09 HazmatInvACME20180810.pdf

Acme Environmental, Inc.

Hazardous Materials Investigation©

Carlsbad Caverns Electrical Distribution System Page 1

PROJECT REPORT

HAZARDOUS MATERIALS INVESTIGATION

CARLSBAD CAVERNS ELECTRICAL

DISTRIBUTION SYSTEM

CARLSBAD CAVERNS NATIONAL PARK

CARLSBAD CAVERNS, NEW MEXICO

Prepared by

ACME ENVIRONMENTAL, INC

3816 CARLISLE NE

ALBUQUERQUE, NM

For

Carlsbad Caverns Electrical Distribution System Page 2

Hazardous Materials Investigation

August 10, 2018 ATTENTION: Jon Holbrook, AIA. LEED AP HDR SUBJECT: Hazardous Materials Investigation PROJECT LOCATION: Carlsbad Caverns National Park Carlsbad, NM

ACME PROJECT #: 18-099

Mr. Holbrook:

Acme Environmental, Inc. (Acme), has completed sampling and investigations of the electrical distribution system at Carlsbad Caverns National Park in Carlsbad, New Mexico.

David Chavez, Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA) Accredited Asbestos Inspector and Industrial Hygiene Technician, performed the investigation

SCHEDULED WORK

Acme performed sampling and investigation of electrical transformers for Polychlorinated biphenyls (PCBs) and Asbestos.

Additionally, Acme inspected cable systems and duct bank enclosures for asbestos.

SUMMARY

Based on the samples collected and analyzed by independent laboratories, no material was considered asbestos containing.

Additionally, based on the samples collected and analyzed by independent laboratories, no material was considered PCB containing.

Please contact our office at (505) 433-4461 if any additional information is required.

Respectfully, Brett Engel President / CEO Qualified Industrial Hygienist

Carlsbad Caverns Electrical Distribution System Page 3

HAZARDOUS MATERIALS INVESTIGATION

PART I: IDENTIFYING INFORMATION

The following investigation and sampling was conducted at Carlsbad Caverns National Park in Carlsbad, New Mexico. It was conducted in an effort to identify hazardous substances prior to disturbance and ultimate disposal.

Based on information provided regarding the electrical systems, it was not possible to definitively identify specific areas serviced by each transformer. Only two transformers were labeled with marker, Elevator #1 & #2. Sampling and investigative work was performed utilizing personal protective controls for energized systems.

Jon Holbrook, AIA of HDR contracted Acme Environmental Inc. to conduct the investigation of the designated property.

Mr. David Chavez, an EPA AHERA Accredited Asbestos Inspector and Industrial Hygiene Technician, performed this investigation in August of 2018. Sampling and analysis was performed in compliance with EPA methods.

PART II: ENVIRONMENTAL RESULTS AND ANALYSES

PCB Testing Report - Transformers

Representative samples of dielectric fluid were collected from suspect electrical transformers. These samples were submitted to an independent laboratory, ALS Environmental Laboratories in Salt Lake City, Utah for PCB analysis.

EPA considers materials containing greater than 50 parts per million (ppm) PCB, “PCB Containing”. Based on sampling and analysis, no material is characterized as PCB containing.

Several observed transformers are hermetically sealed. These systems cannot be sampled without damaging the operational integrity of the device. These were evaluated based on the manufacturing information. Research indicated that no observed transformers are considered PCB containing.

Sampled Transformers

PCB Sample TA001 Visitor Center PCBs below Reporting Limit (RL)

PCB Sample TA002 Resource Center PCBs below Reporting Limit (RL)

PCB Sample TA003 Maintenance PCBs below Reporting Limit (RL)

Carlsbad Caverns Electrical Distribution System Page 4

Observed Transformers (research confirms Non-PCB containing)

Dry Transformer 1 Dry Transformer 2 Superintendent 1

Superintendent 2 Superintendent 3 Visitor Center 1

Visitor Center 2 (Transformer info closeup) Labeled Elevator #1 & #2

Visitor Center 2 ( Full view) Labeled Elevator #1 & #2

Mission 66 Housing

Asbestos Testing Report – Transformers, Cabling and Duct Banks

Representative samples of suspect asbestos containing materials were collected from cable systems and duct bank enclosures. No suspect asbestos was observed relative to any transformers.

These samples were submitted to an independent laboratory, CALabs in Carrollton, Texas for Asbestos analysis.

EPA and OSHA consider materials containing greater than 1% asbestos, as determined by polarized light microscopy, to be Asbestos Containing Materials (ACM).

No materials sampled were found to contain asbestos.

Carlsbad Caverns Electrical Distribution System Page 5

Suspect ACM - Sampled

Visitor Center- Wire Jacketing No Asbestos

Visitor Center – Wire Jacketing No Asbestos

Resource Center – Secondary container No Asbestos

PART III: CONCLUSIONS

Transformer service areas were not specifically identified. Based on information provided regarding the electrical systems, it was not possible to definitively identify specific areas serviced by each transformer. However, two transformers were labeled as Elevator #1 & #2.

Based on the observations and analytical results of the samples submitted, no PCBs or Asbestos were identified in any of the evaluated transformer and electrical distribution systems.

Research on PCB content in transformers included manufacturer contacts and EPA reference document, GUIDELINES FOR DETERMINING PCB STATUS OF

DISTRIBUTION TRANSFORMERS.

Project Report Limitations The environmental services described in this report have been conducted in general accordance with current regulatory guidelines and the standard-of-care exercised by environmental consultants performing similar work in the project area. Variations in site conditions may exist and conditions not observed or described in this report may be encountered during subsequent activities.

Acme’s opinions and recommendations regarding environmental conditions, as presented in this report, are based on visual inspection and limited sampling only. The samples collected and used for testing, and the observations made are believed to be representative of the area(s) evaluated. It should be understood that the conditions of a site could change with time as a result of activities at the subject site or nearby sites.

This report is intended exclusively for use by the clients. Any use or reuse of the findings, conclusions, and/or recommendations of this report by parties other than the client is undertaken at said parties’ sole risk.

Carlsbad Caverns Electrical Distribution System Page 6

Relative Sample Locations

ANALYTICAL REPORT

Brett Engel ACME Environmental, Inc.

3816 Carlisle NE Albuquerque, NM 87107

Phone:

Fax:

E-mail:

(505) 934-0995

(505) 889-8261 acmebrettengel@gmail.com

Report Date: August 27, 2018

34-1822587Workorder:

Carlsbad Caverns 081018 18-99/34-19900Purchase Order:

Project ID:

Project Manager Kevin W. Griffiths

Sampling SiteReceive DateCollect DateLab IDClient Sample ID

1822587001 08/10/18TA001 08/13/18 Carlsbad Caverns

1822587002 08/10/18TA002 08/13/18 Carlsbad Caverns

1822587003 08/10/18TA003 08/13/18 Carlsbad Caverns

Page 1 of 4 Mon, 08/27/18 4:11 PM ENVREP-V4.8

ADDRESS 960 West LeVoy Drive, Salt Lake City, Utah, 84123 USA PHONE FAX+1 801 266 7700 +1 801 268 9992

ALS GROUP USA, CORP. An ALS Limited Company

Project Manager: Kevin W. Griffiths Client: ACME Environmental, Inc.

Workorder: 34-1822587

Analytical Results

Sample ID: 08/10/2018 08/13/20181822587001Lab ID:

Collected:

Received:

TA001 Carlsbad Caverns

Sampling Parameter: NAMatrix:

Media:

Non-Aqueous Liquid

4 oz Glass Jar Wide Mouth Sampling Site:

Analysis: SW 8082, Non-Aq Liq

Analyzed: 08/15/2018 00:00 Batch:

Instrument ID:

EGC/7414 (HBN: 221164) Percent Solid: NA

GCE03

Report Basis: Wet

Preparation: EPA 3580, Waste Dilution, ARO Non-Aqu

Prepared: 08/14/2018 Batch:

Weight/Volume

ENVX/27179 (HBN: 220919)

Initial:

Final:

1.018 grams 10 mL

Result (ug/g)Analyte RL (ug/g) Dilution Qual

Analysis Method - SW 8082

2.0<2.0 10Aroclor 1221

0.98<0.98 10Aroclor 1232

0.98<0.98 10Aroclor 1016

0.98<0.98 10Aroclor 1242

0.98<0.98 10Aroclor 1248

0.98<0.98 10Aroclor 1254

0.98<0.98 10Aroclor 1260

0.98<0.98 10Aroclor 1262

0.98<0.98 10Aroclor 1268

Sample ID: 08/10/2018 08/13/20181822587002Lab ID:

Collected:

Received:

TA002 Carlsbad Caverns

Sampling Parameter: NAMatrix:

Media:

Non-Aqueous Liquid

4 oz Glass Jar Wide Mouth Sampling Site:

Analysis: SW 8082, Non-Aq Liq

Analyzed: 08/15/2018 00:00 Batch:

Instrument ID:

EGC/7414 (HBN: 221164) Percent Solid: NA

GCE03

Report Basis: Wet

Preparation: EPA 3580, Waste Dilution, ARO Non-Aqu

Prepared: 08/14/2018 Batch:

Weight/Volume

ENVX/27179 (HBN: 220919)

Initial:

Final:

1.014 grams 10 mL

Result (ug/g)Analyte RL (ug/g) Dilution Qual

Analysis Method - SW 8082

2.0<2.0 10Aroclor 1221

0.99<0.99 10Aroclor 1232

0.99<0.99 10Aroclor 1016

0.99<0.99 10Aroclor 1242

0.99<0.99 10Aroclor 1248

0.99<0.99 10Aroclor 1254

0.99<0.99 10Aroclor 1260

0.99<0.99 10Aroclor 1262

0.99<0.99 10Aroclor 1268

Page 2 of 4 Mon, 08/27/18 4:11 PM ENVREP-V4.8

Client: ACME Environmental, Inc.

Workorder: 34-1822587

Analytical Results

Sample ID: 08/10/2018 08/13/20181822587003Lab ID:

Collected:

Received:

TA003 Carlsbad Caverns

Sampling Parameter: NAMatrix:

Media:

Non-Aqueous Liquid

4 oz Glass Jar Wide Mouth Sampling Site:

Analysis: SW 8082, Non-Aq Liq

Analyzed: 08/15/2018 00:00 Batch:

Instrument ID:

EGC/7414 (HBN: 221164) Percent Solid: NA

GCE03

Report Basis: Wet

Preparation: EPA 3580, Waste Dilution, ARO Non-Aqu

Prepared: 08/14/2018 Batch:

Weight/Volume

ENVX/27179 (HBN: 220919)

Initial:

Final:

1.036 grams 10 mL

Result (ug/g)Analyte RL (ug/g) Dilution Qual

Analysis Method - SW 8082

1.9<1.9 10Aroclor 1221

0.97<0.97 10Aroclor 1232

0.97<0.97 10Aroclor 1016

0.97<0.97 10Aroclor 1242

0.97<0.97 10Aroclor 1248

0.97<0.97 10Aroclor 1254

0.97<0.97 10Aroclor 1260

0.97<0.97 10Aroclor 1262

0.97<0.97 10Aroclor 1268

Comments

Quality Control: SW 8082 - (HBN: 221164)

MS/MSD and samples required 10x dilution to keep instrument integrity.

Report Authorization

Analyst Peer ReviewMethod

(/S/ is an electronic signature that complies with 21 CFR Part 11)

SW 8082 /S/ Mila V. Potekhin 08/27/2018 15:28 08/27/2018 15:57

/S/ Lyle Edwards

Laboratory Contact Information

(801) 266-7700 alslt.lab@ALSGlobal.com www.alsslc.com

ALS Environmental 960 W Levoy Drive Salt Lake City, Utah 84123

Phone:

Email:

Web:

Page 3 of 4 Mon, 08/27/18 4:11 PM ENVREP-V4.8

Client: ACME Environmental, Inc.

Workorder: 34-1822587

The results provided in this report relate only to the items tested.

Samples were received in acceptable condition unless otherwise noted.

Samples have not been blank corrected unless otherwise noted.

This test report shall not be reproduced, except in full, without written approval of ALS.

General Lab Comments

ALS provides professional analytical services for all samples submitted. ALS is not in a position to interpret the data and assumes no responsibility for the quality of the samples submitted.

All quality control samples processed with the samples in this report yielded acceptable results unless otherwise noted.

ALS is accredited for specific fields of testing (scopes) in the following testing sectors. The quality system implemented at ALS conforms to accreditation requirements and is applied to all analytical testing performed by ALS. The following table lists testing sector, accreditation body, accreditation number and website. Please contact these accrediting bodies or your ALS project manager for the current scope of accreditation that applies to your analytical testing.

Testing Sector Accreditation Body Certificate Number

Website

Environmental PJLA (DoD ELAP)

Utah (TNI) Nevada Oklahoma Iowa

MDL = Method Detection Limit, a statistical estimate of method/media/instrument sensitivity.

RL = Reporting Limit, a verified value of method/media/instrument sensitivity.

CRDL = Contract Required Detection Limit Reg. Limit = Regulatory Limit.

ND = Not Detected, testing result not detected above the MDL or RL.

< This testing result is less than the numerical value.

** No result could be reported, see sample comments for details.

U = Qualifier indicates that the analyte was not detected above the MDL.

J = Qualifier Indicates that the analyte value is between the MDL and the RL. It is also used to indicate an estimated value for tentatively identified compounds in mass spectrometry where a 1:1 response is assumed.

B = Qualifier indicates that the analyte was detected in the blank.

E = Qualifier indicates that the analyte result exceeds calibration range.

P = Qualifier indicates that the RPD between the two columns is greater than 40%.

Result Symbol Definitions

Qualifier Symbol Definitions

Page 4 of 4 Mon, 08/27/18 4:11 PM ENVREP-V4.8

Customer Project:

Reference #: Date: 8/14/2018

Analysis and Method

Discussion

Qualifications

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Materials Characterization - Bulk Asbestos Analysis Laboratory Analysis Report - Polarized Light

ACME Environmental

3816 Carlisle NE

Albuquerque, NM 87107 18-099, Resource Center

CAL18085448AF

Summary of polarized light microscopy (PLM / Stereomicroscopy bulk asbestos analysis) using the methods described in 40CFR Part 763

Appendix E to Subpart E (Interim and EPA 600 / R-93 / 116 (Improved). The sample is first viewed with the aid of a stereomicroscope. Numerous liquid slide preparations are created for analysis under the polarized microscope where identifications and quantifications are preformed. Calibrated liquid refractive oils are used as liquid mouting medium. These oils are used for identification (dispersion staining). A calibrated visual estimation is reported, should any asbestiform mineral be present. Other techniques such as acid washing are used in conjugation with refractive oils for detection of smaller quantities of asbestos. All asbestos percentages are based on calibrated visual estimation traceable to NIST standards for regulated asbestos. Traceability to measurement and calibration is achieved by using known amounts and types of asbestos from standards where analyst and laboratory accuracy are measured. As little as 0.001% asbestos can be detected in favorable samples, while detection in unfavorable samples may approach the detection limit of 0.50% (well above the laboratory definition of trace).

Vermiculite containing samples may contain trace amounts of actinolite/tremolite. When not detected by PLM, these samples should be analyzed using TEM methods and / or water separation techniques. Suspected actinolite/vermiculite presence will be indicated through the sample comment section of this report.

Fibrous talc containing samples may contain a regulated asbestos fiber known as anthophyllite. Under certain conditions the same fiber may actually contain both talc and anthophyllite (a phenomenon called intergrowth). Again, TEM detection methods are recommended. CA Labs PLM report comments will denote suspected amounts of asbestiform anthophyllite with talc, where further analysis is recommended.

Some samples (floor tiles, surfacings, etc.) may contain fibers too small to be delectable by PLM analysis and should be analyzed by TEM bulk protocols.

AIHA LAP, LLC Laboratory #102929

A "trace asbestos" will be reported if the analyst observes far less than 1% asbestos. CA Labs defines "trace asbestos" as a few fibers detected by the analyst in several preparations and will indicate as such under these circumstances.

Since allowable variation in quantification of samples close to 1% is high, <1% may be reported. Such results are ideal for point counting, and the technique is mandatory for friable samples (NESHAP, Nov. 1990 and clarification letter 8 May 1991) under 1% percent asbestos or "trace asbestos".

In order to make all initial PLM reports issued from CA Labs NESHAP compliant, all <1% asbestos results (except floor tiles) will be point counted at no additional charge.

CA Labs is accredited by the National Voluntary Accreditation Program (NVLAP) for selected test methods for airborne fiber analysis (TEM), and for bulk asbestos fiber analysis (PLM). CA Labs is also accredited by AIHA LAP, LLC. in the PLM asbestos field of testing for Industrial Hygiene. All analysts have completed college courses or hold a degree in a natural science (geology, biology, or environmental science). Recognition by a state professional board in one these disciplines is preferred, but not required. Extensive in-house training programs are used to augment the educational background of the analyst. The Laboratory Director and Quality Manager have received supplemental McCrone Research training for asbestos identification. Analysis performed at Crisp Analytical Labs, LLC 1929 Old Denton Road Carrollton, TX 75006

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

Labs

A

C

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 1 of 3

Overview of Project Sample Material Containing Asbestos

Customer Project: 18-099, Resource Center CA Labs Project #: CAL18085448AF

No Asbestos Detected.

Glossary of abbreviations (non-asbestos fibers and non-fibrous minerals):

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Sample # Layer

Analysts Physical Description of

Subsample

Asbestos type / calibrated visual estimate percent

List of Affected Building

Material Types

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

AIHA LAP, LLC Laboratory #102929 ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

This report relates to the items tested. This report is not to be used by the customer to claim product certification, approval or endorsement by NVLAP, NIST, AIHA LAP, LLC, or any other agency of the federal government. This report may not be reproduced except in full without written permission from CA Labs. These results are submitted pursuant to CA Labs' current terms and sale, condition of sale, including the company's standard warranty and limitations of liability provisions and no responsibility or liability is assumed for the manner in which the results are used or interpreted. Unless notified in writing to return the samples covered by this report, CA Labs will store the samples for a period of ninety (90) days before discarding. A shipping or handling fee may be assessed for the return of any samples.

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 2 of 3

Polarized Light Asbestiform Materials Characterization

Customer Info: Attn: Customer Project:

8/14/2018

8/13/18 10:30am

Phone # 8/10/2018

Fax #

Senior Analyst

Julio Robles

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

CA Labs Project #:

ACME Environmental

18-099, Resource Center

CAL18085448AF

3816 Carlisle NE

Albuquerque, NM 87107 Date:

Turnaround Time: Samples Received:

505-872-2263 24 Hours Date Of Sampling:

505-889-8261 Purchase Order #:

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

Homo-geneo us

(Y/N)

Asbestos type / calibrated visual estimate percent

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

1 1-1

Wire Jacketing/ black covering y None Detected 60% fg 40% qu,bi

2 2-1

Wire Jacketing/ black covering y None Detected 100% qu,bi,ot

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

AIHA LAP, LLC Laboratory #102929 Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116). All samples received in good condition unless noted.

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

ca - carbonate gy - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot -other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastonite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay) Approved Signatories:

Tanner Rasmussen Technical Manager

Analyst Tanner Rasmussen

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Labs

A

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 3 of 3

Customer Project:

Reference #: Date: 8/14/2018

Analysis and Method

Discussion

Qualifications

AIHA LAP, LLC Laboratory #102929

A "trace asbestos" will be reported if the analyst observes far less than 1% asbestos. CA Labs defines "trace asbestos" as a few fibers detected by the analyst in several preparations and will indicate as such under these circumstances.

Since allowable variation in quantification of samples close to 1% is high, <1% may be reported. Such results are ideal for point counting, and the technique is mandatory for friable samples (NESHAP, Nov. 1990 and clarification letter 8 May 1991) under 1% percent asbestos or "trace asbestos".

In order to make all initial PLM reports issued from CA Labs NESHAP compliant, all <1% asbestos results (except floor tiles) will be point counted at no additional charge.

CA Labs is accredited by the National Voluntary Accreditation Program (NVLAP) for selected test methods for airborne fiber analysis (TEM), and for bulk asbestos fiber analysis (PLM). CA Labs is also accredited by AIHA LAP, LLC. in the PLM asbestos field of testing for Industrial Hygiene. All analysts have completed college courses or hold a degree in a natural science (geology, biology, or environmental science). Recognition by a state professional board in one these disciplines is preferred, but not required. Extensive in-house training programs are used to augment the educational background of the analyst. The Laboratory Director and Quality Manager have received supplemental McCrone Research training for asbestos identification. Analysis performed at Crisp Analytical Labs, LLC 1929 Old Denton Road Carrollton, TX 75006

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

Summary of polarized light microscopy (PLM / Stereomicroscopy bulk asbestos analysis) using the methods described in 40CFR Part 763

Appendix E to Subpart E (Interim and EPA 600 / R-93 / 116 (Improved). The sample is first viewed with the aid of a stereomicroscope. Numerous liquid slide preparations are created for analysis under the polarized microscope where identifications and quantifications are preformed. Calibrated liquid refractive oils are used as liquid mouting medium. These oils are used for identification (dispersion staining). A calibrated visual estimation is reported, should any asbestiform mineral be present. Other techniques such as acid washing are used in conjugation with refractive oils for detection of smaller quantities of asbestos. All asbestos percentages are based on calibrated visual estimation traceable to NIST standards for regulated asbestos. Traceability to measurement and calibration is achieved by using known amounts and types of asbestos from standards where analyst and laboratory accuracy are measured. As little as 0.001% asbestos can be detected in favorable samples, while detection in unfavorable samples may approach the detection limit of 0.50% (well above the laboratory definition of trace).

Vermiculite containing samples may contain trace amounts of actinolite/tremolite. When not detected by PLM, these samples should be analyzed using TEM methods and / or water separation techniques. Suspected actinolite/vermiculite presence will be indicated through the sample comment section of this report.

Fibrous talc containing samples may contain a regulated asbestos fiber known as anthophyllite. Under certain conditions the same fiber may actually contain both talc and anthophyllite (a phenomenon called intergrowth). Again, TEM detection methods are recommended. CA Labs PLM report comments will denote suspected amounts of asbestiform anthophyllite with talc, where further analysis is recommended.

Some samples (floor tiles, surfacings, etc.) may contain fibers too small to be delectable by PLM analysis and should be analyzed by TEM bulk protocols.

Laboratory Analysis Report - Polarized Light

ACME Environmental

3816 Carlisle NE

Albuquerque, NM 87107 18-099, Visitor Center Carlsbad Caverns, NM

CAL18085449AG

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Materials Characterization - Bulk Asbestos Analysis

Labs

A

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 1 of 3

Overview of Project Sample Material Containing Asbestos

Customer Project: 18-099, Visitor Center Carlsbad Caverns, NM CA Labs Project #: CAL18085449AG

No Asbestos Detected.

Glossary of abbreviations (non-asbestos fibers and non-fibrous minerals):

This report relates to the items tested. This report is not to be used by the customer to claim product certification, approval or endorsement by NVLAP, NIST, AIHA LAP, LLC, or any other agency of the federal government. This report may not be reproduced except in full without written permission from CA Labs. These results are submitted pursuant to CA Labs' current terms and sale, condition of sale, including the company's standard warranty and limitations of liability provisions and no responsibility or liability is assumed for the manner in which the results are used or interpreted. Unless notified in writing to return the samples covered by this report, CA Labs will store the samples for a period of ninety (90) days before discarding. A shipping or handling fee may be assessed for the return of any samples.

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

AIHA LAP, LLC Laboratory #102929 ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Sample # Layer

Analysts Physical Description of

Subsample

Asbestos type / calibrated visual estimate percent

List of Affected Building

Material Types

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 2 of 3

Polarized Light Asbestiform Materials Characterization

Customer Info: Attn: Customer Project:

8/14/2018

8/13/18 10:30AM

Phone # 8/10/2018

Fax #

Senior Analyst

Julio RoblesAnalyst Tanner Rasmussen

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Stanley Massett Technical Manager

Dallas NVLAP Lab Code 200349-0 TEM/PLM TCEQ# T104704513-15-3 TDH 30-0235

AIHA LAP, LLC Laboratory #102929 Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116). All samples received in good condition unless noted.

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

ca - carbonate gy - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot -other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastonite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay) Approved Signatories:

n None Detected 18% fg 82% qu,ma,ot003 3-1 tan paneling n None Detected 18% fg 82% qu,ma,ot002 2-1 tan paneling n None Detected 100% qu,ma001 1-1 black and brown sealant

Homo-geneo us

(Y/N)

Asbestos type / calibrated visual estimate percent

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

505-872-2263 24 hours Date Of Sampling:

505-889-8261 Purchase Order #:

CA Labs Project #:

ACME Environmental

18-099, Visitor Center

Carlsbad Caverns, NM

CAL18085449AG

3816 Carlisle NE

Albuquerque, NM 87107 Date:

Turnaround Time: Samples Received:

CA Labs

Dedicated to Dedicated to Dedicated to Dedicated to

QualityQualityQualityQuality

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Labs

A

/data/wordandspreadsheets/templates/asbestos/PLMReport.xls (Revision 3 3/7/17) Page 3 of 3