BOD Appendix A ACM Survey Report.pdf

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This federal contract opportunity solicitation seeks construction services for infrastructure upgrades at a Veterans Affairs health care facility in Fargo, North Dakota. The solicitation includes demolition, new construction, various trade works, asbestos abatement, and upgrades to the entire campus information technology infrastructure to current VA and industry standards while minimizing downtimes. The solicitation was issued by the Department of Veterans Affairs Technology Acquisition Center Austin for project number 437-21-205 under solicitation number 36C77622B0030. The construction work shall be completed in accordance with specifications, drawings, codes, and other requirements.

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Limited Pre-Renovation Asbestos and Lead-Based Paint Survey

Project No. 437-21-205EHRM Infrastructure Upgrades Fargo Veteran Administration Healthcare System

2101 Elm Street North Fargo, Cass County, North Dakota 58102

March 18, 2022 Terracon Project No. M1217071

Appendix A from the Basis of Design

Prepared for:

Bancroft Architects + Engineers

Northbrook, IL

Prepared by:

Terracon Consultants, Inc.

West Fargo, North Dakota dflook Text Box

APPENDIX A

Terracon Consultants Inc. 860 9th St. NE, Unit K West Fargo, ND 58078

P 701-282-9633 F 701-282-9635 terracon.com

March 18, 2022

Bancroft Architects + Engineers

700 Nicholas Blvd., Suite 300

Northbrook, IL 60007

Attn: Mr. John E. Robbins, AIA, NCARB

P: (847)-952-9362

E: jrobbins@bancroft-ae.com

Re: Limited Pre-Renovation Asbestos and Lead-Based Paint Survey

Project No. 437-21-205EHRM Infrastructure Upgrades

Fargo Veteran Administration Healthcare System

2101 Elm Street North

Fargo, Cass County, North Dakota 58102

Terracon Project No. M1217071

Dear Mr. Robbins, Terracon Consultants, Inc. (Terracon) is pleased to submit this report to Bancroft Architects +

Engineers (Client). This report presents the results of a limited asbestos and lead containing paint survey performed at 2101 Elm Street North in Fargo, North Dakota from September 14 through

September 16, November 17, 2021, January 20 through 21, 2022, and February 9, 2022. The survey was conducted in accordance with Terracon Proposal PM1217071 dated June 9, 2021.

Asbestos-containing materials (ACM) were identified in the samples collected from the subject buildings. Please refer to the attached report for details.

Terracon appreciates the opportunity to provide this service to Bancroft Architects + Engineers. If you have any questions regarding this report, or if you need assistance with development of asbestos abatement specifications, project oversight, or air monitoring, please contact the undersigned at 701-792-2620.

Sincerely, Terracon Consultants, Inc.

Jon Hammer Mike Willey

Staff Scientist Authorized Project Reviewer i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

1.2 Reliance

1.3 Standard of Care

2.0 PROJECT DESCRIPTION

2.1 Building Description

3.0 SCOPE OF SERVICES

3.1 Asbestos Survey

3.2 Sampling for Lead in Paints and Coatings

4.0 REGULATORY REVIEW

4.1 Asbestos

4.2 Lead-Based Paints or Coatings

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Survey Findings

5.2 Lead-Based Paint Survey Findings

5.3 Additional Services

6.0 GENERAL REPORTING LIMITATIONS

APPENDIX A TABLE 1: IDENTIFIED ASBESTOS-CONTAINING MATERIALS BY HA

TABLE 2: IDENTIFIED LEAD-BASED PAINT

TABLE 3: ASBESTOS SURVEY SAMPLE SUMMARY BY HA

TABLE 4: PAINTED SURFACE SAMPLE SUMMARY

APPENDIX B IDENTIFIED ASBESTOS AND LEAD SAMPLE LOCATION EXHIBITS

SAMPLE LOCATION EXHIBITS

APPENDIX C PHOTO LOG

APPENDIX D LABORATORY ANALYTICAL DATA

APPENDIX E LICENSES AND CERTIFICATIONS

Responsive ■ Resourceful ■ Reliable 1

LIMITED PRE-RENOVATION ASBESTOS AND LEAD-BASED PAINT

SURVEY

PROJECT NO. 437-21-205 EHRM INFRASTRUCTURE UPGRADE

FARGO VETERAN ADMINISTRATION HEALTHCARE SYSTEM

FARGO, CASS COUNTY, NORTH DAKOTA 58102

TERRACON PROJECT NO. M1217071

MARCH 18, 2022

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) was retained by Bancroft Architects + Engineers (Client) to conduct a Limited Pre-Renovation Asbestos and Lead-Based Paint Survey (Survey) and to prepare this report (Survey Report) for portions of the Veteran Administration (VA) Main Hospital buildings

1, 9, and 46 including buildings 3, 10-13, 30, 40, 51, 52, and 56 (Buildings) with a main address of

2101 Elm Street North, Fargo, North Dakota 58102 (Property).

The Survey was conducted from September 14 through September 16, November 17, 2021, January 20 through 21, 2022, and February 9, 2022 by AHERA1 accredited and State of North

Dakota certified asbestos inspectors and a State of North Dakota lead paint inspector in general accordance with Terracon Proposal No. PM1217071 dated June 9, 2021. Copies of their inspector certificates are included in Appendix E.

1.1 Project Objective

The objective of the Survey Report is to identify the presence, quantity and location of asbestos-containing materials (ACM) and locations of lead-based paint (LBP) in coatings on building components or substrates in client-designated areas of proposed infrastructure upgrades at the time of the field assessment, subject to the stated reporting and sampling limitations.

1.2 Reliance

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

1 AHERA = Asbestos Hazard Emergency Response Act

Limited Asbestos and Lead-Containing Paint Survey

Project No. 437-21-205 EHRM Infrastructure Upgrade ■ Fargo, ND

March 18, 2022 ■ Project No. M1217071

Responsive ■ Resourceful ■ Reliable 2

1.3 Standard of Care

This Survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the date on which this survey was performed and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by the Client for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

2.0 PROJECT DESCRIPTION

Terracon understands the Survey was requested due to planned renovation activities for IT infrastructure upgrades which require management, documentation and communication of various building materials, and coatings within the Buildings on the Property. The project objective is based upon information required to communicate for compliance with the following summarized requirements:

▪ The Environmental Protection Agency (EPA) 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 requires that potentially regulated ACM (RACM) be identified, classified and quantified prior to planned disturbances or demolition activities.

▪ The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1101 Subpart

Z, Asbestos; regulates asbestos exposure during renovation/demolition activities and requires building and facility owners to determine the presence, location and quantity of

Asbestos Containing Materials (ACM) and/or Presumed ACM (PACM) prior to renovation/demolition activities.

▪ The Asbestos Hazard Emergency Response Act (AHERA), which is referenced in the above regulations, and its regulations requires institutions to inspect for ACM and prepare management plans to take action to reduce asbestos hazards in schools. The

Asbestos School Hazard Abatement Reauthorization Act (ASHARA) expand the accreditation requirements to cover asbestos abatement projects in all public and commercial buildings in addition to schools. It is understood that the VA Hospital follows

AHERA/ASHARA requirements regarding conducting asbestos inspections prior to renovation activities and then acting upon hazards identified.

Responsive ■ Resourceful ■ Reliable 3

▪ OSHA 29 CFR 1926.62 Subpart D, Lead, applies to all renovation/demolition where an employee may be occupationally exposed to lead. The employer shall communicate information concerning lead hazards and communicating information concerning hazards and appropriate protective measures to employees including training.

2.1 Building Description

The locations were generally limited to proposed areas of infrastructure upgrades. Building descriptions and general construction information for the structures assessed on the Property include:

Main Hospital (Buildings 1, 9, and 46)

Building Use: Hospital Occupancy Status: Occupied

Date of Construction:

1928 (Bldg 1)

1945 (Bldg 9)

1985 (Bldg 46)

Renovation Dates: Multiple

No. of Floors 5 Building Square Footage: 498,000

Main Structure:

Poured concrete foundation or slab-on-grade foundation, with concrete masonry unit (CMU) walls, brick and mortar facade with bar joist and metal decking

Exterior Finishes: CMU, brick and mortar

Interior Finishes:

Sheetrock and/or plaster walls & ceilings, carpet, vinyl and/or ceramic tile flooring, suspended ceilings

Roofing System: Built-up asphalt or rubber membrane (with ballast) or EPDM

Building 3

Building Use: Office Space Occupancy Status: Occupied

Date of Construction: 1930 Addition Dates: N/A

No. of Floors 2 Building Square Footage: 2,800

Main Structure: Steel frame

Interior Finishes: Sheetrock walls, carpet and vinyl flooring, suspended ceilings

Responsive ■ Resourceful ■ Reliable 4

Building 10

Building Use: Boiler Plant Occupancy Status: Not occupied

Date of Construction: 1945 Addition Dates: N/A

No. of Floors 2 Building Square Footage: 1945

Main Structure: Concrete, steel frame

Interior Finishes: Sheetrock walls, vinyl flooring, poured concrete ceiling

Building 11

Building Use: Garage Occupancy Status: Occupied

Date of Construction: 1945 Addition Dates: Unknown

No. of Floors 1 Building Square Footage: 4,400

Main Structure: Brick and CMU

Interior Finishes: Brick walls, poured concrete ceilings

Building 12

Building Use: Warehouse Occupancy Status: Occupied

Date of Construction: 1945 Addition Dates: N/A

No. of Floors 1 Building Square Footage: 6,300

Main Structure: CMU/brick and mortar

Interior Finishes: Sheetrock walls and ceilings

Building 13

Building Use: Laundry Occupancy Status: Occupied

Date of Construction: 1945 Addition Dates: N/A

No. of Floors 1 Building Square Footage: 12,000

Main Structure: CMU/Brick and mortar

Interior Finishes: Sheetrock and plaster walls, vinyl flooring, suspended ceilings

Building 30

Date of Construction: 1955 Addition Dates: N/A

No. of Floors 1 Building Square Footage: 4,900

Main Structure: CMU/Brick and mortar

Responsive ■ Resourceful ■ Reliable 5

Building 40

Building Use: Office Space Occupancy Status: Occupied

Date of Construction: 1993 Addition Dates: N/A

No. of Floors 2 Building Square Footage: 22,000

Building 51

Date of Construction: 3,900 Addition Dates: N/A

No. of Floors 1 Building Square Footage: 2011

Interior Finishes: Sheetrock walls, carpet and vinyl flooring, suspended ceilings

Building 52

Date of Construction: 2011 Addition Dates: N/A

No. of Floors 2 Building Square Footage: 4,200

Interior Finishes: Sheetrock walls; carpet, linoleum and vinyl flooring, suspended ceilings

Building 56

Building Use: Chiller Building Occupancy Status: Occupied

Date of Construction: 2018 Addition Dates: N/A

No. of Floors 1 Building Square Footage: 2,100

Main Structure: Steel

Interior Finishes: Metal floor, walls and ceiling

3.0 SCOPE OF SERVICES

3.1 Asbestos Survey

The Survey was conducted by State of North Dakota accredited asbestos inspectors in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, the

Asbestos Hazard Emergency Response Act (AHERA). A summary of survey activities is provided below.

Responsive ■ Resourceful ■ Reliable 6

3.1.1 Visual Assessment

Survey activities were initiated with visual observation of the interior of the buildings to identify accessible homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application.

3.1.2 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 EPA as a material that when dry, may be crumbled, pulverized or reduced to powder by hand pressure, including previously non-friable material when the material becomes damaged to the extent that when dry it may be crumbled, pulverized or reduced to powder by hand pressure. Friability was assessed by physically touching suspect materials. The materials were classified into the three following condition categories:

▪ Not Damaged condition (ND); material with less than or equal to one percent damage or deterioration for the subject surface;

▪ Damaged condition (D); materials which greater than one percent although less than ten percent distributed damage or less than twenty five percent localized damage.

Damage is determined when deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage;

significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM; or damage to jacketing or coatings; and

▪ Significantly Damaged condition (SD); materials where damage impacts at least ten percent of a localized subject surface area or if the damage is evenly distributed representing an area of at least twenty-five percent of the subject surface area.

3.1.3 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Random samples of suspect materials were collected in each HA. 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 using an indelible marker. 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.

Responsive ■ Resourceful ■ Reliable 7

Terracon collected 265 bulk samples of suspect ACM from the Property that were separated by the analytical laboratory into individual layers for analysis.

3.1.4 Sample Analysis

Bulk samples were submitted under chain of custody to EMSL Analytical, Inc. of Tampa, Florida, Indianapolis, Indiana, and New Hope, Minnesota 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. Samples with asbestos concentrations of 10% or less were reanalyzed by the 400-point count method per USEPA Method 600/R-93/116. The 400-point count has a detection limit of

0.25%, which increases the accuracy and precision of the asbestos concentration. EMSL Analytical, Inc. of Tampa, Florida is accredited under the National Voluntary Laboratory Accreditation Program

(NVLAP) Accreditation No. 600215-0; EMSL Analytical, Inc. of Indianapolis, Indiana is accredited under NVLAP Accreditation No. 200188-0; EMSL Analytical, Inc. of New Hope, Minnesota is accredited under NVLAP Accreditation No. 2000019-0.

The percentage of asbestos, where applicable, was determined by microscopic visual estimation or point counting. The NDDEQ, OSHA and EPA define ACM as a material which contains greater than one percent asbestos by qualitative or quantitative analysis techniques. The EPA NESHAP requires quantitative analysis, commonly referred to as a “point count”, for all qualitative analysis results when asbestos is detected in concentrations less than one to ten percent. However, under common practice, qualitative results greater than three and less than ten percent are often accepted to be

ACM.

3.2 Sampling for Lead in Paints and Coatings

The Survey was conducted by State of North Dakota accredited lead risk assessor with the intent of identifying lead in painted/coated building materials that might be subject to processing for beneficial reuse, and for providing information useful in the communication of lead hazards to workers and other occupants. A summary of survey activities is provided below.

3.2.1 Visual Assessment

Survey activities were initiated with visual observation of the areas of renovation in the Buildings to identify accessible homogeneous areas of coated building components. Homogenous coatings were defined as areas of similar coating/painting history, such as color, building component, and location.

Responsive ■ Resourceful ■ Reliable 8

3.2.2 Physical Assessment

A physical assessment of each homogeneous coating was conducted to assess the condition of the coating, and its potential for creating lead dust. The coatings were classified into the three following condition categories:

▪ Intact condition; surface is intact;

▪ Fair condition; damage/deterioration limited to less than 10 square feet on large surface exterior components or 2 square feet on large surface interior components, or less than

10 percent of small surface interior/exterior components; and

▪ Poor condition; damage/deterioration greater than 10 square feet on large surface exterior components or 2 square feet on large surface interior components, or greater than 10 percent of small surface interior/exterior components.

3.2.3 Sample Analysis

Coating materials were analyzed using an Olympus Vanta C-series multi-element spectrum analyzer, Serial No. 806314. The Olympus Vanta C-series is a field portable XRF spectrum analyzer capable of identifying lead concentrations in coatings and paint, which are expressed in mg/cm2.

4.0 REGULATORY REVIEW

4.1 Asbestos

The following are regulations impacting the methods and findings of this Survey. It is not a comprehensive list of all asbestos regulations.

4.1.1 Federal Asbestos Regulations

The asbestos portion of NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. All friable ACM is considered regulated asbestos-containing material (RACM).

The asbestos NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or

Category II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II non-friable ACM that has become friable, will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor

Responsive ■ Resourceful ■ Reliable 9 covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACMs are all non-friable ACMs that are not Category I non-friable ACM.

In their interpretation of layered drywall systems (joint compound, tape, wall board substrates), the

EPA has ruled that unless the entire wall system contains more than 1% friable or potentially friable

ACM (verified by Point Count analysis), then the total wall system is not considered RACM and is not subject to NESHAP regulations. However, OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities (including demolition) be protected from asbestos fibers in excess of the permissible exposure limit of 0.1 fibers/cc air, regardless of the source of the asbestos fibers.

4.1.2 State Asbestos Regulations

The North Dakota Asbestos-Waste Management Program under the North Dakota Department of Environmental Quality (NDDEQ) enforces the asbestos NESHAP as adopted by reference in

North Dakota Administrative Code Chapter 74:36:08. The owner or operator must provide

NDDEQ with written notification at least 10 working days prior to the demolition of any structure, even if asbestos is not present. In cases of renovation, no notification is required if the inspection determines that there are less than 160 square feet or 260 linear feet of regulated ACM (RACM) present.

4.2 Lead-Based Paints or Coatings

Under the US EPA Hazard Standards for Lead in Paint, Dust and Soil (TSCA Section 403), lead-based paint means paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter (1.0 mg/cm²) or more than 0.5 percent by weight. This rule establishes standards to help property owners, lead paint professionals and government agencies identify lead hazards in residential paint, dust and soil. The rule establishes standards for lead-based paint hazards (including hazards from lead in dust and soil) in most pre-1978 housing and child-occupied facilities.

OSHA LBP Rules

OSHA 29 CFR 1926.62 Subpart D, Lead, applies to all renovation/demolition where an employee may be occupationally exposed to lead. The employer shall communicate information concerning lead hazards and communicating information concerning hazards and appropriate protective measures to employees, including training. Where lead is present, it should be assumed that workers will be exposed to lead above the action level and personal protective measures (based on the type of disturbance) should be implemented until an exposure assessment is completed.

State of North Dakota LBP Rules

Lead is regulated by the USEPA, HUD, NDDEQ, and OSHA. The USEPA and NDDEQ regulate lead use, removal, and disposal, and OSHA regulates lead exposure to workers. USEPA and HUD

Responsive ■ Resourceful ■ Reliable 10 regulate lead present in residential and child-occupied facilities. The USEPA defines LBP as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 milligrams per square centimeter (mg/cm2), 5,000 milligrams per kilogram (mg/kg), or 0.5% by dry weight as determined by laboratory analysis. The OSHA standard does not define the amount of lead in paint that constitutes lead-based paint.

The USEPA regulates disposal of hazardous materials. The USEPA has stated that components removed with intact LBP that is not delaminating from the substrate may be disposed as general demolition debris. If the LBP is stripped from components, or if it is delaminating from the substrate, the waste may be subject to hazardous waste rules [i.e., Toxicity Characteristics Leaching

Procedure (TCLP)].

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Survey Findings

Suspect homogeneous materials identified and subsequently sampled for asbestos content during the Survey are listed in the Chain of Custody associated with the laboratory analytical report in

Appendix D. Identified asbestos-containing materials are shown on Table 1: Identified Asbestos-

Containing Materials by HA in Appendix A. Suspect materials identified for each area of the

Buildings are shown on Table 2: Asbestos Survey Sample Summary by Homogenous Area.

Drawings showing the locations of suspect ACM samples collected are shown in Appendix B.

5.1.1 Asbestos Materials Summary Table

The following table below lists all identified materials requiring management due to asbestos, including confirmed asbestos-containing materials (ACM – materials containing greater than one percent asbestos), materials assumed to be ACM but were not sampled due to functional, aesthetic, or safety concerns, and materials containing less than one percent asbestos (which may be managed differently than ACM).

Responsive ■ Resourceful ■ Reliable 11

HA

No.

Material

Description

Material

Location

Percent/Type

Asbestos

NESHAP

Category Condition

Estimate d

Quantity2

Magnesia pipe insulation associated with 8” O.D.

pipe

Main building, room BD-02

5% chrysotile

12% crocidolite

RACM

Not

Damaged

15 LF

Black mastic associated with multicolored carpet

Main building, room 3B-25

PC3 4.25%

chrysotile

Category I non-friable /

RACM

Not

Damaged

196 SF

The asbestos-containing pipe insulation is considered friable ACM or RACM and if in a damaged condition or disturbed by renovation activities must be removed prior to renovation or demolition activities.

If the above listed Category I nonfriable ACM will be subjected to drilling, sanding, grinding, cutting, or abrading, making it friable or RACM, it must be removed in accordance with applicable federal, state, and local regulations prior to disturbance by an asbestos abatement contractor. If disposed at the local landfill, the landfill must receive approval from the NDDEQ.

For any materials in good condition and not impacted by renovation or demolition plans, it is recommended by the EPA that these materials be managed in-place with implementation of an operations and maintenance plan.

If additional but unsampled suspect ACMs are revealed during renovation or demolition activities, the material(s) must be assumed to contain asbestos and treated as such unless sampled by an accredited inspector and laboratory analysis determines otherwise.

5.1.2 Asbestos-Containing Material Classifications

As discussed in Section 4.1, ACMs identified during the Survey were classified as RACM (“friable”), Category I non-friable, or Category II non-friable ACM. These categories are shown on Table 2 in

Appendix A for each material. The classifications indicated are based on the material condition at the time of the survey. Material condition can be subject to change due to factors such as

2 Estimated quantities are based on cursory field observations, and actual quantities may vary significantly, especially if

ACM are present in hidden and/or inaccessible areas not evaluated as part of this survey. SF = square feet, LF = linear feet 3 PC = Point Counted

Responsive ■ Resourceful ■ Reliable 12 mechanical damage (impacts, grinding, sanding, crushing, etc.), moisture damage, weathering

(sun) damage, etc., which may affect material classification.

5.1.3 Asbestos Management Recommendations

Asbestos was detected in samples of suspect materials sampled during the Survey. Refer to Table

1 in Appendix A for information regarding the locations and quantities of suspect ACMs assessed.

Asbestos materials identified in Section 5.1 will require management prior to any demolition, renovation, or operations and maintenance work that might disturb identified or assumed asbestos materials. If previously inaccessible suspected ACM is discovered during renovation/demolition activities, disturbance work should immediately stop, until representative samples can be collected by a licensed asbestos building inspector and laboratory results are available to render a determination regarding asbestos content within the material discovered. Supplemental inspection may be required by the EPA/NDDEQ for inaccessible areas or locations outside of the survey area for inspection and sampling, as identified in Section 6.0 in this Survey Report.

This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. For renovation or demolition projects Terracon recommends a North Dakota accredited asbestos

Project Designer be retained to prepare a project specific specification for the management and/or abatement of ACM identified in this Survey Report, in accordance with applicable regulatory requirements. Additionally, the disposition of non-friable ACMs should be assessed by a Project

Designer based on renovation or demolition plans, including specific considerations of potential for friability during renovation, demolition, and abatement, as well as disposal.

5.2 Lead-Based Paint Survey Findings

Terracon conducted limited lead paint testing of paint/coatings during the Survey of the Buildings targeting building components that might be impacted by renovation activities. Lead-based paint was identified during the Survey.

The following materials were identified as containing LBP:

Component / Substrate

Impacted Location/Functional Space Coating Description*

Building 10 – Boiler House

Door / Wood Bathroom Intact Brown Paint

Responsive ■ Resourceful ■ Reliable 13

The following materials were identified as containing LCP:

Component / Substrate

Impacted Location/Functional Space Coating Description*

Main Hospital

Plaster Main building, BD-02 Peach

Plaster Main building, 1C-99 Tan

GWB Main building, 2C-90 Tan

GWB Main building, 2A-24 Tan

GWB Main building, 2A-22A Tan

GWB Main, building, 2D-19 Tan

GWB Main building, 3C-96 Tan

Plaster Main building, 3B-23 Tan

Metal Main building, 4E-15A Tan

Building 12

Brick Building 12, IRM White

Metal Building 12, Break Room, door

Green

Building 10

Brick Building 10, Upper Mezzanine White

Building 11

Brick Building 11, Shop Tan

Plaster Building 11, Shop White

Plaster Building 11, HAC Blue

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

The above is not a comprehensive survey of all coated surfaces in the Buildings. Coatings on building components similar to identified lead-coated components should also be treated as lead

Responsive ■ Resourceful ■ Reliable 14 coatings unless specific testing results prove otherwise, regardless of surface color, as lead coating layers are often not the top (visible) layer.

Refer to Appendix B and Table 4 in Appendix A for additional information regarding the locations and results of the LBP test locations.

5.2.1 LBP Recommendations

Terracon recommends the project team review the planned renovation activities and communicate the results of the Survey for further determination if lead hazards will be impacted by individuals conducting the proposed renovation activities. These hazards including the appropriate protective measures shall be communicated to employees including training where applicable. Where lead is present, it should be assumed that workers will be exposed to lead above the action level and personal protective measures should be implemented until an exposure assessment is completed.

Lead safe work practices are required to be addressed during work at this construction site.

Additionally, Terracon recommends that prior to commencement of the job each employer shall establish and implement a written compliance program to achieve compliance with OSHA

Permissible Exposure Limits.

5.3 Additional Services

Terracon personnel accredited in asbestos abatement project design, management planning, inspection, and air monitoring, as well as lead remediation are available to assist with project design and risk assessment. We can help manage projects from start to finish, including development of project concepts, budgets, specifications, contractor bidding, contract management, project oversight and monitoring.

6.0 GENERAL REPORTING LIMITATIONS

The Survey was conducted utilizing limited destructive sampling techniques. Therefore, efforts were made to determine if multiple layers of materials were present (e.g., flooring), although limited to the extent of allowable access points with hand tools without affecting security, fire and life safety, slips, trips and/or fall hazards including unacceptable aesthetic or functional damage to building surfaces and materials, as per the judgment of the inspector at the time of the Survey. Therefore, suspect ACM may be present in concealed spaces, cavities, and plenums of the Building that were not inspected during the Survey. Rooms, areas, and spaces outside the Survey Area may include

ACM and suspect materials not addressed by the Survey. Additional inspection by an accredited asbestos inspector is required by EPA prior to demolition or renovation that would impact such materials.

TABLE 1: IDENTIFIED ASBESTOS-CONTAINING MATERIALS BY HA

TABLE 2: IDENTIFIED LEAD CONTAINING PAINT BY SAMPLE NUMBER

TABLE 3: ASBESTOS SURVEY SAMPLE SUMMARY BY HOMOGENEOUS AREA (HA)

TABLE 4: LCP SURVEY SAMPLE ANALYTICAL AND LOCATION SUMMARY

Responsive ■ Resourceful ■ Reliable

Project No. 437-21-205 EHRM Infrastructure Upgrades

Fargo VA Healthcare Systems

2101 Elm Street North

Fargo, Cass County, North Dakota 58078

Table 1 – Identified Asbestos-Containing Materials by Homogenous Area (HA)

HA No. Material Description Location Percent and Type

Asbestos1

NESHAP

Category Condition

OSHA

Classification

Estimated

Quantity2

Magnesia pipe insulation associated with 8” O.D. pipe

Main building, room BD-02

5% chrysotile

12% crocidolite

RACM

Not

Damaged

TSI 15 LF

Black mastic associated with multicolored carpet

Main building, room 3B-25 5% chrysotile

Category I non-friable /

RACM

Not

Miscellaneous 196 SF

Table 2 – Identified Lead-Based Paint

Sample Nos. Location Paint Color Paint Substrate Surface Condition Results (mg/cm2)

165-168 Bathroom, door Brown Wood Intact 3.71215 - >5.0

1 Percent and type asbestos - this column contains both the analytical result of the sample with the highest concentration of asbestos detected in the samples that make up the HA and the types of asbestos identified.

2 Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if ACMs are present in hidden and/or inaccessible areas not evaluated as part of this survey. SF = square feet, LF = linear feet

Project No. 437-21-205 EHRM Infrastructure Upgrade

Fargo, ND ■ Project No. M1217071

Table 3 – Asbestos Survey Sample Summary by Homogeneous Area (HA)

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

1 Base cove 1-MG3-1 Room 111 None detected Not applicable

Not

Damaged Miscellaneous

1 Tan mastic 1-MG3-1 Room 111 None detected Not applicable

Not

Damaged Miscellaneous

1 Gray base cove 1-MG3-2 Room 110 None detected Not applicable

Not

Damaged Miscellaneous

1 Tan mastic 1-MG3-2 Room 110 None detected Not applicable

Not

Damaged Miscellaneous

1 Brown base cove 1-MG3-3 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

1 Yellow/beige mastic 1-MG3-3 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

2 Red paste HA2-FP5-4 Room 111 None detected Not applicable

Not

Damaged Miscellaneous

2 Red paste HA2-FP5-5 Room 110 None detected Not applicable

Not

Damaged Miscellaneous

2 Red paste HA2-FP5-6 Room 211 None detected Not applicable

Not

Miscellaneous

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

Ceiling drywall complex

– Drywall HA3-WB1-7 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– white joint compound HA3-WB1-7 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– brown/white drywall HA3-WB1-8 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– white joint compound HA3-WB1-8 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– brown/white drywall HA3-WB1-9 Room 202 None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– white joint compound HA3-WB1-9 Room 202 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – brown/white drywall HA4-WB1-10 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA4-WB1-10 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – brown/white drywall HA4-WB1-11 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA4-WB1-11 Room 111 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white/brown drywall HA4-WB1-12 Room 211 None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA4-WB1-12 Room 211 None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ Ceiling tile with pinholes HA5-CT4-13 Room 102 None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ Ceiling tile with pinholes HA5-CT4-14 Room 102 None detected

Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

2’x4’ Ceiling tile with pinholes HA5-CT4-15 Room 202 None detected

Not applicable

Not

Damaged Miscellaneous

Brown/gray/green carpet HA6-MG7-16 Room 102 None detected

Not applicable

Not

Damaged Miscellaneous

6 Yellow glue HA6-MG7-16 Room 102 None detected Not applicable

Not

Damaged Miscellaneous

Brown/gray/green carpet HA6-MG7-17 Room 202 None detected

Not applicable

Not

Damaged Miscellaneous

6 Yellow glue HA6-MG7-17 Room 202 None detected Not applicable

Not

Damaged Miscellaneous

Brown/gray/green carpet HA6-MG7-18 Room 202 None detected

Not applicable

Not

Damaged Miscellaneous

6 Yellow glue HA6-MG7-18 Room 202 None detected Not applicable

Not

Damaged Miscellaneous

7 Spotted linoleum HA7-FC5-19 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

7 Yellow mastic HA7-FC5-19 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

7 Spotted linoleum HA7-FC5-20 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

7 Yellow mastic HA7-FC5-20 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

7 Spotted linoleum HA7-FC5-21 Room 211 None detected Not applicable

Not

Damaged Miscellaneous

7 Yellow mastic HA7-FC5-21 Room 211 None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

Wall drywall complex – brown/white drywall HA8-WB1-22 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA8-WB1-22 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – brown/white drywall HA8-WB1-23 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA8-WB1-23 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – brown/white drywall HA8-WB1-24 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Wall drywall complex – white joint compound HA8-WB1-24 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– brown/white drywall HA8-WB1-25 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– white joint compound HA8-WB1-25 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– brown/white drywall HA8-WB1-26 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– white joint compound HA8-WB1-26 IRM room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– brown/white drywall HA9-WB1-27 IRM Room None detected

Not applicable

Not

Damaged Miscellaneous

Ceiling drywall complex

– joint compound HA9-WB1-27 IRM Room None detected

Not applicable

Not

Damaged Miscellaneous

10 Gray window caulk HA10-CA1-28 IRM room None detected Not applicable

Not

Damaged Miscellaneous

10 Gray window caulk HA10-CA1-29 IRM room None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

10 Gray window caulk HA10-CA1-30 IRM room None detected Not applicable

Not

Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

11 9”x9” White floor tile HA11-FT1-31 Office None detected Not applicable

Not

Damaged Miscellaneous

11 Yellow mastic HA11-FT1-31 Office None detected Not applicable

Not

Damaged Miscellaneous

11 9”x9” White floor tile HA11-FT1-32 Office None detected Not applicable

Not

Damaged Miscellaneous

11 Yellow mastic HA11-FT1-32 Office None detected Not applicable

Not

Damaged Miscellaneous

11 9”x9” White floor tile HA11-FT1-33 Office None detected Not applicable

Not

Damaged Miscellaneous

11 Yellow mastic HA11-FT1-33 Office None detected Not applicable

Not

Damaged Miscellaneous

2’x4’ White ceiling tile with pinholes HA12-CT4-34 Office None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ White ceiling tile with pinholes HA12-CT4-35 Office None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ White ceiling tile with pinholes HA12-CT4-36 Office None detected

Not applicable

Not

Damaged Miscellaneous

13 Gray base cove HA13-MG3-37 Office None detected Not applicable

Not

Damaged Miscellaneous

13 Yellow mastic HA13-MG3-37 Office None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

13 Gray base cove HA13-MG3-38 Office None detected Not applicable

Not

Damaged Miscellaneous

13 Yellow mastic HA13-MG3-38 Office None detected Not applicable

Not

Damaged Miscellaneous

13 Gray base cove HA13-MG3-39 Office None detected Not applicable

Not

Damaged Miscellaneous

13 Yellow mastic HA13-MG3-39 Office None detected Not applicable

Not

Damaged Miscellaneous

Front window – gray caulk HA14-CA1-40 Office None detected

Not applicable

Not

Damaged Miscellaneous

Front window – gray caulk HA14-CA1-41 Office None detected

Not applicable

Not

Damaged Miscellaneous

Front window - gray caulk HA14-CA1-42 Office None detected

Not applicable

Not

Damaged Miscellaneous

Back window – gray caulk HA15-CA1-43 Office None detected

Not applicable

Not

Damaged Miscellaneous

Back window – gray caulk HA15-CA1-44 Office None detected

Not applicable

Not

Damaged Miscellaneous

Back window – gray caulk HA15-CA1-45 Office None detected

Not applicable

Not

Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

16 Brown cove base HA16-MG3-46 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

16 Yellow mastic HA16-MG3-46 Room 1025 None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

16 Brown cove base HA16-MG3-47 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

16 Yellow mastic HA16-MG3-47 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

16 Gray cove base HA16-MG3-48 Room 1026 None detected Not applicable

Not

Damaged Miscellaneous

16 Yellow mastic HA16-MG3-48 Room 1026 None detected Not applicable

Not

Damaged Miscellaneous

9”x9” white speckled floor tile HA17-FT1-49 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

17 Yellow mastic HA17-FT1-49 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

9”x9” white speckled floor tile HA17-FT1-50 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

17 Yellow mastic HA17-FT1-50 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

9”x9” white speckled floor tile HA17-FT1-51 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

17 Yellow mastic HA17-FT1-51 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

18 Red paste HA18-CA1-52 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

18 Red paste HA18-CA1-53 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

18 Red paste HA18-CA1-54 Room 1025 None detected Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/gray wallboard HA19-WB1-55 Room 1025 None detected

Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

Wallboard complex – white joint compound HA19-WB1-55 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/gray wallboard HA19-WB1-56 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – white joint compound HA19-WB1-56 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/gray wallboard HA19-WB1-57 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – white joint compound HA19-WB1-57 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ White ceiling tile with pinholes HA20-CT4-58 Room 1025 None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ White ceiling tile with pinholes HA20-CT4-59 Room 1026 None detected

Not applicable

Not

Damaged Miscellaneous

2’x4’ white ceiling tile with pinholes HA20-CT4-60 Room 1026 None detected

Not applicable

Not

Damaged Miscellaneous

Brown/green/beige carpet HA21-MG7-61 Room 1026 None detected

Not applicable

Not

Damaged Miscellaneous

21 Yellow glue HA21-MG7-61 Room 1026 None detected Not applicable

Not

Damaged Miscellaneous

Brown/green/beige carpet HA21-MG7-62 Room 1026 None detected

Not applicable

Not

Damaged Miscellaneous

21 Yellow glue HA21-MG7-62 Room 1026 None detected Not applicable

Not

Damaged Miscellaneous

Brown/green/beige carpet HA21-MG7-63 Room 1026 None detected

Not applicable

Not

Damaged Miscellaneous

21 Yellow glue HA21-MG7-63 Room 1026 None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

9”x9” off white floor tile under carpet HA22-FT1-64 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

22 Yellow mastic HA22-FT1-64 Open office area None detected Not applicable

Not

Damaged Miscellaneous

9”x9” off white floor tile under carpet HA22-FT1-65 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

22 Yellow mastic HA22-FT1-65 Open office area None detected Not applicable

Not

Damaged Miscellaneous

9”x9” off white floor tile under carpet HA22-FT1-66 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

22 Yellow mastic HA22-FT1-66 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Tan/black/beige carpet HA23-MG7-67 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Yellow/green glue HA23-MG7-67 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Tan/black/beige carpet HA23-MG7-68 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Yellow/green glue HA23-MG7-68 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Tan/black/beige carpet HA23-MG7-69 Open office area None detected Not applicable

Not

Damaged Miscellaneous

23 Yellow/green glue HA23-MG7-69 Open office area None detected Not applicable

Not

Damaged Miscellaneous

24 Brown cove base HA24-MG3-70 Open office area None detected Not applicable

Not

Damaged Miscellaneous

24 Yellow mastic HA24-MG3-70 Open office area None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

24 Brown cove base HA24-MG3-71 Open office area None detected Not applicable

Not

Damaged Miscellaneous

24 Yellow mastic HA24-MG3-71 Open office area None detected Not applicable

Not

Damaged Miscellaneous

24 Brown cove base HA24-MG3-72 Open office area None detected Not applicable

Not

Damaged Miscellaneous

24 Yellow mastic HA24-MG3-72 Open office area None detected Not applicable

Not

Damaged Miscellaneous

25 Ceiling insulation HA25-AS5-73 Open office area None detected Not applicable

Not

Damaged Miscellaneous

25 Ceiling insulation HA25-AS5-74 Open office area None detected Not applicable

Not

Damaged Miscellaneous

25 Ceiling insulation HA25-AS5-75 Open office area None detected Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/white wallboard HA26-WB1-76 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – white joint compound HA26-WB1-76 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/white wallboard HA26-WB1-77 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – white joint compound HA26-WB1-77 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – brown/white wallboard HA26-WB1-78 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

Wallboard complex – white joint compound HA26-WB1-78 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

2’x2’ White ceiling tile with pinholes HA27-CT3-79 Open office area None detected

Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

2’x2’ white ceiling tile with pinholes HA27-CT3-80 Open office area None detected

Not applicable

Not

Damaged Miscellaneous

2’x2’ white ceiling tile with pinholes HA27-CT3-81 Open office area None detected

Not applicable

Not

Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

9”x9” white speckled floor tile HA28-FT1-82 Toilet None detected

Not applicable

Not

Damaged Miscellaneous

28 Yellow mastic HA28-FT1-82 Toilet None detected Not applicable

Not

Damaged Miscellaneous

9”x9” white speckled floor tile HA28-FT1-83 Toilet None detected

Not applicable

Not

Damaged Miscellaneous

28 Yellow mastic FA28-FT1-83 Toilet None detected Not applicable

Not

Damaged Miscellaneous

9”x9” white speckled floor tile HA28-FT1-84 Toilet None detected

Not applicable

Not

Damaged Miscellaneous

28 Yellow mastic HA28-FT1-84 Toilet None detected Not applicable

Not

Damaged Miscellaneous

29 Black base cove HA29-MG3-85 Toilet None detected Not applicable

Not

Damaged Miscellaneous

29 Yellow mastic HA29-MG3-85 Toilet None detected Not applicable

Not

Damaged Miscellaneous

29 Black base cove HA29-MG3-86 Toilet None detected Not applicable

Not

Damaged Miscellaneous

29 Yellow mastic HA29-MG3-86 Room 1025 None detected Not applicable

Not

HA No. Material Description Sample

Number Sample Location Lab Results

NESHAP

Category Condition

OSHA

Classification

29 Black base…

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