Building 17 Survey Report.pdf

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Y1DA--Abatement and Clean-up VA Bldgs. 14 & 17 Doris Miller VAMC Waco, TX
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This document is a limited asbestos survey and lead-containing paint sampling report for Building 17 at the Doris Miller Department of VA Medical Center in Waco, Texas. The survey identified asbestos-containing materials in the exterior moisture barrier, resilient floor tile/mastic, and sink coating, which were assessed as non-friable and in good condition. The report provides the classification, condition, and approximate quantities of the confirmed asbestos-containing materials. It also identified nine paint coatings that contain lead in concentrations exceeding 5,000 parts per million, which are considered lead-based paint. Seven additional paint coatings contained detectable lead levels below 5,000 ppm. The report recommends managing the asbestos-containing materials in-place or removing them prior to any renovation or demolition activities, and provides an overview of the regulatory requirements for asbestos and lead-based paint.

The related federal contract opportunity is a solicitation (Solicitation Number 36C25724B0015) for the abatement and clean-up of VA Buildings 14 and 17 at the Doris Miller VA Medical Center in Waco, Texas. The solicitation is being issued by the Department of Veterans Affairs Veterans Health Administration Veterans Integrated Service Network 17.

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Limited Asbestos Survey and

Lead-Containing Paint Sampling Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

Waco, Texas

September 4, 2020

Terracon Project No. 96207499

Prepared for:

Central Texas Veterans Health Care System

Temple, Texas

Prepared by:

Terracon Consultants, Inc.

Austin, Texas

Terracon Consultants, Inc. 5307 Industrial Oaks Boulevard, Suite 160 Austin, Texas 78735

P (512) 442 1122 F (512) 442 1181 terracon.com

Central Texas Veterans Healthcare System

Safety Office (001-SIH)

1901 South 1st Street

Temple, Texas 76504

Attn: Mr. Peter Gilmore, MS, CIH, CSP, CHMM

P: (254) 742-4671

E: peter.gilmore1@va.gov

Re: Limited Asbestos Survey and Lead-Containing Paint Sampling

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive, Waco, Texas

Dear Mr. Gilmore:

The purpose of this report is to present the results of the limited asbestos survey and lead-containing paint sampling performed on August 27, 2020, at the above referenced site in Waco, Texas. This survey was conducted in general accordance with our proposal dated August 18, 2020. We understand that this survey was requested due to potential renovation activities.

Asbestos-containing exterior moisture barrier, resilient floor tile and mastic, and sink coating materials were identified. Please refer to the attached report for details.

Lead-based paint (greater than 5,000 ppm) was identified in nine (9) of the paint coatings. Seven (7) of the paint coatings sampled contain detectable levels of lead and four (4) paint coatings sampled contain levels of lead below the detection limit for the analysis run. Please refer to the attached report for details.

Terracon appreciates the opportunity to provide this service to the Central Texas Veterans Health Care

System. If you have any questions regarding this report, please contact the undersigned at (512) 442-1122.

Sincerely, Terracon Consultants, Inc.

Project Manager: Reviewed By:

Mitch Stogner Richard Ian Howes

Individual Asbestos Consultant / Individual Asbestos Consultant / Lead Inspector Lead Inspector TDSHS License Nos. 105648 / 2060879 TDSHS License Nos. 105406 / 2060584

Responsive ■ Resourceful ■ Reliable

TABLE OF CONTENTS

Page

1.0 INTRODUCTION

1.1 Project Objective

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND RECOMMENDATIONS

6.0 GENERAL COMMENTS

APPENDIX A ASBESTOS SURVEY SAMPLE SUMMARY

APPENDIX B CONFIRMED ASBESTOS-CONTAINING MATERIALS

APPENDIX C ASBESTOS LABORATORY ANALYTICAL REPORTS

APPENDIX D LEAD SAMPLE SUMMARY

APPENDIX E LEAD LABORATORY ANALYTICAL REPORTS

APPENDIX F LICENSES AND CERTIFICATIONS

APPENDIX G SAMPLE LOCATION MAP

Responsive ■ Resourceful ■ Reliable 1

LIMITED ASBESTOS SURVEY AND

LEAD-CONTAINING PAINT SAMPLING REPORT

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

Waco, Texas

1.0 INTRODUCTION

Terracon conducted a limited asbestos survey and lead-containing paint sampling of the former laundry facility (Building 17) at the Doris Miller Department of Veterans Affairs Medical Center campus located at 4800 Memorial Drive in Waco, Texas. The survey was conducted on August

27, 2020, by Mr. Richard Ian Howes, a State of Texas licensed Individual Asbestos Consultant and State of Texas certified Lead Inspector, and Mr. Kenneth Williamson, a State of Texas licensed Asbestos Inspector and State of Texas certified Lead Inspector, in general accordance with our proposal dated August 18, 2020.

Interior and exterior building components (excluding the roof) were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented.

Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids or in other concealed areas. Suspect

ACM samples were collected in accordance with Texas Asbestos Health Protection Rules

(TAHPR) and in general accordance with EPA guidance document number EPA 560 5/84-024 and were intended to identify and assess suspect materials prior to the removal of the unused laundry equipment within the building. Samples were delivered to a National Voluntary Laboratory

Accreditation Program (NVLAP) accredited and Texas Department of State Health Services

(TDSHS) licensed laboratory for analysis by Polarized Light Microscopy (PLM) protocol.

The lead-containing paint sampling was conducted in general accordance with Texas

Environmental Lead Reduction Rules (TELRR) and was intended to identify and assess the lead content of the materials which might be disturbed during the removal of the unused laundry equipment within the building. Samples were delivered to an American Industrial Hygiene

Association (AIHA) accredited laboratory utilizing Atomic Absorption Spectrometry (AAS Flame) methodology.

1.1 Project Objective

Limited Asbestos Survey and Lead-Containing Paint Sampling Report Doris Miller Dept. of VA Medical Ctr. (Former Laundry - Building 17) ■ Waco, Texas September 4, 2020 ■ Terracon Project No. 96207499

Responsive ■ Resourceful ■ Reliable 2

We understand the limited asbestos survey and lead-containing paint sampling was requested to facilitate the reconfiguration of the building following the removal of the unused laundry equipment within Building 17.

The TDSHS regulates asbestos-related activities in the State of Texas. The TDSHS TAHPR require that a licensed Asbestos Inspector conduct an asbestos survey which conforms to generally accepted industry standards such as the protocol specified in 40 CFR Part 763.85, commonly referred to as the Asbestos Hazard Emergency Response Act (AHERA) that applies to schools. Other factors are taken into consideration when determining the best method to determine the location, extent and condition of Asbestos-Containing Materials (ACMs) in a non-school building.

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, which is enforced by the TDSHS, requires that prior to the commencement of demolition or renovation, that the facility or part of the facility affected be thoroughly inspected for the presence of both Friable (Regulated Asbestos-

Containing Building Materials), and Non-Friable (Category I & II Asbestos-Containing

Materials). The Occupational Health and Safety Administration (OSHA) has promulgated a worker protection standard for the disturbance of asbestos during renovation and demolition projects.

The Department of Housing and Urban Development (HUD) guidelines consider a lead content equal to or greater than 5,000 parts per million (PPM) to be the level at which paint is considered to be “lead-based” and at which point a potential hazard exists. The Occupational

Safety and Health Administration (OSHA) considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

2.0 BUILDING DESCRIPTION

Building 17 is a one-story masonry structure with a partial basement, formerly used as a laundry facility. The building appears to have had two loading dock additions constructed on the southeast and northeast corners of the building and a larger western addition added at some point after initial construction of the central building. The original building appears to have a sloped clay tile and felt roof and the western addition and loading dock additions have flat ballasted built-up roof systems. Interior walls consisted of brick, wood, CMU and fired block, and gypsum wallboard with a painted and textured finish. The floors in the building consisted primarily of exposed concrete and resilient floor tile. Ceilings throughout the majority of the building were exposed painted wood, metal and concrete structural components. Suspended acoustic ceiling tile systems were observed in the two loading dock additions, Room 2B, and the Lounge (Room 4). Painted and textured drywall ceilings were observed in Rooms 3 and 3A and above the Shower/Locker Rooms (Rooms 5, 6, and 6A). The heating, ventilation, and air-

Responsive ■ Resourceful ■ Reliable 3 conditioning equipment was observed attached to the exposed ceiling deck, above the suspended acoustical tile, and on the roof of the building.

3.0 FIELD ACTIVITIES

The survey was conducted and bulk material samples were obtained by Mr. Richard Ian Howes, a State of Texas licensed Individual Asbestos Consultant (TDSHS License Number 10-5406) and

State of Texas certified Lead Inspector (TDSHS License Number 2060584), and Mr. Kenneth

Williamson, a State of Texas licensed Asbestos Inspector (TDSHS License Number 60-0050) and

State of Texas certified Lead Inspector (TDSHS License Number 2060499), employed by

Terracon. Copies of Mr. Howes’ and Mr. Williamson’s licenses and certificates are attached in

Appendix F. The survey was conducted in general accordance with the sample collection protocols established in the TAHPR and/or EPA regulation 40 CFR 763, the AHERA. The lead testing was conducted in general accordance with TELRR. A summary of survey activities is provided below.

3.1 Visual Assessment

Our survey activities began with visual observation of the interior and exterior areas of the building to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout in terms of color, texture and date of application. Interior assessment was conducted throughout visually accessible areas of the building where renovations are reportedly planned. Building materials identified as concrete, glass, wood, masonry, metal or rubber were not considered suspect ACM.

Suspect materials located within CMU block, behind mirrors or beneath ceramic tile (when present) were not sampled in order to prevent excessive damage to the material. Suspect materials, such as vermiculite fill, mastic or thin set, should be sampled prior to demolition or renovation activities if the activities will disturb the materials.

3.2 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 which can be crumbled, pulverized or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.3 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA and TAHPR sampling protocols. Random samples of suspect materials were collected in each homogeneous area. The sample team member collected bulk

Responsive ■ Resourceful ■ Reliable 4 samples 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.

Sixty-two (62) bulk samples were collected from twenty (20) homogeneous areas of suspect ACM.

A summary of suspect ACM samples collected during the survey is included as Appendix A.

Twenty (20) bulk samples of paint materials were collected for lead analysis in general accordance with TELRR and HUD Guidelines. The sample team member collected bulk samples and placed the samples in sealable containers labeled with unique sample numbers using an indelible marker. A summary of the suspect lead-based paint samples collected during the survey is included as Appendix D.

3.4 Sample Analysis

Suspect ACM bulk samples were submitted under chain of custody to Moody Labs of Farmers

Branch, Texas for analysis by Polarized Light Microscopy with dispersion staining techniques

(PLM/DS) per EPA’s Method for the Determination of Asbestos in Bulk Building Materials

(600/R-17-116). The percentage of asbestos, where applicable, was determined by microscopical visual estimation. Moody Labs is accredited under the National Voluntary Laboratory Accreditation

Program (NVLAP Accreditation No. 102056-0) and licensed by the TDSHS (License No. 300084).

Analytical results and sample chain-of custody documentation are included in Appendix C of this report.

Bulk samples of the suspect lead-containing paint materials collected were analyzed by

Environmental Hazards Services, L.L.C., an American Industrial Hygiene Association (AIHA) accredited laboratory utilizing Atomic Absorption Spectrometry (AAS Flame) methodology.

Reports of laboratory analysis of the suspect lead-containing paint samples collected and sample chain-of-custody documentation are included in Appendix E.

4.0 REGULATORY OVERVIEW

The State of Texas has established the TAHPR which requires any asbestos-related activity to be performed by an individual licensed by the State of Texas, through the TDSHS. An asbestos related activity consists of the disturbance (whether intentional or unintentional), removal, encapsulation, or enclosure of asbestos, including preparations or final clearance, the performance of asbestos surveys, the development of management plans and response actions, asbestos project design, the collection or analysis of asbestos samples, monitoring for airborne asbestos, bidding for a contract for any of these activities, or any other activity required to be licensed under TAHPR.

Abatement must be performed by a State of Texas licensed asbestos abatement contractor in accordance with a project design prepared by a State of Texas licensed asbestos consultant. In

Responsive ■ Resourceful ■ Reliable 5 addition, third party air monitoring must be conducted during the abatement activities.

The asbestos NESHAP (40 CFR Part 61 Subpart M) regulates asbestos fiber emission and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under NESHAP, asbestos containing building materials are classified as either friable, Category I non-friable or Category

II non-friable ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Category I non-friable ACM includes packing, gaskets, resilient floor coverings and asphalt roofing products containing more than 1% asbestos.

Category II non-friable ACM are any materials other than Category I materials that contain more than 1% asbestos.

Friable ACM, Category I and II non-friable ACM which is in poor condition and has become friable or which will be subject to drilling, sanding, grinding, cutting, or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM). RACM must be removed prior to renovation or demolition activities.

The TAHPR and NESHAP require that written notification be submitted before beginning renovation projects which include the disturbance of any asbestos-containing material (ACM) in a building or facility, or before the demolition of a building or facility, even when no asbestos is present. This written notification must be provided to the TDSHS at least 10 working days prior to the commencement of asbestos abatement or demolition activities. Removal of RACM must be conducted by a State of Texas licensed asbestos contractor. In addition, third party air monitoring must be performed during the abatement.

The OSHA Asbestos standard for the construction industry (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc).

The OSHA standard classifies construction and maintenance activities which could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work. States that administer their own federally approved state OSHA programs may require other precautions.

The Department of Housing and Urban Development (HUD) guidelines consider a lead content equal to or greater than 5,000 parts per million (PPM) to be the level at which paint is considered to be “lead-based” and at which point a potential hazard exists. The Occupational

Safety and Health Administration (OSHA) considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

As the facility is a public facility rather than Child Occupied or Target Housing, HUD and

TDSHS lead regulations do not apply to removal operations with the facility. It is, however, recommended that they be consulted as a general guideline for occupant protection.

Responsive ■ Resourceful ■ Reliable 6

5.0 FINDINGS AND RECOMMENDATIONS

Three (3) homogeneous material sampled and analyzed as part of this survey were found to contain asbestos:

• Exterior Moisture Barrier – The black exterior moisture barrier materials observed on CMU behind the exterior brick on the north, east, and south elevations of the Southeast and

Northeast Loading Dock additions were found to contain 5% Chrysotile asbestos. The asbestos-containing exterior moisture barrier materials identified were noted to be in good condition and were assessed as being non-friable. It is estimated that there exists approximately 1,100 square feet of these materials associated with the Southeast and

Northeast Loading Dock additions.

• Resilient Floor Tile and Mastic – The grey, 12” x 12” resilient floor tile and associated black mastic materials utilized throughout the Lounge (Room 4) were found to contain 5%

Chrysotile asbestos in the mastic. The asbestos-containing resilient floor tile and mastic materials identified were noted to be in good condition and were assessed as being non-friable. It is estimated that there exists approximately 820 square feet of these materials in the above listed area.

• Sink Coating – The white sink coating material utilized on the underside of the stainless-steel sink in the Lounge (Room 4) was found to contain 5% Chrysotile asbestos. The asbestos-containing sink coating materials identified were noted to be in good condition and were assessed as being non-friable. It is estimated that there exists approximately 8 square feet of these materials on the underside of the stainless-steel sink in the Lounge (Room 4).

None of the other suspect building materials sampled and analyzed were found to contain asbestos.

It should be noted that suspect materials, other than those identified during the August 27, 2020, survey may exist within the building. Should suspect materials other than those which were identified during this survey be uncovered prior to or during the renovation or demolition process, those materials should be assumed asbestos-containing until sampling and analysis can confirm or deny their asbestos content.

A summary of the classification, condition and approximate quantity of confirmed ACM are presented in Appendix B. Laboratory analytical reports are included in Appendix C.

If the Client does not intend to renovate or demolish the building, the asbestos-containing materials associated with the building should be managed in place. This in-place management should include such operations as repairing any damaged materials, protecting the remaining asbestos-containing materials from further damage, and developing a plan to periodically monitor

Responsive ■ Resourceful ■ Reliable 7 the condition of the asbestos-containing materials. Notification of the presence of the materials should also be made to residents, employees and outside contractors so that they do not inadvertently disturb the remaining asbestos-containing materials.

If renovation or demolition activities which will disturb the asbestos-containing materials are planned, it is recommended that the asbestos-containing materials be removed prior to conducting any renovation/demolition. The TDSHS TAHPR require that any removal of asbestos-containing materials associated with the structure be conducted by trained and licensed asbestos abatement personnel.

According to TDSHS TAHPR, a removal project involving the removal of friable asbestos-containing materials and/or the removal of more than 160 square feet or 260 linear feet of non-friable asbestos-containing materials would need to be designed by a licensed Individual Asbestos

Consultant. Air monitoring by a licensed third-party Air Monitor would be required during the actual removal work regardless of the size of the project. Terracon would be pleased to provide a proposal to provide these services.

It is important to note the TAHPR and NESHAP require that written notification be submitted before beginning renovation projects which include the disturbance of any asbestos-containing material (ACM) in a building or facility, or before the demolition of a building or facility, even when no asbestos is present. This written notification must be provided to the TDSHS at least

10 working days prior to the commencement of asbestos abatement or demolition activities.

These activities must be performed in accordance with the current TDSHS, EPA, and OSHA guidelines.

Nine (9) of the paint materials sampled and analyzed were found to contain lead in a concentration greater than 5,000 PPM and are considered Lead-Based Paint by EPA and

HUD:

• 17-L01 – The white paint material applied to the exterior concrete skirting and north

Basement wall was found to contain 44,000 ppm lead. This material was observed to be in good condition.

• 17-L02 – The white paint material applied to the exterior wood facia and Basement Level window and door components was found to contain 22,000 ppm lead. This material was observed to be in fair condition.

• 17-L06 – The yellow paint material applied to the metal Loading Dock ramps was found to contain 93,000 ppm lead. This material was observed to be in fair condition.

Responsive ■ Resourceful ■ Reliable 8

• 17-L08 – The white paint material applied to the majority of the interior brick and CMU walls throughout the building was found to contain 53,000 ppm lead. This material was observed to be in overall good condition.

• 17-L09 – The white on yellow paint material applied to the underside of the wood sloped roof deck above the Discharge Area (Room 2) and the Soiled Linen and Sorting Area

(Room 3) was found to contain 170,000 ppm lead. This material was observed to be in fair condition.

• 17-L10 – The white on yellow paint material on primer applied to the metal trusses and joists of the roof structure above the Discharge Area (Room 2) and the Soiled Linen and

Sorting Area (Room 3) was found to contain 200,000 ppm lead. This material was observed to be in good condition.

• 17-L14 – The red paint material applied to the metal fire system piping throughout the building was found to contain 26,000 ppm lead. This material was observed to be in good

• 17-L19 – The red on yellow paint material applied to the metal elevated fire suppression piping above the Discharge Area (Room 2) and the Soiled Linen and Sorting Area (Room 3) was found to contain 52,000 ppm lead. This material was observed to be in good condition.

• 17-L20 – The blue paint material applied to the metal cast iron sewer pipes in the Basement was found to contain 110,000 ppm lead. This material was observed to be in poor condition.

Seven (7) of the paint materials sampled and analyzed as part of this survey were found to contain lead in a concentration exceeding the detection limit, but less than 5,000 PPM which would render the material “Lead-Containing” (considered a potential hazard by

OSHA).

• 17-L03 – The light grey paint material applied to the exterior concrete stair landings at the

Entry Doors was found to contain 420 ppm lead. This material was observed to be in fair

• 17-L04 – The red paint material applied to the exterior metal gutter downspouts (lower sections), Crawlspace Entry Doors, roof access stairs/rails, and handrail at the Basement steps was found to contain 2,200 ppm lead. This material was observed to be in fair

• 17-L05 – The light grey paint material applied to the exterior metal handrails at the Entry

Door landings was found to contain 1,900 ppm lead. This material was observed to be in fair

Responsive ■ Resourceful ■ Reliable 9

• 17-L07 – The white paint material applied to the exterior metal Exit Doors, West Side Doors, and Southwest Door, and on select exterior metal window frame components was found to contain 60 ppm lead. This material was observed to be in good condition.

• 17-L11 – The light blue on white paint material applied to the metal interior door frames throughout the building, and on the metal equipment support in the northeast corner of the

Soiled Linen and Sorting Area (Room 3) was found to contain 48 ppm lead. This material was observed to be in good condition.

• 17-L15 – The light beige paint material applied to the CMU and concrete walls in the

Loading Docs and Room 2B was found to contain 39 ppm lead. This material was observed to be in fair condition.

• 17-L17 – The grey paint material applied to the south CMU wall in Washroom 7A was found to contain 470 ppm lead. This material was observed to be in good condition.

Four (4) paint materials sampled and analyzed as part of this survey were found to contain lead in a concentration below the detection limit and would be considered by

OSHA to present no workforce hazard:

• 17-L12 – The white paint material applied to the metal interior doors throughout the building was found to contain <35 ppm lead. This material was observed to be in good condition.

• 17-L13 – The grey paint material applied to the inside of the metal air handling unit on the northeast corner of the flat roof was found to contain <43 ppm lead. This material was

• 17-L16 – The light grey paint material applied to the metal elevated fan supports in the

Discharge Area, metal wall guard at the South Loading Dock, and select metal door components throughout the building was found to contain <48 ppm lead. This material was

• 17-L18 – The white paint material applied to the drywall construction and wood walls in

Rooms 3 and 3A was found to contain <48 ppm lead. This material was observed to be in good condition.

In areas where the Client does not intend to renovate or demolish the facility, the lead-based/containing paint materials, which will remain in the facility, should be managed in place. It is recommended that this in-place management should include such operations as repairing any damaged materials which are not removed as part of any renovation/demolition operations, protecting the remaining lead-based/containing paint materials from further damage, and

Responsive ■ Resourceful ■ Reliable 10 developing a plan to periodically monitor the condition of the lead-based/containing paint materials. Notification of the presence of the materials should also be made to employees and outside contractors so that they do not inadvertently disturb the remaining lead-containing paint materials.

In areas where renovations are to be conducted which could disturb the lead-based/containing materials, it is recommended that contracting personnel who may disturb the lead-based/containing paint materials within the facility be made aware of the lead content in the materials so that they may exercise proper OSHA procedures for personnel protection or possibly employ protective procedures when working with the coatings.

It is recommended that any wood building components which have lead-based paint coatings and are to be removed as part of any planned renovation project be removed by a lead remediation contractor and prior to disposal, be treated with a lead demolition encapsulant in order to reduce the potential of a lead hazardous waste stream resulting from the project.

It is recommended that any painted metal building components which are to be removed from the facility as part of a renovation or demolition activity be segregated from the waste stream and be transferred to a suitable metal recycling facility.

As the facility is a public facility rather than Target Housing, HUD and TDSHS lead regulations do not apply to removal operations within the facility. It is, however, recommended that they be consulted as a general guideline for occupant protection and that OSHA notification be made to all employees or contractors working on any repair, renovation or demolition projects within the facility.

Compliance with applicable OSHA lead regulations is the responsibility of the contractor performing the work and it is recommended that they be required to communicate potential lead hazards to their workforce and utilize lead-safe work practices such as outlined in the EPA

Renovation, Repair, and Painting Final Rule (40 CFR 745) or applicable portions of the

Structural Steel Painting Council (SSPC) Guidelines. It is further recommended that activities such as flame/torch dismantling, dry sanding and/or dry grinding of any components with lead-containing paint materials applied should be prohibited as part of any repair, renovation or demolition activity.

6.0 GENERAL COMMENTS

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

Responsive ■ Resourceful ■ Reliable 11 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 Central Texas Veterans

Health Care System 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.

Doris Miller Department of VA Medical Ctr. (Former Laundry - Bldg. 17) 4800 Memorial Drive

Photos Taken: 08/27/2020

Photo #1 View of the south and east elevations of the building. Note Southeast Loading Dock addition in the foreground.

Photo #2 View of the south elevation of the Northeast Loading Dock addition where black asbestos-containing waterproofing was sampled behind the brick which was damaged by others.

4800 Memorial Drive

Photo #3 View of the asbestos-containing floor tile and mastic in the Lounge (Room 4).

Photo #4 View of some of the LBP on the underside of the roof deck, on fire lines, and on the roof trusses/joists above the Discharge Area Room 2) and Soiled Linen and Sorting Area (Room 3).

4800 Memorial Drive

Photo #5 View of the LBO (white) on exterior concrete and wood components.

Photo #6 View of the LBP (Yellow) applied to Loading Dock components.

4800 Memorial Drive

Photo #7 View of the interior LBP applied to walls and ceilings and the red LBP applied to fire lines in building.

Photo #8 View of the blue LBP debris from Sewer Lines mixed with debris throughout the Basement Mechanical Room.

APPENDIX A

ASBESTOS SURVEY SAMPLE SUMMARY

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

SAMPLE

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-01 Exterior Window Frame Caulk

– White

Utilized around the majority of exterior window frames

Exterior, north side, west window

No Asbestos

Detected

17-02 Exterior Window Frame Caulk

– White

Utilized around the majority of exterior window frames

Exterior, west side, south window

No Asbestos

Detected

17-03 Exterior Window Frame Caulk

– White

Utilized around the majority of exterior window frames

Exterior, south side, central window

No Asbestos

Detected

17-04 Exterior Door Frame and Wall

Seam Caulk – Light grey

Utilized in the exterior brick wall seams, around most door frames, and at the base of the brick walls

Exterior, west side, South

Door

No Asbestos Detected

17-05 Exterior Door Frame and Wall

Seam Caulk – Light grey

Utilized in the exterior brick wall seams, around most door frames, and at the base of the brick walls

Exterior, south side, center, at wall base

No Asbestos Detected

17-06 Exterior Door Frame and Wall

Seam Caulk – Light grey

Utilized in the exterior brick wall seams, around most door frames, and at the base of the brick walls

Exterior, Basement Level, north side, West Door

No Asbestos Detected

17-07 Exterior Concrete Texture Utilized on the exterior perimeter building skirting

Exterior, south side, center No Asbestos Detected

17-08 Exterior Concrete Texture Utilized on the exterior perimeter building skirting

Exterior, north side, east end No Asbestos Detected

17-09 Exterior Concrete Texture Utilized on the exterior perimeter building skirting

Exterior, east side, center No Asbestos Detected

17-10 Exterior Moisture Barrier –

Black

Observed behind the exterior brick on the north, east and south elevations of the

Southeast and Northeast

Loading Dock additions

Exterior, Northeast

Loading Dock, south side, above Overhead Door

5% Chrysotile

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-11 Exterior Moisture Barrier –

Black

Observed behind the exterior brick on the north, east and south elevations of the

Southeast and Northeast

Loading Dock additions

Exterior, Northeast

Loading Dock, south side, above Overhead Door

5% Chrysotile

17-12 Exterior Moisture Barrier –

Black

Observed behind the exterior brick on the north, east and south elevations of the

Southeast and Northeast

Loading Dock additions

Exterior, Northeast

Loading Dock, south side, above Overhead Door

5% Chrysotile

17-13 Exterior Window Glazing –

White

Utilized on the north Basement windows

Basement Level, north side, east window, interior side

No Asbestos

Detected

17-14 Exterior Window Glazing –

White

Utilized on the north Basement windows

Basement Level, north side, east window, exterior side

No Asbestos

Detected

17-15 Exterior Window Glazing –

White

Utilized on the north Basement windows

Basement Level, north side, east window, exterior side

No Asbestos Detected

17-16 Resilient Floor Tile – 12” x 12”, Tan with yellow mastic

Utilized in the Discharge Area, Soiled Laundry Area, Room 2B, Flat Work Area, and portions of the Wash Room Area

Southeast portion of

Discharge Area

No Asbestos

Detected

17-17 Resilient Floor Tile – 12” x 12”, Tan with yellow mastic

Utilized in the Discharge Area, Soiled Laundry Area, Room 2B, Flat Work Area, and portions of the Wash Room Area

Southwest portion of Flat

Work Area

No Asbestos

Detected

17-18 Resilient Floor Tile – 12” x 12”, Tan with yellow mastic

Utilized in the Discharge Area, Soiled Laundry Area, Room 2B, Flat Work Area, and portions of the Wash Room Area

West central portion of Wash

Room Area

No Asbestos Detected

17-19 Resilient Floor Tile – 12” x 12”, Red with yellow mastic

Utilized as trim tile in the

Discharge Area and Flat Work

Area

Southeast portion of Discharge Area, at Loading Dock

No Asbestos Detected

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-20 Resilient Floor Tile – 12” x 12”, Red with yellow mastic

Utilized as trim tile in the

Discharge Area and Flat Work

Area

North portion of Discharge

Area, at Office

No Asbestos Detected

17-21 Resilient Floor Tile – 12” x 12”, Red with yellow mastic

Utilized as trim tile in the

Discharge Area and Flat Work

Area

South central portion of Flat

Work Area

No Asbestos Detected

17-22 Resilient Floor Tile – 12” x 12”, Light tan with yellow mastic

Utilized in Room 3 below the moving shelves and throughout

Room 3A

Northeast corner of Room 3A No Asbestos Detected

17-23 Resilient Floor Tile – 12” x 12”, Light tan with yellow mastic

Utilized in Room 3 below the moving shelves and throughout

Room 3A

Northeast corner of Room 3A No Asbestos Detected

17-24 Resilient Floor Tile – 12” x 12”, Light tan with yellow mastic

Utilized in Room 3 below the moving shelves and throughout

Room 3A

Central portion of Room 3, below rolling shelves

No Asbestos Detected

17-25 Resilient Floor Tile – 12” x

12”, Grey with black mastic

Utilized throughout the

Lounge (Room 4)

East portion of Lounge 5% Chrysotile in Mastic

17-26 Resilient Floor Tile – 12” x

12”, Grey with black mastic

Utilized throughout the

Lounge (Room 4)

Central portion of Lounge 5% Chrysotile in Mastic

17-27 Resilient Floor Tile – 12” x

12”, Grey with black mastic

Utilized throughout the

Lounge (Room 4)

Southwest portion of

Lounge, at Exit Door

5% Chrysotile in Mastic

17-28 Sink Coating - Black Utilized on the underside of the Lounge sink

Lounge, underside of sink 5% Chrysotile

17-29 Sink Coating - Black Utilized on the underside of the Lounge sink

Lounge, underside of sink 5% Chrysotile

17-30 Sink Coating - Black Utilized on the underside of the Lounge sink

Lounge, underside of sink 5% Chrysotile

17-31 Drywall Construction – Light texture

Utilized on the walls in the

Lounge (Room 4), and on the ceilings in Locker Rooms 5, 6, and 6A, and Room 2D

Central ceiling in Locker

Room 5

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-32 Drywall Construction – Light texture

Utilized on the walls in the

Lounge (Room 4), and on the ceilings in Locker Rooms 5, 6, and 6A, and Room 2D

Wall in Lounge, adjacent to sink

No Asbestos Detected

17-33 Drywall Construction – Light texture

Utilized on the walls in the

Lounge (Room 4), and on the ceilings in Locker Rooms 5, 6, and 6A, and Room 2D

Southwest corner of Lounge, at Exit Door

No Asbestos Detected

17-34 Drywall Construction – Light texture

Utilized on the walls in the

Lounge (Room 4), and on the ceilings in Locker Rooms 5, 6, and 6A, and Room 2D

Central ceiling in Locker

Room 6

No Asbestos Detected

17-35 Drywall Construction – Light texture

Utilized on the walls in the

Lounge (Room 4), and on the ceilings in Locker Rooms 5, 6, and 6A, and Room 2D

East wall of Lounge, at door to Discharge Area

No Asbestos Detected

17-36 Resilient Floor Tile – 12” x 12”, Grey with yellow mastic on tan with yellow mastic

Utilized in Office 2C Northwest corner of Office 2C No Asbestos Detected

17-37 Resilient Floor Tile – 12” x 12”, Grey with yellow mastic on tan with yellow mastic

Utilized in Office 2C Northwest corner of Office 2C No Asbestos Detected

17-38 Resilient Floor Tile – 12” x 12”, Grey with yellow mastic on tan with yellow mastic

Utilized in Office 2C Northwest corner of Office 2C No Asbestos Detected

17-39 Suspended Acoustic Ceiling

Tile – 2’ x 4’, White with fissures and holes

Utilized in the Lounge, Loading

Docks 1 and 2, Office 2C, Room

2B, and Entry 2E

Loading Dock 2, southeast corner

No Asbestos Detected

17-40 Suspended Acoustic Ceiling

Tile – 2’ x 4’, White with fissures and holes

Utilized in the Lounge, Loading

Docks 1 and 2, Office 2C, Room

2B, and Entry 2E

Lounge, central portion No Asbestos

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-41 Suspended Acoustic Ceiling

Tile – 2’ x 4’, White with fissures and holes

Utilized in the Lounge, Loading

Docks 1 and 2, Office 2C, Room

2B and Entry 2E

Office 2C, central portion No Asbestos Detected

17-42 HVAC Duct Mastic – White Utilized on the HVAC ducts in select areas throughout the building

Flat Work Area, west end, center duct

No Asbestos Detected

17-43 HVAC Duct Mastic – White Utilized on the HVAC ducts in select areas throughout the building

Flat Work Area, east end, center duct

No Asbestos Detected

17-44 HVAC Duct Mastic – White Utilized on the HVAC ducts in select areas throughout the building

Flat Work Area, southwest corner duct

No Asbestos Detected

17-45 HVAC Duct Mastic – Grey Utilized on the HVAC ducts in the Break Room and Room 3

Break Room, center No Asbestos Detected

17-46 HVAC Duct Mastic – Grey Utilized on the HVAC ducts in the Break Room and Room 3

Room 3, center No Asbestos Detected

17-47 HVAC Duct Mastic – Grey Utilized on the HVAC ducts in the Break Room and Room 3

Room 3, center No Asbestos Detected

17-48 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the 6” steam/chilled water lines throughout the building

Room 7A, chilled water line, north side, center

No Asbestos Detected

17-49 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the 6” steam/chilled water lines throughout the building

Room 2A, east side steam line

No Asbestos Detected

17-50 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the 6” steam/chilled water lines throughout the building

Basement, condensate line, south side, center area

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-51 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the domestic water lines throughout the building

Basement, domestic water line, north side, center area

No Asbestos Detected

17-52 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the domestic water lines throughout the building

Basement, domestic water line, north side, west end area

No Asbestos Detected

17-53 Thermal System Insulation

Mastic – White on fiberglass insulation with a white paper cover

Utilized on the domestic water lines throughout the building

Basement, domestic water line, Crawlspace 103, north side, at hatch

No Asbestos Detected

17-54 CMU Texture – White Utilized on the walls in Office 2C, Room 2D, Loading Dock 2, and

Entry E2

Loading Dock 2, east wall No Asbestos Detected

17-55 CMU Texture – White Utilized on the walls in Office 2C, Room 2D, Loading Dock 2, and

Entry E2

Southwest corner outside

Office 2C

No Asbestos Detected

17-56 CMU Texture – White Utilized on the walls in Office 2C, Room 2D, Loading Dock 2, and

Entry E2

Wall outside Room 2D, at door

No Asbestos Detected

17-57 Drywall Construction – White with a light texture

Utilized on the walls in Room 2B, and on the walls and ceilings in

Rooms 3 and 3A

Northeast corner of Room 2B No Asbestos Detected

17-58 Drywall Construction – White with a light texture

Utilized on the walls in Room 2B, and on the walls and ceilings in

Rooms 3 and 3A

Northeast corner of Room 3A No Asbestos Detected

17-59 Drywall Construction – White with a light texture

Utilized on the walls in Room 2B, and on the walls and ceilings in

Rooms 3 and 3A

Corner outside Room 3A in

Room 3

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

NUMBER

MATERIAL DESCRIPTION HOMOGENEOUS AREA SAMPLE LOCATION

LAB

RESULTS

17-60 Plaster – Grey Utilized on the upper gable infill between the Soiled Linen and

Discharge Areas

Discharge Area above Office

2C

No Asbestos Detected

17-61 Plaster – Grey Utilized on the upper gable infill between the Soiled Linen and

Discharge Areas

Discharge Area above Office

2C

No Asbestos Detected

17-62 Plaster – Grey Utilized on the upper gable infill between the Soiled Linen and

Discharge Areas

Discharge Area above Office

2C

APPENDIX B

CONFIRMED ASBESTOS-CONTAINING MATERIALS

APPENDIX B

CONFIRMED ASBESTOS-CONTAINING MATERIALS

Doris Miller Department of VA Medical Center

Former Laundry – Building 17

4800 Memorial Drive

SAMPLE NO.

MATERIAL

DESCRIPTION

HOMOGENEOUS

AREA

PERCENT / TYPE

ASBESTOS

NESHAP

CLASSIFICATION

MATERIAL

CONDITION

ESTIMATED

QUANTITY

17-10/11/12 Exterior Moisture

Barrier – Black

Observed behind the exterior brick on the north, east and south elevations of the

Southeast and

Northeast Loading

Dock additions

5% Chrysotile

Category I

Non-Friable

Good 1,100 Sq. Ft.

17-25/26/27 Resilient Floor Tile

– 12” x 12”, Grey with black mastic

Utilized on floor throughout the

Lounge (Room 4)

5% Chrysotile in Mastic

Category I

Non-Friable

Good 820 Sq. Ft.

17-28/29/30 Sink Coating -

Black

Utilized on the underside of the

Lounge sink

5% Chrysotile Category II

Non-Friable

Good 8 Sq. Ft.

Sq. Ft. = square feet

Lin. Ft. = linear feet

Category I: Includes asbestos-containing packings, gaskets, asphaltic roofing products, and resilient flooring.

Category II: Includes any non-friable asbestos-containing materials not categorized as Category I.

Regulated Asbestos-containing Material (RACM): Friable asbestos-containing materials and/or Category I and II non-friable asbestos-containing materials which have a high probability of or have become friable by forces expected to be exerted in the course of a renovation or demolition process.

APPENDIX C

ASBESTOS LABORATORY ANALYTICAL REPORTS

PLM Summary Report

Client :

Project :

Project # :

Identification :

Test Method :

Terracon - Austin

VA Waco, Building 17

96207499

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 8/28/2020, sixty two (62) bulk material samples were submitted by Richard Ian Howes of Terracon - Austin for asbestos analysis by PLM/DS. The

PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

20B-09053

08/27/2020

09/01/2020

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS)

EPA Method 600 / R-93 / 116

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

17-01 Not Provided None Detected - Caulking

17-02 Not Provided None Detected - Caulking

17-03 Not Provided None Detected - Caulking

17-04 Not Provided None Detected - Caulking

17-05 Not Provided None Detected - Caulking

17-06 Not Provided None Detected - Old Caulking

None Detected - New Caulking

17-07 Not Provided None Detected - Texture

17-08 Not Provided None Detected - Texture

None Detected - Black Mastic

17-09 Not Provided None Detected - Plaster

17-10 Not Provided None Detected - Concrete

5% Chrysotile - Black Mastic

17-11 Not Provided None Detected - Concrete

5% Chrysotile - Black Mastic

17-12 Not Provided None Detected - Concrete

5% Chrysotile - Black Mastic

17-13 Not Provided None Detected - Window Glazing

17-14 Not Provided None Detected - Window Glazing

17-15 Not Provided None Detected - Window Glazing

17-16 Not Provided None Detected - Floor Tile

None Detected - Cream Mastic

17-17 Not Provided None Detected - Floor Tile

None Detected - Cream Mastic

Project :

Project # :

Identification :

Test Method :

Terracon - Austin

VA Waco, Building 17

96207499

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 8/28/2020, sixty two (62) bulk material samples were submitted by Richard Ian Howes of Terracon - Austin for asbestos analysis by PLM/DS. The

PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

20B-09053

08/27/2020

09/01/2020

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS)

EPA Method 600 / R-93 / 116

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

17-18 Not Provided None Detected - Floor Tile

None Detected - Cream Mastic

17-19 Not Provided None Detected - Floor Tile

No Mastic

17-20 Not Provided None Detected - Floor Tile

No Mastic

17-21 Not Provided None Detected - Floor Tile

No Mastic

17-22 Not Provided None Detected - Floor Tile

None Detected - Yellow Mastic

17-23 Not Provided None Detected - Floor Tile

None Detected - Yellow Mastic

17-24 Not Provided None Detected - Floor Tile

None Detected - Yellow Mastic

17-25 Not Provided None Detected - Floor Tile

5% Chrysotile - Black Mastic

17-26 Not Provided None Detected - Floor Tile

5% Chrysotile - Black Mastic

17-27 Not Provided None Detected - Floor Tile 1

5% Chrysotile - Black Mastic

None Detected - Floor Tile 2

5% Chrysotile - Black Mastic

17-28 Not Provided 5% Chrysotile - Sink Undercoating

17-29 Not Provided 5% Chrysotile - Sink Undercoating

17-30 Not Provided 5% Chrysotile - Sink Undercoating

17-31 Not Provided None Detected - Texture

17-32 Not Provided None Detected - Texture

Project :

Project # :

Identification :

Test Method :

Terracon - Austin

VA Waco, Building 17

96207499

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 8/28/2020, sixty two (62) bulk material samples were submitted by Richard Ian Howes of Terracon - Austin for asbestos analysis by PLM/DS. The

PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

20B-09053

08/27/2020

09/01/2020

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS)

EPA Method 600 / R-93 / 116

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

17-33 Not Provided None Detected - Texture

17-34 Not Provided None Detected - Joint Compound

None Detected - Texture

17-35 Not Provided None Detected - Texture

17-36 Not Provided None Detected - Top Floor Tile

None Detected - Yellow Mastic

None Detected - Bottom Floor Tile

No Mastic

17-37 Not Provided None Detected - Top Floor Tile

None Detected - Yellow Mastic

None Detected - Bottom Floor Tile

No Mastic

17-38 Not Provided None Detected - Top Floor Tile

None Detected - Yellow Mastic

None Detected - Bottom Floor Tile

None Detected - Yellow Mastic

17-39 Not Provided None Detected - Acoustic Tile

17-40 Not Provided None Detected - Acoustic Tile

17-41 Not Provided None Detected - Acoustic Tile

17-42 Not Provided None Detected - Thermal Insulation

None Detected - Vinyl Wrap

None Detected - Paper / Foil Wrap

None Detected - White Mastic

17-43 Not Provided None…

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