ATT 10 - 626A4-22-700 - Asbestos-Lead Paint Survey.pdf

Limted Asbestos and Lead Paint Survey Report

EHRM Infrastructure Upgrades Alvin C. York TVHS Campus Murfreesboro, Tennessee 3400 Lebanon Pike VA Project No. 626A4-22-700

October 6, 2023 | Terracon Project Number: 18237283

Prepared for:

GDM Inc.

1922 Old Murfreesboro Pike, Ste. 905 Nashville, TN 37217

P (615) 333-6444 Terracon.com

Facilities | Environmental | Geotechnical | Materials i

October 6, 2023

GDM Inc.

2600 American Road, Suite 100 Rio Ranch, NM 87124

Attn: Eric Shreve P: 505-429-2317 E: eshreve@gdm-ae.com

RE: Limited Asbestos and Lead Paint Survey Report EHRM Infrastructure Upgrades Alvin C. York TVHS Campus 3400 Lebanon Pike Murfreesboro, Tennessee Terracon Project No. 18237283 VA Project No. 6264A-22-700

Dear Mr. Shreve:

The purpose of this report is to present the results of a limited asbestos and lead paint survey of 25 buildings located on the Alvin C. York Tennessee Valley Healthcare System (TVHS) campus in Murfreesboro, Tennessee. The survey was conducted in general accordance with Terracon Proposal No. P18237283 dated July 28, 2023. It is our understanding the project includes the addition or modification of 76 telecommunications data closets and replacement/routing of data cable throughout 25 campus buildings and associated crawlspaces and utility tunnels. The intent of the survey is to identify asbestos-containing materials (ACM) and lead-containing paint (LCP) that may be impacted during the renovation process. The survey included assessment of the telecommunications data closet locations to be impacted, as identified in drawings provided to Terracon by GDM, Inc, as well as random sampling of accessible ceiling and walls systems, assessment of random locations above lay-in ceilings, accessible crawlspaces and associated utility tunnel openings. The assessment of locations outside of the data closets were not intended to be comprehensive

The survey was conducted between August 28, 2023 and September 8, 2023. This report contains the location and results of all bulk material samples collected and analyzed and X-ray fluorescence (XRF) lead paint readings. Based upon this survey, asbestos-containing materials and lead-containing painted surfaces were identified within the buildings. Please refer to the attached report for details.

Terracon appreciates the opportunity to provide this service to GDM Inc. and the Alvin C. York TVHS campus. Should you have any questions regarding this report, please contact the undersigned below.

Limited Asbestos and Lead Paint Survey Report EHRM Infrastructure Upgrades | Alvin C. York TVHS Campus

Murfreesboro, Tennessee | October 6, 2023

Facilities | Environmental | Geotechnical | Materials ii

Sincerely, Terracon Consultants, Inc.

Aljus Alcineus Joel Russell Project Manager Group Manager

Matt Johnson Authorized Project Reviewer

Enclosures

Joel Russell https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAYFKgYbqVPLhvUZPFLdK57pksShNuNAFZ https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAYFKgYbqVPLhvUZPFLdK57pksShNuNAFZ https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAYFKgYbqVPLhvUZPFLdK57pksShNuNAFZ

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Table of Contents

1.0 INTRODUCTION

1.1 Project Objective

2.0 PREVIOUS REPORT REVIEW

3.0 GENERAL RENOVATION AREA DESCRIPTION

4.0 FIELD ACTIVITIES

4.1 Visual Assessment

4.2 Physical Assessment

4.3 Sample Collection

4.4 Sample Analysis

5.0 REGULATORY OVERVIEW

6.0 FINDINGS AND RECOMMENDATIONS

7.0 GENERAL COMMENTS AND LIMITATIONS

Appendices Appendix A Inspector Credentials Appendix B Individual Buildings Data Including:

Asbestos Sample Summary Table Confirmed Asbestos-Containing Material Table Asbestos Laboratory Reports Asbestos Sample Location Drawing Asbestos Photos Lead XRF Reading and Summary Table Lead Laboratory Result Sheets LCP Sample Location Drawings

Appendix B.1 Building 1 Appendix B.14 Building 15 Appendix B.2 Building 2 Appendix B.15 Building 16 Appendix B.3 Building 3 Appendix B.16 Building 17 Appendix B.4 Building 4 Appendix B.17 Building 106 Appendix B.5 Building 5 Appendix B.18 Building 112 Appendix B.6 Building 6 Appendix B.19 Building 116 Appendix B.7 Building 7 Appendix B.20 Building 117 Appendix B.8 Building 8 Appendix B.21 Building 118 Appendix B.9 Building 9 Appendix B.22 Building 120 Appendix B.10 Building 10 Appendix B.23 Building 146 Appendix B.11 Building 11 Appendix B.24 Building 147 Appendix B.12 Building 12 Appendix B.25 Tunnels and Crawlspaces Appendix B.13 Building 13

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LIMITED ASBESTOS AND LEAD PAINT SURVEY REPORT

EHRM INFRASTRUCTURE UPGRADES

ALVIN C. YORK TVHS CAMPUS

3400 LEBANON PIKE

MURFREESBORO, TENNESSEE

VA PROJECT NO. 626A4-22-700

Terracon Project No. 18237283 October 6, 2023

1.0 INTRODUCTION

Terracon conducted limited asbestos and lead paint surveys of 25 buildings located on the Alvin C. York TVHS campus in Murfreesboro, Tennessee. This survey was authorized under the EHRM Infrastructure Upgrades project (VA Project No. 626A4-22-700) and was conducted between August 28, 2023 and September 8, 2023 in general accordance with Terracon Proposal No. P18237283 dated July 28, 2023. The buildings included in the project are as follows: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16, 17, 106, 112, 116 East, 116 West, 117, 118, 120, 146, and 147.

Accessible building components and surfaces were inspected for homogeneous areas of suspect asbestos-containing materials (ACM) and lead-containing paint (LCP). A homogeneous area consists of building materials and surfaces which appear similar throughout in terms of color, texture and date of application.

Although reasonable effort was made to survey accessible suspect materials and surfaces, additional suspect but un-sampled materials and surfaces could be located in walls, in voids or in other concealed areas. It should be noted that some rooms were inaccessible at the time of the surveys.

Appendix A contains a copy of the certificates for the accredited asbestos and lead paint inspectors for the project. Appendix B contains individual building data including the following:

Asbestos Sample Summary Table Confirmed Asbestos-Containing Material Table Asbestos Laboratory Reports Asbestos Sample Location Drawing Asbestos Photos Lead XRF and Sample Summary Table Lead Laboratory Result Sheets LCP Sample Location Drawings

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Asbestos:

Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA regulation 40 CFR 763 (Asbestos Hazard Emergency Response Act, AHERA).

Samples were delivered to an accredited laboratory for analysis by polarized light microscopy.

Lead Containing-Paint:

Suspect LCP XRF reading and chip samples were collected to meet informational needs to comply with OSHA requirements for lead-in-air content during disturbance of the leaded materials. The survey was not designed to meet the requirements of the U.S. Department of Housing and Urban Development (HUD).

1.1 Project Objective

It is our understanding the project includes the addition or modification of 76 telecommunications data closets and replacement/routing of data cable throughout 25 campus buildings and associated crawlspaces and utility tunnels. The intent of the survey was to identify asbestos-containing materials (ACM) and lead-containing paint (LCP) that may be impacted during the renovation process.

The survey included assessment of the telecommunications data closet locations to be impacted as identified in drawings provided to Terracon by GDM, Inc, as well as sampling of accessible ceiling and wall systems in and around the proposed and existing telecommunication closets to be impacted, assessments of random locations above lay-in ceilings, and accessible crawlspaces and associated utility tunnel openings. The assessment of locations outside of the data closets were not intended to be comprehensive

Asbestos:

EPA regulation 40 CFR 61.140, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated asbestos-containing building materials be identified, classified and quantified prior to planned disturbances or demolition activities.

Lead Containing-Paint:

OSHA regulation 29 CFR 1926.62 established airborne lead concentration limits for the Construction Industry. OSHA has not established limits for lead content in bulk materials.

Their interpretation on this issue is that any amount of lead may cause airborne concentrations above the established limits. Therefore, during renovation or demolition activities, which may disturb lead, employees must be protected from lead exposures.

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2.0 PREVIOUS REPORT REVIEW

The following previous asbestos survey reports for select buildings on the Alvin C. York campus were provided by the Client for Terracon’s review.

Asbestos Survey, Tennessee Valley Healthcare System Alvin C. York Campus, Murfreesboro, TN, dated February 2021 and prepared by TTL Associates Inc.

The TTL Associates Inc. report included surveys of Buildings 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12/14, 15, 16 and 107. The TTL report primarily identified asbestos-containing flooring, mastics, sealants and pipe insulation within the various buildings. “Presumed” asbestos-containing materials included fire doors, elevator doors, mechanical gaskets, pipe insulation and transite panels. The TTL Associates, Inc. survey included review of asbestos analytical results from EFI Global asbestos surveys performed in 2009, verification of the EFI Global sampling results, as well as additional or supplemental sampling. According to TTL’s review of abatement documents, multiple areas of asbestos-containing flooring and pipe insulation were removed through renovations of various buildings that occurred between issuance of the EFI report in 2009 and completion of the TTL report in 2021.

Although some areas of fiberglass pipe insulation appeared to be newer, throughout the various buildings it is presumed that ACMs identified or assumed in the previous report are present and Terracon did not attempt to identify all previously identified or assumed ACMs.

3.0 GENERAL RENOVATION AREA DESCRIPTION

The project includes the addition or modification of approximately 76 IT data closets and replacement/routing of data cable throughout 25 buildings and associated crawlspaces and utility tunnels on the Alvin C. York campus. The buildings included in the project are as follows: 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 15, 16, 17, 106, 112, 116 East, 116 West, 117, 118, 120, 146, and 147. The survey included sampling of suspect materials located within the IT data closet locations slated to be impacted, as well as sampling of accessible ceiling and walls systems in and around the telecommunication closets, and assessments of random locations above lay-in ceilings and accessible crawlspaces and associated utility tunnel openings. Terracon did not enter and assess utility tunnels beyond the openings within crawlspaces. The location and full extent of building impact from cable routing was unknown at the time of the survey.

The buildings consist of single story and multiple story masonry brick and aluminum structures. The telecommunication rooms/data closets that are slated for renovation and modifications range in size from approximately 50 square feet to about 300 square feet. The interior finishes include painted gypsum board, painted plaster, ceramic tile, concrete block, suspended-ceiling tile, exposed concrete ceiling or metal decking, vinyl floor tile, ceramic

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Facilities | Environmental | Geotechnical | Materials 4 tile, and unfinished painted concrete. The uses/operations within the project buildings include a hospital, offices, rehabilitation centers, pharmacy and maintenance.

The tunnels and crawlspaces consist of concrete floors, block and concrete walls and concrete ceilings. Portions of the tunnel/crawlspace floor contained asbestos beneath the concrete, as labeled at the tunnel access doors, “asbestos beneath the concrete”. The crawlspaces and tunnel openings were visually assessed from the entrances of crawlspaces.

Terracon did not attempt to enter confined spaces to assess the tunnels. Terracon observed cables/wiring, fiberglass insulated pipes and uninsulated piping within the observed crawlspaces and tunnel entrances. It should be noted that Terracon’s observations of the crawlspaces and tunnel access areas were very limited due to access restrictions. Based on review of prior asbestos survey reports for the campus, ACM pipe insulation and ACM mastic on fiberglass pipe insulation were identified within the tunnels and crawlspaces.

4.0 FIELD ACTIVITIES

Mr. James Jackson and Ms. Aljus Alcineus, trained and Tennessee-licensed asbestos building inspectors, conducted the asbestos portion of the survey in general accordance with the protocols established by EPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA). The lead-containing paint survey was conducted by Mr. Jackson, a U.S. Environmental Protection Agency (EPA) and Tennessee certified Lead-Based Paint Inspector/Risk Assessor, to meet informational needs to comply with OSHA requirements for lead-in-air content during disturbance of the leaded materials. The survey was not designed to meet the requirements of the U.S. Department of Housing and Urban Development (HUD). Copies of the inspector credentials are attached as Appendix A. A summary of the field activities is described below.

4.1 Visual Assessment

Our survey activities began with visual observations within the telecommunication closet locations and random accessible offices and corridors. The visual assessment was performed to identify homogeneous areas of suspect asbestos-containing materials and suspect lead-containing painted surfaces. Building materials that were not identified as concrete, glass, wood, masonry, metal, or rubber were considered suspect ACM. Painted surfaces were suspected of containing lead. A visual assessment of each painted surface was conducted to assess its condition. The painted surfaces were assessed as good, fair, or poor condition depending on degrees of cracking, peeling, or chipping

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4.2 Physical Assessment

Asbestos:

A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

Lead-Containing Paint:

No physical assessment of the painted surfaces was performed.

4.3 Sample Collection

Asbestos:

Based on results of visual observations and results from previous survey reports, bulk samples were collected from identified suspect ACMs. The Terracon representative collected bulk samples using wet methods as applicable to reduce the potential for fiber release.

Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. A total of five-hundred sixteen (516) bulk samples were collected from the suspect ACMs associated with the buildings. A sample summary of identified suspect ACMs is included in the individual building data in Appendix B. (Appendices B.1-B.25).

Lead-Containing Paint:

Painted/coated surfaces were analyzed using a SciAps X-550Pb XRF instrument. The X- 550Pb XRF is a handheld, field portable, spectrum analyzer capable of identifying lead concentrations in coatings and paint, which are expressed in mg/cm2. The XRF was calibrated as per manufacturer recommendations before and after use. The Performance Characteristic Sheet (PCS) defines acceptable operating specifications and inconclusive range, or thresholds based upon empirical results from using the inconclusive range. Based on the PCS for the X-550Pb, no substrate corrections are needed and the instrument does not have any inconclusive ranges. The X-550Pb implements the X-ray fluorescent technique using a Rhodium or Gold anode X-ray tube inside the instrument to that uses an electric current under high voltage to produce X-rays. X-ray measurements are made directly on the painted surface of a component (unpainted components may also be tested for lead content). The instrument, which has been pre-calibrated by the manufacturer, is held against the surface to be analyzed. The X-ray detector unit, along with its associated microcomputer, is activated. After an instrument-selected analysis time, the concentration of lead on the surface and in the paint film is read directly from the instrument’s display in units of mg/cm2.

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The X-550Pb XRF (Serial Number X550-523) instrument was operated in the “Quick” Mode for this project. According to EPA guidelines, a lead measurement requires that a reading be taken with a 95% confidence level. This means that the actual measured lead value must exceed the regulatory action level by at least twice the uncertainty value to be considered valid. Uncertainty is not a constant value; it depends on time, measurement, substrate, and the actual lead concentration. The X550 XRF in Quick Mode automatically incorporates these factors to yield 95% confidence readings. Calibration checks were performed prior to, during, and after analyses and were documented to be within the manufacturer’s specifications.

Painted substrates were grouped as homogenous areas for the purposes of this project.

Homogenous areas for this survey are defined as paints and coatings of the same color applied to the same substrate in each building. For this project, XRF results were classified as either less than (<) 0.1 mg/cm2 [limit of detection (LOD) for the X550 XRF] or as the actual analytical finding greater than the LOD. A lead-containing paint (LCP) classification indicates that lead was present on the substrate at a concentration greater than the LOD. It is important to note that any results above the LOD apply not only to the actual homogenous area, but also to any repetitions of the homogenous area in the room or building that were not tested.

In conjunction with the XRF testing, Terracon also collected paint chip samples from surfaces tested to confirm XRF results. Paint chip sampling was conducted in an effort to assist with determining potential engineering controls or other means to ensure OSHA compliance during renovation activities which may disturb the painted surfaces.

The paint chip samples were collected down to the surface substrate so as to include underlying paints in the analysis. Not all surfaces tested by XRF were sampled. The random paint chip samples were selected based on current paint schemes and may not be inclusive of old paint systems covered with newer coatings. Upon collection, the samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

At total of fifty-four (54) paint chip samples were collected from suspect painted surfaces associated with the buildings.

Copies of the XRF data sheets and results of the paint chip analysis can be found in the individual building data in Appendix B. (Appendices B.1-B.25).

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4.4 Sample Analysis

Asbestos:

Bulk samples were submitted under chain of custody to Moody Labs in Farmers Branch, Texas for analysis by polarized light microscopy with dispersion staining techniques per EPA methodology (40 CFR 763, Subpart F). The percentage of asbestos, where applicable, was determined by microscopical visual estimation. Moody Labs is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) and has been assigned the accreditation number 102056-0. The laboratory was instructed to analyze all submitted samples.

Lead-Containing Paint:

The paint chip samples were submitted under a chain of custody to EMSL Analytical, Inc.

(EMSL) for analysis by Flame Atomic Absorption method SW 846 3050B*/7000B. EMSL participates in the American Industrial Hygiene Association (AIHA) Environmental Lead Proficiency Analytical Testing (ELPAT) Program (Accreditation Number 100194), to perform Flame Atomic Absorption analysis. The laboratory was instructed to analyze all the submitted samples.

5.0 REGULATORY OVERVIEW

Asbestos:

The asbestos NESHAP (40 CFR Part 61) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under NESHAP, asbestos-containing building materials are classified as either friable, Category I non-friable or Category II non-friable ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Category I non-friable ACM includes packings, gaskets, resilient floor coverings and asphalt roofing products. Category II non-friable ACM are any materials other than Category I materials that contain more than 1% asbestos.

Friable ACM and Category I and Category II non-friable ACM which is in poor condition and has become friable or which will be subjected to drilling, sanding, grinding, cutting or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM). RACM must be removed prior to renovation or demolition activities. If the amount of RACM exceeds 260 linear feet of pipe insulation or more than 160 square feet in other building components, the owner or operator must provide the Tennessee Department of Environment and Conservation – Division of Air Pollution Control (TDEC-APC) with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities. Removal of RACM

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Facilities | Environmental | Geotechnical | Materials 8 should be conducted by an accredited and appropriately licensed asbestos abatement contractor.

The OSHA Asbestos standard for the construction industry (29 CFR 1910.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 1 f/cc for a 30-minute excursion limit and 0.1 f/cc for an 8-hour permissible exposure limit. The OSHA standard classifies construction and maintenance activities, which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

According to USEPA and the Occupational Safety and Health Administration (OSHA) regulations, an asbestos-containing material (ACM) is considered any material or product containing more than one percent (>1%) asbestos. Per the USEPA, a material with asbestos content ranging from <1% to 10% by PLM, must be analyzed by point count method or must be presumed asbestos-containing. Materials confirmed to be <%1 asbestos by point count analysis are considered by OSHA to be materials of concern. OSHA’s concern is that a material, when disturbed, may emit fiber concentrations greater than 1 f/cc for a 30-minute excursion limit and 0.1 f/cc for an 8-hour permissible exposure limit. Therefore, the renovation/demolition contractor is required to comply with OSHA worker protection regulations during any disturbance or removal of these materials.

Lead-Containing Paint:

Lead is regulated by the OSHA, EPA and the State of Tennessee. Detectable lead quantities may constitute a lead dust hazard during renovation/demolition activities. Personnel performing renovation/demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current Occupational Safety and Health Administration (OSHA) regulations in order to minimize employee exposure. OSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Currently, any proposed renovation/demolition is subject to the OSHA regulation (29 CFR 1926.62 – Lead Exposure in Construction).

Contractors and employers are required to comply with 29 CFR 1926.62. Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (µg/m3) averaged over an eight-hour period without adequate protection. The OSHA Standards also establish an action level of 30 µg/m3, which if exceeded, triggers the requirement for medical monitoring. The OSHA standard does not define the amount of lead in paint that constitutes LCP. A negative exposure assessment per trigger task should be conducted to determine if actual airborne levels are below the required OSHA action and permissible levels.

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The Resource Conservation and Recovery Act (RCRA) regulates hazardous wastes such as lead-containing materials. Under RCRA, lead-containing wastes are considered hazardous waste if TCLP results exceed 5 milligrams per liter (mg/L). Specific regulatory requirements apply to the transport, treatment, storage, or disposal of hazardous wastes.

The above overview is not intended to be inclusive of all potentially pertinent regulatory information. The relevant OSHA, EPA and State of Tennessee standards should be consulted prior to undertaking activities involving the demolition, renovation or maintenance of surfaces coated with LCP or materials that contain lead.

6.0 FINDINGS AND RECOMMENDATIONS

Asbestos Findings:

The following asbestos-containing materials were identified in the surveyed buildings:

Building 1 Identified by Terracon

Black/Brown Mastic on fiberglass pipe insulation (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Identified in Previous Report (not sampled by Terracon) Black Waterproofing Mastic (Cat. I non-friable) Mastic on fiberglass duct insulation

(Cat. I non-friable)

Building 2 Identified by Terracon

9” Green and White Checkered Pattern Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Hard-pack Pipe Insulation (Friable)

Building 3 Identified by Terracon

12” Light and Dark Gray Streaks Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Black mastic on concrete floor (Cat. I non-friable)

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Assumed ACM by Terracon Vinyl Plank Flooring and underlayment/mastic (Cat. I non-friable)

12” Vinyl Floor Tile and associated black or brown mastic (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Black/Brown Mastic on fiberglass pipe insulation (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Building 4 Identified in Previous Report (not sampled by Terracon)

Black/Brown Mastic on fiberglass duct insulation (Cat. I non-friable)

Hard-pack Pipe Insulation (Friable)

Building 5 Identified by Terracon

12” Beige with Brown Specks Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

12” Light Brown Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Black Mastic Associated with 12” Blue Vinyl Floor Tile (Cat. I non-friable)

Black Mastic Associated with 12” off-white with colored specks Vinyl Floor Tile (Cat. I non-friable)

12” Light Brown with Brown & White Specks Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Black/Brown Mastic on fiberglass pipe insulation (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Building 6 Identified by Terracon

12” Off-white with Gray Streaks Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Gray Mastic on Metal Duct (Cat. I non-friable)

12” Light Brown with White & Brown Streaks Vinyl Floor Tile and associated black mastic (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Black/Brown Mastic on fiberglass pipe or duct insulation (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Aircell Pipe and Pipe Fitting Insulation (Friable)

Building 7 Identified in Previous Report (not sampled by Terracon)

Hard-pack Pipe Insulation (Friable)

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Building 8 Identified by Terracon

Black/Brown Mastic on Fiberglass Pipe or Duct Insulation (Cat. I non-friable)

Brown Mastic Beneath Carpet (Cat. I non-friable)

Assumed ACM by Terracon (requested not to sample by VA) Vinyl Plank Flooring and underlayment/mastic, light brown wood pattern (Cat. I non-friable)

Vinyl Plank Flooring and underlayment/mastic, dark brown wood pattern (Cat. I non-friable)

Cove Base Mastic (Cat. I non-friable) Vinyl Sheet Floor, beige with off-white mix (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Hard-pack Pipe Insulation (Friable)

Building 9 Identified by Terracon

Cream Mastic on Metal Duct (Cat. I non-friable)

White Woven Duct Wrap (Friable)

Black Mastic on Concrete Wall (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) Black/Brown Mastic on fiberglass pipe or duct insulation (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Pipe Fitting Insulation on Fiberglass Insulated Pipes (Friable)

Building 10 Identified by Terracon

Black/Brown Mastic on fiberglass pipe or duct insulation (Cat. I non-friable)

Identified in Previous Report (not sampled by Terracon) White Mastic on Fiberglass Insulated

Pipes (Cat. I non-friable) Hard-pack Pipe Insulation (Friable)

Building 11 Identified in Previous Report (not sampled by Terracon)

Black Waterproofing Mastic on Interior side of Exterior Walls (Cat. I non-friable)

Hard-pack Pipe Insulation (Friable)

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Building 12 Asbestos-containing materials anticipated to be impacted by the project were not identified in the samples collected by Terracon or the previous reports.

Building 13 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 13.

Building 15 Asbestos-containing materials anticipated to be impacted by the project were not identified in the samples collected by Terracon or the previous reports.

Building 16 Asbestos-containing materials anticipated to be impacted by the project were not identified in the samples collected by Terracon or the previous reports.

Building 17 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 17.

Building 106 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 106.

Building 112 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 112.

Building 116 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 116.

Building 117 Identified by Terracon

White Mastic on Fiberglass Duct Insulation (Cat. I non-friable)

Building 118 Identified by Terracon

White Mastic on Fiberglass Pipe Insulation (Cat. I non-friable)

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Building 120 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 120.

Building 146 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 146.

Building 147 Asbestos-containing materials were not identified in the samples collected by Terracon. A previous asbestos survey report was not provided to Terracon for Building 147.

Tunnels and Crawlspaces Identified in Previous Report (not observed or sampled by Terracon)

Black/Brown Mastic on fiberglass pipe insulation (Cat. I non-friable)

Hard-pack Pipe Insulation (Friable)

The non-friable materials, Category I and Category II, were observed in good condition.

Typically, undamaged Category I and Category II Non-friable materials are not considered RACM unless they are damaged during renovation. If damage occurs, the material may become friable and thus, be considered RACM. Typically, renovation activities will damage these materials. Therefore, the Category I and Category II Non-friable materials should be removed prior to any impact by the renovation process. Friable materials are considered a RACM and must be removed prior to any impact by renovation activities.

The Confirmed Asbestos Containing Material Tables (including confirmed asbestos-containing materials, asbestos content, NESHAP classification, material condition and estimated quantities, if quantifiable), laboratory analytical reports, asbestos sample location drawings and photographic documentation are located within the Individual Building Data in Appendix B (Appendix B.1-B.25).

Asbestos Recommendations:

Based on Terracon’s site observations, most ACMs are considered to be in good condition and do not have to be removed if not impacted by renovation or demolition activities. ACMs observed in poor condition are identified in the Confirmed Asbestos-Containing Material Tables and should be removed from the buildings. It is the Owner’s intent for this project to remove only the identified ACMs this will be impacted by the project. The ACMs that remain in place, should be maintained in their undamaged state.

The following steps should be taken for the removal of ACMs prior to impact by renovation activities:

1. Notify TDEC-DAPC officials of the impending abatement project electronically at Asbestos.NESHAP.Program@tn.gov or (written) at the following address:

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State of Tennessee Department of Environment and Conservation Division of Air Pollution Control Nashville Environmental Field Office 711 R.S. Gass Boulevard Nashville, Tennessee 37216

2. Remove the materials from the building before any activity begins that would break up, dislodge, or similarly disturb the material.

3. The ACM waste must be manifested and disposed at an appropriately classified landfill and a landfill that is certified to accept RACM and non-RACM wastes.

A Tennessee-accredited asbestos abatement firm should be contracted to perform the asbestos-containing material removal prior to impact by renovation activities. The work should be performed in compliance with federal, state and local guidelines and an abatement specification prepared by a Tennessee accredited asbestos designer.

It should be noted that ACM tar mastic on fiberglass pipes and fiberglass duct insulation as well as ACM pipe insulation may be concealed in walls, pipe chases and above ceilings within the project buildings. Where possible, impact to these materials should be avoided during renovation activities. The materials must be abated prior to renovation activities that will disturb them.

It should be noted that review of the prior asbestos survey report prepared by TTL identified ACM pipe insulation and ACM mastic on fiberglass pipe insulation within the tunnels and crawlspaces. While Terracon did not observe these materials, our observations of the crawlspaces and tunnel access areas were very limited due to access restrictions. These ACM materials should be assumed present within the tunnels and crawlspaces. If encountered, impact to these materials should be avoided when routing and anchoring telecommunications cables.

It should be noted that suspect materials, other than those identified during this survey may exist within the renovation areas of the buildings. While every attempt was made to identify the suspect asbestos-containing materials suspect lead-containing painted surfaces anticipated to be impacted by the project, concealed materials may still be present. Should suspect asbestos materials other than those which were identified and sampled during this survey be uncovered during renovation activities, those materials should be assumed asbestos-containing until sampling and analysis can confirm or deny their asbestos.

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Lead-Containing Paint Findings:

Based on the results of the survey, LCP was identified in surface coatings tested at the buildings. The lead XRF and sample summary tables are included in the Individual Building Data in Appendix B (Appendix B.1-B.25). The following components (listed per building) were identified to contain LCP.

Building 1 Beige Gypsum Board Wall – Room 411 Beige Plaster – Hallway at Room 106A Dark Beige Metal on Door Frame – Room 106A

Building 2 Gray Concrete Floor – Room G20A Beige Plaster – Hallway at Room 105F Beige Gypsum Board Wall – Rooms 105H and 105I

Building 3 Beige Wall Plaster – Room G03A Beige Wall Plaster – Room G20

Building 4 Green Plaster Wall - Room G112A Beige Metal Door Frame - Room G112 Beige Plaster Wall - At 101 Stairwell, at Room G03A Stairwell, Hallway @ Rooms G117, G112 Brown Metal Door Frame – Room 105 Green Plaster Wall - Room G112

Building 5 Lead-Containing Paint was not identified in the areas tested

Building 6 Lead-Containing Paint was not identified in the areas tested

Building 7 Lead-Containing Paint was not identified in the areas tested

Building 8 Beige Plaster Wall - Room G04A Red Concrete Floor - Room G04A White Plaster Ceiling – Room G04 Beige Plaster Wall - Room G04

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Building 9 Beige Metal Door Frame – Room G19 Beige Gypsum Board Wall – Room G02 Light Brown Gypsum Board Wall – Room G02 Gray Concrete Floor – Room G02 Beige Plaster Wall – Rooms 127 and G19 Light Brown Concrete Wall – Room G02 Yellow Gypsum Board Wall - Room G09

Building 10 White Concrete Wall – Room G16 White Gypsum Board Wall – Room G04

Building 11 Beige Gypsum Board Wall – 116A Beige Plaster Wall – Men’s Lounge @ TV

Building 12 White Brick Wall – Room G17A Beige Gypsum Board Wall – Room G17 White Gypsum Ceiling Board – Room G17A

Building 13 Off-white CMU – Room G04BB

Building 15 White Plaster Wall – Room 105U Brown Metal Door Frame – Room 105UA White Plaster Wall – Hallway

Building 16 White Brick Wall – Room G05

Building 17 Lead-Containing Paint was not identified in the areas tested

Building 106 Beige Gypsum Board Wall – Room 120

Building 112 Lead-Containing Paint was not identified in the areas tested

Building 116 Lead-Containing Paint was not identified in the areas tested

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Building 117 Lead-Containing Paint was not identified in the areas tested

Building 118 Lead-Containing Paint was not identified in the areas tested

Building 120 Beige Gypsum Board Wall – Room G02

Building 146 Lead-Containing Paint was not identified in the areas tested

Building 147 Beige Gypsum Board Wall - Room 113

Tunnels and Crawlspaces XRF readings and paint chip samples were not collected in the tunnels and crawlspaces.

Observed floor, wall and ceiling materials consisted of unpainted concrete and concrete block.

Note: The painting history of any given location in an older building often will vary from point to point due to factors including variability in paints used, paint film thickness, variable retention of older paint layers before repainting, demolition/installation of walls during renovations, and unknown historic non-homogenous painting schemes. As such, a given color and building component combination that is currently apparent often will not provide consistent testing results for lead.

Note: All similar components within units not otherwise inspected shall also be considered to be LCP until specifically tested, according to applicable regulations. It should be noted that suspect painted surfaces, other than those identified during this survey may exist within the renovation areas of the buildings. While every attempt was made to identify the suspect lead-containing surfaces anticipated to be impacted by the project, concealed surfaces may still be present. Should suspect painted surfaces other than those which were identified and sampled during this survey be uncovered during renovation activities, those surfaces should be assumed lead-containing until sampling and analysis can confirm or deny their lead content.

Lead-Containing Paint Recommendations:

Based on the findings of this survey, Terracon offers the following recommendations:

Should minor demolition occur, “undamaged” lead-containing paint may remain on the various substrates and the demolition material may be disposed as construction and demolition debris in a Class III and/or IV landfill. Should painted surfaces be “damaged” to

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Facilities | Environmental | Geotechnical | Materials 18 extent that the surfaces are peeling, blistered or cracked, the surfaces must be stabilized prior to demolition or re-finishing.

Stabilization work, if necessary, should be performed by a Tennessee-licensed lead abatement firm, using Tennessee-licensed lead abatement workers under the guidelines developed by a lead abatement designer.

Where lead-containing paint is to be impacted, it should be assumed that workers will be exposed to lead above the action level and personal protective measures should be implemented until an exposure assessment is completed in accordance with OSHA regulation 29 CFR 1926.62. Lead safe work practices are required to be addressed during work activities that may disturb lead painted or coated surfaces.

Care must be taken by the contractor to not exceed the OSHA established Action Level of 30 g/m3 during impact to lead-containing painted surfaces. Detection of these levels can be accomplished by personal air monitoring during the renovation activities that impact the lead-containing painted surfaces.

7.0 GENERAL COMMENTS AND LIMITATIONS

This limited asbestos and lead paint survey was conducted in a manner consistent with the project scope of work outlined in Terracon’s project to GDM Inc. (P18237283) dated July 28, 2023. The level of effort and associated tasks performed for this service was limited to the scope of services outlined in Terracon’s proposal. Terracon did not attempt to identify every potential exposure or hazard present in the buildings. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the buildings. The information contained in this report is relevant to the date on which the site observations were made and should not be relied upon to represent conditions at a later date. The assessment of locations outside of the data closets was not intended to be comprehensive. It should be noted that no attempts were made to demolish wall or hard ceiling systems to find hidden painted surfaces or asbestos-containing materials in the buildings. This report has been prepared on behalf of and exclusively for use by GDM Inc. and Alvin C. York TVHS campus for specific application to their potential project, as discussed. This report is not a bidding document. Any contractor or consultant reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information, which may have been used in the preparation of this report. No warranty, express or implied is made.

During the site reconnaissance Terracon was directed by Mr. John Foster, (Project Engineer) not to collect asbestos and paint chip samples from existing or potential IT closets within newly renovated areas or areas undergoing construction. These included Building 3, room G01; Building 5, rooms G04 and G28A; Building 6, rooms G04 and G28A, Building 7, room 200; and Building 8, rooms 100, 151, and 200 areas.

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Additionally, access to sensitive offices and patient areas were very limited during the survey.

Should suspect materials other than those which were identified during this survey be uncovered prior to or during renovation activities, those materials should be assumed asbestos-containing until sampling and analysis can confirm or deny their asbestos content.

This should include previously unsampled suspect asbestos containing materials within the inaccessible areas.

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APPENDIX A

INSPECTOR CREDENTIALS

By virtue of the certification requirements in Rule Chapter 1200-01-18

EffectiveCertification Number

James A. Jackson

Is hereby certificed to conduct lead-based paint activities in the discipline(s) of:

Expires

Murfreesboro, TN 37130

Under the Seal of the State of Tennessee

This day of .

THE STATE OF TENNESSEE

Discipline

04 January 2023

Type

Department of Environment and Conservation

1709 Carboncopy Ct

11/30/2022TNLBP2021-3478-8186IAnnual Reg 1st Yr 11/30/2023Inspector

11/30/2022TNLBP2021-3478-8187RAnnual Reg 1st Yr 11/30/2023Risk Assessor

D is c ip lin e

E x p ira tio n A c c re d ita tio n

In sp e cto r A

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M a n a g e m e n t P la n n e r

A -M

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-P M

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A lju s L in d s e y -A lc in e u s D

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-N o v -1

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D e p a rtm e n t o f E n v iro n m e n t a n d C o n s e rv a tio n

D iv is io n o f S o lid W a s te

M a n a g e m e n t

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-7

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APPENDIX B

INDIVIDUAL BUILDING DATA

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APPENDIX B.1

BUILDING 1

Building 1 Asbestos Sample Summary Table

Sample Number HA #, Sample Description, Sample Location

Sample Layer Description

Asbestos Result

HA 01, Linoleum (White with Blue Specks), G23F Flooring None Detected HA 01, Linoleum (White with Blue Specks), G23F Clear Mastic None Detected HA 01, Linoleum (White with Blue Specks), G23F Leveling Compound None Detected HA 01, Linoleum (White with Blue Specks), G23F Flooring None Detected HA 01, Linoleum (White with Blue Specks), G23F Clear Mastic None Detected HA 01, Linoleum (White with Blue Specks), G23F Leveling Compound None Detected HA 02, Gypsum Wallboard (White), Joint Compound, G23F Drywall Material None Detected HA 02, Gypsum Wallboard (White), Joint Compound, G23F Joint Compound None Detected HA 02, Gypsum Wallboard (White), Joint Compound, 411 Drywall Material None Detected HA 02, Gypsum Wallboard (White), Joint Compound, 411 Joint Compound None Detected HA 02, Gypsum Wallboard (White), Joint Compound, 128 Drywall Material None Detected HA 02, Gypsum Wallboard (White), Joint Compound, 128 Joint Compound None Detected

006 HA 03, 2 x 2 Suspended Ceiling Tile (White, Pinhole, Busy Cut), G23F Acoustic Tile None Detected 007 HA 03, 2 x 2 Suspended Ceiling Tile (White, Pinhole, Busy Cut), G23F Acoustic Tile None Detected

HA 04, 12 x 12 Vinyl Floor Tile (Off-White with Gray Mix), 411 Floor Tile None Detected HA 04, 12 x 12 Vinyl Floor Tile (Off-White with Gray Mix), 411 Black Mastic None Detected HA 04, 12 x 12 Vinyl Floor Tile (Off-White with Gray Mix), 411 Floor Tile None Detected HA 04, 12 x 12 Vinyl Floor Tile (Off-White with Gray Mix), 411 Black Mastic None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway Insulation None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway Paper / Foil Wrap None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway White Mastic None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway Insulation None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway Paper / Foil Wrap None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway White Mastic None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway No Insulation HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway Paper / Foil Wrap None Detected HA 05, Mastic (White) on Fiberglass Duct, Outside Room 411, Hallway White Mastic None Detected HA 06, Laminate (Light Brown Wood Pattern), 411 Floor Tile None Detected HA 06, Laminate (Light Brown Wood Pattern), 411 Yellow Mastic None Detected HA 06, Laminate (Light Brown Wood Pattern), 411 Floor Tile None Detected HA 06, Laminate (Light Brown Wood Pattern), 411 Yellow Mastic None Detected

015 HA 07, 2 x 4 Suspended Ceiling Tile (White, Pinhole, Busy Cut), 411 Acoustic Tile None Detected 016 HA…