ATTACHMENT 4 - 2013 ATL Asbestos 3-Yr Reinspection Report.pdf

ASBESTOS 3-YEAR REINSPECTION REPORT

For

DEPARTMENT OF VETERANS AFFAIRS

MEDICAL CENTER

1670 CLAIRMONT ROAD

DECATUR, GEORGIA 30033

Date:

August 22, 2013

Prepared by:

MICHAEL F. DURBIN, CIH

DURBIN ENVIRONMENTAL CONSULTANTS, INC.

3461 LAWRENCEVILLE-SUWANEE ROAD, SUITE A

SUWANEE GEORGIA 30024

(678) 482-9917

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TABLE OF CONTENTS

Page #

1. INTRODUCTION 2

2. DISCUSSION AND RESULTS 2

3. RECOMMENDATIONS 4

4. REFERENCES 5

APPENDIX

A. Physical and Hazard Assessment Summary Table For Ceiling Materials

B. Physical and Hazard Assessment Summary Table for Wall Materials

C. Physical and Hazard Assessment Summary Table for Floor Materials

D. Physical and Hazard Assessment Summary Table for Miscellaneous Materials

E. Physical and Hazard Assessment Summary Table for Thermal System Insulation Materials

F. Supplemental Fifth Floor Bulk Sample Table

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1. INTRODUCTION

Durbin Environmental Consultants, Inc., was retained by the Department of Veterans Affairs to perform a 3-year reinspection asbestos assessment at the Medical Center (Atlanta) located at 1670 Clairmont Road, Decatur, Georgia. The 3-year reinspection included a physical and hazard assessment of previously identified friable asbestos containing material. The asbestos assessment was limited to accessible identified asbestos containing materials (ACM) and did not include destructive access methods. The 3-year reinspection was conducted on August 20, 2013 by Sellers C. Carmack of Durbin Environmental Consultants, Inc. Mr. Carmack is currently accredited as an Asbestos Inspector, Management Planner and Project Designer through an Environmental Protection Agency (EPA) approved training provider (Inspector/Management Planner, Certificate # 13423, The Environmental Institute, Expires 9/25/2013).

Quality control for this project was performed by Michael F. Durbin, CIH of Durbin Environmental Consultants, Inc. Michael F. Durbin, CIH is also accredited as an Asbestos Inspector, Management Planner, and Project Designer through an EPA approved training provider (Inspector/Management Planner, Certificate # 13828, The Environmental Institute, Expires 5/13/2014).

2. DISCUSSION AND RESULTS

The asbestos 3-year reinspection was conducted in accordance with the Asbestos Hazard Emergency Response Act (AHERA 40 CFR, Part 763) for the materials included in this specific survey.

Physical and hazard assessments were performed for nonfriable asbestos containing materials: (1) various floor tile and associated mastics/adhesives. On the day of the reinspection, these materials were found to be in good condition.

Physical and hazard assessments of the following friable materials were conducted: accessible hard mud pipe fittings (including joints, valves, T’s, hangars, expansion joints, and all other hand packed insulated fittings) located in the Original Tower, Section C. These materials were generally in good condition on the days of the reinspection. Please refer to Attachment E for the Physical and Hazard Assessment Summary Tables for Thermal System Insulation.

Additionally, the original amosite asbestos fireproofing (removed during a 1980’s asbestos abatement project from ceiling deck) may be present above original walls where they intersect the ceiling deck or structural members and amosite asbestos fireproofing may be present in the wall cavities of original walls and within enclosed structural columns.

Original amosite asbestos fireproofing is present as a contaminant in certain areas throughout Section C (Tower Section) that were not fully abated from the ceiling decks during the 1980’s asbestos abatement project. Previous bulk sampling for the Replace Sprinkler System 2000 Project, Replace AHU Phase I and II Project, Correct Plumbing Deficiencies Project and the Supplemental Bulk Sampling Survey of the 3rd Floor confirmed the presence of asbestos fireproofing. Additionally, a grey/beige hard cementitious (still a friable material because it can be crumbled by hand pressure) fireproofing around various areas of the perimeter of the 5th Floor contained 2-15% amosite asbestos as presented in Appendix F. Note: Areas of the 3rd Floor and areas in the dumbwaiter (abated as part of the Replace AHU I and II Project) indicated up to 25% amosite asbestos.

The fireproofing material was in good condition on the day of the survey and has a low potential for damage during normal building occupancy activities. Refer to Appendix F for the Supplemental Bulk Sample Table for the 5th Floor.

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In areas where the Medical Center personnel can document the removal and disposal of all original walls (i.e., as a result of recent large-scale renovation projects, specifically the 4th Floor, 7th Floor, 8th Floor, the 9th Floor and 10th Floor (the entire floors were abated but if any original walls were left primarily around elevators or stairwells, then there potentially could be original amosite fireproofing that remains concealed behind plaster or gypsum board walls or ceilings), the interior wall cavities can typically be considered free of asbestos debris and the ceiling decks were abated a second time. In all areas of Section C (excluding 4th Floor, 7th Floor, 8th Floor, the 9th Floor and 10th Floor) if debris is observed in these walls cavities, disturbance should cease immediately, until the VA industrial hygienist (VAIH) can arrange for the sampling and analysis of the material. Areas where the original walls have been replaced should be identified and reported to the VAIH so that those areas can be incorporated as part of the VA’s Operation and Maintenance Program. A summary of identified or assumed asbestos containing materials by building sections is as follows:

Section A: Various Floor Tile/Linoleum and/or Associated Mastics, Glues and Adhesives. Note: in certain areas (primarily corridors) new non-asbestos floor coverings have been put over the existing asbestos containing floor tiles and/or associated asbestos containing mastics/glues and adhesives. The new non-asbestos floor coverings were in good condition on the day of the survey.

Section B: Various Floor Tile and/or Associated Mastics, Glues and Adhesives. Note: in certain areas (primarily corridors) new non-asbestos floor coverings have been put over the existing asbestos containing floor tiles and/or associated asbestos containing mastics/glues and adhesives. The new non-asbestos floor coverings were in good condition on the day of the survey. One sample of drywall joint compound indicated less than 1% chrysotile asbestos in Section B. The material was in good condition with low potential for disturbance during normal building occupancy conditions.

Section C: Various Floor Tile and/or Associated Mastics, Glues and Adhesives (Note: in certain areas (primarily corridors) new non-asbestos floor coverings have been put over the existing asbestos containing floor tiles, and/or associated asbestos containing mastics/glues and adhesives), Various Hard Mudded Pipe Fittings (in the Original Tower Section), Original Amosite Asbestos Fireproofing and/or Fireproofing Overspray above Original Wall Partitions or Structural Members (in the Original Tower Section), original amosite fireproofing on deck near the outer perimeter walls, (Refer to Appendix F for an example) and Loose Fireproofing Debris Within Original Wall Cavities (in the Original Tower Section).

Most of the observed, accessible pipe fittings/elbows in Section C are non-suspect PVC with fiberglass fittings. The majority of the ACM hard-mudded pipe fittings are in chases or behind walls.

On the 3rd Floor of Section C, White Canvas Wrapped Duct Insulation with Fiberglass is labeled as ACM and was in good condition on the day of the inspection.

On the 3rd Floor of Section C, Orange Canvas Wrapped Pipe Insulation with Fiberglass is labeled ACM and was in good condition on the day of the inspection.

On the 3rd Floor of Section C, Blue Canvas Wrapped Pipe Insulation with Foamglass is labeled ACM and was in good condition on the day of the survey.

Section D: Various Floor Tile and/or Associated Mastics, Glues and Adhesives. It should be noted that the 1st Floor, 2nd, Floor and 3rd Floor have been remodeled with new floor coverings put on top of the original asbestos floor tiles and/or associated asbestos containing mastics, glues and adhesives with the exception of the stairwells which still has exposed asbestos floor tile with associated asbestos containing mastic, glues and adhesives in good condition. The new non-asbestos floor coverings were in good condition on the day of the survey.

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The identified friable asbestos containing materials were generally in good condition and had a low potential for disturbance for the hard-mudded pipe fittings located in the Original Tower, Section C. The original amosite fireproofing above original wall partitions and on structural members and as overspray on ductwork is in good condition and have a low potential for disturbance (unless affected by renovation, demolition or maintenance activities). The loose amosite fireproofing within original wall cavities has a low potential for disturbance (unless affected by renovation, demolition or maintenance activities). Floor tile and associated mastics and adhesives were generally in good condition on the day of this investigation in all sections of the VAMC in Decatur, Georgia. Note: Fire doors and frames were not sampled during this reinspection, accordingly, they shall be assumed as positive for asbestos unless sampled and determined to be non asbestos.

3. RECOMMENDATIONS

A. All asbestos containing material should be maintained under an asbestos Operations and Maintenance program.

B. Any disturbance of asbestos containing materials due to renovation or demolition activities shall be designed by an accredited asbestos project designer and performed by a licensed asbestos abatement contractor accredited by the State of Georgia and in accordance with all Federal, State of Georgia, and local Dekalb County regulations for asbestos removal and disposal.

C. Communication of asbestos presence should be presented in accordance with the OSHA Asbestos

Standard (29 CFR 1926.1101) to all personnel who may potentially contact or disturb asbestos containing materials. Operations and Maintenance (O&M) and awareness training shall be provided for Class III and IV workers as defined by OSHA 29 CFR 1926.1101.

D. All spray applied fireproofing material contained in the original wall cavities of the Original Tower, Section C, shall be assumed to contain amosite asbestos (the original fireproofing that was removed in the early 1980’s). Also, all spray applied fireproofing on the deck and other surfaces within Section C shall be assumed to contain original amosite asbestos or contamination, with the exception the 4th Floor, 7th Floor, 8th Floor, the 9th Floor and 10th Floor which have all been renovated in the past 6-7 years. It should be noted that if any original walls remain on the renovated floors (i.e. elevators, stairwells) then the possibility exists that the original amosite fireproofing is still present in these locations.

E. VA Project Engineers should maintain copies of renovation as-built drawings showing areas of asbestos abatement. Information should include the type(s) of asbestos containing materials removed and the extent of abatement on each floor. VA Project Engineers should provide this information to the VAIH so the VAIH can update the VA Atlanta O&M Program.

F. VA Project Engineers should maintain copies of renovation/remodeling as-built drawings showing areas where non-asbestos floor coverings have been installed over asbestos containing floor coverings and/or associated asbestos containing mastic/glue/adhesive. VA Project Engineers should provide this information to the VAIH so the VAIH can update the VA Atlanta O&M Program.

G. VA Project Engineers should submit “asbestos free” certification letters for the floors that have been completely renovated to the VAIH so the VAIH can update the VA Atlanta O&M Program.

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4. REFERENCES

1. “Guidance for Controlling Asbestos-Containing Materials in Buildings”

(Purple Book). EPA 560/5-85-024. Office of Pesticides and Toxic Substances Washington, DC 20460.

2. 40 CFR, Part 763, Asbestos Hazard Emergency Response Act

3. 40 CFR, Part 763, Asbestos School Hazard Abatement Reauthorization Act

4. 29 CFR Part 1926.1101 Asbestos

APPENDIX

A. Physical and Hazard Assessment Summary Table for Ceiling Materials

B. Physical and Hazard Assessment Summary Table for Wall Materials

C. Physical and Hazard Assessment Summary Table for Floor Materials

D. Physical and Hazard Assessment Summary Table for Miscellaneous Materials

E. Physical and Hazard Assessment Summary Table for Thermal System Insulation Materials

F. Supplemental Fifth Floor Bulk Sample Table

If you have any questions or comments regarding this reassessment report, please do not hesitate to call.

Sincerely, Durbin Environmental Consultants, Inc.

Sellers C. Carmack Sellers C. Carmack Vice President

Michael F. Durbin, CIH Michael F. Durbin, CIH President

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APPENDIX A

PHYSICAL AND HAZARD ASSESSMENT SUMMARY FOR CEILING MATERIALS

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APPENDIX B

PHYSICAL AND HAZARD ASSESSMENT SUMMARY FOR WALL MATERIALS

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APPENDIX C

PHYSICAL AND HAZARD ASSESSMENT SUMMARY FOR FLOOR MATERIALS

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APPENDIX D

PHYSICAL AND HAZARD ASSESSMENT SUMMARY FOR MISCELLANEOUS MATERIALS

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APPENDIX E

PHYSICAL AND HAZARD ASSESSMENT SUMMARY FOR THERMAL SYSTEM

INSULATION MATERIALS

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APPENDIX F

SUPPLEMENTAL FIFTH FLOOR BULK SAMPLE TABLE

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