attachment 9: inspection report building t7

Attachment 9: Inspection report Building T7

Apex Companies, LLC 58 H Connecticut Avenue South Windsor, CT 06074 T 860.282.1700 F 860.282.1800 apexcos.com

AAttttaacchhmmeenntt 99

Asbestos, Lead Paint, PCBs, and Soil Sampling

Inspection Report for the Department of Veterans Affairs (VA) of Central

Western Massachusetts Healthcare System

Building T7

421 North Main Street Leeds, MA 01053-9764

Apex Project No: ACELA-001

December 15, 2017

Prepared for:

Acela Engineering Co

Daniel Witczak, PE, PMP

1275 Glenlivet Drive, Suite 100

Allentown, PA 18106-3107

APEX COMPANIES, LLC

Prepared by:

Ethan T. Platt

Project Manager

Industrial Hygiene Services

TABLE OF CONTENTS

1.0 INTRODUCTION ................................................................................................................. 2

2.0 ASBESTOS ASSESSMENT AND BULK SAMPLING METHODOLOGY......................... 2

3.0 INSPECTING FOR ACM .................................................................................................... 4

4.0 LABORATORY ANALYSES .............................................................................................. 4

5.0 ASBESTOS RESULTS....................................................................................................... 5

6.0 LEAD SURVEY (Historic, TCLP, Soil) ............................................................................. 6

7.0 POLYCHLORINATED BIPHENYLS (PCBs) RESULTS ................................................... 8

8.0 PCB sOIL RESULTS .......................................................................................................... 8

9.0 INACCESSIBLE AND LIMITED ACCESS SPACES ......................................................... 9

10.0 FINDINGS/RECOMMENDATIONS .................................................................................... 9

11.0 DISCLAIMER .................................................................................................................... 10

FIGURES Figure 1 Site Location Diagrams – Bulk Sample Locations Figure 2 Combined with Historic Site Location Diagram (from Appendix D)

TABLES Table 1 NESHAP Sampling Protocol Table 2 Asbestos Sample Analytical Results Table 3 Pb Soil Analytical Results Table 4 PCB Building Sample Analytical Results Table 5 PCB Soil Analytical Results Table 6 Building Composite Total Character Leachate Procedure Soil Analytical Results

APPENDICES Appendix A Personnel and Laboratory Certifications Appendix B Laboratory Data Sheets and Chain-of Custodies Appendix C Photographs Appendix D Client Provided Historic Reports

VA of Western Massachusetts December 15, 2017

Asbestos, Lead, PCBs, and Soil Survey – Attachment:9 (Building T7) Page 2

1.0 INTRODUCTION At the request of Acela Engineering Co (Acela) on behalf of the Department of Veterans Affairs (VA) of

Central Western Massachusetts Healthcare System(VA), Apex Companies, LLC (Apex) has conducted

an inspection of Building T7 on the VA Campus located at 421 North Main Street in Leeds,

Massachusetts. The building was unoccupied at the time of the survey and was inspected for the

presence of asbestos-containing materials (ACMs), lead based paint via Total Characteristic Leachate

Procedure (TCLP), Polychlorinated biphenyls (PCBs), and soil samples were collected and analyzed for

the presence of lead (Pb) and PCBs along the building ‘drip line’ where possible. The survey services

were conducted on November 6 through 10, 2017.

Mr. Ethan T. Platt (Apex) was the inspector performing the inspection activities at the project site. Mr.

Platt is a Massachusetts Department of Labor Standards (MADOLS)-licensed asbestos Consultant

Inspector (License No. AM000219). Copies of Mr. Platt’s certifications are provided in Appendix A.

Apex conducted a visual inspection of the interior and exterior areas of the building. During the visual

inspection, Apex identified and collected eight (8) samples of suspect ACMs, one sample for TCLP lead,

one (1) soil sample for lead, (1) soil sample for PCBs, and four (4) bulk sample for PCBs. While Apex

made every attempt to seek out and sample all suspect materials, due to limitations, there exists the

possibility that unidentified materials may remain in the building. At the time of demolition, any materials

not identified in this report that is uncovered should be considered to be an ACM unless testing proves

otherwise.

In addition to Apex’s inspection the VA supplied a historic report produced by Mabbett & Associates, Inc.

(2010). Where feasible this historic report has been incorporated into this report.

The remaining building’s components, as best that can be safely assessed were inspected for suspect

materials. All of the samples collected were analyzed via polarized light microscopy (PLM) to determine

the presence of asbestos.

2.0 ASBESTOS ASSESSMENT AND BULK SAMPLING METHODOLOGY Survey and assessment protocols used were based on those adopted by the United States

Environmental Protection Agency (EPA) as detailed in the National Emission Standard for Hazardous Air

Pollutants (NESHAP) 40 Code of Federal Regulations (CFR) 61, Subpart M. Mr. Platt conducted the on-

site inspection and assessments.

Asbestos bulk samples were collected and analyzed using the EPA’s NESHAP protocol as follows:

• Sampling locations were initially chosen in a randomly distributed;

• Suspended ceiling tiles were moved slowly in a horizontal position;

• The sample areas were wetted (not saturated) during sampling to minimize fiber release;

• The suspect ACM was sampled using a utility knife, wood chisels, coring tools, or forceps. The

tool that minimized the disturbance to the sample material, was least likely to cause fiber release,

and was most efficient for sampling the particular material was used;

• All layers of suspected ACMs were sampled, with sample integrity maintained;

• The bulk sample size was approximately two square centimeters (cm2) or smaller;



• Wherever possible, samples were collected from damaged areas to minimize fiber release;

• Each sample was placed in a clear plastic container and the outside wet-wiped, sealed, and

labeled with a unique sample number. This number, along with other pertinent information, was

recorded on the bulk sample chain of custody and field form;

• The sampling tool was cleaned with a damp disposable towel between sample collection.

The sampling protocol established by NESHAP was used to determine the required number of samples

for this survey based on function (surfacing, thermal system insulation, or miscellaneous materials) and

homogeneous building materials. A homogeneous area is defined as an area where a suspect material is

uniform in texture, color, and appears to have been installed at the same time. Materials appearing to be

identical but determined by the inspector to have been installed at different time periods were treated as

different suspect materials.

The NESHAP protocol was used to determine functional areas, and subsequent, homogeneous areas of

construction in the building.

Three forms of asbestos are typically found in buildings:

• sprayed- or troweled-on surfacing materials (spray-on fireproofing and plaster);

• thermal system insulation (insulation on pipes, boilers and other mechanical equipment); and

• miscellaneous materials such as floor tiles, ceiling tiles, roofing materials, drywall composition,

window caulking / glazing, etc.

NESHAP recommends the collection of a minimum number of samples for each suspect ACM. Apex

follows the NESHAP sampling protocol for each survey conducted. In addition, Apex generally collects a

minimum of one to three samples per suspect homogeneous material. However, in cases where the

material is hidden beneath layers the sample numbers are often reduced.

Identification of types of materials and the number of samples collected during the Apex survey, which is

based on the NESHAP sampling protocol is identified in Table 1. The suspect and accessible materials

that were observed in the facility were sampled per this protocol. Apex developed a sampling strategy

following a walk-through visual inspection of the accessible areas of the building. This allowed the

inspector to evaluate the construction of the building, as well as identify suspect homogeneous ACMs for

sampling purposes.

Apex made every attempt to visually assess the entire structure included in this survey, as well as to

collect samples of all suspect materials identified. However, some areas of the building were not

inspected due to being inaccessible due to occupancy or without extensive demolition (such as wall

interiors) and areas where safety would be compromised by entering (such as confined spaces or inside

active machinery). Any new materials found in these areas during renovations or demolition is to be

considered ACMs until sampling and testing confirms otherwise.

Once homogeneous suspect materials were identified, Apex began the collection of these materials for

submission to the laboratory.



3.0 INSPECTING FOR ACM This inspection and sampling was conducted on an area-by-area basis. Materials that were considered

suspect were identified and the number of samples to be collected of these suspect materials was

determined by the inspector using NESHAP protocols. As defined by NESHAP, suspect materials include

the following building material types:

• surfacing materials - including plaster, spray-applied or troweled-on wall/ceiling coatings;

• thermal system insulation (TSI) - including pipe insulation, duct insulation, boiler lagging; and

• miscellaneous materials - including ceiling tile, floor tiles and mastics, gaskets (if accessible), fire

doors, and wallboard/spackling compound.

Suspect materials that are homogeneous in nature (i.e., uniform in color and texture) were identified,

touched to determine friability, and sampled by removing a small piece that was then placed in a labeled

container. For a given homogeneous area, one or more samples were collected in a randomly distributed

manner in accordance with NESHAP provisions (40 CFR 61). Unless specifically referenced, materials

not considered by the NESHAP rules as suspect ACMs were not addressed by Apex during this survey.

Several suspect ACMs identified at the building warranted special scrutiny or otherwise required special

consideration. These materials were:

• Joint Compound/Sheetrock: if sheetrock (wallboard and ceiling board) and its associated joint

compound were considered suspect ACM and sampled separately in accordance with OSHA

requirements. If either component was found to contain more than one percent asbestos, the entire

wall system would be considered ACM; and

• Vinyl floor tiles and mastics: If floor tiles and underlying mastics were considered suspect ACM.

Each flooring material and its associated mastic were sampled separately. If either component was

found to contain greater than one percent asbestos, then only that material was considered ACM.

However, if positive mastic adheres to floor tile, the floor tile must be considered contaminated.

Based on this observation, the characterization of the homogenous material underneath (i.e., tile or

mastic), if any, was extrapolated to the entire floor surface of that area. The base flooring was

examined to the subflooring.

4.0 LABORATORY ANALYSES In order to determine whether the materials are asbestos containing (i.e., contain more than one percent

asbestos as defined by the EPA, or containing ‘1% or more’ per MADEP 310 CMR 7.15) EMSL Analytical,

Inc. in Cinnaminson, New Jersey analyzed samples for asbestos content. EMSL is a National Voluntary

Laboratory Accreditation Program (NVLAP)-accredited laboratory. Sample designations, gross

descriptions, and analytical results are provided in Table 2. Laboratory analytical reports and field

sampling logs are presented in Appendix B.

Asbestos fiber content is estimated by optically comparing the quantity of non-asbestos material to

asbestos fibers utilizing polarized light microscopy/dispersion staining (PLM/DS). The lower limit of

reliable detection using PLM is 1%. Samples that contain 1% or more asbestos are reported in percent



ranges. Samples that contain asbestos in a concentration lower than the limit of reliable detection (<1%)

are reported as “<1%”. Samples in which no asbestos is observed are reported as “None Detected”.

EMSL analyzed four (4) of the six (6) collected bulk samples via PLM.

5.0 ASBESTOS RESULTS

Asbestos-containing building materials were detected in Building T7 of the VA campus site located at

421 North Main Street Leeds, Massachusetts. A material is considered by the EPA to be asbestos-

containing if at least one sample collected from the homogeneous area shows asbestos present in an

amount greater than one percent (>1%), and the Massachusetts DEP further defines the asbestos

containing material as ‘1% or more’ per MADEP 310 CMR 7.15. The full sample list is provided in Table

2. A copy of the laboratory ACM sample results is provided in Appendix B.

The following building materials contained ≥ 1 % asbestos:

Sample # 02a-c Exterior Metal to Wood Sealant

5% Chrysotile

~500 sf – at the metal roof to wood interface

Historic Sample # 03a-c 12”x12” Gray floor tile

3% Chrysotile

~250 sf – Office area

Historic Sample # 05a-c 9”x9” Gray floor tile

3% Chrysotile

~150 sf – bathroom and hall



6.0 LEAD SURVEY (Historic, TCLP, Soil)

Historic Report

In 2010 Mabbett & Associates conducted a full Lead Paint inspection via XRF. Lead was found to be

present (see below table). This report is attached as Appendix D.

The HUD/EPA standard for lead-based paint of equal to or greater than 1.0 mg/cm2.

TCLP Lead Assessment Apex collected building composite samples to represent the building’s construction and components. This

composite sample was collected to determine whether components of either building which is slated for

demolition have hazardous levels of lead-based paint. This TCLP analysis is conducted to determine

whether debris generated from demolition needs to be disposed of as hazardous lead waste. The EPA

has determined that if the result of the analysis is more than 5.0 milligram per liter (mg/L) then the waste

needs to be disposed of as lead-contaminated waste.

The representative composite sample of building materials was collected, and submitted to the laboratory

for analysis by EMSL. The results of all TCLP are summarized in Table 6:

Summary of Positive XRF Measurements

Northampton VA Medical Center, Building T7

Reading

No. Floor Location

Substrate and

Component Side Condition Color

Results

(mg/cm2)

2710 First Exterior Wood Wall (Exterior) South Peeling White 7.7

2713 First Exterior Wood Window

Casing South Peeling White 21.9

2714 First Exterior Wood Window Sash South Peeling White 24.5

2715 First Exterior Metal Wall (Exterior) East Peeling White 4.9

2717 First Exterior Metal Roof East Peeling Brown 4.7

2718 First Exterior Wood Trim East Peeling White 4.5

2719 First Exterior Metal Security Bars East Peeling Brown 1.7

2720 First Exterior Wood Door North Fair Brown 6.5

2721 First Exterior Wood Door Casing North Fair White 23.8

2723 First Paint Shop Wood Window Sash West Intact White 0.11

2725 First Paint Shop Metal Beam West Intact White 0.5

2728 First Paint Shop Wood Door North Fair White 17.3

2733 First Office Wood Screen Door North Intact White 10.4

2736 First Toilet Wood Stall West Intact Gray 0.16

2737 First Toilet Wood Column North Intact White 0.11

2738 First Toilet Wood Window

Casing West Intact White 0.14

2739 First Toilet Wood Window Sash West Intact White 0.16



The TCLP laboratory result for lead is reported 94 mg/L for Building T7. The result does exceed the

regulatory threshold of 5.0 mg/L. The TCLP laboratory report is provided in Appendix B.

It is important to note that the OSHA 29 CFR 1926.62 (the Lead in Construction Standard) applies to

demolition activity that disturbs any lead-containing paint. Therefore, paints that were not classified as

lead-based paint but did have a lead detection are regulated under this standard in addition to paints

classified as lead-based paint. Because several paints did contain low levels of lead, the OSHA Lead in

Construction Standard should be utilized during building demolition.

The Lead paint is present in the building as sampled via XRF.

Please refer to the report in Appendix D

Lead in Soil

Lead is naturally present in all soils. It occurs generally in the range of 15 to 40 parts lead per million parts

of soil (ppm), or 15 to 40 milligrams lead per kilogram of soil (mg/kg). Pollution can increase soil lead

levels to several thousand ppm; the major cause of soil lead contamination in populated areas is the

weathering, chipping, scraping, sanding, and sand-blasting of structures bearing lead-based paint.

In the past, significant causes of soil contamination by lead included the use of tetraethyl lead as an anti-

knock ingredient in gasoline and lead arsenate as an insecticide in fruit orchards. Automotive lead

emissions have effectively ceased with the phasing out of leaded fuels, and with the development of more

effective pesticides and Integrated Pest Management (IPM), lead arsenate is no longer in use.

Unfortunately, lead persists in soil for many hundreds of years and past use of these products continues

to present problems in some areas.

Soil lead becomes a health risk when directly ingested or inhaled as dust. Garden produce, which has

accumulated lead in its tissue or has soil particles adhering to it, can also be a hazard if eaten. Lead

poisoning is a particular concern for young children (under 6) because their rapidly developing bodies are

very sensitive to the effects of lead, and their play habits tend to increase exposure.

Under 40 CFR 261 the regulatory threshold is 5.0 mg/L (or 5,000 mg/kg). The four (3) drip line samples

were found to be below the threshold. The results are summarized in Table 3 below.

TABLE 3

TCLP Lead in Soil for Building T7

Sample Number Location Result (mg/l)

Pb-T7-01 South side drip line < 0.40



7.0 POLYCHLORINATED BIPHENYLS (PCBS) RESULTS

Many building products produced from the 1950’s through the 1970’s were manufactured with PCBs as a

key ingredient because of their non-flammability, chemical stability, high boiling point, and electrical and

thermal insulating properties. PCBs were also added to many building products as a plasticizer, which

increased their flexibility. Although the use of products with PCBs is unauthorized per Section 6(e)(2) of

the Toxics Substances Control Act (TSCA) and in Chapter 40, Section 761.20 of the Code of Federal

Regulations (CFR), there is no regulatory requirement to test products in use to determine their PCB

concentration.

If PCBs are detected in building materials at concentrations between 1 ppm and 50 ppm and the building

materials meet the definition of a PCB Excluded Product as defined in 40 CFR 761.3, then the

Massachusetts Department of Environmental Protection (DEP) recommends that the building materials

be removed.

Building materials containing PCBs at concentrations greater than or equal to 50 parts per million (ppm)

are not authorized for use under Section 6(3)(2) of TSCA and must be removed and properly disposed of

as PCB Bulk Product Waste in accordance with 40 CFR 761.62.

Apex collected samples from different materials in the building. These samples were also analyzed for

PCBs in accordance with EPA 40 CFR 761. Refer to Table 4 - PCB Bulk Sample Results. The results for

Table 4 are summarized below:

Sample Number Location / Material

Total result mg/Kg

(see Appendix B and Table 4)

ND = None Detected

PCB-B-T7-01 Exterior Window Glazing ND

PCB-B-T7-02 Exterior paint 1.5

PCB-B-T7-03 Interior Floor paint 28

PCB-B-63-04 Metal to wood sealant ND

The bulk material samples were submitted to EMSL Analytical, Inc., a certified laboratory, for analysis.

The samples were prepared and analyzed in accordance with the EPA analytical method SW-846 3540C.

Refer to Appendix B for the laboratory analytical reports.

.

8.0 PCB SOIL RESULTS

Representative soil samples were collected from each of building ‘drip-lines’ where possible submitted for

laboratory analysis. Collected soil samples were placed within laboratory provided pre-preserved

glassware and submitted to EMSL for analysis for PCBs.

Laboratory samples were analyzed in accordance EPA SW-846 3550B/8082A/608 method.

The PCB regulations separate PCB waste into two categories, with different disposal requirements for

each. When assessing your building, it is important to determine what types of PCB waste you will be



disposing of.

A PCB-containing material is considered PCB bulk product waste if the concentration of PCBs in the

material is greater than or equal to (≥) 50 ppm (see, 40 C.F.R. § 761.3). PCB bulk product waste includes

waste derived from manufactured products containing PCBs in a non-liquid state where the concentration

at the time of designation for disposal is ≥ 50 ppm PCBs (see, 40 C.F.R. §§ 761.3 & 761.62). Additionally,

the definition of PCB bulk product waste includes building materials that have been coated or serviced

with PCBs. That is, masonry, wood, metals, and other building materials that are purposely coated with a

PCB-containing material are regulated as PCB bulk product waste if the material coating the building

materials contains PCBs at concentrations ≥ 50 ppm.

If PCBs have contaminated either the surrounding building materials or adjacent soil, these materials are

considered PCB remediation waste. PCB remediation waste is subject to the cleanup and disposal

requirements according to 761.61.

Although state, local, and federal regulations may allow for the disposal of materials containing PCBs at

concentrations of <50 ppm, some disposal facilities will not accept waste with any concentration of PCBs.

When finding a disposal facility, you should ensure that the facility is able and willing to accept the waste.

Based on the soil analytical data, a reportable condition under the MCP and under 40CFR761 does not

exist and the soils may be re-used. A summary of the soil sample results are provided in Table 5 (which

is summarized below). A copy of the laboratory analytical report is provided in Appendix B.

TABLE 5 summery

PCB in Soil for Building T7


ND = None Detected

PCB-T7-01 South side drip line 0.233

9.0 INACCESSIBLE AND LIMITED ACCESS SPACES

Every reasonable attempt was made to locate ACM in the areas surveyed. No area were determined to

be inaccessible. However there are always the potential of concealed areas/materials that are considered

likely to contain suspect ACMs.

10.0 FINDINGS/RECOMMENDATIONS

Materials suspected of potentially containing asbestos were identified during the inspection and sampled

for asbestos content. According to the laboratory analysis, there is several building materials found to

contain 1% or greater asbestos. Table 2, the Homogeneous Material List, provides a complete list of the

identified suspect ACMs.

Since hidden ACMs maybe present, actions should be taken to prevent fiber release and to minimize



exposure to the customers, building owners, employees and demolition contractors to asbestos fibers.

The following are Apex’s recommendations for management of these ACMs.

• The renovation/demolition contractor and other subcontractors working within the building should

be made aware of the locations of the ACMs and the possibility of concealed suspect ACMs that

could be found during renovation/demolition activities. They should be advised not to disturb the

identified ACMs or suspect ACMs.

• OSHA requirements do apply when trace amounts of asbestos are found. OSHA requires that

any detectable level of asbestos is hazardous, and workers must not exceed permissible

exposure limits during removal. Apex recommends that any material with <1% asbestos be

treated and handled as if it were an ACM up until the point of disposal. ACM with concentration

<1% do not require to be disposed of as asbestos, even under OSHA regulation.

• Any concealed building materials discovered during renovation/demolition activities, which are

suspected to contain asbestos, should be sampled by a MA DLS-licensed asbestos inspector and

analyzed by an NVLAP-accredited laboratory to confirm the absence or presence of asbestos

prior to the disturbance of such materials. If the materials are found to contain asbestos,

applicable local, state and federal regulations will apply.

• During planned future demolition activities that will impact the identified ACMs in the project site,

they should be properly removed by a MA DLS-licensed asbestos abatement contractor prior to

construction activities. Abatement activities must be performed in compliance with applicable

local, state, and federal requirements.

• Any construction waste or debris leaving the site should be tested for waste characterization and

disposal purposes.

11.0 DISCLAIMER

The results, findings, conclusions, and recommendations expressed in this report are based only on

conditions that were noted during the November 6 through November 10, 2017, inspection of Building T7

of the VA of Western Massachusetts, located in Leeds Massachusetts. Apex’s selection of sample

locations and frequency of sampling was based on Apex’s observations and the assumption that like

materials in the same area are homogeneous in content, so far as access was granted.

This report is for the sole benefit of Acela Engineering and the VA of Western Massachusetts, and may

not be relied upon by any other person or entity. The findings and conclusions for this work are limited in

time and scope to the circumstances. Implementation or use of the recommendations, findings, or

conclusions from this work in no way assures the elimination of present or future liability of fulfillment of

the property owner’s obligation under any local, state, or federal laws.

The report is designed to aid the building owner, architect, construction manager, general contractors,



and potential asbestos abatement contractors in locating ACM. Under no circumstances is the report

to be utilized as a bidding document or as a project specification document since it does not have

all the components required to serve as an Asbestos Project Design document or an Abatement

Work Plan. The quantities of ACMs identified in this report are only estimates and should not be used for

bidding or developing specifications for abatement. It is the responsibility of the asbestos abatement

contractor to calculate actual quantities and develop the abatement plan accordingly.

Our professional services have been performed, our findings obtained, and our conclusions and

recommendations prepared in accordance with customary principles and practices in the fields of

environmental science and engineering. This statement is in lieu of other statements either expressed or

implied. This report does not warrant against future operations or conditions, nor does it warrant against

operations or conditions present of a type or at a location not investigated.

Any conditions or materials that could not be visually identified on the surface were not inspected and

may differ from those conditions or materials noted. It was not within the scope of the inspection to

remove surface materials to investigate portions of the structure or materials that lay beneath the surface.

FIGURES

TABLES

TABLE 1

NESHAP SAMPLING PROTOCOL

Type of Material Estimated Quantity Required Samples

Sprayed or Troweled-on Surfacing Material

Greater than 5,000 ft2 7

Between 1,000 ft2 and 5,000 ft2 5

Less than 1,000 ft2 3

Thermal System Insulation All Quantities 3

Miscellaneous Materials All Quantities

Per NESHAP, these materials must be sampled “in a manner sufficient to determine whether or not they contain asbestos.” Apex will generally collect 1 to 3 samples of such material based upon the inspector’s judgment.

NOTE: These sampling protocol quantities are per functional area and/or homogeneous area.

TABLE 2

Building T7 ASBESTOS SAMPLE RESULTS

MATERIAL TYPE LOCATION SAMPLE

IDs

ASBESTOS

CONTENT

Confirmatory Sample – Exterior window glazing

Windows 01a None Detected

Metal roof to wood siding sealer At metal to roof interface 02a-c 5% Chrysotile

2’x4’ Suspended Ceiling Tiles Office 03A None Detected

Particle board wallboard Office & Hall 04a-c None Detected

ACM Table from 2010 Report

12” white floor tile Office 01a-c None Detected

Mastic for 12” white floor tile Office 02a-c None Detected

12” gray floor tile Office 03a-c 3% Chrysotile

Mastic for 12” gray floor tile Office 04a-c None Detected

9” gray floor tile Hallway and bathroom 05a-c 5% Chrysotile

Mastic for 9” gray floor tile Hallway and bathroom 06a-c None Detected

2’x4’ Suspended Ceiling Tiles Office 07a-c None Detected

Confirmatory Sample – Exterior window glazing

Windows 08a-b None Detected

TABLE 3

TCLP Lead in Soil for Building T7


Pb-T7-01 South side drip line < 0.40

Table 4

PCB Bulk Sample Results

Sample # Description

PCB-B-T7-01

Building T7 – Exterior window glazing

PCB Parameter Sample Results Detection Limit Units Method

Aroclor-1016 ND 0.94 mg/kg dry SW-846 3540C










PCB-B-T7-02

Building T7 – Exterior Paint







Aroclor-1254 1.5 0.95 mg/kg dry SW-846 3540C





PCB-B-T7-03

Building T7 – Interior Floor Paint







Aroclor-1254 24 0.94 mg/kg dry SW-846 3540C

Aroclor-1260 4.0 0.94 mg/kg dry SW-846 3540C



Table 4

PCB Bulk Sample Results

Continued


PCB-B-T7-04

Building T7 – Wood to metal sealer











1 μg /kg = 0.001 mg/kg : 1mg/kg = 1,000 μg/kg

Table 5

PCB Soil Sample Results


PCB-T7-01

Building T7 – North side drip line soil











1 μg /kg = 0.001 mg/kg : 1mg/kg = 1,000 μg/kg

TABLE 6

TCLP LEAD SAMPLING RESULTS

Sample Number Location of Material TCLP Lead Concentration

TCLP-T7 Building T7: Building Composite sample 94 mg/L

The TCLP laboratory result for lead is reported at 94 mg/L for Building T7. The result does exceed the regulatory threshold of 5.0 mg/L. The TCLP laboratory report is provided in Appendix B.

APPENDIX A

Certifications

AIHA Laboratory Accreditation Programs, LLC

acknowledges that

EMSL Analytical, Inc. 200 Route 130 North, Cinnaminson, NJ 08077

Laboratory ID: 100194 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2005 international standard, General Requirements for the Competence of Testing and Calibration Laboratories in the following:

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE Accreditation Expires: September 01, 2018 ENVIRONMENTAL LEAD Accreditation Expires: September 01, 2018 ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: September 01, 2018 FOOD Accreditation Expires: UNIQUE SCOPES Accreditation Expires: Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:2005 and AIHA-LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA-LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.

William Walsh, CIH Chairperson, Analytical Accreditation Board

Cheryl O. Morton Managing Director, AIHA Laboratory Accreditation Programs, LLC

Revision 15: 03/30/2016 Date Issued: 08/31/2016

http://www.aihaaccreditedlabs.org/

Effective: 04/10/2015 100194_Scope_IHLAP (Method Addition)_2017_04_12 Page 1 of 2

AIHA Laboratory Accreditation Programs, LLC

SCOPE OF ACCREDITATION EMSL Analytical, Inc. Laboratory ID: 100194 200 Route 130 North, Cinnaminson, NJ 08077 Issue Date: 04/13/2017 The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory’s current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

Industrial Hygiene Laboratory Accreditation Program (IHLAP)

Initial Accreditation Date: 02/01/1989

IHLAP Scope Category

Field of Testing (FoT) (FoTs cover all relevant

IH matrices)

Technology sub-type/ Detector

Published Reference Method/Title of In-

house Method

Method Description or Analyte

(for internal methods only)

Chromatography Core

Gas Chromatography

GC/FID

NIOSH 1003 Modified NIOSH 1005

NIOSH 1400 Modified NIOSH 1500 Modified NIOSH 1501 Modified NIOSH 1550 Modified NIOSH 1603 Modified NIOSH 2000 Modified

GC/ECD

NIOSH 5502 Modified NIOSH 5503 Modified NIOSH 5510 Modified OSHA 1010 Modified

GC/MS GC/MS EPA TO-15 Gas Chromatography (Diffusive Samplers) NIOSH 1501 Modified

Ion Chromatography (IC)

NIOSH 6004 Modified NIOSH 6011 NIOSH 7903

OSHA ID-165SG OSHA ID-214

OSHA ID-215 Modified

Liquid Chromatography HPLC/FL NIOSH 2016 Modified HPLC/UV NIOSH 5506 Modified HPLC/MS NIOSH 9111 Modified

Spectrometry Core Atomic Absorption CVAA NIOSH 6009 Modified

Effective: 04/10/2015 100194_Scope_IHLAP (Method Addition)_2017_04_12 Page 2 of 2

IHLAP Scope Category

Field of Testing (FoT) (FoTs cover all relevant

IH matrices)

Technology sub-type/ Detector

Published Reference Method/Title of In-

house Method

Method Description or Analyte

(for internal methods only)

Spectrometry Core

Atomic Absorption CVAA

OSHA ID-140 Modified OSHA ID-145

FAA NIOSH 7082 GFAA NIOSH 7105

Inductively-Coupled Plasma

ICP/MS NIOSH 7300 Modified ICP/AES NIOSH 7300 Modified

X-ray Diffraction (XRD) NIOSH 7500 Modified OSHA ID-142 Modified

UV/VIS (Colorimetric) NIOSH 6010 Modified

Asbestos/Fiber Microscopy Core

Polarized Light Microscopy (PLM) EPA 600/R-93/116

Phase Contrast Microscopy (PCM) NIOSH 7400

Transmission Electron Microscopy (TEM)

EPA AHERA - 40 CFR Part 763

EPA AHERA Method (40 CFR 763, Subpart E,

Appendix A, Mandatory Method

NIOSH 7402

Miscellaneous Core Gravimetric

NIOSH 0500 NIOSH 0600 NIOSH 5524

Thermo-optical Analysis (TOA) NIOSH 5040

Beryllium Testing Inductively-Coupled Plasma ICP/MS NIOSH 7300

NIOSH 7303

A complete listing of currently accredited Industrial Hygiene laboratories is available on the AIHA-LAP, LLC website at: http://www.aihaaccreditedlabs.org

http://www.aihaaccreditedlabs.org/

APPENDIX B

Laboratory Data Sheets and Chain-of-Custodies

APPENDIX B

Laboratory Data Sheets and Chain-of Custodies

Asbestos

EMSL Analytical, Inc.200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974

http://www.EMSL.com / [email protected]

041732757EMSL Order:

Customer ID: APEX30

Customer PO:

Project ID:

Attention: Phone:Ethan Platt (860) 282-1700

Fax:Apex Companies, LLC (860) 282-1800

Received Date:58H Connecticut Ave. 11/13/2017 9:00 AM

Analysis Date:South Windsor, CT 06074 11/19/2017

Collected Date: 11/06/2017

Project: VA Central Western Massachusetts on behalf of Acela Engineering / Building T7 / VAMC Northampton Campus,

MS 138 / 421 North Main Street, Leeds, MA 01053

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

01A

041732757-0001

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Building T7 Exterior -

Exterior Window

Glazing

02A

041732757-0002

5% ChrysotileNon-fibrous (Other)95%White/Black

Non-Fibrous

Homogeneous

Building T7 Exterior -

Metal to Wood Siding

Sealant

02B

041732757-0003

Positive Stop (Not Analyzed)Building T7 Exterior -


Sealant

02C

041732757-0004

Positive Stop (Not Analyzed)Building T7 Exterior -


Sealant

03A

041732757-0005

None DetectedNon-fibrous (Other)20%Cellulose

Min. Wool

60%

20%

Tan/White

Fibrous

Homogeneous

Office End Room -

2x4 SCT

04A

041732757-0006

None DetectedNon-fibrous (Other)5%Cellulose95%Brown

Fibrous

Homogeneous

Office - Particle Board

Walls

04B

041732757-0007


Fibrous

Homogeneous

Hall - Particle Board

Walls

04C

041732757-0008


Fibrous

Homogeneous

Hall - Particle Board

Walls

Analyst(s)

Edward Zambrano (3)

Natalia Dispensa (3)

Benjamin Ellis, Laboratory Manager

or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no

responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim

product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL

recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless

requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Initial report from: 11/20/2017 07:59:20

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 11/20/2017 7:59 AM

OrderID: 041732757

Page 1 Of 1

APPENDIX B


Building Composite TCLP (Lead)

Client Sample Description ConcentrationLab ID AnalyzedLead

Collected

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone/Fax: (856) 303-2500 / (856) 786-5974http://www.EMSL.com [email protected]

Attn: Ethan PlattApex Companies, LLC58H Connecticut Ave.South Windsor, CT 06074

Received: 11/13/17 10:30 AM

ACELA-001

Fax: (860) 282-1800Phone: (860) 282-1700

Project:

Collected:

Test Report: Toxicity Characteristic Leaching Procedure (SW846, 1311/7420)

201711719CustomerID: APEX30CustomerPO:ProjectID:

EMSL Order:

Site: Bldg T7201711719-0001T7 94 mg/L11/14/2017

Site: Bldg T8201711719-0002T8 50 mg/L11/14/2017

Site: Bldg T12201711719-0003T12 27 mg/L11/14/2017

Site: Bldg T13201711719-0004T13 48 mg/L11/14/2017

Site: Bldg T15201711719-0005T15 0.72 mg/L11/14/2017

Site: Bldg 27201711719-000627 <0.40 mg/L11/15/2017

Site: Bldg 34201711719-000734 78 mg/L11/15/2017

Site: Bldg 35201711719-000835 <0.40 mg/L11/15/2017

Site: Bldg 40201711719-000940 <0.40 mg/L11/15/2017

Site: Bldg 41201711719-001041 53 mg/L11/15/2017

Site: Bldg 42201711719-001142 <0.40 mg/L11/16/2017

Site: Bldg 52201711719-001252 <0.40 mg/L11/16/2017

Site: Bldg 63201711719-001363 <0.40 mg/L11/16/2017

Page 1 of 1

Phillip Worby, Lead Laboratory Manageror other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 11/20/2017 9:29:41 AM

The test results contained within this report meet the requirements of NELAC unless otherwise noted. This report relates only to those items tested. Samples received in good condition unless otherwise noted. Quality Control Data associated with this sample set is within acceptable limits, unless otherwise noted. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit.Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367

Initial report from 11/20/2017 09:29:41

http://www.EMSL.com

mailto:[email protected]

OrderID: 201711719

Page 1 Of 2

OrderID: 201711719

Page 2 Of 2

APPENDIX B


TCLP Lead in Soil

Client Sample Description ConcentrationLab ID AnalyzedLead

Collected



Received: 11/15/17 10:30 AM

ACELA-001 / Bldg T7

Fax: (860) 282-1800Phone: (860) 282-1700

Project:

11/14/2017Collected:

Test Report: Toxicity Characteristic Leaching Procedure (SW846, 1311/7420)


EMSL Order:

Site: South Side201711850-0001Pb-T7-01 <0.40 mg/L11/17/201711/14/2017

Page 1 of 1

Phillip Worby, Lead Laboratory Manageror other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 11/22/2017 10:02:09 AM

The test results contained within this report meet the requirements of NELAC unless otherwise noted. This report relates only to those items tested. Samples received in good condition unless otherwise noted. Quality Control Data associated with this sample set is within acceptable limits, unless otherwise noted. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit.Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367

Initial report from 11/22/2017 10:02:09

http://www.EMSL.com


OrderID: 201711850

Page 1 Of 2

OrderID: 201711850

Page 2 Of 2

APPENDIX B


PCBs in Building Materials

Phillip Worby, Environmental Chemistry Laboratory Director

Approved By:

Fax: (860) 282-1800Phone: (860) 282-1700

The following analytical report covers the analysis performed on samples submitted to EMSL Analytical, Inc. on 11/13/2017. The results are tabulated on the attached data pages for the following client designated project:

ACELA-001 / Bldg T7

The reference number for these samples is EMSL Order #011709079. Please use this reference when calling about these samples. If you have any questions, please do not hesitate to contact me at (856) 303-2500.

11/29/2017Attn: Ethan PlattApex Companies, LLC58H Connecticut Ave.South Windsor, CT 06074

The test results contained within this report meet the requirements of NELAP and/or the specific certification program that is applicable, unless otherwise noted.NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, CA ELAP 1877

The samples associated with this report were received in good condition unless otherwise noted. This report relates only to those items tested as received by the laboratory. The QC data associated with the sample results meet the recovery and precision requirements established by the NELAP, unless specifically indicated. All results for soil samples are reported on a dry weight basis, unless otherwise noted. This report may not be reproduced except in full and without written approval by EMSL Analytical, Inc.

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone: (856) 303-2500 Fax: (856) 858-4571 Email: [email protected]

Page 1 of 3




EMSL Order:

Analytical Results


Received: 11/13/17 9:00 AM

ACELA-001 / Bldg T7

Fax: (860) 282-1800Phone: (860) 282-1700

Project:

Client Sample Description Lab ID:PCB-B-T7-01 011709079-0001Bldg T7 Ext. Window Glaze

Collected: 11/8/2017

Method Parameter Result UnitsAnalysis Date AnalystRL

Prep Date Analyst

3540C/8082A Aroclor-1016 EHND mg/Kg 11/29/20170.94 11/28/2017 AB









Client Sample Description Lab ID:PCB-B-T7-02 011709079-0002Bldg T7 Ext. Paint



Prep Date Analyst






3540C/8082A Aroclor-1254 EH1.5 mg/Kg 11/29/20170.95 11/28/2017 AB




Client Sample Description Lab ID:PCB-B-T7-03 011709079-0003Bldg T7 Int. Floor Paint



Prep Date Analyst






3540C/8082A Aroclor-1254 EH24 mg/Kg 11/29/20170.94 11/28/2017 AB

3540C/8082A Aroclor-1260 EH4.0 mg/Kg 11/29/20170.94 11/28/2017 AB



Page 2 of 3ChemSmplw/RDL/NELAC-7.44.3 Printed: 11/29/2017 5:14:24 PM

http://www.EMSL.com




EMSL Order:

Analytical Results


Received: 11/13/17 9:00 AM

ACELA-001 / Bldg T7

Fax: (860) 282-1800Phone: (860) 282-1700

Project:

Client Sample Description Lab ID:PCB-B-T7-04 011709079-0004Bldg T7 Metal / Wood Seal



Prep Date Analyst










ND - indicates that the analyte was not detected at the reporting limitRL - Reporting Limit (Analytical)

Definitions:


http://www.EMSL.com


OrderID: 011709079

Page 1 Of 1

APPENDIX B


PCBs in Soil

Phillip Worby, Environmental Chemistry Laboratory Director

Approved By:

Fax: (860) 282-1800Phone: (860) 282-1700

The following analytical report covers the analysis performed on samples submitted to EMSL Analytical, Inc. on 11/13/2017. The results are tabulated on the attached data pages for the following client designated project:

ACELA-001

The reference number for these samples is EMSL Order #011709080. Please use this reference when calling about these samples. If you have any questions, please do not hesitate to contact me at (856) 303-2500.

11/27/2017Attn: Ethan PlattApex Companies, LLC58H Connecticut Ave.South Windsor, CT 06074

The test results contained within this report meet the requirements of NELAP and/or the specific certification program that is applicable, unless otherwise noted.NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, CA ELAP 1877

The samples associated with this report were received in good condition unless otherwise noted. This report relates only to those items tested as received by the laboratory. The QC data associated with the sample results meet the recovery and precision requirements established by the NELAP, unless specifically indicated. All results for soil samples are reported on a dry weight basis, unless otherwise noted. This report may not be reproduced except in full and without written approval by EMSL Analytical, Inc.

EMSL Analytical, Inc.200 Route 130 North, Cinnaminson, NJ 08077Phone: (856) 303-2500 Fax: (856) 858-4571 Email: [email protected]

Page 1 of 2




EMSL Order:

Analytical Results


Received: 11/13/17 4:30 PM

ACELA-001

Fax: (860) 282-1800Phone: (860) 282-1700

Project:

Client Sample Description Lab ID:PCB-T7-01 011709080-0001South Side



Prep Date Analyst

SM 2540G Total Solids MM89 % 11/14/20170.0 11/14/2017 MM

3550C/8082A Aroclor-1016 EHND µg/Kg 11/15/201719 11/14/2017 SD





3550C/8082A Aroclor-1254 EH140 µg/Kg 11/15/201719 11/14/2017 SD

3550C/8082A Aroclor-1260 EH93 µg/Kg 11/15/201719 11/14/2017 SD



ND - indicates that the analyte was not detected at the reporting limitRL - Reporting Limit (Analytical)

Definitions:


http://www.EMSL.com


OrderID: 011709080

Page 1 Of 1

APPENDIX C

Photographic Log

Photograph 1 View of exterior front of the Building T7

Photograph 2 View of exterior back of Building T7

Photograph 3 View of the interior of Building T7

APPENDIX D

Historic Reports

VOLUME II

ASBESTOS CONTAINING MATERIAL &

LEAD CONTAINING PAINT

SURVEY REPORT

BUILDING T7

VISN 1 Northampton VA Medical Center

421 North Main Street Leeds, Massachusetts

Project No. 2009023.011 December 30, 2010

5 Alfred Circle Bedford, MA 01730-2318

Telephone: (781) 275-6050 Toll Free: (800) 877-6050 Facsimile: (781) 275-5651

[email protected] www.mabbett.com

© 2010, Mabbett & Associates, Inc.

Northampton VAMC - Building T7 December 2010 ©2010, Mabbett & Associates, Inc. Page i Vol II Survey Rpt Northampton Bldg T7 FINAL(12-30-10).doc

ACKNOWLEDGMENT This Asbestos Containing Materials (ACM) and Lead Containing Paint (LCP) Building Survey Report was prepared for the Veterans Affairs (VA) New England Healthcare System (VISN 1) in accordance with an established scope of work as defined in Contract Number VA241-P-1653. The information presented herein is based on the facts and information conveyed to or received by Mabbett & Associates, Inc. (M&A) during the preparation of this report. If any of the information provided to M&A that was used in preparing this report is incorrect, incomplete, or subject to change, M&A would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to M&A as of the date of this report and considered applicable to this report. This individual building report from Volume II which contains building specific lead and asbestos findings is part of the Comprehensive VAMC Lead and Asbestos Survey Report consisting of:

Volume I - General

Chapter 1 - Introduction and Executive Summary Chapter 2 - Asbestos Operations & Maintenance (O&M) Manual Chapter 3 - Asbestos Containing Materials (ACM) Survey Tables Chapter 4 - Lead Containing Paint Survey Tables

Volume II – Individual Building Reports

Individual Building Reports Chapters including:

Cover page with building number Building narrative summary Floor plans Relevant asbestos findings for the building Relevant lead containing paint findings for the building Relevant photos

Volume III – Appendices and Supporting Data

Appendix A - Asbestos Laboratory Analysis Reports and Laboratory Certifications Appendix B - Inspector Field Data Sheets/Chains-of-Custody Appendix C - Personnel Certifications & Licenses Appendix D - XRF Performance Characteristics/Calibration Records Appendix E - Lead Laboratory Analysis Reports and Laboratory Certifications (If Applicable)

Volume IV – HUD Residential LBP Reports (If Applicable)

Northampton VAMC - Building T7 December 2010 ©2010, Mabbett & Associates, Inc. Page ii Vol II Survey Rpt Northampton Bldg T7 FINAL(12-30-10).doc

This report was prepared by the following Mabbett & Associates, Inc. personnel: Michael F. Delaney Project Manager Massachusetts Asbestos Inspector AI031436 Massachusetts Management Planner AP000048 This report has been reviewed and approved by: MABBETT & ASSOCIATES, INC.

Robert K. McKinley, MPH, CIH, LIH Director of Industrial Hygiene Services Massachusetts Asbestos Inspector AI000314

Northampton VAMC - Building T7 December 2010 ©2010, Mabbett & Associates, Inc. Page iii Vol II Survey Rpt Northampton Bldg T7 FINAL(12-30-10).doc

TABLE OF CONTENTS Description Page 1.0 INTRODUCTION & EXECUTIVE SUMMARY ....................................................................1 2.0 BUILDING DESCRIPTION .................................................................................................1 3.0 ASBESTOS SURVEY.........................................................................................................1

3.1 Sampling Methodology .............................................................................................. 1 3.2 Analytical Methodology.............................................................................................. 3 3.3 Summary of Asbestos Containing Materials (ACM) Findings .................................... 3

4.0 LEAD SCREENING SURVEY ............................................................................................4 4.1 Screening Survey Methodology................................................................................. 4 4.2 Summary of Lead Screening Survey Findings........................................................... 5

5.0 LIMITATIONS.....................................................................................................................6 6.0 CLOSING REMARKS.........................................................................................................6

6.1 Asbestos.................................................................................................................... 6 6.2 Lead Containing Paint ............................................................................................... 7

Tables Table 1 – Specific Inaccessible Areas ........................................................................................2 Table 2 – Summary of Positive ACM Samples ...........................................................................4 Table 3 – Summary of Positive XRF Measurements ..................................................................5 Table 4 – Summary of ACM Building Results, including negative results.................. Appendix A Table 5 – Summary of XRF Measurements............................................................... Appendix B Figures Figure 1 – Asbestos Survey Summary Plan - Building T7, Floor 1 Figure 2 – Lead Survey Summary Plan - Building T7, Floor 1 Appendices Appendix A – Table 4, Summary of ACM Building Results, including negative results Appendix B – Table 5, Summary of XRF Measurements Appendix C – Relevant Photographs of ACM Appendix D – Relevant Photographs of Non-Intact Lead Containing Paint

Northampton VAMC - Building T7 December 2010 ©2010, Mabbett & Associates, Inc. Page 1 of 7 Vol II Survey Rpt Northampton Bldg T7 FINAL(12-30-10).doc

1.0 INTRODUCTION & EXECUTIVE SUMMARY Mabbett and Associates, Inc. (M&A), with Covino Environmental Associates, Inc. (Covino) as a sub-contractor, performed surveys for suspect asbestos containing building materials (ACM) and screenings of suspect lead containing paint (LCP) surfaces utilizing an X-Ray Fluorescence (XRF) analyzer. Surveys were performed of selected buildings at the VA Medical Center (VAMC) located at 421 North Main Street, Leeds, MA, under Contract VA241-P-1653. A complete list of buildings surveyed is in Volume I of this report. Site survey work was performed during May and June 2010, by appropriately credentialed personnel as required. Collected suspect ACM samples were submitted to a certified analytical laboratory for asbestos analysis by polarized light microscopy (PLM) using positive stop methodology and transmission electron microscopy (TEM) where indicated. When necessary, paint chip samples were collected and submitted to a certified analytical laboratory for lead content analysis using atomic absorption spectroscopy. The survey effort involved the collection of the following samples, resulting in the following conclusions:

24 bulk samples for suspect ACM were collected in this building. Based on laboratory analysis of suspect ACM, 2 of the collected samples

contained asbestos greater than or equal to 1%. 31 XRF analyzer measurements of building surfaces were taken in this building. 17 of the XRF measurements revealed concentrations of lead that exceeded

0.1 mg/cm2. This building report consists of a summary of findings, floor plans indicating positive sample locations, detailed analytical findings for the specific surveyed building materials, and photos of identified ACM. In addition, photos of lead containing paint greater than 1.0 mg/cm2 and in an other than intact condition, when observed, were provided. Laboratory certificates of analysis and field data sheets for this building report are available in Volume III of the Comprehensive VAMC Lead and Asbestos Survey Report. 2.0 BUILDING DESCRIPTION According to information provided by the VAMC Office of Facilities Management and observations made by the M&A team at the time of the survey, Building T7 was a Storage Building and occupied approximately 1,200 square feet. 3.0 ASBESTOS SURVEY

3.1 Sampling Methodology

A visual screening inspection was conducted by state licensed asbestos inspectors throughout the building to identify locations of suspect ACM. Only areas that were accessible during the field work phase were inspected. Every effort was made during the initial field survey work to access areas as necessary to complete the survey. However, if any areas remained inaccessible to the survey team, they are indicated in Table 1 below.


Table 1 – Specific Inaccessible Areas Northampton VA Medical Center, Building T7

Building Floor Room

No. Reason Area Was Inaccessible and Survey

Impacts, If Applicable

There were no inaccessible areas identified during this survey.

Other general areas that were inaccessible or where the survey was limited to visual observation only are identified below: • Within walls • Within fire doors • Enclosed pipe/duct chases • Inside mechanical equipment/ductwork • Above fixed drywall or plaster ceilings ACM surveys should be performed prior to any proposed renovations or maintenance involving inaccessible areas. Bulk samples were collected of suspect ACM in accordance with US Environmental Protection Agency (EPA) Asbestos Hazard and Emergency Response Act (AHERA) and VISN 1 approved M&A VISN 1 Survey Program Standard Operating Procedure (SOP). Roofing materials were not sampled unless otherwise indicated in order to maintain applicable warranties. Bulk suspect ACM sampling was conducted according to the following sampling plan: (a) Surfacing material:

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

(2) At least five bulk samples shall be collected from each homogeneous area that is greater than 1,000 ft2 but less than or equal to 5,000 ft2.

(3) At least seven bulk samples shall be collected from each homogeneous area that is greater than 5,000 ft2.

(b) Thermal system insulation:

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

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

(3) Sufficient samples shall be collected from elbows and fittings to determine if it contains ACM.

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


(c) Miscellaneous material: (1) At least one bulk sample shall be collected from each homogeneous area that is less

than 100 ft2. (2) At least three bulk samples shall be collected from each homogeneous area that is

greater than 100 ft2.

3.2 Analytical Methodology

The collected bulk samples were submitted under chain of custody procedures to ProScience Analytical Services, Inc. (ProScience) of Woburn, MA for polarized light microscopy (PLM) analysis of bulk materials via EPA 600/R-93/116 Method. If applicable, sample results that revealed trace concentrations of asbestos by PLM were re-analyzed using transmission electron microscopy (TEM) analysis. ProScience is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 200090-0). Duplicate bulk samples were submitted to Covino. Covino is accredited by the American Industrial Hygiene Association (AIHA) and participates in the National Voluntary Laboratory Accreditation Program (NVLAP Lab Code 101781-0). A summary table containing the duplicate bulk sample results is provided in Volume I, Chapter 1, Table 4. Copies of the laboratory accreditations are included in Volume III of the Comprehensive VAMC Lead and Asbestos Survey Report. Bulk sample results are summarized in Table 4 – Summary of ACM Building Survey Results. The EPA and Occupational Safety and Health Administration (OSHA), and the Commonwealth of Massachusetts Division of Occupational Safety (DOS) define any material that contains greater than one percent (>1%) asbestos as being an ACM. The Commonwealth of Massachusetts Department of Environmental Protection (DEP) defines any material that contains equal to or greater than one percent (≥1%) asbestos as being an ACM. As such, the analytical laboratory identified bulk samples as positive for asbestos that met the regulatory criteria of equal to or greater than one percent (≥1%) asbestos.

3.3 Summary of Asbestos Containing Materials (ACM) Findings

3.3.1 Data Tables, Laboratory Results, and Field Notes Collected bulk samples confirmed by the analytical laboratory to contain ≥1% asbestos are listed in Table 2 - Summary of Positive ACM Samples. Samples analyzed by PLM containing trace levels of asbestos, defined as < 1%, are listed in Table 4 with the TEM analysis results. Volume III of the Comprehensive VAMC Lead and Asbestos Survey Report includes copies of the laboratory certificates of analysis (including duplicate samples) and Inspector Data Sheets.


Table 2 - Summary of Positive ACM Samples Northampton VA Medical Center, Building T7

Estimated Quantity Sample

No. Sample

Location ACM

Location Description of Material

Percent and Type of

Asbestos

Amount Units

Condition

VISN 1 RISK

Hazard Category

1-4*

3A 3B 3C

Office Office 12"x12"

Gray Floor Tile

3% Chrysotile 250 SF Good 4

5A Hall 5B Bath 5C Bath

Hallway &

Bathroom

9"x9" Gray Floor Tile

5% Chrysotile 150 SF Good 4

Footnotes: SF - Square Feet 1 - Analyzed by TEM LF - Linear Feet EA - Each CF - Cubic Feet * The VISN 1 hazard assessment scale 1 – 4 is a relative indicator of the risk and need for response/remediation. (1) represents the highest priority (e.g. removal or encapsulation) whereas a (4) represents the lowest priority (monitor as part of 6 month O&M program). The rating assigned by an Asbestos Management Planner, takes into account: condition, friable vs. non-friable, accessibility, occupancy (e.g. continuous, intermittent or occasional and patients/staff/visitors), potential for air erosion, potential for vibration damage, potential for disturbance/damage (e.g. exposed and in an accessible location), and potential for water damage. 3.3.2 Photographs Representative photographs of identified ACM are provided in Appendix C of this report. 3.3.3 CADD Drawings The location of each ACM sample and its abridged sample ID is shown on the CADD drawings in the Figures Section of this report. The sample ID on the drawings has been abridged (by excluding the individual room number from the full sample ID) for aesthetic purposes. Each positive ACM sample location is colored red and marked with an asterisk (*), while stop positives are marked with two (**). Building areas containing ACM have been indicated with hatching to identify the location of the identified ACM. 4.0 LEAD SCREENING SURVEY

4.1 Screening Survey Methodology

M&A completed a Lead Containing Paint Risk Analysis in accordance with the SOP and determined that a LCP screening survey was warranted in this building. The LCP screening


survey was performed by trained lead inspectors/screeners meeting the qualifications outlined in the SOP. The screening survey measured lead concentrations in accessible building surfaces by using a Niton XLp 303A XRF (serial number 18580 and 24687). The XRF instrument was calibrated at the frequency specified in the SOP.

4.2 Summary of Lead Screening Survey Findings

4.2.1 Data Tables As specified by VISN 1, a description of XRF-screened painted interior and exterior building components containing lead at concentrations greater than 0.1 mg/cm2 have been included in Table 3 below:

Table 3 - Summary of Positive XRF Measurements Northampton VA Medical Center, Building T7

Reading No.

Floor Location Substrate and Component

Side Condition Color Results

(mg/cm2)


2713 First Exterior Wood Window

Casing South Peeling White 21.9

2714 First Exterior Wood Window Sash South Peeling White 24.5 2715 First Exterior Metal Wall (Exterior) East Peeling White 4.9 2717 First Exterior Metal Roof East Peeling Brown 4.7 2718 First Exterior Wood Trim East Peeling White 4.5 2719 First Exterior Metal Security Bars East Peeling Brown 1.7 2720 First Exterior Wood Door North Fair Brown 6.5 2721 First Exterior Wood Door Casing North Fair White 23.8 2723 First Paint Shop Wood Window Sash West Intact White 0.11 2725 First Paint Shop Metal Beam West Intact White 0.5 2728 First Paint Shop Wood Door North Fair White 17.3 2733 First Office Wood Screen Door North Intact White 10.4 2736 First Toilet Wood Stall West Intact Gray 0.16 2737 First Toilet Wood Column North Intact White 0.11

2738 First Toilet Wood Window

Casing West Intact White 0.14


In addition, XRF measurements collected during the screening survey of interior and exterior building components are included in Table 5 – Summary of XRF Measurements. Table 5 includes a description of each screened surface and resulting XRF-measured lead concentration. 4.2.2 Photographs Representative photographs of building materials greater than or equal to 1.0 mg/cm2 and where in other than in intact condition (e.g. fair, peeling, cracking) are provided in Appendix D of this report.


4.2.3 CADD Drawings Based on the results of the lead screening survey a table of LCP components identified with > 0.1 mg/cm2 was developed. This table is available on the CADD drawings for use by the VAMC for exposure assessments and preliminary renovation planning. Based on the results of the survey these components identified in the CADD table and on the plan should be assumed to be LCP unless otherwise determined. 5.0 LIMITATIONS

This inspection report is the result of a diligent search of the building for ACM and LCP. Only accessible areas were included in this survey. However comprehensive this inspection appears, it does not claim to have identified all of the ACM and LCP that could be present in the facility. M&A’s survey was performed with limitations inherent to visual inspections. M&A has conducted this assessment with reasonable care and has performed this project within generally accepted industry standards. There can be no assurances, and M&A makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results provided.

6.0 CLOSING REMARKS

Prior to initiating plans for maintenance, renovation or demolition activities, the VAMC should review the asbestos and lead survey results to determine whether any of the materials identified as ACM or LCP will be disturbed by proposed work activities.

6.1 Asbestos

The purpose of the ACM survey was to identify ACM in the building within the limitations of the survey for worker protection purposes and future renovation or demolition planning purposes. In regards to asbestos, any suspect material encountered during renovation/demolition that is not identified in this report as being non-ACM should be assumed to be ACM unless sample results prove otherwise. Suspect ACM that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, that was not inspected should be assumed to contain asbestos if discovered during any renovation process or until otherwise verified. If ACM must be disturbed, the ACM must be removed by a licensed asbestos abatement contractor and be performed in accordance with applicable regulations. If proposed work activities will not disturb ACM, continuous monitoring of ACM should be conducted throughout work activities to ensure the ACM remains in an intact condition. Additionally, prior to commencing work activities, contractors involved with the work activities should be made aware of the location of ACM, within the building in which they will be working. Additional information regarding asbestos management and the Operations & Maintenance (O&M) program is outlined in the VAMC campus wide Asbestos O&M Management Plan available in Volume I of the Comprehensive VAMC Lead and Asbestos Survey Report.


6.2 Lead Containing Paint

The purpose of the LCP screening survey was to identify patterns of LCP. For the purpose of this LCP screening survey, representative interior and exterior building components were tested. The regulations addressing LCP in non-residential buildings are focused on protecting workers who are involved with paint disturbing activities and related waste disposal activities. Worker protection is regulated by OSHA regulations as well as applicable state regulations. These regulations involve air monitoring of workers to determine exposure levels when disturbing paint containing measurable lead. A LCP determination cannot determine a safe level of lead, but is intended to provide guidance as to the locations of where LCP is present. VA employees and contractors may use this information to better determine exposures of workers to airborne lead by understanding the different concentrations of lead paint on representative components and surfaces. Worker exposure controls can then be implemented and air monitoring can then be performed during activities that disturb paint on representative surfaces. A concentration of lead greater than or equal to 1.0 mg/cm2 exceeds HUD residential standards and is an indicator of risk. OSHA does not specify a safe concentration of LCP. However, for the purposes of this LCP screening survey the lead concentrations greater than 0.1 mg/cm2 have been utilized as a threshold established by VISN 1 for areas where possible worker exposures may occur.

Figures

Appendix A

Table 4 Summary of ACM Building Results

Amount Units

1A Office -12"x12" White

Floor TileNAD - - - -

1B Office -12"x12" White


1C Office -12"x12" White


2A Office -12"x12" White

Floor Tile MasticNAD - - - -

2B Office -12"x12" White


2C Office -12"x12" White


3A Office Office12"x12" Gray

Floor Tile3% Chrysotile 250 SF Good 4

3B Office Office12"x12" Gray

Floor Tile

3C Office Office12"x12" Gray

Floor Tile

4A Office -12"x12" Gray


4B Office -12"x12" Gray


4C Office -12"x12" Gray


5A HallHallway &

Bathroom

9"x9" Gray Floor

Tile5% Chrysotile 150 SF Good 4

5B BathHallway &

Bathroom

9"x9" Gray Floor

Tile

5C BathHallway &

Bathroom

9"x9" Gray Floor

Tile

6A Bath -9"x9" Gray Floor

Tile MasticNAD - - - -

6B Bath -9"x9" Gray Floor


6C Bath -9"x9" Gray Floor


7A Office - 2'x4' Ceiling Tile NAD - - - -

7B Office - 2'x4' Ceiling Tile NAD - - - -

7C Office - 2'x4' Ceiling Tile NAD - - - -

8A Exterior - Window Glazing NAD - - - -

8B Exterior - Window Glazing NAD - - - -

Estimated

QuantityCondition

VISN 1

RISK

Hazard

Category

1-4*

Stop Positive See 5A



Table 4 - Summary of ACM Building Survey Results



Sample

No.

Sample

Location

ACM

Location

Description of

Material

Percent and

Type of

Asbestos

Northampton VAMC - Building T7

©2010, Mabbett Associates, Inc. Page 1 of 2December 2010

Appendix A, Table 4 - Survey Report Northampton Building T7

Estimated

QuantityCondition

VISN 1

RISK

Hazard

C t

Table 4 - Summary of ACM Building Survey Results


Sample

No.

Sample

Location

ACM

Location

Description of

Material

Percent and

Type of

A b t8C Exterior - Window Glazing NAD - - - -

1 - Analyzed by TEM TR - Trace

SF - Square Feet

LF - Linear Feet

EA - Each

CF - Cubic Feet

* - The VISN 1 hazard assessment scale 1 – 4 is a relative indicator of the risk and need for response/remediation. (1)

represents the highest priority (e.g. removal or encapsulation) whereas a (4) represents the lowest priority (monitor as part

of 6 month O&M program). The rating, assigned by an Asbestos Management Planner, takes into account the following

criteria: condition, friable vs. non-friable, accessibility, occupancy (e.g. continuous, intermittent or occasional,

patients/staff/visitors), potential for air erosion, potential for vibration damage, potential for disturbance/damage (e.g.

exposed and in an accessible location), and potential for water damage.

ND - None Detected (TEM)

Footnotes:

NAD - No Asbestos Detected (PLM)



Appendix A, Table 4 - Survey Report Northampton Building T7

Appendix B

Table 5 Summary of XRF Measurements


2711 First Exterior Metal Door South Cracked Brown 0.01

2712 First Exterior Wood Door Casing South Peeling White 0.01

2713 First Exterior Wood Window Casing South Peeling White 21.9

2714 First Exterior Wood Window Sash South Peeling White 24.5

2715 First Exterior Metal Wall (Exterior) East Peeling White 4.9

2717 First Exterior Metal Roof East Peeling Brown 4.7

2718 First Exterior Wood Trim East Peeling White 4.5

2719 First Exterior Metal Security Bars East Peeling Brown 1.7

2720 First Exterior Wood Door North Fair Brown 6.5

2721 First Exterior Wood Door Casing North Fair White 23.8

2722 First Paint Shop Wood Window Casing West Fair White 0.03

2723 First Paint Shop Wood Window Sash West Intact White 0.11

2724 First Paint Shop Metal Radiator West Fair Gray 0.04

2725 First Paint Shop Metal Beam West Intact White 0.5

2726 First Paint Shop Concrete Floor West Fair Multi 0.05

2727 First Paint Shop Fiberglass Ceiling West Fair White 0

2728 First Paint Shop Wood Door North Fair White 17.3

2729 First Paint Shop Wood Door Casing North Fair White 0.08

2730 First Paint Shop Wood Wall (Interior) North Fair Multi 0.02

2731 First Office Wood Wall (Interior) South Intact White 0

2732 First Office Wood Door Casing South Intact White 0.01

2733 First Office Wood Screen Door North Intact White 10.4

2734 First Toilet Vat Floor West Intact Gray 0.01

2735 First Toilet Metal Radiator North Intact White 0.06

2736 First Toilet Wood Stall West Intact Gray 0.16

2737 First Toilet Wood Column North Intact White 0.11

2738 First Toilet Wood Window Casing West Intact White 0.14


2740 First Toilet Wood Door East Cracked Tan 0.05

2741 First Toilet Wood Door Casing East Cracked Tan 0.07

Black -

Blue -

Red -

Side Condition

Font Color Annotation

Below the VISN1 Threshold of 0.1 mg/cm2

Above the VISN1 Threshold of 0.1 mg/cm2, but less than 1.0 mg/cm

2

Greater than 1.0 mg/cm2

Table 5 - Summary of XRF Measurements


ColorResults

(mg/cm2)

Reading

No.Floor Location

Substrate and

Component



Appendix B, Table 5 - Survey Report Northampton Building T7

Appendix C

Relevant Photographs of ACM

12”x12” Gray Floor Tile

Sample 03A

9”x9” Gray Floor Tile

Sample 05A

Northampton VAMC – Building T7 December 2010

©2010, Mabbett & Associates, Inc. Page 1 of 1 Appendix C, Survey Report Northampton Bldg T7 (12-30-10)

Appendix D

Relevant Photographs of Non-Intact Lead Containing Paint Greater than 1.0 mg/cm2

Northampton VAMC – Building T7 December 2010 ©2010, Mabbett & Associates, Inc. Page 1 of 1 Appendix D - Relevant Photos Lead Bldg T7.doc

Wood Wall (Exterior), Wood Window Casing, Wood Window Sash, Metal Wall (Exterior), Metal

Roof, Wood Trim and Metal Security Bars Samples 2710, 2713-2715 and 2717-2719

attachment 9: inspection report building t7

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