Asbestos and HazMat Summary 565-21-101 Halls and Walls.pdf

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Z1DA--Renovate Halls and Walls Basement and First Floor
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This document contains an asbestos and hazardous materials survey report for the planned renovation of halls and walls in the basement and first floor of Building 1 at the Fayetteville Veteran Affairs Medical Center in Fayetteville, North Carolina. The report summarizes the results of an inspection conducted on January 31, 2022, which found no asbestos-containing materials or lead-based paint in the renovation areas. A total of 240 fluorescent light tubes and 16 exit light batteries were identified as universal waste that will require proper handling and disposal. Related solicitation number 36C24623B0041 from the Department of Veterans Affairs seeks renovation services for the basement and first floor areas, with an emphasis on abatement of identified universal wastes and compliance with all applicable regulations for hazardous material handling and removal.

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35% SCHEMATIC DESIGN SUBMISSION

ASBESTOS & HAZMAT MATERIALS SUMMARY

FAYETTEVILLE VA MEDICAL CENTER – FAYETTEVILLE, NC

BUILDING 1 HALLS AND WALLS PROJECT 550-21-101

Date: February 23, 2022

Items: Summary Results of Asbestos & HazMat, Site Visit, Visual Inspection, Lab Results

Site Visit: January 31, 2022

Inspectors: Brett Brumbaugh, Castle Hill Associates

Findings: Universal Wastes are present in the renovation areas No asbestos containing materials are present No lead-based paint was identified in the areas

Universal Waste Materials Summary

Hazardous Materials Locations Quantity

Fluorescent tubes & CFL Bulbs Basement and 1st floors 240 fixtures

Batteries in exit light fixtures Basement and 1st floors 16 fixtures

35% SCHEMATIC DESIGN SUBMISSION

ASBESTOS & HAZMAT MATERIALS SUMMARY

FAYETTEVILLE VA MEDICAL CENTER – FAYETTEVILLE, NC

BUILDING 1 HALLS AND WALLS PROJECT 550-21-101

Estimator: Brett Brumbaugh

Notes: Based on 2022-23 construction and bidding (normal working hours)

EXCLUDES:

• Overtime or shift work.

INCLUDES:

• Bonds, insurance, contractor overhead and profit

• Prevailing wage rates for Fayetteville, NC

Cost Index: North Carolina

Description Material Quantity Unit Cost Amount

HazMat Removal

02 84 16 Fluorescent tubes removal (EA) 240 $6.00 $1,440.00

02 84 16 Backup battery removal/disposal (EA) 16 $50.00 $800.00

TOTAL COST ESTIMATE $2,240.00

ASBESTOS & LEAD PAINT SAMPLING REPORT

for

FAYETTEVILLE VA MEDICAL CENTER

FAYETTEVILLE, NC

PROJECT:

BUILDING 1 – BASEMENT & 1st FLOOR

HALLS AND WALLS PROJECT

PROJECT 565-21-1021

INSPECTION DATE:

JANUARY 31, 2022

CONSULTANT:

CASTLE HILL ASSOCIATES, LLC

1197 FARNSWORTH RD., UNIT E

WATERVILLE, OH 43566

567-952-0212 www.CASTLEHILLASSOCIATES.com

TABLE OF CONTENTS

• ASBESTOS & LEAD PAINT SAMPLING SUMMARY

• ABESTOS BULK SAMPLING DESCRIPTIONS AND LAB RESULTS

• LEAD XRF SAMPLING RESULTS

• ASBESTOS LABORATORY REPORT

• ASBESTOS LABORATORY CERTIFICATIONS

• INSPECTOR CERTIFICATIONS

APPENDIX A – 2019 ASBESTOS REINSPECTION FOR BUILDING 1

ASBESTOS & LEAD-BASED PAINT SURVEY REPORT

PROJECT 565-21-101

ASBESTOS INSPECTION SUMMARY

On January 31, 2022, Brett Brumbaugh of Castle Hill Associates performed an asbestos survey and lead XRF testing prior to the planned renovations in Building 1 on the basement and first floors of the Fayetteville VAMC in Fayetteville, NC. Bulk samples were collected of suspect asbestos containing materials that had not been previously sampled during previous asbestos surveys in the building. There were 22 bulk samples taken as part of this survey with the materials identified in the report included in this submission.

The asbestos bulk sampling conducted as part of this project was based upon the appearance, texture, and location of the suspect materials. All bulk samples were analyzed utilizing current EPA methods for PLM (Polarized Light Microscopy) by EMSL Analytical in Plymouth, MI. EMSL is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program) and also an American Industrial Hygiene Association (AIHA) accredited laboratory.

Prior to this sampling, Castle Hill was provided with previous sampling results conducted by the VA including the last 3-year reinspection conducted by Castle Hill Associates in 2019 which is included in Appendix A.

Lead paint testing was conducted on all painted surfaces in the renovation areas using a Viken Detection Pb200i direct read XRF analyzer. Painted components that were tested in the areas are considered to be “lead-based” paint as defined by the US EPA (greater than 1.0 mg/cm2).

The inspection was conducted and the report was prepared by Brett Brumbaugh who is licensed by the State of North Carolina as an Asbestos Inspector and is also an EPA Licensed Lead Risk Assessor. Mr. Brumbaugh has been conducting asbestos surveys and lead sampling since 1987, and is a registered environmental property assessor (REPA) and certified environmental and safety officer (CESCO) through the NREP (National Registry of Environmental Professionals)

Asbestos Materials Summary

• No asbestos containing materials were identified in the renovation areas.

Lead-Based Paint Summary As a result of the XRF testing of the building components in the work areas, there were no building components identified which contained quantities of lead above the EPA & HUD “Lead Based Paint Federal Action Level” for a painted surface containing less than 1.0 mg/cm² or greater using the XRF technology.

UNIVERSAL WASTES FINDINGS

The universal waste survey was conducted to identify all confirmed and potential universal wastes (PCB and mercury containing components, High Intensity Discharge (HID) lighting lamps, transformers, thermostats, hydraulic lifts, switches, and other suspect equipment) which may require special handling and disposal as part of renovation or demolition projects.

As a result of this inspection, the following Universal Wastes were identified in the renovation areas of the building:

Hazardous Materials Locations Quantity

Fluorescent tubes & CFL Bulbs Basement and 1st floor halls 240 fixtures

Batteries in exit light fixtures Basement and 1st floor halls 16 fixtures

CONCLUSIONS/RECOMMENDATIONS

UNIVERSAL WASTES: The identified Universal Wastes are not required to be removed prior to renovation, however if they are removed then they must be handled, transported, and disposed/recycled in an EPA approved facility by persons with proper training in the handling of Universal Wastes.

Respectfully Submitted, Brett L. Brumbaugh, REPA, CESCO State of North Carolina Asbestos Inspector, License # 12411 Lead Risk Assessor – EPA License # LBP-R-I216003-1

ASBESTOS SAMPLING PROTOCOL

The bulk samples were collected from locations that were selected to be representative of the building materials. Sampling was accomplished using the simplified sampling scheme referenced in the AHERA regulations and found in the “Pink Book”. Locations of individual samples are referenced on this report.

The samples were either collected with a coring tool designed for asbestos sampling or placed into a plastic bag for laboratory analysis. The samples were analyzed via polarized light microscopy with dispersion staining, using the “Interim method for the Determination of Asbestos in Bulk Insulation Samples” found in Appendix A to Subpart F in 40 CFR Part 763.

The regulations require specific numbers of samples be obtained per homogeneous area. For example, when sampling for joint compound or asbestos in hard plaster (sprayed-on or troweled-on surfacing materials) samples are to be taken based on the following increments: 0 to 1000 square feet of material, 3 samples are necessary. From 1001 to 5000 square feet, 5 samples are necessary, over 5000 square feet 7 samples are required. If during analysis any samples are found to contain asbestos, the entire homogeneous area is delineated as asbestos containing material. In the case of pipe insulation or other types of manufactured materials, the regulations require only enough samples to ascertain whether asbestos is present. In this case, the minimum number of samples to collect and analyze is usually three. The sampling performed in this inspection followed these sampling guidelines.

ASBESTOS GLOSSARY OF TERMS

Friable asbestos material: means any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763 section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Category I Non-friable Asbestos Containing Material (ACM) means asbestos containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more that 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy.

Category II Non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos Containing Material (RACM): means (a) Friable asbestos material, (b) Category I non-friable ACM that has become friable, (c) category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) 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 expected in the course of demolition or renovation operations regulated by this subpart.

ASBESTOS BULK SAMPLE DESCRIPTIONS & RESULTS

Facility: Fayetteville VA Medical Center Project: Building 1 Basement & 1st Floor (Halls & Walls) Project: 565-21-101 Sampling Date: January 31, 2022 Analysis Date: February 4-7, 2022 Laboratory: EMSL Analytical, Inc. – Plymouth, MI Accreditation: NVLAP Asbestos Bulk Accredited Laboratory 101048-4 Sampler: Brett Brumbaugh License #: 12411 – N. Carolina Asbestos Inspector

SAMPLE

# MATERIAL DESCRIPTION SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1a 12” tan floor tile Stairwell B01 No Asbestos Detected

1b Beige mastic “” No Asbestos Detected

2a 12” tan floor tile Stairwell 101 No Asbestos Detected

2b Beige mastic “” No Asbestos Detected

3 Yellow cove base mastic E. end of B. hallway by entry No Asbestos Detected

4 Yellow cove base mastic 1st floor hall by 128 No Asbestos Detected

5 Drywall joint compound Basement hallway by Dental No Asbestos Detected

6 Drywall joint compound Basement hall by B10 stairs No Asbestos Detected

7 Drywall joint compound 1st hallway by front lobby No Asbestos Detected

8 2x2 lay-in ceiling tile Basement hall by B15 No Asbestos Detected

9 2x2 lay-in ceiling tile 1st hallway E. of lobby No Asbestos Detected

10 Yellow mastic for vinyl plank flooring Basement hall by 76A No Asbestos Detected

11 Yellow mastic for vinyl plank flooring 1st hallway by 109 No Asbestos Detected

12 Yellow mastic for rubber edge guards Basement hall by 76A No Asbestos Detected

13 Yellow mastic for rubber edge guards 1st hallway by 109 No Asbestos Detected

14a Hard plaster (finish coat) Basement hall by 76A No Asbestos Detected

14b Hard plaster (base coat) “” No Asbestos Detected

15a Hard plaster (finish coat) 1st hallway by front lobby No Asbestos Detected

15b Hard plaster (base coat) “” No Asbestos Detected

16a Hard plaster (finish coat) 1st hallway by 109 No Asbestos Detected

16b Hard plaster (base coat) “” No Asbestos Detected

Notes:

• Asbestos containing materials are defined by containing greater than 1% asbestos.

• Previously tested Asbestos materials were not re-sampled as part of this project.

ASBESTOS LABORATORY REPORT

EMSL ANALYTICAL, INC.

EMSL Analytical, Inc.

15111 Northville Rd Plymouth, MI 48170

Tel/Fax: (734) 668-6810 / (734) 668-8532 http://www.EMSL.com / annarborlab@emsl.com

082200310EMSL Order:

Customer ID: CHAS42

Customer PO: FVA

Project ID:

Attention: Phone:Brett Brumbaugh (567) 952-0212

Fax:Castle Hill Associates, LLC

Received Date:218-A Mechanic St. 02/03/2022 8:00 AM

Analysis Date:Waterville, OH 43566 02/04/2022 - 02/07/2022

Collected Date:

Project: Fayetteville VAMC

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

082200310-0001

None DetectedNon-fibrous (Other)98%Cellulose2%Black

Non-Fibrous

Homogeneous

Mastic

082200310-0001A

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Floor Tile

082200310-0001B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Adhesive

082200310-0002

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

Floor Tile

082200310-0002A

None DetectedNon-fibrous (Other)100%Cellulose<1%Yellow

Non-Fibrous

Homogeneous

Adhesive

082200310-0003

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Mastic

082200310-0004

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Mastic

082200310-0005

None DetectedMica

Non-fibrous (Other)

5%

95%

White

Non-Fibrous

Homogeneous

Drywall Mud

082200310-0006

None DetectedMica

Non-fibrous (Other)

4%

96%

White

Non-Fibrous

Homogeneous

Drywall Mud

082200310-0007

None DetectedMica

Non-fibrous (Other)

3%

97%

White

Non-Fibrous

Homogeneous

Drywall Mud

082200310-0008

None DetectedPerlite

Non-fibrous (Other)

30%

10%

Cellulose

Min. Wool

30%

30%

Gray/White

Fibrous

Heterogeneous

Ceil Tile

082200310-0009

None DetectedPerlite

Non-fibrous (Other)

30%

10%

Cellulose

Min. Wool

30%

30%

Gray/White

Fibrous

Heterogeneous

Ceil Tile

082200310-0010

None DetectedNon-fibrous (Other)97%Cellulose3%Yellow

Non-Fibrous

Homogeneous

Mastic

082200310-0011

None DetectedNon-fibrous (Other)98%Cellulose2%Yellow

Non-Fibrous

Homogeneous

Mastic

082200310-0012

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Mastic

082200310-0013

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Mastic

Initial report from: 02/07/2022 15:50:13

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 2/7/2022 3:50 PM

Tel/Fax: (734) 668-6810 / (734) 668-8532 http://www.EMSL.com / annarborlab@emsl.com

082200310EMSL Order:

Customer ID: CHAS42

Customer PO: FVA

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

082200310-0014

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Finish Coat

082200310-0014A

None DetectedQuartz

Non-fibrous (Other)

5%

95%

Gray

Non-Fibrous

Homogeneous

Base Coat

082200310-0015

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Finish Coat

082200310-0015A

None DetectedQuartz

Non-fibrous (Other)

6%

94%

Cellulose<1%Gray

Non-Fibrous

Homogeneous

Base Coat

082200310-0016

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Finish Coat

082200310-0016A

None DetectedQuartz

Non-fibrous (Other)

8%

92%

Gray

Non-Fibrous

Homogeneous

Base Coat

Analyst(s)

Ashton Bullock (18)

Waverly Ferguson (4)

Ryan Shannon, Laboratory Manager or Other Approved Signatory

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. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non- friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Plymouth, MI NVLAP Lab Code 101048-4

Initial report from: 02/07/2022 15:50:13

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 2/7/2022 3:50 PM

OrderID: 082200310

OrderID: 082200310

LEAD XRF TESTING DATA

Project: Fayetteville VAMC - Bldg. 1

Project: Basement & 1st Floor Halls and Walls

Inspector: Brett Brumbaugh

Date: 1/31/2022

XRF Mfg.: Viken Detection

Model: Pb200i

Type: XRF Lead Paint Analyzer

Serial # 2757

Reading # Building Area Component Paint Color Pb Conc.

mg/cm2 Result

1 Basement hall by B39 Metal door frame Yellow 0.1 Negative

2 Basement hall by B39 Metal exit door Yellow -0.2 Negative

3 Stairwell B35 Plaster wall Yellow -0.1 Negative

4 Corridor COAN Elevator door frame White -0.2 Negative

5 Corridor COAN Plaster wall White 0.2 Negative

6 Basement hall by B36 Plaster wall Yellow 0.2 Negative

7 Basement hall by B37 Metal door frame Yellow 0.3 Negative

8 Basement hall by B38 Wood door frame White -0.1 Negative

9 Basement hall by B39 Drywall wall White 0.0 Negative

10 Basement hall by B31 Wood window sill White -0.2 Negative

11 Basement hall by B46 Wood window sill White -0.1 Negative

12 Corridor COAS Passage door frame Yellow -0.2 Negative

13 1st hall by 109 Drywall wall Yellow 0.4 Negative

14 1st hall by 113 Plaster wall Yellow 0.0 Negative

15 1st hall by 122 Plaster wall Yellow 0.1 Negative

16 1st hall by 1121 Metal door frame White -0.1 Negative

17 1st hall by 116 Plaster wall White 0.3 Negative

18 1st hall by 109 Metal door frame White -0.1 Negative

19 1st hall by 136 Metal railing White -0.4 Negative

20 Stairwell 1-01 Stair Riser White -0.1 POSITIVE

21 1st hall by 133 Plaster wall Yellow -0.1 Negative

22 1st hall by 136 Plaster wall Yellow 0.0 Negative w

LABORATORY CERTIFICATIONS

INSPECTOR CERTIFICATIONS

National Registry of Environmental Professionals

For Environmental Certifications

This is to Certify that

Brett Brumbaugh having sucessfully demonstrated to the Academic Board of this organization the required level of knowledge and ability, is here by awarded the distinction of

Registered Environmental Property Assessor together with all rights, benefits and privileges attached thereto and that the name and title of the aforementioned registrant is today placed upon the register of the organization.

Given under our hands on this 31st day of October, 1996.

Registrant Number

This Certificate is the property of the National Registry of Environmental Professionals and must, upon demand, be returned.

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National Registry of Environmental Professionals

For Environmental Certifications

This is to Certify that

Brett L. Brumbaugh having sucessfully demonstrated to the Academic Board of this organization the required level of knowledge and ability, is here by awarded the distinction of

Certified Environmental and Safety Compliance Officer together with all rights, benefits and privileges attached thereto and that the name and title of the aforementioned registrant is today placed upon the register of the organization.

Given under our hands on this 15th day of September, 2016.

123337

Registrant Number

This Certificate is the property of the National Registry of Environmental Professionals and must, upon demand, be returned.

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APPENDIX A

PREVIOUS INSPECTION REPORT

ASBESTOS REINSPECTION REPORT

LOCATION:

FAYETTEVILLE VA MEDICAL CENTER

2300 RAMSEY STREET

FAYETTEVILLE, NC 28301

PROJECT NO.: V06-18-102

CONTRACT: 36C24619N0872

INSPECTION DATES:

AUGUST 26-27, 2019

PRIME CONTRACTOR:

CASTLE HILL ASSOCIATES, LLC

218-A MECHANIC ST.

WATERVILLE, OH 43566

567-952-0212

FAYETTEVILLE VA MEDICAL CENTER - FAYETTEVILLE, NC

AUGUST 2019

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

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

Appendix C – Photographs of Asbestos Materials

Appendix D – Asbestos Laboratory Reports

Appendix E - Inspector Certifications

Appendix F - Lab Certifications

Appendix G – Asbestos Locations and Sample Location Drawings

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

1.0 EXECUTIVE SUMMARY

On August 26-27, 2019, Castle Hill Associates, LLC was contracted by the US Department of Veterans Affairs (VA) to perform asbestos re-inspections of 23 buildings on the site of the Fayetteville VA Medical Center in Fayetteville, NC. The survey was performed as part of the VA Project Number V06-18-102 under Contract 36C24618Q0693. The Performance Work Statement (PWS) issued by the VA defined the scope of work for the asbestos survey. The buildings that were surveyed as part of this project included:

Building Number

Building Name/Description Total Square

Footage Year Built

1 Main Hospital 257,923 1939; Renovated 1988

3 Medical Center Ancillary Services 48,025 1939; Renovated 1976

4 Admin Education Nursing 10,100 1939

8 Health Admin Services 5,557 1939

9 Engineering Shops/Garages 6,073 1939

10 Laundry Plant/Drug Cache 7,912 1939; Renovated 1995

11 Boiler Plant 8,047 1939

15 Garage near Quarters 180 1939

16 Garage near Quarters 1,500 1939

18 Garage Storage 367 1939

20 Engineering Storage 300 1977

21 Computer Building 2,508 1986; Renovated 1994

22 Incinerator Building (no incinerator) 373 1988

24 Hazardous Waste Storage 200 1996

30 Quonset Hut Storage Building 1,300 1959

34 Generator Building 504 1973

35 Chiller Plant 2,417 1974

37 Electrical Distribution 250 1977

The inspection was conducted by Brett Brumbaugh. The project manager was Mr. Brumbaugh who has been conducting asbestos surveys, sampling, and consulting work since 1987. He is a State of North Carolina Asbestos Inspector. There was a previous asbestos reinspection and sampling conducted at the facility most recently in 2013 and those reports were reviewed and utilized by Castle Hill prior to this inspection. There were no limitations or exceptions to the PWS for the surveys conducted.

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 North Carolina asbestos inspection and 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 ANALYTICAL METHODS AND LIMITATIONS

3.1 Asbestos Sampling Protocol

EPA and OSHA define an ACBM as any material which contains greater than 1 percent asbestos. 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.

All bulk samples were analyzed utilizing current EPA methods for PLM (Polarized Light Microscopy) by EMSL Analytical in Plymouth, MI. EMSL is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program) and also an American Industrial Hygiene Association (AIHA) accredited laboratory.

4.0 SUMMARY OF FINDINGS

4.1 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

12” or 9” vinyl floor tile and/or black mastic Basement, 1st, 2nd, 3rd, 4th, and 5th floors 8,620 sf Window glazing and window frame caulk Basement, 1st, 2nd, 3rd, 4th, and 5th floors All windows Pipe insulation behind walls and above ceilings

Basement, 1st, 2nd, 3rd, 4th, and 5th floors Unknown

Exterior door frame caulk Basement, 1st, and 5th floors 26 doors Exterior vent pipe caulk 5th floor 16 vents

Building 3 - Medical Center Ancillary Services

Pipe insulation on steam and domestic water lines

Mechanical Rooms 2 & 3; and assumed to be located behind plaster walls & ceilings

180 lf

12” vinyl floor tile and black mastic 1st, 2nd, 3rd, and 4th floors 820 sf

Building 4 - Admin Education Nursing lines

Inaccessible wall chases and ceiling plenums Unknown

12” vinyl floor tile and mastic Basement 140 sf

Building 8 - Health Admin Services lines

Inaccessible wall chases and ceiling plenums Unknown

12” vinyl floor tile and mastic 1st floor custodial storage closet 104 15 sf

Building 9 - Engineering Shops/Garages lines

Inaccessible wall chases and ceiling plenums Unknown

12” vinyl floor tile and mastic 103B, 104, 110, 111, and 113 1,020 sf Residual mastic under carpeting 108 and 109 1,100 sf

Building 10 - Laundry Plant/Drug Cache

• All known asbestos containing materials have been removed from this building.

Building 11 - Boiler Plant

Window glazing and caulking All windows (basement, 1st, and 2nd floors) 26 windows 12” vinyl floor tile and mastic Office, locker room, and hallway 494 sf

Building 15 - Garage near Quarters

• There are no known asbestos containing materials in this building.

Building 16 – Garage near Quarters

Building 18 – Garage Storage

Building 20 – Engineering Storage

Building 21 – Computer Building

Building 22 – Incinerator Building

Building 24 – Hazardous Waste Storage

Building 30 – Quonset Hut Storage Building lines

W. entrance and ceiling plenum 290 lf

Exterior caulking on metal roofing All seams of roofing 680 lf

Building 34 – Generator Building

Building 35 – Chiller Plant

Window glazing and caulking All windows 6 windows 12” vinyl floor tile and mastic Office 120 sf

Building 37 – Electrical Distribution

5.0 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 Categories define 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

6.0 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 VA Medical Centers, 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 costlier 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.

7.0 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.

Respectfully Submitted:

Brett L. Brumbaugh, REPA, CESCO State of North Carolina Asbestos Inspector License Number 12411

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

AUGUST 2019

ASBESTOS BULK SAMPLING INFORMATION

Facility:

Building:

Sampling Date:

Analysis Dates:

Laboratory:

Accreditation:

Sampler:

Accreditation:

Fayetteville VA Medical Center – Fayetteville, NC Building 1 - Main Hospital August 26, 2019 September 3, 2019 EMSL Analytical - Plymouth, MI NVLAP Asbestos Bulk Accredited Laboratory # 101048-4 Brett Brumbaugh State of North Carolina – Asbestos Inspector #12411

PLM Laboratory Analysis Result

SAMPLE

NUMBER

MATERIAL SAMPLE LOCATION

LABORATORY ANALYSIS

RESULT

1 Spray-on fireproofing on column Penthouse – S. side No Asbestos Detected

2 Spray-on fireproofing on column Penthouse – Middle No Asbestos Detected

3 Spray-on fireproofing on column Penthouse – N. side No Asbestos Detected

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

APPENDIX B

Asbestos Quantities, Assessments, & Remediation Cost Estimates

Fayetteville VAMC - Fayetteville, NC

Asbestos Assessments and Cost Estimates

August 2019

Asbestos Material Locations Quantity

AHERA

Category

Friability

%Damage

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

12” or 9” vinyl floor tile and/or black mastic Basement, 1st, 2nd, 3rd, 4th, and 5th floors 8,620 sf MISC Non-friable

0% 1 O&M; Remove at renovation or demolition 7 No damage $43,100

Window glazing and window frame caulk Basement, 1st, 2nd, 3rd, 4th, and 5th floors All windows MISC Non-friable

0% 1 O&M; Remove at renovation or demolition 7 No damage $120,000

Pipe insulation behind walls and above ceilings Basement, 1st, 2nd, 3rd, 4th, and 5th floors Unknown TSI Friable 0% 1 O&M; Remove at renovation or demolition 7 No damage Unknown

Exterior door frame caulk Basement, 1st, and 5th floors 26 doors MISC Non-friable

0% 1 O&M; Remove at renovation or demolition 7 No damage $52,000

Exterior vent pipe caulk 5th floor 16 vents MISC Non-friable

0% 1 O&M; Remove at renovation or demolition 7 No damage $16,000

TOTALS 0 $231,100

Note: The start date for all response actions is October of 2019

PHOTOGRAPHS OF ASBESTOS MATERIALS

Photo 1-1 12” tan vinyl floor tile and black mastic

Photo 1-2

12” white vinyl floor tile and black mastic

Photo 1-3 9” red vinyl floor tile and black mastic

Photo 1-4 Window glazing and window frame caulk

PHOTOGRAPHS OF ASBESTOS MATERIALS

Photo 1-5 Window glazing and window frame caulk

Photo 1-6

Exterior door frame caulk

Photo 1-7

Exterior door frame caulk

APPENDIX D

ASBESTOS LABORATORY REPORTS

Tel/Fax: (734) 668-6810 / (734) 668-8532 http://www.EMSL.com / annarborlab@emsl.com

081902549EMSL Order:

Customer ID: CHAS42

Customer PO: VISN6

Project ID:

Attention: Phone:Brett Brumbaugh (567) 952-0212

Fax:Castle Hill Associates, LLC

Received Date:218-A Mechanic St. 08/30/2019 12:00 PM

Analysis Date:Waterville, OH 43566 09/03/2019

Collected Date:

Project: VISN 6 - Fayetteville VAMC

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

081902549-0001

None DetectedNon-fibrous (Other)100%Glass<1%White

Non-Fibrous

Homogeneous

081902549-0002

None DetectedNon-fibrous (Other)98%Glass2%White

Non-Fibrous

Homogeneous

081902549-0003

None DetectedNon-fibrous (Other)96%Glass4%White

Non-Fibrous

Homogeneous

081902549-0004

None DetectedNon-fibrous (Other)98%Wollastonite

Fibrous (Other)

2%

<1%

Gray/Beige

Non-Fibrous

Homogeneous

081902549-0005

None DetectedMica

Non-fibrous (Other)

<1%

100%

Wollastonite<1%Gray/White/Beige

Non-Fibrous

Homogeneous

081902549-0006

None DetectedMica

Non-fibrous (Other)

2%

98%

Wollastonite<1%Gray/White

Non-Fibrous

Homogeneous

081902549-0007

None DetectedNon-fibrous (Other)100%Wollastonite<1%Gray/White

Non-Fibrous

Homogeneous

Caulk A

081902549-0007A

2% ChrysotileQuartz

Non-fibrous (Other)

2%

96%

Gray/White/Silver

Non-Fibrous

Heterogeneous

Caulk B

Result includes a small amount of inseparable attached material

081902549-0008

None DetectedNon-fibrous (Other)100%Wollastonite<1%Gray/White

Non-Fibrous

Homogeneous

Caulk A

081902549-0008A

2% ChrysotileQuartz

Non-fibrous (Other)

4%

94%

Gray/White/Silver

Non-Fibrous

Heterogeneous

Caulk B

Result includes a small amount of inseparable attached material

081902549-0009

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Caulk A

081902549-0009A

2% ChrysotileNon-fibrous (Other)96%Wollastonite2%Gray

Non-Fibrous

Homogeneous

Caulk B

Result includes a small amount of inseparable attached material

081902549-0010

2% ChrysotileNon-fibrous (Other)98%Gray/White

Non-Fibrous

Homogeneous

081902549-0011

2% ChrysotileNon-fibrous (Other)98%Gray/White/Beige

Non-Fibrous

Homogeneous

081902549-0012

2% ChrysotileQuartz

Non-fibrous (Other)

4%

94%

Gray

Non-Fibrous

Homogeneous

Initial report from: 09/04/2019 12:16:53

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 9/4/2019 12:16 PM

Tel/Fax: (734) 668-6810 / (734) 668-8532 http://www.EMSL.com / annarborlab@emsl.com

081902549EMSL Order:

Customer ID: CHAS42

Customer PO: VISN6

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

081902549-0013

None DetectedNon-fibrous (Other)88%Cellulose

Min. Wool

3%

9%

Gray/White

Fibrous

Homogeneous

081902549-0014

<1% ChrysotileNon-fibrous (Other)100%Gray

Fibrous

Homogeneous

081902549-0015

2% ChrysotileNon-fibrous (Other)98%Gray

Non-Fibrous

Homogeneous

081902549-0016

<1% ChrysotileNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

081902549-0017

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Floor Tile

081902549-0017A

None DetectedNon-fibrous (Other)100%Cellulose<1%Gray/Tan

Non-Fibrous

Homogeneous

Adhesive

081902549-0018

None DetectedNon-fibrous (Other)20%Synthetic

Min. Wool

<1%

80%

Gray

Fibrous

Homogeneous

081902549-0019

None DetectedNon-fibrous (Other)10%Cellulose

Min. Wool

<1%

90%

Gray

Fibrous

Homogeneous

081902549-0020

None DetectedNon-fibrous (Other)15%Min. Wool85%Gray

Fibrous

Homogeneous

Insulation

081902549-0020A

None DetectedQuartz

Non-fibrous (Other)

4%

96%

Gray

Non-Fibrous

Homogeneous

Concrete

081902549-0021

None DetectedNon-fibrous (Other)100%Wollastonite<1%White/Beige

Non-Fibrous

Homogeneous

081902549-0022

None DetectedNon-fibrous (Other)100%Wollastonite<1%Gray/White/Beige

Non-Fibrous

Homogeneous

081902549-0023

None DetectedNon-fibrous (Other)100%Wollastonite<1%White/Beige

Non-Fibrous

Homogeneous

081902549-0024

None DetectedNon-fibrous (Other)100%Wollastonite<1%White

Non-Fibrous

Homogeneous

Analyst(s)

Rebecca Newman (20)

Remy Sherman (9)

Ryan Shannon, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 "Interim

Method"), but augmented with procedures outlined in the 1993 ("final") version of the method. 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 . Interpretation and use of test results are the responsibility of the client. All samples received in acceptable condition unless otherwise noted. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. EMSL recommends gravimetric reduction for all non -friable organically bound materials prior to analysis. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Plymouth, MI NVLAP Lab Code 101048-4

Initial report from: 09/04/2019 12:16:53

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 9/4/2019 12:16 PM

APPENDIX G

ASBESTOS LOCATIONS & SAMPLE LOCATION DRAWINGS

CASTLE HILL ASSOCIATES, LLC.

DEPARTMENT OF VETERANS AFFAIRS

FAYETTEVILLE VA MEDICAL CENTER

FAYETTEVILLE, NORTH CAROLINA

2019 ASBESTOS REINSPECTION

VA CONTRACT NUMBER: 36C24619N0872

LEGEND

ABC

PROJECT V06-18-102 VISN ASBESTOS SURVEY

ASBESTOS CONTAINING MATERIALS NOT SHOWN ON DRAWINGS

AutoCAD SHX Text ENVIRONMENTAL CONSULTANT: 218-A MECHANIC STREET, WATERVILLE, OHIO 43566 Tel: (567) 952-0212

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AutoCAD SHX Text FACILITY ASBESTOS RE-SURVEY VETERANS ADMINISTRATION MEDICAL CENTER FAYETTEVILLE, NORTH CAROLINA

AutoCAD SHX Text V06-18-102

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AUGUST 2019

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AFS

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BLB

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FAYETTEVILLE, NORTH CAROLINA

AutoCAD SHX Text Dates

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TITLE SHEET

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CS

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ASBESTOS-CONTAINING PIPE INSULATION

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ASBESTOS-CONTAINING WINDOW GLAZING AND WINDOW FRAME CAULK

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ASBESTOS-CONTAINING 12" OR 9" VINYL FLOOR TILE AND/OR BLACK MASTIC

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ASBESTOS-CONTAINING PIPE INSULATION BEHIND WALLS AND ABOVE CEILINGS

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ASBESTOS-CONTAINING EXTERIOR DOOR FRAME CAULK

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ASBESTOS-CONTAINING EXTERIOR VENT PIPE CAULK

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ASBESTOS-CONTAINING EXTERIOR WINDOW FRAME CAULK

N

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BUILDING #1 - BASEMENT FLOOR PLAN

LEGEND

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FC

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GATE

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UP

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DN

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AERATOR

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STERILIZERS

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AutoCAD SHX Text FACILITY ASBESTOS RE-SURVEY VETERANS ADMINISTRATION MEDICAL CENTER FAYETTEVILLE, NORTH CAROLINA

AutoCAD SHX Text V06-18-102

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JULY 2019

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ASBESTOS-CONTAINING 12" OR 9" VINYL FLOOR TILE AND/OR BLACK MASTIC

S

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BUILDING #1 - FIRST FLOOR PLAN

LEGEND

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FC

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COUNTER

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