Attachment 2A Regulated Building Materials Survey Report.pdf

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REGULATED BUILDING MATERIALS

SURVEY REPORT

Upgrade Steam Distribution System VA Project No. 626A4-22-202

VA Tennessee Valley Healthcare System, Murfreesboro Campus 3400 Lebanon Road Murfreesboro, TN 37129

Mabbett Project No. R2023044.000

June 5, 2023

Prepared For:

AE Works Ltd 418 Beaver Street Sewickley, PA 15143

Mabbett & Associates, Inc. www.mabbett.com 105 Central Street, Suite 4100 Stoneham, MA 02180-1260 T. 781-275-6050 F: 781-954-5155

Massachusetts | Virginia | Rhode Island | New York

© 2023, Mabbett & Associates, Inc.

REGULATED BUILDING MATERIALS SURVEY REPORT

Upgrade Steam Distribution System | Murfreesboro VAMC | Murfreesboro, TN

© 2023, Mabbett & Associates, Inc. Page i June 5, 2023 Project No. R2023044.000 Murfreesboro VAMC Upgrade Steam RBM Survey Report Final

ACKNOWLEDGEMENT

This Regulated Building Materials Survey Report has been prepared by Mabbett & Associates, Inc. (Mabbett®) for the Upgrade Steam Distribution System project at the VA Tennessee Valley Healthcare System, Murfreesboro Campus, located at 3400 Lebanon Road in Murfreesboro, Tennessee, VA Project No. 626A-22-202. The information presented herein is based on the facts and information conveyed to or received by Mabbett during the preparation of this report. If any of the information provided to Mabbett that was used in preparing this report is incorrect, incomplete, or subject to change, Mabbett would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to Mabbett as of the date of this report and considered applicable to this report.

The attached Regulated Building Materials Survey Report was prepared by Mr. Kevin M. Donovan, Regulated Building Materials Consultant of Mabbett & Associates, Inc.

This report has been reviewed and approved by:

Michael F. Delaney Director, Building Sciences Group

MFD/fmz

© 2023, Mabbett & Associates, Inc. Page ii June 5, 2023

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION

2.0 ASBESTOS SURVEY

2.1 Sampling Methodology

2.2 Analytical Methodology

2.3 Summary of Asbestos Containing Materials Findings

3.0 LEAD CONTAINING PAINT SURVEY

3.1 Sampling Methodology

3.2 Analytical Methodology

3.3 LCP Results

4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 Asbestos

4.2 Lead Containing Paint

5.0 LIMITATIONS

TABLES

Table 1 – Estimated Quantities of ACM Table 2 – Summary of Lead Paint Chip Analytical Results

FIGURE

RBM-1 – Regulated Building Materials Sample Locations Plan

APPENDICES

Appendix A – Summary of ACM Sampling Results Appendix B – Asbestos Laboratory Report and Chains of Custody Appendix C – Lead Paint Chip Laboratory Report and Chains of Custody

© 2023, Mabbett & Associates, Inc. Page 1 June 5, 2023

1.0 INTRODUCTION

Mabbett and Associates, Inc. (Mabbett®) and ECS Southeast, LLP performed a survey for regulated building materials (RBM) as part of the Upgrade Steam Distribution System project at the VA Tennessee Valley Healthcare System, Murfreesboro Campus located at 3400 Lebanon Road in Murfreesboro, Tennessee. Site survey work was performed from April 24 - 27, 2023, by appropriately credentialed regulated building material inspectors and consisted of the following activities:

A review of the existing facility drawings and project scope;

An Asbestos Containing Material (ACM) survey of suspect materials (Analysis by Polarized Light Microscopy

[PLM]; and Limited Lead Containing Paint (LCP) sampling (Analysis by atomic absorption [AA]).

The survey was limited to materials and areas associated with the campus steam system with areas identified on Schematic Design drawing MS101 provided to Mabbett by the client. The survey included entry into to steam manholes with confined space entry support provide by VA Safety personnel. Areas and materials outside of this scope of work were not included in the survey and report.

© 2023, Mabbett & Associates, Inc. Page 2 June 5, 2023

2.0 ASBESTOS SURVEY

A visual screening inspection was conducted by Tennessee licensed asbestos inspectors to identify locations of suspect ACM and conceptualize the sampling program. Only areas that were accessible during the field work phase were inspected. Reasonable efforts were made during the initial field survey to access areas as necessary to complete the asbestos survey and sampling program.

Prior to the execution of this RBM survey, existing building plans for the area of the Upgrade Steam Distribution System project locations were examined to discern the age, location, and condition of existing materials, as well as the renovation history of the building areas and structures being impacted.

Typical manhole construction was a concrete vault. Some of the manholes had dry floors while others had mud and or water on the floors. Manhole #3 was not accessible at the time of the survey due to a steam leak.

Typical crawl space construction was concrete with concrete deck, columns, and walls with a concrete floor over ACM contaminated soil. These spaces were typically dry at the time of inspection.

2.1 Sampling Methodology

Site inspection work was performed on April 24 - 27, 2023, by Tennessee licensed Asbestos Inspectors Mr. Kevin M.

Donovan (#AI-186596-130047) of Mabbett and Associates, Inc., and Mr. Douglas Rice (#AI-18335-1126634) of ECS Southeast, LLP. Bulk asbestos samples were collected using EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763, and Asbestos Hazard Emergency Response Act (AHERA) protocols. The inspection was limited to areas that may be impacted by the proposed project. Bulk suspect ACM sampling was generally conducted according to the following sampling protocol:

Friable surfacing material:

At least three bulk samples shall be collected from each homogeneous area that is 1,000 ft2 or less.

At least five bulk samples shall be collected from each homogeneous area that is greater than

1,000 ft2 but less than or equal to 5,000 ft2.

At least seven bulk samples shall be collected from each homogeneous area that is greater than

5,000 ft2.

Thermal system insulation:

At least three bulk samples shall be collected from each homogeneous area of thermal system insulation.

At least one bulk sample shall be collected from each homogeneous area of patched area of thermal system insulation.

Sufficient samples shall be collected from elbows and fittings to determine if they contain ACM.

Bulk samples shall not be collected from any homogeneous area where the state licensed asbestos inspector determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACM.

Miscellaneous material:

At least two bulk sample shall be collected from each homogeneous area that is less than

100 ft2.

At least three bulk samples shall be collected from each homogeneous area that is greater than

100 ft2.

© 2023, Mabbett & Associates, Inc. Page 3 June 5, 2023

Areas that were inaccessible, or where the survey was limited to visual observation only, are identified below:

Manhole #3 (Steam Leak) Buried steam tunnels Enclosed pipe/duct chases

2.2 Analytical Methodology

The collected bulk samples were submitted under chain of custody (COC) procedures to Scientific Analytical Institute, Inc (SAI) of Greensboro, North Carolina for PLM analysis. SAI is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP).

Bulk sample results from this inspection are summarized in Appendix A, Summary of ACM Sampling Results. The EPA, Occupational Safety and Health Administration (OSHA), and Regulations of the State of Tennessee defines any material that contains greater than one percent (>1%) asbestos as being an ACM. As such, the analytical laboratory identified bulk samples as positive for asbestos that met the regulatory criteria of greater than one percent (>1%) asbestos. Laboratory reports and COC documentation are provided in Appendix B of this report.

2.3 Summary of Asbestos Containing Materials Findings

Mabbett identified eight (8) homogenous materials and collected thirty-five (35) representative bulk ACM samples. Thirty-five (35) samples were analyzed by PLM. The laboratory-reported analytical data indicated that six (6) of the materials sampled as part of this survey contained 1% or greater asbestos and are classified as ACM.

Estimated quantities of materials identified as ACM during this survey are presented in Table 1.

Contaminated soil, water and debris is assumed in majority of manholes. According to information provided to the inspectors, the crawl spaces were partially abated and contaminated soil encapsulated with a 4-inch concrete slab.

TABLE 1

Estimated Quantities of ACM

A/E Design Services to Upgrade Steam Distribution System Alvin C. York VAMC, Murfreesboro, TN

Location Description of Material Percent and Type of Asbestos

Estimated Quantity Amount Units

Manhole and Steam Tunnels/Vaults Pipe and Fitting Insulation

10% - 40% Chrysotile, 10% Amosite & 5% -

10% Crocidolite

5,150* LF

Manhole and Steam Tunnels/Vaults Contaminated Soil/Water/Debris PACM Not

Quantified

Manholes Black Patch Material 15% Chrysotile 15 SF

Crawl Spaces Black Coating on Fiberglass Pipe 6% Chrysotile 50 SF

Crawl Spaces White Fiberglass End Sealant NAD – 10% Chrysotile 200 SF

Notes: LF = Linear Feet, SF = Square Feet, PACM = Presumed ACM, *Quantity from 4/14/2023 Project Cost Summary

© 2023, Mabbett & Associates, Inc. Page 4 June 5, 2023

3.0 LEAD CONTAINING PAINT SURVEY

The limited LCP survey included the collection of paint chips from painted surfaces and systems in the areas surveyed that may be impacted by the Upgrade Steam Distribution System Project. Fourteen (14) samples of different homogenous areas of paint were collected during this survey. Paint chip samples were submitted under standard COC procedures to Scientific Analytical Institute, Inc. (SAI) in Greensboro, North Carolina. Analysis was conducted using AA EPA method SW-846 3050B/6010C/7000B.

3.1 Sampling Methodology

Paint chip samples are collected using a sharp hand tool to score and peel paint off a 1 square inch (or larger) area of the substrate. Different tools such as chisels, putty knives, and hammers may also be needed in the collection of paint chips. All tools are cleaned after each sample to prevent cross contamination. Collected paint chip samples are submitted under COC procedures to an accredited laboratory and analyzed via Flame Atomic Absorption Spectrophotometry (AA).

3.2 Analytical Methodology

The regulations addressing LCP in non-residential buildings are focused on occupational exposures involved with paint-disturbing activities and related waste-disposal activities. Occupational exposure to lead is regulated by OSHA regulation 29 CFR 1926.62, Lead in Construction, as well as other applicable state and local regulations. An LCP survey cannot determine a safe level of lead for the purpose of paint-disturbing/waste-disposal activities but is intended to provide guidance as to the locations of surfaces containing lead.

Contractors may use this information to better determine where worker exposures to airborne lead and other hazards may occur. They can then assess the potential magnitude of exposure to their employees and identify the controls necessary to limit health risks. This information can also be used for pre-characterization of demolition waste streams prior to toxicity characteristic leaching procedure (TCLP) sampling in accordance with 40 CFR Part 261.

3.3 LCP Results

A concentration of lead greater than or equal to 0.5 percent by weight (equivalent to 5,000 ppm) or 1.0 mg/cm² exceeds EPA and HUD residential standards and is considered an indicator of risk. The results of this LCP sampling survey identified five (5) of the samples at a level indicative of risk.

The results of the limited LCP sampling are summarized in Table 2, with laboratory reports provided in Appendix C.

Table 2 Summary of Lead Paint Chip Analytical Results

A/E Design Services to Upgrade Steam Distribution System

Murfreesboro VAMC, Murfreesboro, TN Sample # Location Substrate and Component Color Result (% weight)

Pb-01 Building 3, Fan Room 12 Crawl Space Entry Metal Door Yellow 2.9%

Pb-02 Building 4, B03 Crawl Space Entry Metal Door Frame Yellow 0.28%

Pb-03 Building 6, Crawl Space Entry Metal Door Yellow 0.19% Pb-04 Building 7, Crawl Space Entry Metal Door Frame Yellow 0.23% Pb-05 Building 8, Crawl Space Entry Metal Door Red 0.31%

© 2023, Mabbett & Associates, Inc. Page 5 June 5, 2023

Table 2 Summary of Lead Paint Chip Analytical Results

A/E Design Services to Upgrade Steam Distribution System

Murfreesboro VAMC, Murfreesboro, TN Sample # Location Substrate and Component Color Result (% weight)

Pb-06 Building 9 – Fan Room 21, Crawl Space Entry Concrete Threshold Yellow 0.015%

Pb-07 Building 10, Mechanical Room Metal Railing Yellow 6.5%

Pb-08 Building 11, Mechanical Room Pit Metal Ladder Yellow 4.7%

Pb-09 Building 12, Crawl Space Entry Metal Door Frame White 0.6%

Pb-10 Building 14, Crawl Space Entry Metal Door Brown 0.0055%

Pb-11 Building 15, Room SP101 Brick Wall White <0.0051% Pb-12 Building 16, Condensate Pit Concrete Floor Gray 0.13%

Pb-13 Building 107, Crawl Space Entry Metal Door Brown 8.90%

Pb-14 Building 112, Room 109 Metal Pipe Red 7.9%

© 2023, Mabbett & Associates, Inc. Page 6 June 5, 2023

4.0 CONCLUSIONS AND RECOMMENDATIONS

4.1 Asbestos

Materials containing asbestos were identified in the areas surveyed. Any suspect materials encountered during demolition or renovation activities that were not identified in this report as being non-ACM, should be assumed to be ACM unless sample results prove otherwise. Suspect ACM that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, should be assumed to contain asbestos if discovered during any demolition or renovation process or until otherwise verified. ACM must be abated and properly disposed of prior to disturbance by state licensed and properly trained contractors. All abatement must be performed in accordance with federal, state, and local requirements.

4.2 Lead Containing Paint

The purpose of the limited LCP survey was to identify similar areas of LCP. During the on-site survey, representative samples of similar areas of interior building coatings were collected and analyzed for lead content.

The regulations addressing LCP in non-residential buildings are focused on occupational exposures involved with paint-disturbing activities and related waste-disposal activities.

Occupational exposure to lead during construction is regulated by OSHA regulation 29 CFR 1926.62 “Lead in Construction,” as well as other applicable state and local regulations. These regulations involve air monitoring to determine worker exposure levels when disturbing paint containing measurable levels of lead. This LCP survey cannot determine a safe level of lead for the purpose of paint-disturbing activities. However, this report is intended to provide guidance as to the location of LCP so it can be controlled, abated, or disposed of properly during this project’s construction related activities. Information gathered during this LCP survey should be used to determine where worker exposures to airborne lead may occur. Additionally, this information should also be used to assess the potential for exposure to workers, and for determining appropriate controls necessary to limit his or her health risks during this project.

A concentration of lead greater than or equal to 0.5 percent by weight (5,000 ppm) or 1.0 mg/cm2 exceeds EPA and HUD residential standards is considered an indicator of risk. Representative samples of LCP waste to be generated during building renovation, or following demolition but prior to disposal, should be collected and analyzed using toxicity characteristic leaching procedure (TCLP) in accordance with 40 CFR Part 261. Management and disposal of lead containing waste must be done in accordance with all applicable local, state, and federal regulations.

OSHA regulations may require certain procedures for any paint that contains lead, even if it is below EPA and HUD levels. All LCP identified, regardless of the lead content, should either be sampled and analyzed by TCLP and then handled/disposed of accordingly, or segregated from other large-scale debris and then managed as hazardous waste in accordance with federal, state, and local hazardous waste disposal regulations.

© 2023, Mabbett & Associates, Inc. Page 7 June 5, 2023

5.0 LIMITATIONS

This survey report is the result of a diligent and thorough inspection for regulated building materials of the designated areas and materials that may be impacted by the Upgrade Steam Distribution System Project.

Inaccessible areas were not included in this survey. Although a comprehensive inspection was performed, Mabbett does not claim to have identified all hazardous materials that could be present in the facility (for example, materials potentially located within inaccessible areas). Mabbett has conducted this assessment with reasonable care and has performed this project in accordance with generally accepted industry standards. There can be no assurances, and Mabbett makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported herein.

© 2023, Mabbett & Associates, Inc. FIGURE June 5, 2023

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© 2023, Mabbett & Associates, Inc. APPENDIX A June 5, 2023

APPENDIX A

Summary of ACM Sampling Results

Appendix A Summary of ACM Sampling Results

A/E Design Services to Upgrade Steam Distribution System Murfreesboro VAMC, Murfreesboro, TN

Sample No. Sample Location Description of Material Percent and Type of

Asbestos

01A Manhole #4 <6" Pipe Insulation 15% Chrysotile & 10% Amosite

01B Manhole #11 <6" Pipe Insulation 15% Chrysotile & 10%

01C Manhole #12 <6" Pipe Insulation 15% Chrysotile & 10%

01D Manhole #14 <6" Pipe Insulation 15% Chrysotile & 10%

01E Manhole #16 <6" Pipe Insulation 40% Chrysotile

01F Manhole #16-6 <6" Pipe Insulation 40% Chrysotile

01G-A Manhole #118 <6" Pipe Insulation NAD

01G-B Manhole #118 <6" Pipe Insulation 10% Chrysotile

02A Manhole #4 >6" Pipe Insulation 20% Chrysotile & 10%

02B Manhole #11 >6" Pipe Insulation 20% Chrysotile

02C Manhole #12-11 >6" Pipe Insulation 20% Chrysotile & 5% Crocidolite

02D Manhole #12 >6" Pipe Insulation 20% Chrysotile & 5%

02E Manhole #14 >6" Pipe Insulation 20% Chrysotile & 5% Crocidolite

02F Manhole #16 >6" Pipe Insulation 10% Chrysotile & 20%

02G Manhole #16-6 >6" Pipe Insulation 10% Chrysotile & 20%

03A Manhole #11 Black Patch Material 15% Chrysotile

03B Manhole #12-11 Black Patch Material 15% Chrysotile

03C Manhole #12 Black Patch Material 15% Chrysotile

04A Manhole #12 White Fiberglass End Sealant NAD

04B Manhole #12-11 White Fiberglass End Sealant 8% Chrysotile

04C Manhole #16 White Fiberglass End Sealant NAD

04D Manhole #14 White Fiberglass End Sealant NAD

05A Building 112, Room 109 Skim-coat on Wall NAD

05B Building 112, Room 109 Skim-coat on Wall NAD

05C Building 112, Room 109 Skim-coat on Wall NAD

06A Building 11, Pit Stick-pin Adhesive NAD

06B Building 11, Pit Stick-pin Adhesive NAD

07A Building 3, Fan Room 12 Black Coating on Fiberglass Pipe 6% Chrysotile

07B Building 3, Fan Room 12 Black Coating on Fiberglass Pipe 6% Chrysotile

Appendix A Summary of ACM Sampling Results

A/E Design Services to Upgrade Steam Distribution System Murfreesboro VAMC, Murfreesboro, TN

Sample No. Sample Location Description of Material Percent and Type of

Asbestos

07C Building 3, Fan Room 12 Black Coating on Fiberglass Pipe 6% Chrysotile

08A Building 6, Fan Room 16 White Fiberglass End Sealant NAD

08B Building 9, Crawl Space White Fiberglass End Sealant 10% Chrysotile

08C Building 12, Crawl Space White Fiberglass End Sealant 10% Chrysotile

08D Building 16, Condensate Pit White Fiberglass End Sealant NAD

08E Building 112, Room 109 White Fiberglass End Sealant 10% Chrysotile

Notes:

NAD = No Asbestos Detected

© 2023, Mabbett & Associates, Inc. APPENDIX B June 5, 2023

APPENDIX B

Asbestos Laboratory Report and Chains of Custody

© 2023, Mabbett & Associates, Inc. APPENDIX C June 5, 2023

Appendix C

Lead Paint Chip Laboratory Report and Chains of Custody