Attachment 3 - 765-24-700 EHRM HAZMAT SURVEY - Final.pdf

Categorical Exclusion Checklist

EHRM Infrastructure Upgrades Great Lakes CMOP Hines, IL

Bldg 37NW, 5000 5th Street

Hines, IL 60141

Proposed Great Lakes Consolidated Mail Outpatient Pharmacy

VA Project 765-24-700

Atriax Project No. 24-017-700

May 7, 2025

Terracon Project No. 11247292A

Prepared for:

Atriax, PLLC Hickory, North Carolina

Prepared by:

Terracon Consultants, Inc.

Omaha, Nebraska

Categorical Exclusion Checklist Great Lakes Consolidated Mail Outpatient Pharmacy

1. Project title:

EHRM Infrastructure Upgrades Great Lakes CMOP Hines, IL

2. VHA facility name and address:

Edward Hines, Jr. VA Hospital Bldg 37NW, 5000 5th Avenue Hines, IL 60141

3. Contact person name, e-mail, telephone number and Fax number:

Jessica Engelbart, Jessica.Engelbart@terracon.com, 402-330-2202 (Phone), 402-330-7606 (Fax)

4. Project location:

Great Lakes Consolidated Mail Outpatient Pharmacy Building #37 5000 5th Avenue Hines, Cook County, Illinois 60141

5. Description of project (Describe all phases of the overall project of which this project is part.

The project includes selected interior renovations within Building 37 associated with upgrading the Great Lakes Consolidated Mail Outpatient Pharmacy (CMOP) Infrastructure to support the new Electronic Health Record Modernization (EHRM) system. There will be interior demolition in Rooms C106A, C106B, and C1061 involving architecture, fire, mechanical, electrical, and telecom. Additional telecom demolition will be in rooms C1060, C1080A, and C1085. As part of the project, the existing Server Room (C106A) will be expanded into the surrounding space (C1060B). The upgrade activities include infrastructure improvements; relocation of power distribution, services, IT equipment, and communication infrastructure; and upgrading the fiber infrastructure backbone to the telecommunication room and telecommunication enclosures.

Phase I consists of:

1. Installation of a construction barrier. 2. Reroute ductwork and piping into rooms C1060A and C1060B. All construction material will be removed. 3. Remove equipment from rooms C1060A and C1060B and complete demolition work.

Phase II consists of:

1. Complete buildout of new Data Center. 2. Install CRAC unities. 3. Install UPS units, panel boards, and busway systems. 4. Install temporary fiber between the new Data Center and the existing Server Room to provide connectivity during the equipment migration. 5. Install new primary and redundant backbone pathway infrastructure and cable to existing and new Telecom Room and Telecom Enclosure locations. Route the new pathway infrastructure to the new Data Center. 6. Demolish the existing infrastructure and cabling. 7. Remove temporary fiber and cabling connecting the new Data Center to the existing Server Room.

6. Describe project’s surroundings and use of VA and non-VA land in proximity to projects.

The site is located on VA-owned property, an existing medical complex in Building #37. The building where the project is taking place is surrounded by offices, bathrooms, and maintenance rooms. Building #37 is bound by parking and 17th Street, followed by the Loyola University Medical Center Complex to the north, Highway 171 and Miller Meadow Park to the east, and by parking, office buildings associated with the VA complex to the mailto:Jean.Ramer@terracon.com south and west. Also, there is to the south is a railroad.

7. List regulatory and other agencies that are required to issue permits and other approvals for project.

No other known permits are required prior to proceeding.

ENVIRONMENTAL CHECKLIST ISSUES (QUESTIONS)

Issues

Impact

PSI

LSI/M

LSI

NI

NA

Comments/Supporting Documentation Mitigative Measures Attach Additional Sheets If Necessary

PSI – Potentially a Significant Impact LSI/M – Less Than Significant Impact Providing Mitigation is Incorporated into Project LSI – Less Than Significant Impact NI – Environmental Issue is Present in Project, -- There Is No Significant Impact NA – Environmental Issue Does Not Apply to Project

Skip to II. AIR QUALITY if the project does not involve a new structure / property improvement or modification of an existing structure / property improvement.

____ Check if you skip to II AIR QUALITY

I. AESTHETICS -- Would the project:

a) Have a substantial adverse effect on a scenic vista?

NA The project site is located within the existing Hines, IL VA Medical Center campus. The project is to be conducted within the interior of a building; therefore, the aesthetics of the complex will not change. There will be minor construction on the roof. Since the aesthetics will not be modified, no modification of the surrounding and project area scenic vistas or views will be impacted.

b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?

NA The project does not modify or impact the exterior of the structures or include ground disturbance. Therefore, no impact.

c) Substantially degrade the existing visual character or quality of the site and its surroundings?

NA The project site includes renovations within an existing building, which does not consist of extensions or additions and therefore will not have an impact on the visual character of the site and its surroundings.

d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?

NA The project site includes renovations within an existing building, no new light source will be added to the exterior of the building. No impact anticipated.

II. AIR QUALITY -- Would the project: Note: Where available, the significance criteria established by the applicable air quality management or air pollution control districts may be relied upon to make the following determinations.

Skip to III. BIOLOGICAL RESOURCES if the project will not during construction or operation result in 1. a new source of air pollution, 2. modification of an existing source of air pollution or 3. objectionable odor.

__X__ Check if you skip to III BIOLOGICAL RESOUCES

a) Conflict with or obstruct implementation of the applicable air quality plan?

b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation?

c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?

d) Release toxic substances to the air in quantities that could affect human health or safety, or environmental quality?

e) Release substances for which there is a National Ambient Air Quality Standard (such as sulfur or nitrogen oxides, carbon monoxide, lead, particulates, etc.)?

f) Result in the installation of devices including an incinerator that produce air emissions that are regulated by federal, state or local requirements?

g) Create objectionable odors affecting a substantial number of people?

h) Include a fossil fuel (natural gas, gasoline, diesel fuel, coal, etc.) burning heating system with a total capacity greater than 1 million BTU/hour?

III. BIOLOGICAL RESOURCES --

Would the project:

a) Have a substantial adverse effect, either directly or through habitat modifications, on rare, threatened, or endangered species, or a critical habitat?

NA A federally listed species list and critical habitat determination was obtained from the United States Fish and Wildlife Service’s (USFWS) Information for Planning and Consultation (IPaC) system. Five listed species are not likely to be present on the site: Rufa Red Knot (Calidris canutus rufa), Eastern Massasauga (Sistrurus catenatus), Hines’ Emerald Dragonfly (Somatochlora hineana), Eastern Prairie Fringed Orchid (Platanthera leucophaea), and the Leafy

Prairie-clover (Dalea foliosa). In addition, the Monarch Butterfly (Danaus plexippus) is proposed for listing, and the Whooping Crane (Grus americana) is listed as an Experimental Population, Non-Essential. The proposed project will not include ground disturbance or modify the exterior of the building, therefore, no impact to federally listed species is present.

b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the US Fish and Wildlife Service?

NA The proposed project will not include ground disturbance or modify the exterior of the building; therefore, no impact to federally listed species is expected.

c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?

NA A review of the USFWS National Wetland Inventory Map was conducted. A freshwater emergent wetland is mapped approximately

0.45 miles southeast of the project site, off-site. Since the proposed project will not modify the existing footprint of the building or include any ground disturbance, no impact to the off-site wetland is expected.

d) Interfere substantially with the movement of any native, resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?

NA The project will not include any ground disturbance or removal of vegetation; no impact to species or habitat is anticipated.

e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?

NA The project will not include any ground disturbance or removal of vegetation;

therefore, no biological associated policies apply.

f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?

NA The project will not include any ground disturbance or removal of vegetation;

therefore, compliance with habitat conservation plans is not required.

IV. CULTURAL RESOURCES --

Skip to V. GEOLOGY AND SOILS if the project does not involve historical, archaeological, or paleontological resources or the disturbance of human remains.

____ Check if you skip to V. GEOLOGY AND SOILS

a) Cause a substantial adverse change in the significance of a historical resource?

NI A Desktop Cultural Resources Assessment was completed by Terracon on April 24, 2025.

Two above-ground resources are eligible for NRHP listing within the Review Area, and 16 additional resources that are contributing to a National Register District. Because of the presence of historic age structures within the

APE, an architectural survey may be deemed necessary by SHPO to determine if the building is eligible for NRHP listing under Section 106.

b) Cause a substantial adverse change in the significance of an archaeological resource?

LSI The project building is unevaluated at this time for eligibility on the NRHP List. The building first appeared on topographic maps in 1956. However, due to the proposed project renovations, they will not have an adverse effect on archaeological resources.

c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?

NI One archaeological site was recorded in the review area. Construction will not directly or indirectly impact this site.

d) Disturb any human remains, including those interred outside of formal cemeteries?

NI There will be no disturbance of human remains.

V. GEOLOGY AND SOILS -- Would the project:

Skip to VI. HAZARDS AND HAZARDOUS MATERIALS if the project does not involve the disturbance of soil.

___X_ Check if you skip to VI. HAZARDS AND HAZARDOUS MATERIALS

a) Result in substantial soil erosion or the loss of topsoil?

b) Be located on a geologic unit or soil that is either unstable or would become unstable as a result of the project and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse?

c) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial risks to life or property?

VI. HAZARDS AND HAZARDOUS

MATERIALS -- Would the project:

a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?

NI Hazardous materials will not be used in the construction or operations of the facility in any amount that would create a hazard to the public. Management practices will be utilized for fuels or other potentially hazardous substances that may be necessary for construction. A spill control plan will be implemented for construction equipment as necessary.

b) Create a significant hazard to the public or the environment through reasonably foreseeable release of

NI

Hazardous materials will not be used in the construction or operations of the facility in any amount that would create a significant hazard hazardous materials to the environment?

to the public or the environment.

c) Generate more than 100 kilograms of hazardous waste per month during construction or operation?

NI Hazardous materials will not be used for the duration of construction. Prior to rehabilitation activities, known asbestos-containing materials and lead-based paint will be removed and disposed of in accordance with state and federal requirements. The materials removed would be considered waste.

d) Be located on property that state or federal officials have identified as a hazardous or solid waste site or a CERCLA site?

NI Based on a review of NEPA Assist for the site, there are hazardous or solid waste sites listed within 0.5 miles of the project area. The property has several LUST listings within the VA Medical Complex. Four of the six listings have No Further Action Letters. Building #218 and Building #5, both located near 5th Avenue & Roosevelt Road, have an active LUST listing. Neither of these is adjacent to the proposed building under construction. The proposed project will not require ground disturbance. No impact is anticipated.

e) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?

NI Under the project, access to the facility would not be modified; therefore, no impact on the accessibility to or from the site for emergency responses is anticipated.

f) Include the construction or close out of a solid waste management facility such as a landfill?

NA A solid waste facility is not located at the site.

g) Involve structures that contain asbestos containing material (for demolition and renovation projects and projects that involve transfer or use of structure / property by non-VA entity)?

LSI/M An Asbestos Survey was conducted by Terracon on February 27, 2025. The survey was conducted by an Asbestos Hazard Emergency Response Act (AHERA) accredited Asbestos Inspector. Building areas were visually assessed and sampled for suspect asbestos-containing materials (ACM).

The results of the survey are below:

ACM was not identified in the samples collected from the project-specific areas to be renovated. However, the following materials listed in the table below were not sampled per the direction of the VA and are assumed to contain asbestos unless sampled in the future and have laboratory analysis.

Description NESHPA Classification

Condition Quantity

Asphalt roof

Category I Nonfriable

Good > 500 sq ft

Asphalt flashing

Category 1 Nonfriable

Good > 750 sq ft

Prior to disturbing any of the areas that contain these materials, they will be removed, contained, and disposed of in accordance with state and federal regulations. A copy of the report is attached to this document.

h) Involve structures painted with lead-based paint (for demolition and renovation projects and projects that involve transfer or use of structure / property by non-VA entity)?

LSI/M A Lead-Based Paint Survey was conducted by Terracon on February 27, 2025. The survey was conducted by a State of Illinois-certified Lead Inspector. Rooms that are going to be demolished were assessed for lead-based paint (LBP) by analyzing five paint chip samples.

LBP was identified in hardware storage (columns) and the server room (support beam and pipe).

Prior to disturbing any of the areas that contain these materials, they will be removed, contained, and disposed of in accordance with state and federal regulations. A copy of the report is attached to this document.

i) Involve renovation or demolition of structure that housed a laboratory or stored hazardous chemicals or hazardous waste?

NA The project does not involve renovation or demolition of structures that house a laboratory or store hazardous chemicals or hazardous waste; therefore, no impact.

j) Involve the closing out or removal of an above ground or underground storage tank?

NA The project does not require the removal or modification of an existing underground or above ground storage tank, therefore no impact.

VII. HYDROLOGY AND WATER

QUALITY -- Would the project:

Skip to VII. d) HYDROLOGY AND WATER QUALITY if the project does not involve a discharge to groundwater or surface water resulting from construction or operation. __X__ Check if you skip to VII. d) HYDROLOGY AND WATER QUALITY

a) Violate any water quality standards or waste discharge requirements?

b) Degrade water quality in a sole source aquifer?

c) Affect chemical quality of ground or surface waters (pH, dissolved oxygen, nutrients, dissolved solids, pesticides, etc.)?

d) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net reduction in aquifer volume or a lowering of the local groundwater table level.

Skip e), f), g), h) and i) (below) and go to VIII LAND USE AND PLANNING if the project does not involve construction of a new structure; changing the footprint of an existing building; or construction of new infrastructure, including, but not limited to parking lots and roads.

_X_ Check if you skip to VII. e) to i) HYDROLOGY AND WATER QUALITY

e) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river?

f) Substantially alter the existing drainage pattern of the site or area in a manner which would result in flooding on or off site?

g) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff?

h) Place a structure within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?

i) Expose people or structures to a significant risk of loss, injury or death involving flooding?

VIII LAND USE AND PLANNING -

a) Conflict with any applicable land use plan, policy, or regulation of an agency that has jurisdiction over the project?

NA The project is located within an existing health facility campus. There will be no change in land use, zoning, or planning initiatives of the community. No impact.

IX. NOISE -- Would the project result in:

a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable regulations and standards?

NA The proposed project is located within a commercial area outside of the medical center.

The area in the immediate vicinity is not a sensitive receptor. Construction noise is anticipated and work will be limited to traditional business hours to reduce the impacts as much as possible to surrounding areas. No impact is anticipated.

b) Exposure of persons to or the generation of excessive groundborne vibration or groundborne noise levels?

NA Subsurface work is not anticipated as part of the proposed project; therefore, no impact is anticipated.

c) A substantial temporary or permanent increase in ambient noise levels in the project vicinity above levels existing without the project?

NA The proposed project will include construction noise that is temporary and may be present throughout the day or during intervals. The level and duration of construction related noise is dependent upon the type of renovation activities. Upon completion of the proposed project ambient noise levels would return to the current level. During construction, activities would be limited to business hours. No impact is anticipated.

X. POPULATION AND HOUSING --

a) Induce substantial population growth in an area, either directly or indirectly?

NA The proposed project will not increase or decrease the number of people served locally;

therefore, no impact is anticipated.

b) Displace substantial numbers of existing housing or persons, necessitating the construction of replacement housing elsewhere?

NA The proposed project is located within an existing development and will not require acquisition of property. No impact is anticipated.

XI. PUBLIC SERVICES

a) Would the project result in substantial adverse impacts associated with changes in infrastructure needed to maintain acceptable levels of public service associated with:

Fire protection?

NI The project facility currently has fire protection.

The sprinkler system will be removed and a new one will be installed and modified to accommodate the new architectural configurations and tied into the existing campus fire alarm system. It will require a fire suppression shutdown for the area of work affected by the project. At times when the fire suppression system is drained and shut down, the installing contractor shall provide a temporary fire alarm and fire extinguisher. The building will be on Fire Watch during the switch-over. The work will meet the VA Fire Protection Design Manual. Therefore, no additional need for fire protection is anticipated.

Police protection?

NA The project will not increase or decrease the number of people served locally; therefore, no additional need for police protection is anticipated.

Schools?

NA The current site and proposed project does not involve permanent residents; therefore, no impact to schools or students is anticipated.

Parks?

NA The project will renovate the existing structure at the site and will not modify the park to the east. No impact is anticipated.

Other public facilities?

(Specify)

NA

The Loyola University Medical Center complex is to the north. The project will renovate an existing structure and will not impact the medical complex to the north. No impact is anticipated.

XII. TRANSPORTATION / TRAFFIC --

a) Cause an increase in traffic which is substantial when compared to the existing traffic load and capacity of the roads in the vicinity of the project?

NI The project has the potential to increase the number of vehicles present on site during construction activities; however, these vehicles will be located within areas that will not impact the available parking spaces for employees and visitors. Also, additional vehicles traveling to/from the site are anticipated to be less than significant since the project involves renovation and does not require large pieces of equipment, vehicles, or numerous contractors.

XIII. UTILITIES AND SERVICE

SYSTEMS -- Would the project:

a) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available?

NA The project is located on a developed site and will utilize the existing utilities and service systems on site.

b) Result in wastewater that exceeds wastewater treatment requirements or capacity of the applicable state, regional or local water pollution agency?

NA The quantity of wastewater generated is not anticipated to be modified. The current wastewater treatment plan has adequate capacity to treat any minor increase in wastewater that would occur from construction.

c) Result in the construction of new water or wastewater treatment facilities or the expansion of existing facilities that could result in significant environmental impacts?

NA The project does not involve building or expanding a wastewater treatment facility or related infrastructure. No impact is anticipated.

d) Result in the discharge of industrial waste to wastewater treatment facilities?

NA The project will not result in the discharge of industrial waste.

e) If the answer to d) is “yes”, is discharge of any of the industrial waste limited or prohibited?

NA Not applicable.

f) Require or result in the construction of new storm water drainage facilities or the expansion of existing facilities, the construction of which could cause significant environmental effects?

NA The project will not include ground disturbance; therefore, construction or post-construction best management practices or stormwater systems will not be modified/required.

g) Be able to obtain sufficient drinking water from existing sources and entitlements?

NA The facility currently utilizes drinking water from the city-owned water utility. Since the facility is on a public drinking water system, and the number of people served will not increase, the current drinking water infrastructure is adequate. No impact anticipated.

h) Require the installation or removal of above ground or underground storage tanks?

NA The project does not include ground disturbance; therefore, no impact is anticipated.

i) Be served by a landfill or other solid waste disposal facility with sufficient permitted capacity to accommodate the project’s solid waste disposal needs?

NI The project will not result in any significant change to the number of people served locally;

therefore, the waste generated by the normal operations of the facility is not anticipated to change. Waste generated during the construction activities would be disposed of at a licensed landfill; therefore, no adverse impact to a municipal solid waste landfill is anticipated.

j) Result in the disturbance of > 1 acre and need to obtain storm water discharge permit?

NA The project disturbance will take place inside the building and will not require any ground disturbance; therefore, no impacts to stormwater associated with construction activities are anticipated.

XIV – REAL PROPERTY TRANSFER Note: Items under XIV REAL PROPERTY TRANSFER should be addressed if the project involves: VA purchasing, selling, donating, or otherwise acquiring or transferring real property; or an enhanced use lease or similar project involving long term use of VA property.

Skip to XV. – ENVIRONMENTAL PERMITTING if the project does not involve real property transfer or an enhanced use lease.

__X__ Check here if you skip to XV. – ENVIRONMENTAL PERMITTING

a) What has been the use of the property at question in the past:

_____Health care?

_____Industrial?

_____Residential?

_____Commercial (e.g., Office/Store)?

_____Other (specify)?

_____Unknown?

b) Has past use of property involved storing, handling or use of hazardous materials, or the release of hazardous material to the environment?

c) Has a Phase I Environmental Assessment (EA) been performed in accordance with ASTM specification 1527?

d) Has a Phase I EA been expanded to cover asbestos containing material and lead-based paint?

e) Does the Phase I EA conclude that there are environmental conditions that need to be further addressed?

f) Has a Phase II EA (or its equivalent) been prepared to address environmental conditions identified in either the Phase I EA or other environmental review?

g) Has Phase I EA and Phase II EA and other project data been reviewed to both determine if remedial action is needed and assess possible future VA environmental liabilities associated with the project?

XV – Environmental Permitting – Does the project involve

a) Installation or modification of new equipment or infrastructure that would require a federal, state or local environmental permit. This would include equipment or infrastructure that produces air emissions (e.g., boiler or incinerator); wastewater, industrial wastewater or stormwater discharge;

solid or hazardous waste; or otherwise impacts on environmental media?

NA The project does not include the installation of new equipment that would generate emissions or a discharge of any kind. No additional permitting is required.

ENVIRONMENTAL FACTORS THAT WILL POTENTIALLY HAVE A SIGNIFICANT IMPACT ON THE

ENVIRONMENT

If it is determined that any of the checklist responses under Aesthetics, Air Quality, Biological Resources, etc. indicate a “Potentially Significant Impact”, the appropriate category should be checked. This individual should also sign and date this information.

Aesthetics

Air Quality

Biological Resources

Cultural Resources

Hazards & Hazardous Materials

Hydrology / Water Quality

Land Use / Planning

Mineral Resources

Noise

Population / Housing

Public Services

Transportation/Traffic

Utilities / Service Systems

Recreation

Real Property Transfer

DETERMINATION OF WHETHER THE PROJECT IN ITS ENTIRETY WILL HAVE A

SIGNIFICANT IMPACT ON THE ENVIRONMENT

In accordance with VHA policy and guidance, a senior VHA facility manager (i.e., VHA facility director or VHA facility associate director) is to determine if the project taken in its entirety will have a significant impact on the environment. This official is to indicate their determination in the table below and sign and date the table.

I am a senior VHA facility manager and have reviewed the information contained in this document. After appropriate review and discussion with VHA facility staff and others, I have determined that the subject project:

WILL NOT have a significant effect on the environment.

MAY HAVE a significant effect on the environment. HOWEVER, revisions to the project have been made to mitigate perceived significant environmental impacts.

MAY HAVE a significant effect on the environment, and an Environmental Assessment or Environmental Impact Statement is required.

Name of VAMC or Other VHA Facility Senior Manager Making Determination

Title Date

Attachments

Facilities | Environmental | Geotechnical | Materials I

Limited Hazardous Building Materials Inspection Report Hines VA EHRM Infrastructure Upgrades Project

Great Lakes Consolidated Mail Outpatient Pharmacy

5000 South 5th Avenue, Building 37 NW

Hines, Cook County, Illinois 60141

May 13, 2025 | Terracon Project Number: 11247292

Prepared for:

Atriax PLLC Hickory, North Carolina

Prepared by:

Terracon Consultants, Inc.

Glendale Heights, Illinois

192 Exchange Boulevard Glendale Heights, Illinois 60139-2089

P 630-717-4263 F 630-357-9489 Terracon.com

Facilities | Environmental | Geotechnical | Materials

May 13, 2025

Atriax PLLC PO Box 1629 Hickory, North Carolina 28603

Attn: Mr. Stephen Collar P: (828) 315-9962 E: Stephen.Collar@AtriaxGroup.com

RE: Limited Hazardous Building Materials Inspection Report Hines VA EHRM Infrastructure Upgrades Project Great Lakes Consolidated Mail Outpatient Pharmacy 5000 South 5th Avenue, Building 37 NW Hines, Cook County, Illinois 60141 Terracon Project No. 11247292

Dear Mr. Collar:

Terracon Consultants, Inc. (Terracon) is pleased to submit this limited hazardous building materials inspection report to Atriax PLLC (Client) regarding the above-referenced project. These services were conducted at the project site February 27, 2025 in accordance with Terracon’s proposal number P11247292, dated September 20, 2024 .We understand that this inspection scope of services was requested due to the renovation of areas scheduled to be impacted in the future by the EHRM Infrastructure Upgrades project regarding Building 37 NW of the Great Lakes Consolidated Mail Outpatient Pharmacy (CMOP) facility located at 5000 South 5th Avenue, Hines, Illinois. The areas scheduled for future renovation activities include Hardware Storage (C1061), Server Room (C1060A), UPS Room (C1060B), and a small portion of the roof.

Asbestos-containing materials (ACM) were not identified as a result of this inspection, but assumed ACM were identified. Lead-based paint (LBP) (testing combinations found to have greater than or equal to 0.5% lead by weight) was identified. Also, based on the visual investigation performed for this inspection, regulated materials were identified. Please refer to the attached report for further detail.

Hazardous Building Materials Inspection Report Hines VA EHRM Infrastructure Upgrades Project – Great Lakes CMOP | Hines, Illinois May 13, 2025 | Terracon Project No. 11247292

Facilities | Environmental | Geotechnical | Materials II

Terracon appreciates the opportunity to provide these consulting services to Atriax PLLC. If we can be of further assistance, please contact us at 630.717.4263.

Sincerely, Terracon Consultants, Inc.

Christopher J. Heynen Joseph A. Tussey, CHMM Senior Staff Scientist Authorized Project Reviewer

Limited Hazardous Building Materials Inspection Report

May 13, 2025 | Terracon Project No. 11247292

Facilities | Environmental | Geotechnical | Materials

Table of Contents

Introduction Reliance

Site Description

Field Activities - Asbestos Visual Assessment

Physical Assessment

Sample Collection

Sample Analysis

Regulatory Overview

Field Activities - Lead Visual Assessment

Physical Assessment

Sample Collection

Sample Analysis

Regulatory Overview

Field Activities – Regulated Materials PCB-Containing Components

Mercury-Containing Components

CFCs and Hydro-Chlorofluorocarbons (HCFCs)

Chemicals, Hazardous Waste and Oil

Batteries

Radioactive Sources

Findings Asbestos Findings

Lead Findings

Regulated Materials Findings

Limited Hazardous Building Materials Inspection Report Hines VA EHRM Infrastructure Upgrades Project – Great Lakes CMOP | Hines, Illinois May 13, 2025 | Terracon Project No. 11247292

Facilities | Environmental | Geotechnical | Materials

General Comments

Appendices

APPENDIX A Asbestos Inspection Sample Summary

APPENDIX B Confirmed and Assumed Asbestos-Containing Materials

APPENDIX C Asbestos Analytical Laboratory Data

APPENDIX D Lead Analytical Laboratory Data

APPENDIX E Licenses and Certifications

APPENDIX F Photographs

APPENDIX G Sample Location Maps

APPENDIX H Prior Report

Facilities | Environmental | Geotechnical | Materials 1

LIMITED HAZARDOUS BUILDING MATERIALS

INSPECTION REPORT

Hines VA EHRM Infrastructure Upgrades Project Great Lakes Consolidated Mail Outpatient Pharmacy

5000 South 5th Avenue, Building 37 NW Hines, Cook County, Illinois 60141

Terracon Project No. 11247292 May 13, 2025

Introduction

Terracon Consultants, Inc. (Terracon) conducted a hazardous building materials inspection, which included an asbestos-containing materials (ACM), lead-based paint (LBP), and visual hazardous building materials inspection which was limited to project-specific areas to be renovated. This inspection was requested due to the renovation of areas scheduled to be impacted by the EHRM Infrastructure Upgrades project regarding Building 37 NW of the Great Lakes Consolidated Mail Outpatient Pharmacy (CMOP) facility located at 5000 South 5th Avenue, Hines, Illinois. The areas scheduled for renovation include Hardware Storage (C1061), Server Room (C1060A), UPS Room (C1060B), and a small part of the roof. Terracon reviewed a prior ACM and LBP report for the building which had been prepared 2018 by Carnow, Conibear, and Associates, Ltd. Terracon conducted inspection and sampling activities in the areas scheduled for renovation for this project since it appeared that materials in these areas were not specifically sampled during the prior inspection in 2018. The prior 2018 report is included in Appendix H.

The pre-renovation hazardous building materials inspection for this project was conducted on February 27, 2025, by State of Illinois Department of Public Health (IDPH) licensed building inspectors in general accordance with Terracon’s proposal number P11247292, dated September 20, 2024. Accessible building components were inspected within the building areas referenced above, and homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented. Although reasonable effort was made to inspect accessible suspect materials, additional suspect but unsampled materials could be located in walls, in voids or in other concealed areas. Bulk samples from suspect ACM were collected in accordance with the sampling protocols outlined in United States Environmental Protection Agency (USEPA) 40 Code of Federal Regulations Part 763-Asbestos, Subpart E-Asbestos-Containing Materials in Schools (40 CFR 763; known as the Asbestos Hazard Emergency Response Act [AHERA]). Samples were delivered to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for analysis by polarized light microscopy (PLM). USEPA regulation 40 CFR 61, Subpart M, 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 and IDPH requires that regulated and potentially regulated ACM be identified, classified, and quantified prior to planned renovation or demolition activities.

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In conjunction with the asbestos inspection, Terracon conducted a LBP inspection regarding representative visible and accessible painted building components. Unique paint sampling combinations were visually identified and documented. This lead inspection was not intended to meet the requirements of the US Department of Housing and Urban Development (USHUD) Guidelines. Although reasonable effort was made to inspect the substrates for unique painting combinations, additional suspect but untested paint could be located at the site due to an undetected change in the paints or variations in lead concentrations in homogeneous paint combinations.

Terracon also conducted a visual assessment of the project areas to identify materials that may be classified as hazardous (and non-hazardous), special or universal waste and other materials that may require special handling prior to disposal.

Reliance

This report is for the exclusive use of Atriax PLLC (Client) for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and the Client. Reliance on this report by the Client and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report, and the agreement between Terracon and the Client. The limitations of liability defined in the agreement is the aggregate limit of Terracon’s liability to the Client.

Site Description

This inspection was requested due to the renovation of areas scheduled to be impacted by the EHRM Infrastructure Upgrades project in Building 37 NW of the Great Lakes Consolidated Mail Outpatient Pharmacy (CMOP) facility located at 5000 South 5th Avenue, Hines, Illinois. The areas scheduled for renovation include Hardware Storage (C1061), Server Room (C1060A), UPS Room (C1060B), and a small portion of the roof. In the areas for renovation, interior finishes generally consist of drywall and vinyl cove base on walls, flooring consists of exposed concrete and vinyl floor tiles, and ceilings consist of acoustical drop-in ceiling tiles. Readily accessible suspect asbestos-containing thermal system insulation (TSI) was not observed. The heating, ventilation, and air conditioning (HVAC) system is mounted on the roof, which is a flat roof.

Field Activities - Asbestos

The inspection was conducted by Mr. Chris Heynen and Ms. Heather Eckard who are IDPH-licensed asbestos building inspectors (license # 100-19246 & # 100-10397, respectively). Copies of their licenses are attached in Appendix E. The ACM inspection was conducted in accordance with the sampling protocols outlined in USEPA 40 CFR 763, Subpart E, Section 763.86 AHERA. A summary of the inspection activities follows.

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Visual Assessment

Terracon’s inspection activities began with visual observation of building materials within the project-specific areas to be renovated to identify homogeneous areas and quantify materials suspected of containing asbestos (suspect ACM). A homogeneous area consists of materials that appear similar throughout in terms of color and texture. Homogeneous areas of suspect ACM were visually identified and documented. Although reasonable effort was made to inspect accessible suspect materials, additional suspect, but unsampled, materials could be located in walls, voids or in other concealed areas. Materials identified as glass, wood, or metal were not considered suspect ACM.

Physical Assessment

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 USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

Sample Collection

Based on results of the visual assessment, bulk samples of suspect ACM were collected in accordance with USEPA sampling protocols. Random samples of suspect materials were collected in each homogeneous area. The bulk samples were collected using wet methods, as applicable, to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers.

The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content.

Terracon collected a total of 27 bulk samples from nine (9) homogeneous areas of suspect ACM during this limited inspection. The homogeneous areas of suspect ACM identified and sampled during the inspection are listed in Appendix A. Photos of each HA of suspect ACM sampled are included in Appendix F. Sample locations are indicated on drawings included in Appendix G.

Sample Analysis

Bulk samples were submitted under chain of custody to Moody Labs, LLC (Moody) of Farmers Branch, Texas, a laboratory accredited under the National Voluntary Laboratory Accreditation Program (NVLAP; Lab No. 102056-0) for analysis by PLM with dispersion staining techniques per USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93-116). The percentage of asbestos, if present, was determined by microscopic visual estimation using PLM.

The laboratory analytical report is included in Appendix C. A copy of Moody’s certification is provided in Appendix E.

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Regulatory Overview

The asbestos NESHAP (40 CFR 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing materials prior to demolition or renovation activity. Under NESHAP, ACMs are classified as friable, Category I nonfriable, or Category II nonfriable ACM. Friable materials are those that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Category I nonfriable ACM includes packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1% asbestos. Category II nonfriable ACMs are any materials other than Category I materials that contain more than 1% asbestos. Friable ACMs and Category I and Category II nonfriable ACMs that are in poor condition and have become friable; will be subjected to drilling, sanding, grinding, cutting, or abrading; or could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM).

In Illinois, asbestos activities are regulated by the Illinois Environmental Protection Agency (IEPA) and IDPH. IEPA regulates asbestos fiber emissions under Illinois Administrative Code (IAC) 35 Part 228 Asbestos. For large projects (greater than 160 square feet and/or 260 linear feet) and demolition projects, the owner or operator must provide the IEPA with written notification and payment of applicable fees for removal activities at least 10 working days prior to the commencement of asbestos abatement activities.

IDPH regulates asbestos abatement activities in schools and other buildings under 77 IAC 855 Asbestos Abatement for Public and Private Schools and Commercial and Public Buildings in Illinois.

Under 77 IAC 855.100 License Requirements, IDPH requires that any asbestos-related activity conducted in schools be performed by personnel licensed by the IDPH. This includes asbestos workers, supervisors, inspectors, management planners, project designers, project managers, air sampling professionals, and contractors. 77 IAC 855 specifies work practices and controls for all schools.

The Occupational Safety and Health Administration (OSHA) asbestos standard for the construction industry (29 CFR 1926.1101) regulates workplace exposure to asbestos during ACM removal. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below the permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) or 1.0 f/cc as a 30-minute excursion limit. The OSHA standard classifies the types of construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work.

The above overview is not intended to be Inclusive of all potentially pertinent regulatory information. The relevant city, state, USEPA, and OSHA standards should be consulted prior to undertaking activities involving the demolition, renovation, or maintenance of ACMs.

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Field Activities - Lead

In conjunction with the asbestos inspection, Terracon conducted an inspection of representative building components to identify, test, and assess the condition of accessible painted building components suspected of containing lead (suspect paint). As this inspection is for the purpose of renovation, it was not intended to meet the requirements of the USHUD Guidelines. The inspection was conducted by Ms. Heather Eckard, who is a State of Illinois licensed lead inspector (license number 010996). A copy of the lead inspector license is attached in Appendix E.

Visual Assessment

The inspection activities began with visual observation of the project-specific areas to identify suspect paint. An inventory of suspect paint was compiled that documented the general location of the materials. A visual assessment of suspect paint was conducted to assess the condition of the paint and assign a condition of intact or poor. Areas of damaged, peeling, or flaking paint were documented.

Physical Assessment

A physical assessment of each unique combination of paint in the study area was conducted to assess the condition of the paint systems. Paint was visually assessed and assigned a condition of intact or poor.

Sample Collection

Representative paint chip samples were collected. Terracon collected five (5) chip samples from painted surfaces with the project-specific areas. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. Photos of the sampled paint are included in Appendix F. Paint sample locations are indicated on drawings included in Appendix G.

Sample Analysis

The paint chip samples were submitted under COC to EMSL Analytical, Inc (EMSL) of Hillside, Illinois for analysis by flame atomic absorption spectroscopy (AAS) in accordance with National Institute for Occupational Safety and Health (NIOSH) Method 7082 Lead. EMSL is accredited by the AIHA Laboratory Accreditation Programs, LLC under the Environmental Lead Laboratory Accreditation Program (ELLAP) Accreditation No. LAP-102992. The laboratory analytical data is included in Appendix D. A copy of their accreditation is included in Appendix E.

Regulatory Overview

The USHUD and USEPA definition for lead-based paint is 0.5% (5,000 milligrams per kilogram [mg/kg], 5,000 parts per million [ppm]) lead dry weight by laboratory analysis. The USHUD and USEPA definition of LBP is directed at protecting the general population from exposure to lead in

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Facilities | Environmental | Geotechnical | Materials 7 residential and child-occupied (<6 years of age) settings. By contrast, the duty of OSHA is to protect workers during construction activities that may generate elevated airborne lead concentrations. OSHA states that construction work (which includes renovation, maintenance, and demolition) carried out on structures coated with paint that has lead concentrations lower than the USHUD and USEPA regulatory limits can still result in airborne lead concentrations in excess of regulatory limits.

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint (lead-containing paint (LCP)), as even small concentrations of lead can result in unacceptable employee exposures depending upon the method of removal and other workplace conditions. Under this standard, construction includes, but is not limited to, the following:

Demolition or salvage of structures where lead or materials containing lead are present Removal or encapsulation of materials containing lead New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead Installation of products containing lead Lead contamination/emergency clean-up Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed Maintenance operations associated with construction activities described above

Employers must assure that no employee will be exposed to lead at…