Attachment 12 - Toxic Materials - Executive Summary.pdf

Final Design Submittal

II. Environmental ACM & LBP Testing

Mold Testing PCB Testing

Full Reports in Appendix E

Renovate Common Area Restrooms, Project No. 573-20-604, TMM-2110 Malcom Randall VA Medical Center, Gainesville, Florida

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ACM & LCP TESTING

1.1 INTRODUCTION

The purpose of this limited renovation survey was to identify accessible asbestos-containing materials (ACMs) and lead-containing paint (LCP) and their general locations within the Malcom Randall VA Medical Center, located at 1601 SW Archer Road in Gainesville, Florida. The scope of the survey was limited to client-identified common area restrooms, as depicted in the Toland Mizell Molnar, LL provided list and drawings, dated February 7, 2022. The asbestos survey was conducted pursuant to National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61) requirements, associated with the scheduled renovations plans. The survey was performed on March 7-9, 11, and 22-24, 2022, by Mr. Michael D. Harrell, an Environmental Protection Agency/ Asbestos Hazard Emergency Response Act (EPA/AHERA) accredited inspector and EPA Lead Risk Assessor, and Mr. Mark Fohn, Environmental Protection Agency/Asbestos Hazard Emergency Response Act (EPA/AHERA) accredited inspector. The scope of this survey did not include demolition of any building components, evaluation of architectural plans, or removal cost estimating.

1.2 FACILITY DESCRIPTION

Building 1 A summary of the facility investigated is outlined in the table below.

Facility Type: Medical Construction Date: 1967 Number of Floors: Two in Scope

Exterior Floor Support: Concrete Slab on Grade Wall Support: Concrete Block (CMU), Precast Concrete Panels

Exterior Finish: Not In Scope Roof System Type: Not In Scope

Interior Wall Substrate: Drywall and Joint Compound, Plaster, Drywall Wall Finishes: Paint, Ceramic Tile, Cove Base Floor Finishes: Vinyl Floor Tile, Ceramic Tile Ceiling System: Drywall and Joint Compound, Suspended Ceiling System Ceiling Finishes: Paint, Suspended Ceiling Tiles

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Building 12 Facility Type: Medical

Construction Date: Unknown Number of Floors: One in Scope

Exterior Floor Support: Concrete Slab on Grade Wall Support: Concrete Block (CMU), Precast Concrete Panels

Exterior Finish: Not In Scope Roof System Type: Not In Scope

Interior Wall Substrate: Drywall and Joint Compound, Plaster Wall Finishes: Paint, Ceramic Tile, Cove Base Floor Finishes: Vinyl Floor Tile, Ceramic Tile Ceiling System: Suspended Ceiling System, Plaster Ceiling Finishes: Suspended Ceiling Tiles, Paint

Renovate Common Area Restrooms, Project No. 573-20-604, TMM-2110 Malcom Randall VA Medical Center, Gainesville, Florida

2.0 ASBESTOS

2.1 ASBESTOS SURVEY PROCEDURES

The survey was performed by visually observing accessible areas within the scope of work.

EPA/AHERA accredited inspectors performed the visual observations (refer to Appendix B for personnel qualifications).

After the overall visual survey was completed, representative sampling areas were determined.

The surveyors delineated homogeneous areas of suspect materials and samples of each material were obtained, in general accordance with regulations as established by the Occupational Safety and Health Administration (OSHA) and NESHAP. The field surveyors determined sample locations based on previous experience. Both friable and non-friable materials were sampled. A friable material is one that can be crushed when dry by normal hand pressure. This survey did not include the demolition of building components to access suspect material.

After completion of the fieldwork, the samples were delivered to GLE’s National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for analysis. The samples were analyzed by Polarized Light Microscopy (PLM) coupled with dispersion staining, in general accordance with EPA-600/R-93/116. Utilizing this procedure, the various asbestos minerals (chrysotile, amosite, crocidolite, actinolite, tremolite, and anthophyllite) can be determined. The percentages of asbestos minerals in the samples were visually determined by the microscopist. Please note that the EPA designates all materials containing greater than one percent asbestos as an “asbestos-containing material” (ACM).

Regulated Asbestos-Containing Material (RACM) is defined as (a) Friable asbestos materials,

(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-

Page II-4 friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Category I and Category II non-friable ACM, as defined by the EPA:

▪ Category I non-friable ACM means asbestos-containing packings, gaskets, resilient floor covering, asphalt roofing products, and pliable sealants and mastics that are in good condition and not friable, containing more than one percent asbestos, as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM.

▪ Category II non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the methods specified in Appendix E, Subpart E, 40 CFR Part 763 Section 1, PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

2.2 IDENTIFIED SUSPECT ASBESTOS-CONTAINING MATERIALS

A total of three hundred fifty-five samples of suspect building materials were collected from the facility during the survey, representing one hundred seventeen different identified homogeneous areas. The results of the laboratory analyses are included in Appendix A, and the approximate extent to which ACM was observed to be present is indicated on the Asbestos Sample Location Plans in Appendix C. Photographs of the various materials sampled are included in Appendix D.

Due to accessibility issues, access to plenum spaces was limited throughout.

A summary of the homogenous sampling areas of suspect ACM determined to be present is outlined in the following table.

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MOLD TESTING

1.0 INTRODUCTION

At the request of Toland Mizell Molnar, LLC (TMM), GLE Associates, Inc. (GLE) conducted a limited mold assessment on March 25, 2022, within the Malcom Randall VA Medical Center, located at 1601 SW Archer Road, in Gainesville, Florida. The objective of this assessment was to determine if mold amplification was present in response to occupant concerns. Specifically, the scope of services included the following:

Limited Visual Assessment and Moisture Measurements Microbial Surface Sampling

Consequently, this report is limited to the specified scope of services. While additional comments may be provided, the additional comments are submitted as a courtesy and are not intended to expand the original scope of this investigation. This report outlines the background information, our procedures and methodology, sample results, findings, conclusions, and recommendations.

2.0 BACKGROUND

The Client requested a limited mold assessment of Restroom EB46-1 at the Malcom Randall VA Medical Center, in Gainesville, Florida. This assessment is part of VA Project 573-20-604 “Renovate Common Area Restrooms” and was requested to determine if mold amplification was present in the aforementioned space.

3.0 PROCEDURES AND METHODOLOGY

3.1 Limited Visual Assessment and Moisture Measurements

GLE assessed immediately accessible, interior areas of the subject building for visual evidence of water and/or mold-impacted materials, including, but not limited to, building materials exhibiting visible water staining, water damage, mold growth, and/ or elevated moisture content. Non-destructive visual observations were utilized for this task.

A FLIR Systems Model C2 infrared thermal camera was utilized to scan readily accessible interior areas of the subject facility for indications of thermal anomalies indicating potential elevated moisture content. Moisture content measurements were confirmed with a handheld moisture meter, a GE Protimeter SurveyMaster or equivalent instrument. The moisture meter was utilized to collect moisture measurements from areas exhibiting visible water intrusion. Elevated moisture measurements, greater than or equal to 20% Wood Moisture Equivalent (WME) or Moisture Content (MC), may be an indication of previous or active water intrusion, and may provide an environment favorable for fungal proliferation. See Appendix D for site drawings and Appendix E for photographic documentation.

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3.2 Particulate Surface Sampling

Particulate surface samples were collected of assumed mold growth to identify the genus, growth stage (spores, intact hyphae, hyphae fragments, etc.), and to estimate the density and/or potential spread at the time of sampling. The samples were delivered, under strict chain-of-custody, to EMSL, an AIHA EMLAP/A2LA-accredited laboratory, for viable and non-viable mold spore analysis. Semi-quantitative results were reported as counts of fungal structures, to include spores, hyphae, and other particulates. See Appendix A for laboratory analytical results.

4.0 FINDINGS

4.1 Limited Visual Assessment and Moisture Measurements

GLE performed a walkthrough visual assessment of accessible areas of concern within the scope of work. The assessment identified water and/or mold impacted materials, including, but not limited to, building materials exhibiting visible water staining, water damage, and/or mold growth. Visual observations are outlined in Table 4.1-1 – Summary of Water/Mold Damage.

TABLE 4.1-1 – SUMMARY OF WATER/MOLD DAMAGE

Renovate Common Area Restrooms

Room EB46-1 Project 573-20-604

Malcom Randall VA Medical Center 1601 SW Archer Road

Gainesville, Florida 32608-1197

Area Damage Type Location Building

Material

Approx.

Quantity

(H’xL’)

%WME Photo Number

EB46-1 N/A Open Plenum Area Ceiling Tile - - 2 EB46-1 WS South Wall in Plenum Drywall 10 SF <20% 3 EB46-1 N/A North Wall by Toilet Drywall - - 4

* Approximate quantities listed as height in feet by length in feet, unless otherwise noted AMG – Assumed Mold Growth SAMG – Surficial Assumed Mold Growth N/A – Not Applicable WS – Water-Stained WD – Water-Damaged MG – Mold Growth SF – Square Feet %WME – % Wood Moisture Equivalent

4.2 Particulate Surface Sampling

Two particulate surface samples were collected from within the area to evaluate the possibility of mold growth. A copy of the laboratory analytical report is included in Appendix A.

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Analytical results which indicated “rare” or “low” counts of fungal spores and hyphae are not indicative of fungal growth associated with the sampled surface.

Analytical results which indicated “medium” or “high” (in bold) counts of fungal spores and hyphae are indicative of fungal growth associated with the sampled surface.

TL-01: Plenum Wall

“Rare” counts of the spore type Alternaria (Ulocladium).

TL-02: Wall by Toilet

“Rare” counts of the spore type Cladosporium.

5.0 CONCLUSIONS AND RECOMMENDATIONS

Based on the results of the assessment, GLE provides the following conclusions:

1. Visibly water-stained materials were observed in the assessed areas as outlined in Table 4.1-1.

2. The results of the particulate surface sampling are not indicative of fungal growth associated with the sampled surface.

Based on the findings of the assessment, GLE recommends the following:

1. All water/mold damaged building materials identified in Table 4.1-1 should be properly remediated in accordance with the remediation recommendations presented in Appendix B - Remediation Recommendations.

Renovate Common Area Restrooms, Project No. 573-20-604, TMM-2110 Malcom Randall VA Medical Center, Gainesville, Florida

6.0 LIMITATIONS

GLE performed the scope of services as presented in our proposal. Reasonable effort has been made by GLE personnel to assess representative locations within the facility.

Destructive sampling was not utilized as part of this assessment. GLE assumes no liability for existing conditions or damage within the subject facility or for any consequential effects that may result from our services and collection of field samples and measurements.

Mold growth may occur in various areas of a structure where water/moisture leak(s) are not addressed. These areas include cavities/enclosures and adjacent building materials that house plumbing/drainage-lines and can be affected by moisture intrusion from the exterior the building.

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This investigation did not include areas not known to have been affected by water damage moisture damage or inaccessible areas; therefore, the potential for mold growth in these areas cannot be dismissed at this time.

The information contained in this report was prepared based upon specific parameters requested by the Client. If additional information is available or becomes available, it should be forwarded for our review to determine if changes to our conclusions and recommendations are necessary. The data and evaluation in the report reflects conditions identified at the time of our site visit, and should not be construed as being representative of the site at a later date. GLE assumes no liability for any perceived or documented health effects of tenants, visitors, contractors, or any other individual that has or may come in contact with the building that may be attributable to the microbial conditions present within the building.

The information herein is only for the specific use of the Client and GLE. GLE accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless written authorization has been obtained from GLE. This report is not intended to be used as a document to render health related opinions.

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PCB TESTING

1.0 INTRODUCTION

Between March 7 and March 24, 2022, a limited PCBs in caulk survey was conducted at the Malcom Randall VA Medical Center, located in Gainesville, Florida. The survey was performed by Mr. Michael Harrell and Mr. Mark Fohn of GLE. The survey was conducted to determine the presence or absence of PCBs in caulk and the relative condition of the caulk at the time of sampling. The survey was limited to caulking materials in Client-identified areas, where planned disturbance of caulk will occur

GLE understands that the limited survey was conducted to provide information needed to comply with the Environmental Protection Agency’s (EPA) guidance documentation on PCBs in caulk during renovation, maintenance or demolition. PCBs are man-made chemicals that persist in the environment and were widely used in construction materials and electrical products prior to 1978. Although the manufacture and most uses of PCBs were banned and phased out in 1978, the EPA has evidence that many buildings across the country constructed or renovated in the 1950 to 1978 timeframe may have PCBs at high levels in the caulk around windows and door frames, between masonry columns, mastics, expansion joints and in other masonry building materials. This caulk may be present inside and on the exterior of buildings as well as surrounding surfaces.

PCBs can cause a variety of adverse health effects. PCBs have been documented to cause cancer in animals as well as other adverse effects to the immune system, reproductive system, nervous system and endocrine system. Exposure to PCBs may occur as a result of their release from the caulk into the air, and exposure to indoor dust, surrounding surfaces and soils through direct contact.

A PCB bulk product waste is defined by the Toxic Substances Control Act (TSCA), in 40 CFR 761, as a material with a PCB concentration equal to or greater than 50 parts per million (ppm). If PCBs have contaminated either the surrounding building materials or adjacent soils, these materials are considered PCB remediation waste. PCB bulk product waste disposal is subject to EPA regulations under TSCA (40 CFR 761.62) and per Rule 62-701.300(5) of the Florida Administrative Code.

PCBs were manufactured and sold under many names, with the most common being the Aroclor series. Aroclor is a PCB mixture produced from approximately 1930 to 1979. There are many types of Aroclors, and each has a distinguishing suffix number that indicates the degree of chlorination.

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2.0 Sampling and Analytical Procedures

The survey was performed by observing and testing accessible building caulk within the Client-identified restrooms of the Malcom Randall VA medical Center. The surveyors delineated representative areas of suspect materials and composite samples of each material were obtained. Two composite caulk samples were collected from representative locations.

Testing of the caulk was performed by collecting a minimum of six grams (g) of caulk from the sample locations. The samples were submitted to EMSL Analytical, Inc., an accredited laboratory recognized under the National Environmental Laboratory Accreditation Program (NELAP), located in Indianapolis, Indiana. The samples were analyzed by EPA Method SW-846 8082A for nine common Aroclors.

3.0 Survey Results

Analytical results indicate that the caulk samples tested from Building 1 and Building 12 Client-identified restrooms contain concentration of PCBs (Aroclor-1248) within the caulk greater than the reporting limit, but less than 50 mg/Kg.

The sampling results are presented in Table 1, “Summary of PCB Sample Analytical Results”, located in Appendix A of this report. The analytical results are reported in milligrams per Kilogram (mg/Kg), which is numerically equivalent to ppm. The laboratory analytical results and chain of custody are provided in Appendix B.

4.0 Condition Assessment

The surveyor observed the extent of caulk deterioration by rating the caulk condition as intact or poor. If deterioration or separation of the caulk from the substrate was observed, it was given a poor designation. The condition of the caulk observed at the time of the sampling event is included in Table 1 in Appendix A of this report.

5.0 CONCLUSIONS AND RECOMMENDATIONS

As previously stated, analytical results indicate that the caulk samples tested from Building 1 and Building 12 Client-identified restrooms, contain concentrations of PCBs (Aroclor-1248) within the caulk greater than the reporting limit, but less than 50 mg/Kg.

Therefore, these products are not defined as PCB bulk product waste. However, for those employees who will be disturbing the PCB-containing caulking, the employer must implement OSHA prescribed protective measures in all operations where there is the potential for an exposure to hazardous conditions. The employee protection measures include but are not limited to the following: appropriate respiratory protection (based on results of a negative exposure assessment), appropriate personal protective clothing and equipment (including chemical resistant gloves, disposable coveralls and shoe covers, and safety glasses or protective goggles), change areas, hand washing facilities, and training. In addition, any work involving disturbance of PCB-containing caulk should include

Page II-11 minimizing dispersal by covering the work areas with heavy polyethylene sheeting as well as isolating the HVAC system and reducing exposure through the use of HEPA equipped vacuums and/or ventilation.

Additionally, the EPA recommends air testing to determine if PCB levels in the air exceed EPA’s suggested public health levels if concerns about exposure to PCB’s exist.

6.0 LIMITATIONS AND CONDITIONS

Due to the inaccessibility of some building elements, it is conceivable that all potential PCB caulking within the extents of this survey may not have been located and identified. We do warrant, however, that the investigations and methodology reflect our best efforts based upon the prevailing standard of care in the environmental industry.

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