following collected bulk sample materials contained asbestos by Polarized Light Microscopy (PLM) (reference Appendix A for the Asbestos Bulk Sampling Summary followed by the Laboratory Report and Representative Photographs of Suspect Asbestos Containing Materials).

1. Saddle Block Pipe Insulation – Foam Glass or White Friable (HM #11)

2. 12” x 12” Ceiling Tile, Large Holes with Glue Dots (HM #16)

Reference Appendix A for the Asbestos Bulk Sampling Summary followed by the Laboratory Report and Representative Photographs of Suspect Asbestos Containing Materials). Note: Floor covering and associated mastics, glues and adhesives and radiator heat shields (Transite-type) shall be assumed to contain asbestos, but are not scheduled for disturbance as part of this project.

Building 3 - Lead

All six (6) of the representative paint chip samples taken from painted surfaces in Building 3, in areas that will be impacted by the scheduled renovation project, had detectable levels of lead above the EPA/HUD definition of Lead Based Paint (LBP), a painted surface or component that contains lead equal to or in excess of 0.5% by weight via Flame Atomic Absorption Spectrophotometer (AAS) analysis.

Note: Disturbance to any painted item/surface/component shall be done in compliance with the OSHA Construction Industry Standard for Lead (29 CFR 1926.62). The Occupational Safety and Health Administration (OSHA) Construction Industry Standard for Lead (29 CFR 1926.62) does not reference the HUD definition for LBP. If detectable levels of lead are identified in any painted surface, paint disturbance will fall under the OSHA Lead Standard. OSHA 29 CFR

1926.62 requires employers to perform exposure monitoring for employees whose tasks disturb or potentially disturb lead. The data contained in this survey report should be provided to the Contractor, prior to the Contractor submitting bids for maintenance, renovation or demolition work. The Contractor shall assume that all painted surfaces may contain detectable levels of lead for purposes of this project and demonstrate through personal air sampling that airborne lead levels will not exceed 30 micrograms (µg) lead per cubic meter (m3) of air determined as an 8-hour time-weighted average (TWA), for each representative task and trade that disturbs painted surfaces.

Building 3 - PCBs/Fluorescent Lights

The specific construction date of the VAMC Alexandria, Building 3, is unknown, but is reportedly circa 1940s - 1950’s. Substantial renovation has occurred in these specific area as evidenced by relatively new construction products. All ballasts installed or manufactured prior to 1978, shall be assumed to contain PCBs unless specifically labeled as having no PCBs.

Page AppE - 10

All known or assumed PCB ballasts, capacitors or other PCB articles shall be handled in accordance with 40 CFR Part 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions and State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

All batteries, mercury-containing equipment and bulbs shall be handled in accordance with 40 CFR Part 273 Standards for Universal Waste Management and State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

Refrigerants shall be disposed on in accordance with Section 608 of the Clean Air Act (EPA Refrigerant and Recycling Rule and 40 CFR Part 82 Protection of Stratospheric Ozone) in addition to the State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1).

Fluorescent lights and high intensity discharge bulbs (HID) and other mercury-containing bulbs are regulated under the Resource Conservation and Recovery Act (RCRA) Universal Waste Rule (UWR) and Subtitle C hazardous waste regulations and the State of Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart 1). Accordingly, all bulbs shall be disposed of or recycled in accordance with the current policy of the VA Medical Center, Alexandria, Louisiana.

Refer to Appendix B for the Paint Chip Sample Summary followed by Laboratory Data and Representative Photographs of Paint Chip Samples.

5. RECOMMENDATIONS

A. The asbestos containing material survey report shall be maintained at the job site during performance of the construction activities. Provide at least ten (10) working days advanced written NESHAP Notification to the Louisiana Department of Environmental Quality, Office of Environmental Services, Public Participation and Permit Support Division, Notification and Accreditation Section by mail to: LDEQ Office of Environmental Services, Public Participation and Permit Support Division, Notification & Accreditation Section, P.O. Box 4313, Baton Rouge, LA 70821-4313. If overnight or hand delivery send to LDEQ Office of Environmental Services, Public Participation and Permit Support Division, Notification & Accreditation Section, 602 North 5th Street, Baton Rouge, LA 7082.

B. The asbestos material involved in this project is classified as NESHAP Regulated Asbestos Containing Material (RACM) ACM and Category I Non-friable (ACM) and OSHA Class I and Class II Asbestos.

C. Communication of this asbestos survey report results shall be presented in accordance with the OSHA 29 CFR 1926.1101 Asbestos Standard to all personnel who may enter or perform work on this Building 3 Project at the VA Medical Center (VAMC), Alexandria, Louisiana.

D. Asbestos waste shall be disposed of at a site recognized by DEQ, Office of Environmental Services, in accordance with Subchapter M. Asbestos, Subsection 5151 Emission Standard for Asbestos, Subsection N, Standards for Active Waste Disposal Sites.

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6. REFERENCES

1. Guidance for Controlling Asbestos-Containing Materials in Buildings”

(Purple Book). EPA 560/5-85-024. Office of Pesticides and Toxic Substances Washington, DC 20460.

2. 40 CFR, Part 763, Asbestos Hazard Emergency Response Act

3. 40 CFR, Part 763, Asbestos School Hazard Abatement Reauthorization Act

4. 40 CFR, Part 61, Subpart M Asbestos

5. 29 CFR Part 1926.1101 Asbestos

6. State of Louisiana, Regulations Governing Asbestos Abatement Projects: Chapter 27, Asbestos-Containing Materials (ACM) in Schools and State Buildings, Subsection 2701 (LAC 33:III. Chapter 27); and Chapter 51, Emission Standard for Asbestos

7. State of Louisiana Contractors Licensing Laws and Rules and Regulations, Title 37, Chapter 24

8. Louisiana Hazardous Waste Regulations (LAC 33:V.Subpart1)

If you have any questions or comments regarding this report, please do not hesitate to contact Michael F. Durbin, CIH at 770-601-7791.

Sincerely, Durbin Environmental Consultants, Inc.

Michael F. Durbin, CIH Michael F. Durbin, CIH, (Asbestos in Buildings Inspector #138242, Expires 1/27/2021 and the Louisiana Department of Environmental Quality, Accreditation Number JI138242, expiration Date January 27, 2021) President

Page AppE - 12

APPENDIX A

Asbestos Bulk Sampling Summary Followed by the Laboratory Data and Representative Photographs of Suspect Asbestos Containing Materials

Page AppE - 13

Sample Number

Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-PI1-01

Medium Pressure

Steam Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI1-02

Medium Pressure

Steam Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI1-03

Medium Pressure

Steam Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement 1

3-PI1-04

Medium Pressure

Steam Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Attic

3-PI2-01

Low Pressure Steam Paper Wrapped Pipe

Insulation NAD N/A See Lab

Report Building 3, Basement

3-PI2-02

Low Pressure Steam Paper Wrapped Pipe

Insulation NAD N/A See Lab

Report Building 3, Basement

3-PI2-03

Low Pressure Steam Paper Wrapped Pipe

Insulation NAD N/A See Lab

Report Building 3, Basement 2

3-PI2-04

Low Pressure Steam Paper Wrapped Pipe

Insulation NAD N/A See Lab

Report Building 3, Attic

3-PI3-01

Hot Water Supply

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI3-02

Hot Water Supply

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement 3

3-PI3-03

Hot Water Supply

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI4-01

Cold Water Paper

Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement 4

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Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-PI4-02

Cold Water Paper

Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI4-03

Cold Water Paper

Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement 4

3-PI5-01

Condensate Return

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI5-02

Condensate Return

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement 5

3-PI5-03

Condensate Return

Paper Wrapped Pipe Insulation

NAD N/A See Lab Report

Building 3, Basement

3-PI6-01

Brown Paper Wrapped

Pipe Insulation with Metal Bands

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

3-PI6-02

Brown Paper Wrapped

Pipe Insulation with Metal Bands

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

3-PI6-03

Brown Paper Wrapped

Pipe Insulation with Metal Bands

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

114A

3-DI1-01 Foil Wrapped Duct Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

3-DI1-02 Foil Wrapped Duct Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

Outside Room

3-DI1-03 Foil Wrapped Duct Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

3-DI2-01

Foil Wrapped Duct

Insulation with Black Mastic

NAD N/A See Lab Report

Attic 8

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Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-DI2-02

Foil Wrapped Duct

Insulation with Black Mastic

NAD N/A See Lab Report

Building 3, Attic

3-DI2-03

Foil Wrapped Duct

Insulation with Black Mastic

NAD N/A See Lab Report

Building 3, Attic 8

3-DI3-01 Paper Wrapped Duct Insulation NAD N/A See Lab

Report Building 3, Attic

3-DI3-02 Paper Wrapped Duct Insulation NAD N/A See Lab

Report Building 3, Attic 9

3-DI3-03 Paper Wrapped Duct Insulation NAD N/A See Lab

Report Building 3, Attic

3-DT1-01

Beige Paper Like Duct

Tape on Seams of Metal Duct

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

3-DT1-02

Beige Paper Like Duct

Tape on Seams of Metal Duct

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

3-DT1-03

Tape on Seams of Metal Duct

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

3-DT1-04

Beige Paper Like Duct

Tape on Seams of Metal Duct

NAD N/A See Lab Report

Building 3, 2nd Floor Corridor.

217A

3-DT1-05

Tape on Seams of Metal Duct

NAD N/A See Lab Report

Building 3, Attic

3-SB1-01

Saddle Block Pipe Insulation – Foam

Glass NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

3-SB1-02

Saddle Block Pipe Insulation – Foam

Glass NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

Outside Room

120A

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Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-SB1-03

Saddle Block Pipe Insulation – White

Friable 15% Amosite Yes See Lab

Report

Building 3, 1st Floor Corridor.

3-SB1-04

Insulation – White

Friable 15% Amosite Yes See Lab

Report

Building 3, 2nd Floor Corridor.

3-SB1-05

Insulation – White

Friable 15% Amosite Yes See Lab

Report

Building 3, 2nd Floor Corridor.

Outside Room

217A

3-SB1-06

Saddle Block Pipe Insulation – White

Friable 15% Amosite Yes See Lab

Report

Building 3, 3rd Floor Corridor.

3-PF1-01 Hard Mudded Pipe Fitting Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

3-PF1-02 Hard Mudded Pipe Fitting Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

Outside Room

3-PF1-03 Hard Mudded Pipe Fitting Insulation NAD N/A See Lab

Report

Building 3, 1st Floor Corridor.

3-CT1-01 2’ X 4’ Ceiling Tile, Long Fissures & Holes NAD N/A See Lab

Report

Building 3, Basement, Loose Tile

3-CT1-02 2’ X 4’ Ceiling Tile, Long Fissures & Holes NAD N/A See Lab

Report Building 3, 1st

Floor Room 107

3-CT1-03 2’ X 4’ Ceiling Tile, Long Fissures & Holes NAD N/A See Lab

Report Building 3, 1st

Floor Room 108 13

3-CT1-04 2’ X 4’ Ceiling Tile, Long Fissures & Holes NAD N/A See Lab

Report

Building 3, 2nd Floor Corridor.

3-CT2-01

2’ X 2’ Ceiling Tile, Gouges/Mars & Pinholes

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

Page AppE - 17

Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-CT2-02

2’ X 2’ Ceiling Tile, Gouges/Mars & Pinholes

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

3-CT2-03

2’ X 2’ Ceiling Tile, Gouges/Mars & Pinholes

NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

3-CT3-01 2’ X 4’ Ceiling Tile, Small Gouges & Holes NAD N/A See Lab

Report Building 3, 1st

Floor Room 104

3-CT3-02 2’ X 4’ Ceiling Tile, Small Gouges & Holes NAD N/A See Lab

Report Building 3, 1st

Floor Room 104 15

3-CT3-03 2’ X 4’ Ceiling Tile, Small Gouges & Holes NAD N/A See Lab

Report Building 3, 1st

Floor Room 104

3-CT4-01

12” x 12” Ceiling Tile, Large Holes with Glue

Dots

2% Chrysotile in Glue Dots No See Lab

Report

Building 3, 2nd Floor Corridor.

3-CT4-02

12” x 12” Ceiling Tile, Large Holes with Glue

Dots

2% Chrysotile in Glue Dots No See Lab

Report

Building 3, 2nd Floor Corridor.

Outside Room

3-CT4-03

12” x 12” Ceiling Tile, Large Holes with Glue

Dots

2% Chrysotile in Glue Dots No See Lab

Report

Building 3, 2nd Floor Corridor.

3-CT5-01 2’ X 2’ Ceiling Tile, Mottled Texture NAD N/A See Lab

Report

Building 3, 3rd Floor Corridor.

3-CT5-02 2’ X 2’ Ceiling Tile, Mottled Texture NAD N/A See Lab

Report

Building 3, 3rd Floor Corridor.

Outside Room

3-CT5-03 2’ X 2’ Ceiling Tile, Mottled Texture NAD N/A See Lab

Report

Building 3, 3rd Floor Corridor.

3-RF-01

Black Felt Layer

Under Red Clay Roof Tiles

NAD N/A See Lab Report

Attic 18

Page AppE - 18

Description Asbestos Present

Friable Non- Asbestos Material Present

Sample Location

HM

3-RF-02

Black Felt Layer

Under Red Clay Roof Tiles

NAD N/A See Lab Report

Building 3, Attic

3-RF-03

Black Felt Layer

Under Red Clay Roof Tiles

NAD N/A See Lab Report

Building 3, Attic 18

3-P-01 Plaster Material NAD N/A See Lab Report

Building 3, Basement

3-P-02 Plaster Material NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

3-P-03 Plaster Material NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

3-P-04 Plaster Material NAD N/A See Lab

Building 3, 2nd Floor Corridor.

Outside Room

217A

3-P-05 Plaster Material NAD N/A See Lab Report

Building 3, 2nd Floor Corridor.

3-P-06 Plaster Material NAD N/A See Lab

Building 3, 3rd Floor Corridor.

317A

3-P-07 Plaster Material NAD N/A See Lab

Building 3, 3rd Floor Corridor.

3-FS-01 Red Fire Safe Material NAD N/A See Lab

Building 3, Basement

3-FS-02 Red Fire Safe Material NAD N/A See Lab Report

Building 3, 1st Floor Corridor.

Outside Room

120A

3-FS-03 Red Fire Safe Material NAD N/A See Lab Report

Building 3, 2nd Floor Corridor.

NAD – No Asbestos Detected; N/A – Not Applicable

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Representative Photographs of Suspect Asbestos Containing Materials

Page AppE - 37

1. Medium Pressure Steam Paper Wrapped Pipe Insulation (HM #1)

2. Low Pressure Steam Paper Wrapped Pipe Insulation (HM #2)

Page AppE - 38

3. Hot Water Supply Paper Wrapped Pipe Insulation (HM #3)

4. Cold Water Paper Wrapped Pipe Insulation (HM #4)

Page AppE - 39

5. Condensate Return Paper Wrapped Pipe Insulation (HM #5)

6. Brown Paper Wrapped Pipe Insulation with Metal Bands (HM #6)

Page AppE - 40

7. Foil Wrapped Duct Insulation (HM #7)

8. Foil Wrapped Duct Insulation with Black Mastic (HM #8)

Page AppE - 41

9. Paper Wrapped Duct Insulation (HM #9)

10. Beige Paper Like Duct Tape on Seams of Metal Duct (HM #10)

Page AppE - 42

11. Saddle Block Pipe Insulation – Foam Glass or White Friable (HM #11)

12. Hard Mudded Pipe Fitting Insulation (HM #12)

Page AppE - 43

13. 2’ X 4’ Ceiling Tile, Long Fissures & Holes (HM #13)

14. 2’ X 2’ Ceiling Tile, Gouges/Mars & Pinholes (HM #14)

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15. 2’ X 4’ Ceiling Tile, Small Gouges & Holes (HM #15)

16. 12” x 12” Ceiling Tile, Large Holes with Glue Dots (HM #16)

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17. 2’ X 2’ Ceiling Tile, Mottled Texture (HM #17)

18. Black Felt Layer Under Red Clay Roof Tiles (HM #18)

Page AppE - 46

19. Plaster Material (HM #19)

20. Red Fire Safe Material (HM #20)

Page AppE - 47

APPENDIX B

Lead in Paint Summary followed by the Laboratory Report and Representative Photographs

Page AppE - 48

Collection Date

Sample Number

Description Location Analytical Method

Percent Lead by Weight (wt%)

3/12/2020 3-PC-01 Green Paint on Plaster Wall

Building 3, Basement AAS 0.887

3/12/2020 3-PC-02 Black Paint on Concrete Wall

Building 3, Basement AAS 5.752

3/12/2020 3-PC-03 Beige Paint on Plaster Wall

Building 3, 1st Floor Room 104 AAS 0.720

3/12/2020 3-PC-04 Green Paint on Plaster Ceiling

Building 3, 2nd Floor Room 217A AAS 1.238

3/12/2020 3-PC-05 Beige Paint on Plaster Ceiling

Building 3, 2nd Floor Room 223 AAS 2.647

3/12/2020 3-PC-06 Beige Paint on Plaster Ceiling

Building 3, 3rd Floor Room 303 AAS 0.872

Page AppE - 49

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Representative Photographs of Paint Chip Samples

Page AppE - 56

1. Green Paint on Plaster Wall, Building 3, Basement (Sample # 3-PC-01)

2. Black Paint on Concrete Wall, Building 3, Basement (Sample # 3-PC-02)

Page AppE - 57

3. Beige Paint on Plaster Wall, Building 3, 1st Floor Room 104 (Sample # 3-PC-03)

4. Green Paint on Plaster Ceiling, Building 3, 2nd Floor Room 217A (Sample # 3-PC-04)

Page AppE - 58

5. Beige Paint on Plaster Ceiling, Building 3, 2nd Floor Room 223 (Sample # 3-PC-05)

6. Beige Paint on Plaster Ceiling, Building 3, 3rd Floor Room 303 (Sample # 3-PC-06)

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APPENDIX C

Asbestos Inspector Accreditation Certification and Laboratory Accreditation

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ASBESTOS 3-YEAR REINSPECTION REPORT

for the

DEPARTMENT OF VETERANS AFFAIRS

ALEXANDRIA VAMC

PINEVILLE, LA

RFQ #:

VA256-17-Q-0029

INSPECTION DATES:

JANUARY 23-26, 2017

PRIME CONTRACTOR:

USFIN DEVELOPMENT, LLC.

5808 NEATHAMMER LN.

EDWARDSVILLE, IL 62025

419-382-9574

BUILDING 3 EXTRACT - 20 DECEMBER 2019

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DEPARTMENT OF VETERANS AFFAIRS

ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

TABLE OF CONTENTS

1.0 ASBESTOS INSPECTION SUMMARY

2.0 APPENDICES

Appendix A – Asbestos Cost Estimates by Building

Appendix B – Asbestos Homogeneous Areas by Building

Appendix C – Asbestos Material Assessments Areas by Building

Appendix D – Asbestos Location Drawings

Appendix E - Inspector Certifications & Training

Page AppE - 67

ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

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 IDEM Louisiana Department of Environmental Management 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 USFin USFin Development, LLC VA United States Department of Veterans Affairs VAMC VA Medical Center XRD X-Ray Diffraction

Page AppE - 68

ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

1.0 ASBESTOS INSPECTION SUMMARY

EXECUTIVE SUMMARY

From January 23-26, 2017, USFin Development, LLC performed a 3-year AHERA asbestos reinspection at the Alexandria VAMC located in Pineville, LA in accordance with RFQ VA256-17-Q-0029. The purpose of the inspection was to update existing survey information from the previous asbestos reinspection conducted in 2013 by Altec Environmental Consultants. 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.

The inspection was conducted by Brett Brumbaugh and Sam Ansara (USFin) and Jeremiah Garms of PSI/Intertek. The project manager was Mr. Brumbaugh who has been conducting asbestos surveys, sampling, and asbestos management planning work since 1987.

Previous sampling results and inventory spreadsheets from the previous survey and additional asbestos information provided by the current staff of the VAMC were used in this report. No additional samples of newly identified suspect materials were collected during this inspection.

Certain areas such as inaccessible pipe chases, areas above fixed permanent ceilings, and flooring materials located beneath carpeting were not inspected or tested.

2.0 ASBESTOS BACKGROUND

The term asbestos describes six naturally occurring fibrous minerals found in certain types of rock formations. The minerals chrysotile, amosite, and crocidolite have been most commonly used in building products such as floor tile, pipe insulation, boiler insulation, asbestos cement materials, roofing materials, and plasters. The minerals anthophyllite, actinolite, and tremolite are not frequently found in ACBM.

Intact and undisturbed ACBM do not pose a health risk. They may, however, become a health hazard if they are damaged, disturbed, or deteriorate over time and release fibers into the air. If released into the air, asbestos fibers may be inhaled. After prolonged or intense exposure, inhaled asbestos fibers may cause various types of lung disease. The health risks associated with asbestos exposure are greater for those who smoke.

3.0 REGULATORY BACKGROUND

3.1 Federal Regulations

The United States Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and delegated states are responsible for regulating environmental exposure and protecting workers from asbestos exposure. OSHA is responsible for the health and safety of workers who may be exposed to asbestos in connection with their jobs (Occupational Exposure to Asbestos; Title 29, Code of Federal Regulations (CFR) Parts 1910.1001 and 1926.1101). The EPA and state regulators are responsible for developing and enforcing

Page AppE - 69

ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

regulations necessary to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health.

In 1979, EPA began an asbestos technical assistance program for building owners, environmental groups, contractors, and industry. In May 1982, EPA issued the first regulation intended to control asbestos in schools under the authority of the Toxic Substances Control Act (TSCA); this regulation is known as the Asbestos-in-Schools Rule.

Two EPA regulations govern asbestos: the Asbestos Hazard Emergency Response Act (AHERA) and the National Emission Standards for Hazardous Air Pollutants (NESHAP).

AHERA

In 1986, Congress enacted AHERA (Title 40, CFR Part 763) which mandated a regulatory program to address the asbestos hazards in schools. A part of AHERA deals with the mandatory training and accreditation of persons who perform certain types of asbestos-related work in schools.

Subsequently, in 1990 Congress amended AHERA to extend some of the training and accreditation requirements to persons performing such work in public and commercial buildings.

AHERA requires inspections of school buildings to determine the conditions of ACBM and preparation of management plans which recommend the best way to reduce the asbestos hazards.

The United States Veterans Administration (VA) has adopted many of the requirements of AHERA for surveys performed at VA facilities. The methods may include removal, encapsulation, enclosure, repair, and operations and maintenance to protect human health and the environment from ACBM.

NESHAP

The Clean Air Act (CAA) of 1970 required EPA to develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health; therefore, EPA promulgated NESHAP (Title 40, CFR Part 61) on April 6, 1973.

NESHAP is intended to minimize the release of asbestos fibers during certain activities (i.e., renovations, demolition, and installations). It specifies work practices to be followed during renovations of buildings (except apartment buildings that have no more than four dwelling units) which contain a specific amount of friable asbestos. NESHAP requires that buildings be inspected for ACBM prior to renovation/demolition projects.

NESHAP also requires owners and operators subject to the asbestos rules to notify delegated state and local agencies and/or the regional EPA offices before demolition or renovation activities begin. In addition, NESHAP requires the removal of all friable ACBM prior to demolition.

OSHA

OSHA began regulating workplace asbestos exposure in 1970, adopting a permissible exposure limit (PEL) to regulate worker exposure. The original asbestos standard has been revised several times to better protect workers. On August 10, 1994, OSHA issued a revised final standard regulating asbestos exposure in all industries. The newly revised standard for the construction

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ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

industry lowers the PEL. The revised standard also establishes a new classification system for asbestos construction work, which clearly spells out mandatory work practices to follow to reduce worker exposures (see Occupational Exposure to Asbestos, Title 29, CFR 1926.1101).

3.2 State and Local Regulations

Louisiana state regulations are similar to the Federal regulations. In many instances state and local asbestos regulations are more stringent, therefore, it is recommended that the applicable state asbestos regulation(s) be reviewed before the start of any renovation/demolition projects.

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.

4.0 ANALYTICAL METHODS AND LIMITATIONS

4.1 Bulk Sampling Protocol

EPA and OSHA define an ACBM as any material which contains greater than 1percent asbestos (some state regulations may be more stringent). The ACBM inspection and bulk sampling were performed in accordance with the methods outlined in the EPA guidance document titled Guidance for Controlling Asbestos-Containing Materials in Buildings (Document No. 560/5-85/024). In addition, bulk sampling of asbestos was performed in accordance with 40 CFR Part 763, AHERA requirements for number of samples and types of ACBM to be sampled. According to these requirements, materials are classified as either surfacing (e.g., decorative plaster, spray-applied fireproofing), thermal system insulation (e.g., pipe insulation, pipe fitting insulation, boiler insulation), or miscellaneous materials (e.g., floor tile, ceiling tile, plaster, wallboard, mastics).

The number of samples collected from each material varies based on the classification of the material and increases as the potential for a non-uniform mixture of asbestos in the material increases. Typically, regulations require a minimum number of samples to be collected from the different classifications of suspect ACBM, as follows:

• Surfacing Material

a) Three samples from homogeneous areas up to 1,000 square feet

b) Five samples from homogeneous areas between 1,000 and 5,000 square feet

c) Seven samples from homogeneous areas over 5,000 square feet

• Thermal System Insulation

a) Minimum of three samples per homogeneous area

• Miscellaneous Material

a) Minimum of two samples per homogeneous area, but must be sufficient to determine asbestos content

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ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

5.0 SUMMARY OF FINDINGS

5.1 Survey Access Limitations

All accessible areas within the facilities were inspected for ACBM, including access panels to chases, areas above suspended ceilings, and crawl spaces. Any areas not inspected included non-accessible pipe chases, areas above plaster ceilings, areas above patient-care operations, secured areas, and areas occupied by patients where access could not be gained.

The areas not inspected, or where access could not be obtained, must be assumed to contain asbestos and be inspected prior to any renovation or demolition activities.

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, USFin recommends that exploratory demolition be performed and a qualified inspector be utilized to examine the areas and collect samples as needed. USFin recommends sampling of roofing materials, duct mastics, laboratory equipment and electrical components (not specifically examined as part of this survey) if renovation activities are planned which may disturb these materials.

Respectfully Submitted:

Brett L. Brumbaugh – Project Manager

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ALEXANDRIA VAMC – PINEVILLE, LA

JANUARY 2017

LISTING OF BUILDINGS INSPECTED

BLDG.

# BUILDING NAME YEAR BUILT # OF FLOORS SQUARE

FOOTAGE

1 Administration Building 1929 4 29,600

2 C&P 1929 4 62,500

3 Women' s Clinic 1929 3 27,500

4 Food and Nutrition 1929 3 24,000

5 Engineering 1929 3 38,500

6 HR 1929 3 40,500

7 Hospital 1950 7 260,500

8 Canteen Service 1940 3 22,500

13 Metal Shop 1929 1l 6,800

15 Fire Station 1931 2 7,500

18 Quarters 1929 3 2,748

19 Quarters 1929 3 5,090

20 Quarters 1929 3 5,090

21 Quarters 1929 3 5,090

22 Quarters 1929 3 4,285

38 Generator Building 1 440

39 Generator Building 1 440

42 Pump House 1 150

117 Paint Shop 1946 1 1,050

120 Paint Shop 1946 1 1,050

TOTAL SQUARE FOOTAGE 545,333

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APPENDIX A

Asbestos Cost Estimates - Building 3

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- 7

APPENDIX B

Asbestos Homogeneous Areas - Building 3

Page AppE - 76

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APPENDIX C

Asbestos Material Assessments Areas - Building 3

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APPENDIX D

Asbestos Location Drawings Building 3

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