Attachment 10 Leesburg Farm Asbestos Survey - Report.pdf

Prepared by:

Terracon Consultants, Inc.

Winter Park, FL

Hazardous Materials Survey Report Leesburg Farm – Designated Structures

23402 USDA Road

Groveland, Florida 34736

February 25, 2026 | Project Number: H1267029

Prepared for:

The Johnson-McAdams Firm, PA

108 West Market Street PO Box 513

Greenwood, MS 38935

1675 Lee Road Winter Park, FL 32789

P (407) 740-6110

Terracon.com

March 6, 2026

The Johnson-McAdams Firm, PA

108 West Market Street PO Box 513

Greenwood, MS 38935

Attn: Ms. Rebecca (Becky) P. Palmer, NCARB, AIA, LEED AP BD+C, GPCP, GGP

P: (662) 455-4945

E: becky.palmer@jmcfirm.com

RE: Hazardous Materials Survey Report

Leesburg Farm – Designated Structures

23402 USDA Road

Groveland, Florida 34736

Terracon Project No. H1267029

Dear Ms. Palmer:

Terracon Consultants, Inc. (Terracon) is pleased to present the results of the asbestos, lead paint, and hazardous materials survey performed on February 3, 2026, at the address referenced above in Groveland, Florida. This survey was conducted in general accordance with our Proposal No. PH1267029 dated January 14, 2026. We understand this survey was requested for planned demolition of two greenhouses, renovation of a greenhouse, and demolition of two pump houses within the north portion at the site.

Asbestos was detected in samples of non-friable gray caulking at entrance doors to the northwest and south greenhouses.

Detectable levels of lead were reported above the laboratory method detection limit in four of the six samples of paint chips.

No polychlorinated biphenyls (PCBs) were detected in four caulk samples.

Please refer to the attached report for details.

Hazardous Materials Survey Proposal Leesburg Farm Leesburg, FL February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials

Terracon appreciates the opportunity to provide these services to The Johnson-McAdams Firm, PA. If you have any questions regarding this report, please contact John O’Reilly at

(407) 740-6110.

Sincerely, Terracon Consultants, Inc.

Florida Asbestos Consultant Business No. ZA337

Prepared by: Reviewed by:

John O’Reilly Brian J. DuChene, P.E., FLAC Senior Scientist Authorized Project Reviewer

Florida Licensed Asbestos Consultant No. EA75

Hazardous Materials Survey Proposal

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials

Table of Contents

1.0 Introduction 1

1.1 Project Objective

1.2 Reliance

2.0 Building Description

3.0 Field Activities

3.1 Asbestos Survey

Visual Assessment

Physical Assessment

Sample Collection

3.2 Lead Paint Sampling

Site Limitations

Methodology and Analysis

3.3 Hazardous Materials

PCB Caulk Survey

Miscellaneous Materials of Concern

4.0 Findings and Recommendations

4.1 Asbestos

4.2 Lead Paint

4.3 PCB Caulks and other Miscellaneous Hazardous Materials

5.0 Limitations/General Comments

Appendix A Tables

Appendix B Exhibit

Appendix C Laboratory Analytical Reports and COCs

Appendix D Photographic Documentation

Appendix E Regulatory Overview

Appendix F: Inspector Licenses & Certificates

Limited Hazardous Materials Survey

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 1

1.0 Introduction

Terracon Consultants, Inc. (Terracon) conducted an asbestos, lead paint, and hazardous materials survey of three greenhouses and two pump house structures at the Leesburg Farms at the address referenced above in Groveland, Florida. Other structures at the site were excluded from this survey. The survey was conducted on February 3, 2026, by Mr. Ian Heneryand Mr. John O’Reilly, both Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos inspectors, in general accordance with the Terracon’s Proposal No.

PH1267029 dated January 14, 2026. Mr. O’Reilly is also a United States Environmental Protection Agency (EPA)-accredited lead paint inspector.

Interior and exterior building components, including roofing materials, were surveyed, and homogeneous areas of suspect asbestos-containing materials (ACM) and lead-containing paint (LCP) / lead-based paint (LBP) were visually identified and documented. Visual evaluations for potential disturbance to PCB caulk and other miscellaneous hazardous materials were also performed. Although reasonable effort was made to survey all accessible suspect materials, additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas.

The subject survey areas for each structure are outlined in Exhibit 1 in Appendix B.

Terracon understands that the northwest greenhouse, northeast greenhouse, and both pump house structures shown in Exhibit 1 are planned to be demolished. The south greenhouse is planned for renovation. A former greenhouse scheduled to be surveyed for renovation (east of the south greenhouse) had been removed prior to our site visit.

The purpose of the survey was to:

Locate, sample (if accessible), quantify, and assess suspect building materials for asbestos content;

Locate, measure, and quantify dominant-type, representative surface coatings (i.e., paint) for lead content; and

Visually assess and quantify readily accessible building caulks suspected of containing PCBs, and other miscellaneous hazardous building components such as fluorescent, mercury vapor, high intensity discharge (HID), and other lamps, as well as liquid mercury-containing equipment such as switches, thermostats, and other temperature control and HVAC devices.

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1.1 Project Objective

Terracon also understands that the intent of the assessment is to assist the Client with communicating the presence, location, identity, condition, and approximate quantities of asbestos-containing materials (ACMs) in the areas accessible to employees, vendors, and contractors expected to be working at the site in order to meet the requirements of the Occupational Safety and Health Administration (OSHA) communication of hazard requirements found at 29 CFR 1926.1101.

OSHA has promulgated a worker protection standard for the disturbance of lead-containing paints during demolition projects. The lead paint sampling was performed to meet informational needs to comply with the OSHA Lead in Construction Standard (29 CRF 1926.62). Currently, the proposed demolition and renovation activities that may impact lead paint are subject to OSHA regulation 29 CFR 1926.62 – Lead Exposure in Construction.

Contractors should be notified of the presence of regulated materials in areas where demolition and renovation activities might result in potential employee exposures so that they can take the necessary actions to comply with OSHA requirements and disposal requirements. The Resource Conservation and Recovery Act (RCRA) provides the EPA with the authority to regulate the waste status of demolition and renovation debris containing mercury. Specific regulatory requirements must be addressed prior to transporting, treating, storing, or disposing of regulated or hazardous wastes.

1.2 Reliance

This report is prepared for the exclusive use and reliance of the Client. Use or reliance by any other party is prohibited without the written authorization of the Client and Terracon.

Reliance on the report by the Client and all authorized parties will be subject to the terms, conditions, and limitations stated in Terracon’s proposal and the Agreement for Services. The limitation of liability defined in the Agreement for Services is the aggregate limit of Terracon’s liability to the Client and all relying parties.

2.0 Building Description

The greenhouse structures were out of service and consist of unpainted metal framing, plexiglass ceiling and wall panels, metal entrance doors and concrete floor slabs.

Concrete block planters or painted metal beam supports for planters were typically observed within the interiors. Overhead propane heaters and wall-mounted fans were observed at each of the greenhouses.

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 3

The two pumphouse structures consist of unpainted aluminum sheds with concrete slabs below metal fuel pump equipment and piping. Portions of the piping and remnants of a former dispenser were observed by the pumphouse structures.

3.0 Field Activities

Terracon conducted the field services on February 3, 2026, 2026. At the time of field services, the designated structures being evaluated were unoccupied and mechanical equipment and utilities were inactive.

3.1 Asbestos Survey

The asbestos survey was conducted by AHERA-accredited building inspectors, Mr. Ian Henery and Mr. John O’Reilly. Copies of team members’ asbestos inspector certificates and applicable licenses are attached in Appendix F. The survey was conducted in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, the AHERA. A summary of survey activities is provided below.

Visual Assessment

Our survey activities began with visual observation of the interior, exterior, and roofs of the buildings to identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color, texture, and date of application. The assessment was conducted throughout visually accessible areas of the building. Although reasonable efforts were made to identify suspect ACM, additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas. Building materials identified as glass, wood, metal, or rubber were not considered suspect ACM.

Physical Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability is assessed by physically touching suspect ACM.

Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Terracon collected random samples from each HA of suspect ACM observed. Team members collected bulk samples using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

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Terracon collected 63 bulk samples from 20 HAs of suspect ACM observed. A listing of suspect ACM observed and sampled during the survey is provided below. Materials in bold were found to contain asbestos.

Greenhouses

Gray door caulk – NW greenhouse

White hard caulk

Black caulk

White/clear caulk

White semi-hard flue caulk

Concrete slab

Concrete block & mortar

Concrete pad

Concrete block & pad

Gray caulk – S greenhouse

East and West Pump House Structures

Gray/White exterior wall caulk

Concrete floor slabs

Sample Analysis

Bulk samples were submitted under chain of custody to Cates Laboratories (Cates), for analysis by Polarized Light Microscopy per EPA methodology EPA/600/R-93/116. The percentage of asbestos, where applicable, was determined by microscopic visual estimation or point counting. Cates Laboratories is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 200569-0). The asbestos analytical laboratory report is provided in Appendix C. A summary of identified ACM is provided in Appendix A.

3.2 Lead Paint Sampling

Site Limitations

It should be noted that suspect LCP/LBP, other than those identified during the survey, may be present in the buildings. The LCP/LBP testing performed is not considered comprehensive in nature and the results are not intended to be used to determine lead hazards, develop abatement plans, or prepare detailed cost estimates for abatement. Suspect LCP/LBP which has not been specifically evaluated should be tested prior to disturbance of the material. If suspect LCP/LBP is identified during the renovation process, those materials should be assumed LCP/LBP until testing can be performed to determine whether a lead is present in the paint.

February 24, 2026 Terracon Project No. H1267029

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Methodology and Analysis

Paint chip samples were collected from dominant-type, representative painted surface coatings to determine lead content, measured by percent by weight. Suspect lead paint samples were collected in general accordance with the EPA’s work practice standards for conducting lead paint activities (40 CFR 745.227). Currently, the anticipated demolition or renovation activities that could potentially disturb lead paint are subject to the OSHA regulations (29 CFR 1926.62 – Lead).

The lead paint sampling began with the Terracon representative walking the buildings to visually identify unique combinations of suspect lead paint. A unique combination of paint is based on paint color, building component, and substrate. A visual assessment of each unique combination of suspect lead paint was conducted to assess the condition of the paint. Based on the results of the visual observation, Terracon collected six bulk paint chip samples for laboratory analysis.

The collected paint chip samples were submitted under a chain of custody to EMSL Analytical, Inc. Orlando, Florida., an AIHA ELLAP accredited (Lab ID: 163563) laboratory, for analysis by Flame Atomic Absorption Spectrophotometry (FAA) method SW846- 3050B/7000B.

The lead paint testing scope was not meant to be a surface-by-surface investigation and was limited to the components tested as indicated in this report. Paints containing lead may be concealed beneath other layers of paint and the data presented is relative to the sample locations tested with the assumption that similar surfaces are uniform throughout at other locations.

3.3 Hazardous Materials

PCB Caulk Survey

Terracon collected four bulk caulk samples for laboratory analysis of PCBs by EPA Methods 3540C and 8082A. The laboratory results are included in Appendix F. A summary of the PCB in caulk samples collected are included in Appendix A.

Miscellaneous Materials of Concern

Terracon visually evaluated for suspect regulated materials associated with emergency exit lights, smoke detectors, fire alarms, and CFC refrigerants in HVAC equipment. Other than the need to properly disconnect propane heaters in greenhouses and properly dispose fuel-stained concrete slabs in the two pump house structures, no additional regulated materials of concern were identified. No items suspected of containing mercury, such as fluorescent, mercury vapor, HID and other lamps, or liquid mercury-containing equipment such as switches, thermostats, and other temperature control and HVAC devices were observed within the designated structures.

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 6

Please note, no building components were opened, deconstructed, or sampled to verify if they exhibit hazard waste characteristics.

4.0 Findings and Recommendations

4.1 Asbestos

Asbestos was identified at concentrations greater than 1% in the following materials:

Northwest Greenhouse (JA1, JA2, JA3)

Gray Door Caulk -North Double Door (2% Chrysotile) o Approximately one square foot

South Greenhouse (H1 & H2)

Gray caulk – North Door Frame (3% Chrysotile) o Approximately one square foot

The asbestos-containing grey door caulks at north double doors of the northwest and south greenhouses are considered Category II non-friable materials that appeared in good condition.

Terracon recommends the proper removal and disposal of the identified asbestos-containing materials by a Florida-licensed asbestos abatement contractor (F.S. 469) prior to demolitions or renovation activities that disturb the ACM.

The asbestos analytical laboratory reports for PLM analysis are provided in Appendix C. A summary of the approximate quantity of materials identified as containing asbestos fibers is presented in Appendix A. Representative photographs are provided in Appendix D.

It should be noted that suspect materials, other than those identified during the February 3, 2026, 2024, survey may exist within the structures at the site. Should suspect materials other than those which were identified during this survey be uncovered prior to or during the demolition process, those materials should be assumed asbestos-containing until sampling and analysis can confirm or refute their asbestos content.

Table 1 included in Appendix A contains a summary of identified asbestos-containing materials. The laboratory analytical report and chain of custody are included in Appendix C.

A summary of applicable asbestos regulations is provided in Appendix E.

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 7

4.2 Lead Paint

Lead was detected in the following 4 of 6 paint chip samples collected from dominant-type, representative painted building components:

Green/ Grey Metal Cabinets in NE greenhouse o L1 – 0.570% weight

Green Metal Planter Beams in NW greenhouse o L2 – 0.0122% weight

Yellow Metal Pump House Piping o L5 – 4.90% weight

Red Metal Dispenser by East Pump House o L6 – 0.0190% weight

We recommend that any materials known to be LCP or LBP be removed in whole architectural components to the degree possible. Sanding, grinding, or other abrasive or aggressive methods of paint removal should be avoided. Applicable regulations include but are not necessarily limited to the following:

Lead-Based Paint Activities: Training, Certification, and Work Practice Requirements, 40 CFR Part 745.

Resource Conservation and Recovery Act (RCRA), 40 CFR Part 260, 261, 262, 263, 264.

OSHA Lead in Construction Standard, 20 CFR 1926.62.

A lead-paint sampling summary table is provided in Appendix A. The lead paint analytical laboratory report is provided in Appendix C. General photographs of the building are provided in Appendix D.

Contractors should be made aware of the presence of identified lead coatings, so that they may maintain compliance with worker protection regulations, employ lead-safe work practices, and/or conduct a negative exposure assessment per OSHA (29 CFR

1926.62 – Lead Exposure in Construction).

Please note that if any untested paints are encountered, they must be assumed to contain lead and addressed accordingly for OSHA compliance with the Lead in Construction Standard 29 CFR 1926.62, or otherwise sampled for laboratory analysis in an effort to refute the positive assumption.

The paint chip sample results are further summarized in Table 2, which is included in Appendix A. The laboratory analytical report and chain of custody are included in Appendix C. A summary of applicable lead regulations is provided in Appendix E.

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 8

4.3 PCB Caulks and other Miscellaneous Hazardous Materials

None of the caulk samples contained detectable PCB concentrations.

Other than the need to properly disconnect propane heaters in greenhouses and properly dispose fuel-stained concrete slabs in the two pump house structures, no additional regulated materials of concern were identified.

Laboratory analytical reports of PCBs in caulk are included in Appendices C. Representative photographs are included in Appendix D.

5.0 Limitations/General Comments

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

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 9

Appendix A Tables

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 10

TABLE 1: IDENTIFIED ASBESTOS CONTAINING MATERIALS SUMMARY

Homogeneous Area ID

Material Description Material Locations Condition Friable?

Percent/Type Asbestos

NESHAP

Category

Estimated Quantity of

ACM

MATERIALS CONTAINING GREATER THAN 1% ASBESTOS

Northwest Greenhouse

JA1

Grey Door

Caulk North Double Door Good No

2% Chrysotile Category

II

1 SF

JA2 2% Chrysotile

JA3 2% Chrysotile

South Greenhouse

H1 Grey Caulk North Door Frame Good No

3% Chrysotile Category

II

1 SF

H2 3% Chrysotile

SF = Square Feet

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 11

TABLE 2 – Lead Paint Chip Sample Summary

Sample ID Color Substrate Sample Location Paint

Condition

Test Result (% Lead by

Weight)

JE50571-01 Green / Gray Metal Green / Grey Metal Cabinets Good 0.570%

JE50571-02 Green Metal Metal planter Beams Good 0.0122%

JE50571-03 White Metal Metal Center Door Good <0.0064%

JE50571-04 Gray Metal Metal Electric Panel Good <0.0099%

JE50571-05 Yellow Metal Metal Pump Piping Good 4.90%

JE50571-06 Red Metal Metal Dispenser Good 0.0190%

< = Not detected above the analytical method’s reporting limit.

Bold: Analytical results indicate detectable lead concentrations above the analytical method’s reporting limit.

Limited Hazardous Materials Survey Proposal

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 12

Appendix B Exhibit

Survey Area Map

Leesburg Farm Limited Hazardous Materials Survey

23402 USDA Road, Groveland, FL 1675 Lee Rd

Winter Park, FL 32789-2207

H1267029

AS SHOWN

02/25/2026

Project No.

Scale:

Client:

Date:

Exhibit

The Johnson- McAdams Firm PA

Key: Planned Hazardous Material Survey Area

Repair Required Planned to be Demolished

X No longer on Site - Demolished

Bulk Sample Location Plan

Leesburg Farm Limited Hazardous Materials Survey 23402 USDA Road,Groveland, FL1675 Lee Rd

Winter Park, FL 32789-2207

H1267029

DIAGRAM IS FOR GENERAL LOCATION ONLY,

AND IS NOT INTENDED FOR CONSTRUCTION

PURPOSES 2/25/2026

Project No.

No.

Client:

Date:

Exhibit

AS SHOWN

Scale:

The Johnson- McAdams Firm PA

Approximate Suspect Bulk Sample

February 24, 2026 Terracon Project No. H1267029

Facilities | Environmental | Geotechnical | Materials 13

Appendix C Laboratory Analytical Reports and COCs

PLM REPORT SUMMARY

Cates Laboratories NVLAP Lab No. 200569-0 1339 Motor Circle TDSHS License No. 30-0287 Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-43455

Project (Line 1): Leesburg Farm Set No.: 62657

Project (Line 2): 23402 USDA Road, Groveland, FL Report Date: 2/12/2026

Project No: H1267029 Sample Date: 2/3/2026

Identification: Asbestos, Bulk Sample Analysis Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 1 of 5

On 2/6/2026, sixty-three (63) bulk samples were submitted by Mr. John O'Reilly of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab Sample No.

Client Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) materials that are friable or may become friable be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced except in full.

CL1457849 JA1

Grey Door Caulk - Northwest Greenhouse, North Double Door

2% Chrysotile - Caulking

CL1457850 JA2

CL1457851 JA3

CL1457852 JB1

White Hard Caulk Northwest - North Wall Patch

None Detected - Caulking

CL1457853 JB2

White Hard Caulk Northeast - North Wall Seam by Gutter

CL1457854 JB3

White Hard Caulk Northeast - North above Double Door

CL1457855 JC1

Black Caulk - North Greenhouse, North Fan Tops

CL1457856 JC2

CL1457857 JC3

CL1457858 JD1

White/Clear Caulk - Northeast Greenhouse, Northeast Fan Top Seal

CL1457859 JD2

White/Clear Caulk - Northeast Greenhouse, Northwest Fan Side

CL1457860 JD3

White/Clear Caulk - Northwest Greenhouse, North Door

CL1457861 JE1

White Caulk, Semi-Hard - South Door Frame Top

CL1457862 JE2

CL1457863 JE3

CL1457864 JF1

White Gutter Caulk - Northwest Greenhouse

CL1457865 JF2

White Gutter Caulk - Northwest Greenhouse

CL1457866 JF3

White Gutter Caulk - Northeast Greenhouse

CL1457867 JG1

White Semi-Hard Flue Caulk - Northwest Heater

CL1457868 JG2

CL1457869 JG3

1339 Motor Circle TDSHS License No. 30-0287 Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-43455

Project (Line 1): Leesburg Farm Set No.: 62657

Project (Line 2): 23402 USDA Road, Groveland, FL Report Date: 2/12/2026

Project No: H1267029 Sample Date: 2/3/2026

Identification: Asbestos, Bulk Sample Analysis Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 2 of 5

On 2/6/2026, sixty-three (63) bulk samples were submitted by Mr. John O'Reilly of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab Sample No.

Client Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) materials that are friable or may become friable be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced

CL1457870 JH1

White Flue Caulk - South Greenhouse, Northside

CL1457871 JH2

CL1457872 JH3

CL1457873 JI1

White Caulk - Base of East Pump House

CL1457874 JI2

White Caulk - Base of East Pump House

CL1457875 JI3

White Caulk - Base of West Pump House

CL1457876 A1

Concrete Slab - Northwest Greenhouse

None Detected - Concrete

CL1457877 A2

Concrete Slab - North Greenhouse

CL1457878 A3

Concrete Slab - Center Greenhouse

CL1457879 A4

Concrete Slab - Northeast Greenhouse

CL1457880 A5

Concrete Slab - East Greenhouse

CL1457881 B1

Concrete Block & Mortar - North Greenhouse

None Detected - CMU Block None Detected - Mortar

CL1457882 B2

CL1457883 B3

CL1457884 C1

Concrete Pad - North Greenhouse Exterior

CL1457885 C2

Concrete Pad - North Greenhouse Exterior

CL1457886 C3

Concrete Pad - Northeast Greenhouse Exterior

CL1457887 C4

Concrete Pad - Northeast Greenhouse Exterior

CL1457888 D1

Concrete Block & Pad - Northeast Greenhouse

1339 Motor Circle TDSHS License No. 30-0287 Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-43455

Project (Line 1): Leesburg Farm Set No.: 62657

Project (Line 2): 23402 USDA Road, Groveland, FL Report Date: 2/12/2026

Project No: H1267029 Sample Date: 2/3/2026

Identification: Asbestos, Bulk Sample Analysis Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 3 of 5

On 2/6/2026, sixty-three (63) bulk samples were submitted by Mr. John O'Reilly of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab Sample No.

Client Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) materials that are friable or may become friable be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced

CL1457889 D2

CL1457890 D3

CL1457891 E1

Concrete Block & Mortar - South Greenhouse

CL1457892 E2

CL1457893 E3

CL1457894 F1

Concrete Slab - South Greenhouse

CL1457895 F2

CL1457896 F3

CL1457897 G1

CL1457898 G2

CL1457899 G3

CL1457900 H1

Grey Caulk - South Greenhouse North Door Frame

3% Chrysotile - Caulking

CL1457901 H2

Grey Caulk - South Greenhouse North Door Frame

3% Chrysotile - Caulking

CL1457902 H3

Grey Caulk - South Greenhouse South Door Frame

CL1457903 I1

Clear Caulk - South Greenhouse, North Door Frame

CL1457904 I2

Clear Caulk - South Greenhouse, Northwest Fan

CL1457905 I3

Clear Caulk - South Greenhouse, Northwest Plastic Siding

CL1457906 PA1

Concrete Block & Mortar - Pump House East

1339 Motor Circle TDSHS License No. 30-0287 Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-43455

Project (Line 1): Leesburg Farm Set No.: 62657

Project (Line 2): 23402 USDA Road, Groveland, FL Report Date: 2/12/2026

Project No: H1267029 Sample Date: 2/3/2026

Identification: Asbestos, Bulk Sample Analysis Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 4 of 5

On 2/6/2026, sixty-three (63) bulk samples were submitted by Mr. John O'Reilly of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab Sample No.

Client Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) materials that are friable or may become friable be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced

CL1457907 PA2

Concrete Block & Mortar - Pump House East

CL1457908 PB1

Concrete Slab - Pump House East

CL1457909 PB2

Concrete Slab - Pump House West

CL1457910 PB3

Concrete Slab - Pump House West

CL1457911 PA3

Concrete Block & Mortar - Pump House West

1339 Motor Circle TDSHS License No. 30-0287 Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-43455

Project (Line 1): Leesburg Farm Set No.: 62657

Project (Line 2): 23402 USDA Road, Groveland, FL Report Date: 2/12/2026

Project No: H1267029 Sample Date: 2/3/2026

Identification: Asbestos, Bulk Sample Analysis

Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS) EPA Method 600/R-93/116 Page 5 of 5

On 2/6/2026, sixty-three (63) bulk samples were submitted by Mr. John O'Reilly of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein.

STATEMENT OF LABORATORY ACCREDITATION

The samples were analyzed in general accordance with the procedures outlined in the U.S. EPA Interim Method for the Determination of Asbestos in Bulk Insulation Samples as found in 40 CFR, Part 763, Subpart E, Appendix E (formerly Subpart F, Appendix A), or the current U.S. EPA method (EPA Method 600/R-93/116) for the analysis of asbestos in building materials, by polarized light microscopy. The results of each bulk sample relate only to the material tested and the results shall not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government.

Specific questions concerning bulk sample results shall be directed to the Laboratory Director.

Analyst:

John R. Cates

Laboratory Director: John R. Cates, P.G.

Approved Signatory:

TESTING

NVLAP LAB CODE 200569-0

ANALYTICAL REPORT

PREPARED FOR

Attn: John O'Reilly Terracon Consulting Eng & Scientists

1675 Lee Road Winter Park, Florida 32789

Generated 2/16/2026 11:52:31 AM

JOB DESCRIPTION

Leesburg Farm

JOB NUMBER

670-79858-1

See page two for job notes and contact information.

Altamonte Springs FL 32701

481 Newburyport Avenue

Eurofins Orlando

Eurofins Orlando

Job Notes

This report may not be reproduced except in full, and with written approval from the laboratory. The results relate only to the samples tested. For questions please contact the Project Manager at the e-mail address or telephone number listed on this page.

The test results in this report relate only to the samples as received by the laboratory and will meet all requirements of the methodology, with any exceptions noted. This report shall not be reproduced except in full, without the express written approval of the laboratory. All questions should be directed to the Eurofins Drinking Water and Wastewater Southeast, LLC Project Manager.

Authorization

Generated

2/16/2026 11:52:31 AM

Authorized for release by Kaitlin Dylnicki, Project Manager kaitlin.dylnicki@et.eurofinsus.com (407)339-5984

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Table of Contents

Client: Terracon Consulting Eng & Scientists Project/Site: Leesburg Farm

Laboratory Job ID: 670-79858-1

Eurofins Orlando

2/16/2026

Cover Page

Table of Contents

Definitions/Glossary

Case Narrative

Detection Summary

Client Sample Results

Surrogate Summary

QC Sample Results

QC Association Summary

Lab Chronicle

Certification Summary

Method Summary

Sample Summary

Chain of Custody

Receipt Checklists

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Case Narrative Client: Terracon Consulting Eng & Scientists Job ID: 670-79858-1 Project: Leesburg Farm

Eurofins Orlando

Job ID: 670-79858-1 Eurofins Orlando

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Appendix D Photographic Documentation

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Photo #1 Representative view of the exterior finishes at NW and NE greenhouses.

Photo #2 Asbestos-containing grey caulk on at north double doors of the northwest greenhouse.

Photo #3 Non-asbestos white caulk at doors of the northeast greenhouse.

Photo #4 Non-asbestos white caulk at gutters and wall seams.

Photo #5 Asbestos-containing grey caulk on the door frame of the south greenhouse.

Photo #6 Lead-containing paint on cabinet in the northeast greenhouse.

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Photo #7 Lead-containing paint on metal planter support beams in the northeast greenhouse.

Photo #8 Representative view of the pump house structures.

Photo #9 Typical view of lead-containing yellow paint on piping at pumphouses and fuel stains on concrete

Photo #10 Lead-containing red paint on dispenser by east pumphouse.

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Appendix E Regulatory Overview

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Asbestos Regulations

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

1. Friable ACM

2. Category I non-friable ACM or

3. Category II non-friable ACM.

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

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

In the State of Florida, asbestos activities are regulated by the Florida Department of Environmental Protection (FDEP). RACM must be removed prior to renovation or demolition activities which will disturb the materials. The owner or operator must provide the FDEP with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities. Removal of any RACM or ACM must be conducted by a State of Florida-licensed asbestos abatement contractor.

The OSHA Asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc). The OSHA standard classifies construction and maintenance activities which could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

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Lead Paint Regulations

Lead is regulated by the EPA, the United States Department of Housing and Urban Development (HUD), FDEP and OSHA. The EPA and FDEP regulate lead use, removal, and disposal, and OSHA regulates lead exposure to workers. The EPA and HUD, with their small child-safety focus, define Lead-Based Paint (LBP) as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 mg/cm2, 5,000 mg/kg, or 0.5% by dry weight as determined by laboratory analysis.

However, for the purpose of the OSHA lead standard, with its focus on the safety/exposure of construction workers, paint-containing lead includes any detectable concentrations of metallic lead, all inorganic lead compounds, and organic lead soaps.

The OSHA Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon the method of removal and other workplace conditions.

Under this standard, construction includes, but is not limited to, the following:

Demolition or salvage of structures with lead or materials containing lead

Removal or encapsulation of materials containing lead

New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead

Installation of products containing lead

Lead contamination/emergency clean-up

Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed

Maintenance operations associated with construction activities described above

If lead is present, an initial determination must be made by the competent person to evaluate whether exposure is at or above the Action Level (AL) of 30 micrograms per cubic meter of air (µg/m3) and the Permissible Exposure Level (PEL) of 50 µg/m3. Certain prescriptive work practices, engineering controls, and personal protective equipment is mandated based on the activity disturbing the lead containing coatings (such as abrasive blasting or torch cutting). Personal air testing and blood testing may also be required depending on the level of exposure. EPA regulates the disposal of potential toxic waste containing lead under the Resource Conservations and Recovery Act (RCRA).

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Waste streams from construction activities which may exhibit lead toxicity must be characterized prior to disposal to determine the appropriate disposal procedures and landfill location. However, both the EPA and FDEP generally exempt whole architectural elements from buildings with lead-containing paint from this requirement.

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PCB Regulations

USEPA regulates disposal of mercury-containing fluorescent lights tubes as universal waste under 40 CFR 273. Disposal of mercury from other sources is regulated under 40 CFR 260- 262.

OSHA regulates occupational exposure to mercury under 29 CFR 1910.1000 Air Contaminants, Table Z-1 – Limits for Air Contaminants. The PEL for mercury is 0.1 milligrams per cubic meter (mg/m3) as an 8-hr TWA.

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Miscellaneous Hazardous Materials

Electrical and hydraulic equipment such as in ballasts, transformers or lift systems may contain mineral oil with minor amounts of PCBs and could be considered “PCB contaminated” (PCB content 50 mg/kg or ppm). EPA regulates transportation, disposal, and spill cleanup of PCB-containing ballasts under the Toxic Substances Control Act (TSCA), which can be found in 40 CFR 761. OSHA regulates occupational exposure to PCBs under 29 CFR 1910.1000 Air Contaminants, Table Z 1 – Limits for Air Contaminants.

EPA regulates disposal of mercury-containing fluorescent light tubes as universal waste under 40 CFR 273. Disposal of mercury from other sources is regulated under 40 CFR 260-262.

Mercury containing devices can be recycled by following Chapter 62-737, Florida Administrative Code. Mercury-containing equipment, such as fluorescent light tubes, must be sent to an approved recycling facility that recovers mercury. OSHA regulates occupational exposure to mercury under 29 CFR 1910.1000 Air Contaminants, Table Z 1 – Limits for Air Contaminants. The PEL for mercury is 0.1 milligrams per cubic meter (mg/m3) as an 8-hr time-weighted average (TWA).

Refrigeration/air conditioning (AC) equipment has historically used refrigerants, such as CFCs and hydrochlorofluorocarbons (HCFCs), which deplete the stratospheric ozone layer. Newer refrigeration/AC equipment is likely to contain hydrofluorocarbons (HFCs), which are used as ozone-friendly substitutes for CFCs and HCFCs. EPA regulates disposal of ozone-depleting substances (ODS) and their substitutes under 40 CFR 82. The regulations require recovery of the refrigerants by certified technicians and appropriate reclamation or disposal.

Ionization smoke detectors containing less than 1 microcurie ( Ci) of americium-241 are exempt from Nuclear Regulatory Commission regulations. However, some state and local laws and regulations prohibit the disposal of ionization smoke detectors in the municipal waste stream. For this reason, smoke detectors containing radioactive material should be returned to the manufacturer for disposal. If the manufacturer refuses to accept the return of the smoke detector, check with the local governmental agency.

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Appendix F: Inspector Licenses & Certificates