1240LQ23Q0075 Attachment 02 - Monument Fire Center Asbestos Survey Report.pdf

Teamwork - Trust - Leadership Since 1927

April 28, 2022 Project No. 2202201

Ms. Tanya Spanfellner

Department of Agriculture

Forest Service

Boise National Forest

1249 S Vinnell Way Suite 200

Boise, ID 83709

MONUMENT FIRE CENTER – ASBESTOS SURVEY REPORT

PIKE PEAK RD-MONUMENT FIRE CENTER

3751 MOUNT HERMAN ROAD

MONUMENT, CO 80132

Dear Ms. Spanfellner:

Please find enclosed the report for the United States Environmental Protection Agency (USEPA)

National Emission Standards for Hazardous Air Pollutants (NESHAP), (40 CFR, Part 61) asbestos survey of a Monument Fire Center – Barracks (Site) located at 3751 Mount Herman Road in

Monument, Colorado.

B2 Environmental, Inc. (B2E), a subcontractor to TTL Associates, Inc. (TTL) performed the asbestos survey at the Site on April 12, 2022. Eight suspect homogeneous materials were identified to contain asbestos at the Site from which 21 samples were collected and 28 layers were analyzed by the laboratory. One material (HA2) was identified as asbestos containing based on the laboratory analytical results. The laboratory analysis was performed using polarized light microscopy (PLM) analysis which utilizes dispersion staining techniques (ref.: USEPA Method

600/R-93/116) to determine the asbestos content of the bulk samples. The laboratory analysis was performed by International Asbestos Testing laboratories (IATL), Inc. located at 9000 Commerce

Parkway, Suite B, in Mt. Laurel, New Jersey. Please refer Appendix A for the analytical data in the attached report in Attachment A.

B2E collected paint samples from selected building component surfaces coated with suspect lead-based paint on April 12, 2022. B2E collected the paint samples in general accordance with a selected sampling strategy based on modifications from the United States Housing and Urban

Development (HUD) Chapter 7 of the Guidelines for the evaluation and Control of Lead-Based

Paint Hazards in Housing (2012 Revision). Six paint chip samples were collected and analyzed by the laboratory. The laboratory analysis was performed using the ASTM approved method, D3335 utilizing flame atomic absorption (AA). The laboratory analysis was performed by International

Asbestos Testing laboratories (IATL), Inc. located at 9000 Commerce Parkway, Suite B, in Mt.

Laurel, New Jersey. Please refer Appendix A for the analytical data in the attached report in

Attachment B.

Ms. Tanya Spanfellner TTL Project No. 2202201 Forest Service Page 2

Teamwork - Trust - Leadership Since 1927

B2E performed a microbial assessment of Monument Fire Center -Barracks on April 12, 2022 to provide information regarding potential microbial growth and develop a mold remediation work plan. Surface tape samples of suspect visible fungal growth from the basement men’s shower room walls were collected and placed on a glass microscope slides sealed in plastic slide holders supplied by the laboratory and shipped via overnight courier to IATL International located at 9000

Commerce Parkway, Suite B in Mount Laurel, New Jersey for direct microscopic analysis to identify fungal spores and particulates. A visual assessment to determine areas of visible suspect mold growth and areas of past and/or present moisture intrusion was also performed at the time of the surface tape sample collection. Please refer Appendix A for the analytical data in the attached report in Attachment C. A remediation plan is also included in the report.

TTL appreciates the opportunity to provide the Department of Agriculture with environmental and testing services. Should you have any questions or require additional information, please contact

Mr. Harjot Singh at (419) 214-5058.

Sincerely, TTL Associates, Inc.

Harjot Singh Tony Finch, CPG

Project Manager Senior Project Manager

V:\Toledo\Department of Agriculture\Monument Fire Center Investigation Monument, CO 2022 (2202201)\Reports and Other Deliverables\Monument Fire Center Asbestos Survey Report - Letter.docx

Harry Singh Stamp

Harry Singh Stamp

ATTACHMENT A

ASBESTOS SURVEY REPORT

ASBESTOS SURVEY REPORT

MONUMENT FIRE CENTER - BARRACKS

3751 MOUNT HERMAN ROAD

MONUMENT, COLORADO 80132

Client:

TTL ASSOCIATES, INC.

44265 PLYMOUTH OAKS BOULEVARD

PLYMOUTH, MICHIGAN 48170

Consultant:

B2 ENVIRONMENTAL, INC.

4503 SOUTH 90TH STREET

OMAHA, NEBRASKA 68127

B2E Project Number: 10846.0004

April 27, 2022

Prepared by:

Brock Flowers Environmental Manager

Reviewed by:

Paul Virgillito, CHMM, CIEC, REP Associate

TOC

TABLE OF CONTENTS

1.0 SCOPE OF SERVICES

2.0 GENERAL SITE CONDITIONS

3.0 ASBESTOS SURVEY REPORT

3.1 Homogeneous Areas

3.2 Sampling Strategy

3.3 Suspect Asbestos-Containing Materials

3.4 Laboratory Analytical Results

3.5 Recommendations

4.0 ASSUMPTIONS AND LIMITATIONS

APPENDICES

LABORATORY ANALYTICAL REPORT .................................................................... APPENDIX A

PHOTOGRAPHIC LOG ............................................................................................... APPENDIX B

QUALIFICATIONS ....................................................................................................... APPENDIX C

1.0 SCOPE OF SERVICES

B2 Environmental, Inc. (B2E) performed a United States Environmental Protection Agency (USEPA) National Emission Standards for Hazardous Air Pollutants (NESHAP), (40 CFR, Part

61) asbestos inspection of a Monument Fire Center - Barracks located at 3751 Mount Herman Road in Monument, Colorado.

B2E provided a representative asbestos inspection at the identified building in general accordance with the referenced agreement and as outlined below:

1. Review existing asbestos reports relating to the site, if available.

2. Survey the site building(s), or site component(s).

3. Identify accessible suspect asbestos-containing materials (ACM) in general accordance with the United States Environmental Protection Agency (USEPA) and National Emissions for Hazardous Air Pollutants (NESHAP), (40 CFR, Part 61).

4. Collect and analyze bulk samples of suspect materials.

5. Quantify any asbestos containing materials and record location.

2.0 GENERAL SITE CONDITIONS

The inspection included one (1) multi-story Monument Fire Center - Barracks, constructed with concrete and wood. No previous asbestos reports or construction drawings were provided to B2E prior to the inspection.

3.0 ASBESTOS SURVEY REPORT

On April 12th, 2022, B2E inspector Brian Jones inspected the site for asbestos-containing building materials. Mr. Jones has completed the requisite training for asbestos accreditation as an inspector at a state approved training provider under Toxic Substances Control Act (TSCA) Title II. Mr. Heizer’s State of Colorado asbestos inspector number is 22365.

B2E visually inspected the site for the presence of suspect ACM. Materials that were hidden, not accessible (i.e. boilers, areas of safety concern), or when sampled would damage the integrity of the structure or component (i.e. electrical wiring), were not sampled as part of this inspection. B2E did not sample materials that were visibly identified as non-asbestos (fibrous glass, foam rubber, wood, etc.). The asbestos inspection consisted of three steps: 1) a visual inspection of the site(s);

2) a determination of homogeneous areas with suspect surfacing, thermal system insulation, and miscellaneous materials; and 3) sampling accessible, friable, and non-friable, suspect materials.

Friable materials are materials that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable materials are materials that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable materials, when subjected to sanding, grinding, cutting, or abrading, may become friable.

3.1 Homogeneous Areas

Prior to sampling, B2E identified homogeneous areas to facilitate a sampling strategy. A homogeneous sampling area is described as one or more areas with suspect material similar in appearance and texture that have the same installation date and function. The actual number of samples collected from each homogeneous sampling area varies, dependent upon material type and the professional judgment of the inspector.

3.2 Sampling Strategy

B2E’s sampling strategy incorporated Asbestos Hazard Emergency Response Act (AHERA) requirements, quantities of suspect material, and the inspector’s judgment to aid in the identification of suspect ACM. B2E’s sampling strategy was to identify and collect accessible suspect ACM in general accordance with the USEPA NESHAP, (40 CFR, Part 61). If the analytical results indicated that all the samples collected per homogeneous area did not contain asbestos, then the homogeneous area (material) was considered non-asbestos containing.

However, if the analytical results of one or more of the samples collected per homogeneous area indicated that asbestos was present in quantities greater than one percent asbestos (as defined by USEPA), all of the homogeneous area (material) was treated as an asbestos-containing material regardless of other analytical results. B2E did not sample materials that the accredited inspector visually determined to be non-asbestos (i.e. fibrous glass, foam rubber, etc.). Actual collection of a bulk asbestos sample involves physically removing approximately one square inch (1 in2) of the material and placing it in an airtight sample container marked with a unique identification number.

3.3 Suspect Asbestos-Containing Materials

The following table contains a list of building materials suspected of containing asbestos:

3 7 5 1 M O U N T H E R M A N R O A D - B A R R A C K S

S U S P E C T B U I L D I N G M A T E R I A L S

Material Location Sample Number

Ceiling Texture (white) Throughout HA1-1,2,3

Wall Texture (white) Stairwells HA2-1,2,3

Stucco Throughout HA3-1,2,3

Floor Tile (brown) with Mastic (black) 1st & 2nd Floor HA4-1,2,3

Drywall Throughout HA5-1,2,3

Joint Compound Throughout HA6-1,2,3

Shingle (black) Roof HA7-1,2,3

2’x4’ Ceiling Tile (white) Shower Rooms HA8-1,2,3

3.4 Laboratory Analytical Results

IATL International located at 9000 Commerce Parkway, Suite B in Mt. Laurel, New Jersey analyzed the bulk samples using polarized light microscopy (PLM). PLM analysis utilizes dispersion staining techniques (ref.: USEPA Method 600/R-93/116) to determine the asbestos content of the bulk samples collected at the site. This laboratory is currently recognized by the United States Department of Commerce’s National Voluntary Laboratory Accreditation Program (NVLAP) for conformance with criteria set forth in the National Institute of Standards and Technology (NIST) Handbook 150:2016 and the International Organization for Standardization (ISO)/International Electrotechnical Commission (IEC) Guide 17025:2005. NVLAP accredits testing and calibration laboratories that are found competent to perform specific tests or calibrations, or types of tests or calibrations. NIST Handbook 150:2016 sets forth the basic procedures under which NVLAP operates, and the general accreditation requirements that testing and calibration laboratories must meet if they wish to demonstrate that they operate a quality system, are technically competent, and are able to generate technically valid results.

The following table is a summary of the suspect ACM that have been determined, through laboratory analysis and/or assumed, to contain asbestos:

3 7 5 1 M O U N T H E R M A N R O A D - B A R R A C K S

A S B E S T O S - C O N T A I N I N G M A T E R I A L S

MATERIAL LOCATION

SAMPLE

NUMBER

NESHAP

CATEGORY

FRIABLE(1) QUANTITY(2)

ASBESTOS

CONTENT

Wall Texture (white) Stairwells HA2-1,2,3

RACM

FRIBALE

1,500 SF 5.2%

Chrysotile

Any material that contains greater than one percent asbestos is considered an ACM and is categorized as either friable ACM or non-friable ACM. Friable ACM is categorized as regulated asbestos-containing material (RACM). There are two categories of non-friable materials:

Category I non-friable ACM and Category II non-friable ACM.

• Category I non-friable ACM is any asbestos-containing packing, gasket, resilient floor covering or asphalt roofing product which contains more than one percent asbestos.

• Category II non-friable ACM is any material, excluding Category I non-friable ACM, containing more than one percent asbestos.

Details of sample analysis are included in Appendix A, which contains a listing of all analyzed samples, sample locations, and analytical results relating to the site. Asbestos analytical results are reported as percentage and type. Other common non-asbestos components may also be noted in the analytical report.

Building materials containing any detectable amounts of asbestos are regulated by Occupational Safety and Health Administration (OSHA), and applicable work practices and prohibitions must be followed accordingly.

State and local requirements may differ from NESHAP requirements. Consult with appropriate agencies prior to commencing abatement and/or demolition activities.

3.5 Recommendations

B2E identified one (1) asbestos-containing material during its survey: wall texture. B2E offers the following recommendations for the asbestos-containing materials:

• Inspect – conduct periodic inspections to ensure asbestos-containing material is in place and in good condition. A basic Operations and Maintenance plan (O&M) should be prepared for this material.

• Maintain, Repair and/or Abate – If damage is detected, repair or abate as needed. Do not disturb, cut, grind, or sand asbestos-containing material. A licensed contractor should perform all work.

4.0 ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in this report are based solely on conditions noted during B2E’s inspection of the site. Qualifications for the field personnel are provided in Appendix C and analytical laboratory are provided in Appendix A. As the user of this report, the client and respective contractors are advised of the following limitations on the information presented in this report.

1. This report is intended for the sole use of the Client. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users and use or re-use of this document or the findings, conclusions, or recommendations is at the risk of said user.

2. Building materials may be present that were not accessible for testing by B2E and may not be discovered until after demolition/renovation activities begin.

3. The report is designed to aid the building owner, architect, construction manager, general contractor, and potential asbestos abatement contractor 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.

4. This asbestos inspection was performed in a manner consistent with the level of care and skill ordinarily exercised by environmental professionals practicing contemporaneously under similar conditions in the area of the project in question. No other warranty, express or implied, is given and all other warranties are hereby expressly disclaimed. 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.

5. This report is not a comprehensive site evaluation and should not be construed as such.

Only those structures specifically stated in Section 2.0 General Site Conditions are included in this report.

APPENDIX A

LABORATORY ANALYTICAL REPORT

Lab No.: 7407295 Client No.: HA1-1

Analyst Observation: White Texture Client Description: Wall/Ceiling Texture

Location: Throughout Facility:

Percent Asbestos:

None Detected

Percent Non-Asbestos Fibrous Material:

Percent Non-Fibrous Material:

Lab No.: 7407296 Client No.: HA1-2

Lab No.: 7407297 Client No.: HA1-3

Lab No.: 7407298 Client No.: HA2-1

Analyst Observation: White Wall Texture Client Description: Wall Texture

Location: Stairwell

PC 3.3 Chrysotile

96.7

Lab No.: 7407299 Client No.: HA2-2

PC 5.2 Chrysotile

94.8

Lab No.: 7407299(L2) Client No.: HA2-2

Analyst Observation: Off-White/Lt Grey Wall Texture

PC 4.1 Chrysotile

95.9

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Nam Kim

04/14/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

PLM BULK SAMPLE ANALYSIS SUMMARY

Client: TTL442

Dated : 4/15/2022 2:43:45 Page 1 of 8

Lab No.: 7407300 Client No.: HA2-3

PC 4.6 Chrysotile

95.4

Lab No.: 7407301 Client No.: HA3-1

Analyst Observation: Lt Tan Stucco Client Description: Stucco

Lab No.: 7407302 Client No.: HA3-2

Lab No.: 7407303 Client No.: HA3-3

Trace Cellulose

Lab No.: 7407304 Client No.: HA4-1

Analyst Observation: Brown/Black Vinyl Sheet Flooring Client Description: Brown Floor Tile With Mastic

Location: 1st and 2nd Floor

Lab No.: 7407304(L2) Client No.: HA4-1

Analyst Observation: Clear/Beige Mastic

1 Cellulose

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Nam Kim

04/14/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 4/15/2022 2:43:45 Page 2 of 8

Lab No.: 7407305 Client No.: HA4-2

Lab No.: 7407305(L2) Client No.: HA4-2

Analyst Observation: Clear/Beige Mastic

Lab No.: 7407306 Client No.: HA4-3

Lab No.: 7407306(L2) Client No.: HA4-3

Lab No.: 7407307 Client No.: HA5-1

Analyst Observation: Off-White Drywall Client Description: Sheetrock

3 Cellulose

Lab No.: 7407308 Client No.: HA5-2

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Nam Kim

04/14/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 4/15/2022 2:43:45 Page 3 of 8

Lab No.: 7407309 Client No.: HA5-3

Lab No.: 7407310 Client No.: HA6-1

Analyst Observation: White Joint Compound Client Description: Joint Compound

Lab No.: 7407311 Client No.: HA6-2

Lab No.: 7407312 Client No.: HA6-3

Lab No.: 7407313 Client No.: HA7-1

Analyst Observation: Black Shingle Client Description: Black Shingle

Location: Roof

1 Fibrous Glass

Lab No.: 7407314 Client No.: HA7-2

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Nam Kim

04/14/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 4/15/2022 2:43:45 Page 4 of 8

Lab No.: 7407315 Client No.: HA7-3

Lab No.: 7407316 Client No.: HA8-1

Analyst Observation: Off-White/Lt Grey Ceiling Tile; 2x4 Client Description: White Ceiling Tile 2x4

Location: Shower Rooms

5 Fibrous Glass 25 Cellulose

Note: Mastic not present.

Lab No.: 7407317 Client No.: HA8-2

Note: Mastic not present.

Lab No.: 7407318 Client No.: HA8-3

Note: Mastic not present.

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Nam Kim

04/14/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 4/15/2022 2:43:45 Page 5 of 8

Appendix to Analytical Report Customer Contact: Rob Serlin Method:40 CFR Appendix E to Subpart E of Part 763, interim method for the Determination of Asbestos in Bulk Insulation Samples, USEPA 600, R93-116 and NYSDOH ELAP 198.1 as needed.

This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.

Please note the following points of contact for any questions you may have.

iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Kelly Klippel Sample Login Notes: See Batch Sheet Attached Sample Matrix: Bulk Building Materials Exceptions Noted: See Following Pages

General Terms, Warrants, Limits, Qualifiers:

General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.

iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.

This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.

This report shall not be reproduced except in full, without written approval of the laboratory.

Information Pertinent to this Report:

Analysis by US EPA 600 93-116: Determination of Asbestos in Bulk Building Materials by Polarized Light Microscopy (PLM).

Certifications:

NIST-NVLAP No. 101165-0• NYSDOH-ELAP No. 11021• AIHA-LAP, LLC No. 100188•

Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. PC Trace represents a <0.25% amount. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.

Analytical Methodology Alternatives: Your initial request for analysis may not have accounted for recent advances in regulatory requirements or advances in technology that are routinely used in similar situations for other qualified projects. You may have the option to explore additional analysis for further information. Below are a few options, listed as the matrix followed by the appropriate methodology. Also included are links to more information on our website.

Bulk Building Materials that are Non-Friable Organically Bound (NOB) by Gravimetric Reduction techniques employing PLM and TEM: ELAP 198.6 (PLM-NOB), ELAP 198.4 (TEM-NOB) See additional information at the end of this appendix.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

Page 6 of 8Dated : 4/15/2022 2:43:45

Loose Fill Vermiculite Insulation, Attic Insulation, Zonolite (copyright), etc.: US EPA 600 R-4/004 (multi-tiered analytical process) Sprayed On Insulation/Fireproofing with Vermiculite (SOF-V): ELAP 198.8 (PLM-SOF-V)

Soil, sludge, sediment, aggregate, and like materials analyzed for asbestos or other elongated mineral particles (ex. erionite, etc.): ASTM D7521, CARB 435, and other options available

Asbestos in Surface Dust according to one of ASTM's Methods (very dependent on sampling collection technique – by TEM): ASTM D 5755, D5756, or D6480

Various other asbestos matrices (air, water, etc.) and analytical methods are available.

Disclaimers / Qualifiers:

There may be some samples in this project that have a "NOTE:" associated with a sample result. We use added disclaimers or qualifiers to inform the client about something that requires further explanation. Here is a list with highlighted disclaimers that may be pertinent to this project. For a full explanation of these and other disclaimers, please inquire at customerservice@iatl.com.

1) Note: No mastic provided for analysis.

2) Note: Insufficient mastic provided for analysis.

3) Note: Insufficient material provided for analysis.

4) Note: Insufficient sample provided for QC reanalysis.

5) Note: Different material than indicated on Sample Log / Description.

6) Note: Sample not submitted.

7) Note: Attached to asbestos containing material.

8) Note: Received wet.

9) Note: Possible surface contamination.

10) Note: Not building material. 1% threshold may not apply.

11) Note: Recommend TEM-NOB analysis as per EPA recommendations.

12) Note: Asbestos detected but not quantifiable.

13) Note: Multiple identical samples submitted, only one analyzed.

14) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.080%.

15) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.125%.

16) Note: This sample contains >10% vermiculite mineral. See Appendix for Recommendations for Vermiculite Analysis.

Recommendations for Vermiculite Analysis:

Several analytical protocols exist for the analysis of asbestos in vermiculite. These analytical approaches vary depending upon the nature of the vermiculite mineral being tested (e.g. un-processed gange, homogeneous exfoliated books of mica, or mixed mineral composites).Please contact your client representative for pricing and turnaround time options available.

iATL recommends initial testing using the EPA 600/R-93/116 method. This method is specifically designed for the analysis of asbestos in bulk building materials. It provides an acceptable starting point for primary screening of vermiculite for possible asbestos.

Results from this testing may be inconclusive. EPA suggests proceeding to a multi-tiered analysis involving wet separation techniques in conjunction with PLM and TEM gravimetric analysis (EPA 600/R-04/004).

For New York State customers, NYSDOH requires disclaimers and qualifiers for various vermiculite containing samples that direct analysis via ELAP198.6 and ELAP198.8 for samples that contain >10% vermiculite mineral where ELAP198.6 may be used to evaluate the asbestos content of the material. However, any test result using ELAP198.6 will be reported with the following disclaimer: “ELAP198.6 method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing >10% vermiculite.”

Further information on this method and other vermiculite and asbestos issues can be found at the following: Agency for Toxic Substances and Disease Registry (ATSDR) www.atsdr.cdc.gov, United States Geological Survey (USGS) www.minerals.usgs.gov/minerals/, US EPA www.epa.gov/asbestos. The USEPA also has an informative brochure "Current Best Practices for Vermiculite Attic Insulation" EPA 747F03001 May 2003, that may assist the health and remediation professional. NYS customers please follow current NYSDOH ELAP requirements per policy on subject of surfacing and vermiculite, May 6, 2016, Testing Requirements for Surfacing Material Containing Vermiculite (https://www.wadsworth.org/sites/default/files/WebDoc/I198_8_02_2.pdf)

The following is a summary of the analytical process outlines in the EPA 600/R-04/004 Method:

1)Analytical Step/Method: Initial Screening by PLM, EPA 600R-93/116 Requirements/Comments: Minimum of 0.1 g of sample. ~0.25% for most samples.

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

Page 7 of 8Dated : 4/15/2022 2:43:45

2)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

3)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Floats" only.

4)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

5)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Suspension" only.

*With advance notice and confirmation by the laboratory.

**Approximately 1 Liter of sample in double-bagged container (~9x6 inch bag of sample).

New York State Department of Health requires that samples originating from NYS that they categorize as Non-friable Organically Bound materials can only be confirmed as None Detected for asbestos by method 198.4. See the table below for a list of those materials. (ENVIRONMENTAL LABORATORY APPROVAL PROGRAM CERTIFICATION MANUAL - ITEM No. 198.1, Revision Date 5/6/16)

*Asphalt Shingles, Caulking, Ceiling Tiles with Cellulose, Duct Wrap, Glazing, Mastic, Paint Chips, Resilient Floor Tiles, Rubberized Asbestos Gaskets, Siding Shingles, Vinyl Asbestos Tile, NOB materials (other that SM-V) with <10% vermiculite, Any material (Friable or NOB other than SM-V) with >10% vermiculite.

Statistically derived uncertainty with any measure should be taken into consideration when reviewing and interpreting all reported data and results. A more comprehensive listing of accuracy, precision, and uncertainty as it impacts this method is available upon request.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/14/2022Report Date:

Report No.: 658517 - PLM Project: Monument Co Project No.:

Page 8 of 8Dated : 4/15/2022 2:43:45

APPENDIX B

PHOTOGRAPHIC LOG

#1 Viewing HA-1. #2 Viewing HA-2. Asbestos Containing Material

#3 Viewing HA-3. #4 Viewing HA-4.

#5 Viewing HA-5 & HA-6. #6 Viewing HA-7

#7 Viewing HA-8.

APPENDIX C

QUALIFICATIONS

ATTACHMENT B

LEAD BASED PAINT REPORT

LEAD BASED PAINT REPORT

3751 MOUNT HERMAN ROAD

MONUMENT, COLORADO 80132

Client:

TTL ASSOCIATES, INC.

4503 SOUTH 90TH STREET

April 19, 2022

1.0 LEAD-BASED PAINT

1.1 Sampling Methods and Laboratory Analytical Results

2.0 ASSUMPTIONS AND LIMITATIONS

LEAD-BASED PAINT LABORATORY ANALYTICAL REPORT ................................ APPENDIX A

PHOTOGRAPHIC LOG (POSITVE MATERIALS ONLY) ............................................ APPENDIX B

1.0 LEAD-BASED PAINT

On April 12, 2022, B2E collected paint samples from selected building component surfaces coated with suspect lead-based paint. B2E collected the paint samples in general accordance with a selected sampling strategy based on modifications from the United States Housing and Urban Development (HUD) Chapter 7 of the Guidelines for the evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Revision). Survey criteria included the sampling of painted surfaces on the interior of the building.

1.1 Sampling Methods and Laboratory Analytical Results

B2E collected six (6) paint chip samples from surfaces coated with suspect lead-based paint.

IATL International located at 9000 Commerce Parkway, Suite B in Mount Laurel, New Jersey, analyzed the samples in accordance with the United States Environmental Protection Agency (USEPA) using the ASTM approved method, D3335 utilizing flame atomic absorption (AA).

The following table presents the building components sampled for lead-based paint and analytical results.

Table 1: Suspect Lead-Based Painted Building Materials

MATERIAL LOCATION

SAMPLE

NUMBER

LEAD

CONTENT*

Beige Paint (drywall) Interior – Throughout L1-1 <0.0055

Beige Paint (drywall) Interior – Throughout L1-2 <0.0068

Beige Paint (drywall) Interior – Throughout L1-3 0.0055

White Paint (drywall) Interior – Throughout L2-1 <0.0068

White Paint (drywall) Interior – Throughout L2-2 <0.0077

White Paint (drywall) Interior – Throughout L2-3 <0.0074

* Samples are reported in percent lead (%) by weight.

ND = None Detected

Any paint or surface coating that contains ≥ 0.500% lead by weight is considered lead-containing and must be managed during demolition and/or renovation. The paints listed above do not represent all painted building components at the site. The paints, tested and untested, that do not contain lead in concentrations ≥ 0.500% lead by weight, may contain detectable amounts of lead.

It is B2E’s opinion that paint films and/or surface coatings containing any detectable concentration of lead should be viewed as a potential source of exposure and health hazard.

Except for the following, construction and renovation debris from commercial and industrial sites;

and lead, cadmium, and chromium-based paint waste from removal or remediation activities must be managed and disposed of as a RCRA hazardous waste if they meet the toxicity characteristic for lead under RCRA.

Whole-building demolition debris can be characterized as inert or nonhazardous waste if:

1. Other hazardous components are not present or are removed and disposed separately.

2. Metal components are removed to the extent feasible as scrap materials for reuse/recycling.

3. All remaining materials must comprise a single discrete waste stream at the point of generation and disposed of together.

Details of sample analysis are included in Appendix A, which contains a listing of analyzed samples, and analytical results for the building components sampled. Results are reported in percent lead by weight.

Building materials containing any detectable amounts of lead are regulated by OSHA, and applicable work practices and prohibitions must be followed accordingly.

State and local requirements may differ from RCRA requirements. Consult with appropriate agencies prior to commencing renovation and/or demolition activities.

2.0 ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in this report are based solely on conditions noted during B2E’s assessment of the site. Qualifications for the field personnel and analytical laboratory reports are provided in the appendices. As the user of this report, the client and respective contractors are advised of the following limitations on the information presented in this report.

1. This report is intended for the sole use of the client. The scope of services performed in execution of this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document or the findings, conclusions, or recommendations is at the risk of said user.

2. Building materials may be present that were not accessible for testing by B2E and may not be discovered until after demolition/renovation activities begin.

3. The report is designed to aid the building owner, architect, construction manager, general contractor, and potential asbestos abatement contractor 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 Workplan.

4. This assessment was performed in a manner consistent with the level of care and skill ordinarily exercised by environmental professionals practicing contemporaneously under similar conditions in the area of the project in question. No other warranty, express or implied, is given and all other warranties are hereby expressly disclaimed.

LEAD-BASED PAINT LABORATORY ANALYTICAL REPORT

Lab No.: 7407073 Client No.: L1-1

Description: Beige Paint Location:

Result (% by Weight): <0.0055 Result (ppm): <55 Comments: ***

Lab No.: 7407074 Client No.: L1-2

Description: Beige Paint Location:

Result (% by Weight): <0.0068 Result (ppm): <68 Comments: ***

Lab No.: 7407075 Client No.: L1-3

Description: Beige Paint Location:

Result (% by Weight): 0.0055 Result (ppm): 55 Comments: ***

Lab No.: 7407076 Client No.: L2-1

Description: White Paint Location:

Result (% by Weight): <0.0068 Result (ppm): <68 Comments: ***

Lab No.: 7407077 Client No.: L2-2

Description: White Paint Location:

Result (% by Weight): <0.0077 Result (ppm): <77 Comments: ***

Lab No.: 7407078 Client No.: L2-3

Description: White Paint Location:

Result (% by Weight): <0.0074 Result (ppm): <74 Comments: ***

Laboratory Director

Approved By:

Date Analyzed:

4/14/2022Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Chad Shaffer

04/15/2022 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/15/2022Report Date:

Report No.: 658478 - Lead Paint Project: Monument Co Project No.:

LEAD PAINT SAMPLE ANALYSIS SUMMARY

Dated : 4/15/2022 1:57:00 Page 1 of 3

Appendix to Analytical Report:

Method: ASTM D3335-85a, US EPA SW846 3050B:7000B

This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.

Please note the following points of contact for any questions you may have.

iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Kelly Klippel Sample Login Notes: See Batch Sheet Attached Sample Matrix: Paint Exceptions Noted: See Following Pages

General Terms, Warrants, Limits, Qualifiers:

General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.

iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.

This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.

This report shall not be reproduced except in full, without written approval of the laboratory.

Information Pertinent to this Report:

Analysis by ASTM D3335-85a by AAS

Certification:

- National Lead Laboratory Program (NLLAP): AIHA-LAP, LLC No. 100188

- NYSDOH-ELAP No. 11021

This report meets the standards set forth in the EPA's National Lead Laboratory Accreditation Program (NLLAP) through the Laboratory Quality System Requirements (LQSR) Revision 3.0 November 5, 2007. All Environmental Lead Proficiency Analytical Testing (ELPAT) is through the AIHA-PAT established program.

Regulatory limit is 0.5% lead by weight (EPA/HUD guidelines). Recommend multiple sampling for all samples less than regulatory limit for confirmation.

All results are based on the samples as received at the lab. iATL assumes that appropriate sampling methods have been used and that the data upon which these results are based have been accurately supplied by the client.

Method Detection Limit (MDL) per EPA Method 40CFR Part 136 Apendix B.

Reporting Limit (RL) based upon Lowest Standard Determined (LSD) in accordance with AIHA-ELLAP policies.

LSD=0.2 ppm MDL=0.006% by weight. RL= 0.010% by weight (based upon 100 mg sampled).

Disclaimers / Qualifiers:

There may be some samples in this project that have a "NOTE:" associated with a sample result. We use added disclaimers or qualifiers to inform the client about something that requires further explanation. Here is a complete list with highlighted disclaimers pertinent to this project. For a full explanation of these and other disclaimers, please inquire at customerservice@iatl.com.

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/15/2022Report Date:

Report No.: 658478 - Lead Paint Project: Monument Co Project No.:

Page 2 of 3Dated : 4/15/2022 1:57:00

* Insufficient sample provided to perform QC reanalysis (<200 mg) ** Not enough sample provided to analyze (<50 mg) *** Matrix / substrate interference possible.

< less than sign, signifies none-detected below the empirical value based upon sub-sampled mass. This is often below the Reporting Limit (see above).

Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: TTL Associated, Inc.

44265 Plymouth Oaks Blvd Plymouth MI 48170

4/15/2022Report Date:

Report No.: 658478 - Lead Paint Project: Monument Co Project No.:

Page 3 of 3Dated : 4/15/2022 1:57:00

(NO LEAD CONTIANING PAINTS)

ATTACHMENT C

MICROBIAL ASSESSMENT/REMEDIATION WORK PLAN

MICROBIAL ASSESSMENT/REMEDIATION WORK PLAN

3751 MOUNT HERMAN ROAD

MONUMENT, COLORADO 80132

Client:

TTL ASSOCIATES, INC.

4503 SOUTH 90TH STREET

April 19, 2022

1.0 SCOPE OF SERVICES

2.0 GENERAL SITE CONDITIONS

3.0 MICROBIAL SAMPLING

4.0 MOLD VISUAL ASSESSMENT

5.0 CONCLUSIONS AND RECOMMENDATIONS

6.0 REMEDIATION WORK PLAN

6.1 Introduction

6.2 Scope of Work

6.3 Removal of Mold

6.3.1 General Provisions

6.3.2 Definitions/Regulatory Agencies

6.3.3 Submittals

6.3.4 Remediation Requirements

6.3.5 Disposal of Waste Material

6.3.6 Clearance Criteria

7.0 ASSUMPTIONS AND LIMITATIONS

MICROBIAL LABORATORY REPORTS .................................................................... APPENDIX A

PHOTOGRAPHIC LOG ............................................................................................... APPENDIX B

1.0 SCOPE OF SERVICES

B2 Environmental, Inc. (B2E) performed a microbial assessment of Monument Fire Center - Barracks located at 3751 Mount Herman Road in Monument, Colorado, to provide information regarding potential microbial growth and develop a mold remediation work plan. B2E conducted sampling for surface spore concentrations at the identified building in general accordance with the following guidance documents:

• Indoor Environmental Standards Organization (IESO), Standards of Practice for the Assessment of Indoor Environmental Quality, Volume 1: Mold Sampling; Assessment of Mold Contamination, 2002;

• Occupational Safety and Health Administration (OSHA) Technical Manual, OSHA Instruction TED 01-00-015 [TED 1-0.15A]; and

B2E followed sections of these guidance documents as generally appropriate for this assessment.

2.0 GENERAL SITE CONDITIONS

The assessment site is a multi-story barracks constructed of concrete, brick and metal. It is climate controlled by a central heating, ventilating, and air conditioning (HVAC) system. B2E did not detect off-odors but did identify evidence of moisture intrusion and visible suspect mold growth at the time of the assessment.

3.0 MICROBIAL SAMPLING

B2E conducted microbial sampling for surface fungal spore concentrations. Please refer to Appendix A for laboratory results. B2E collected surface tape samples of suspect visible fungal growth from the basement men’s shower room walls. B2E placed the surface tape samples on a glass microscope slides sealed in plastic slide holders supplied by the laboratory and shipped via overnight courier to IATL International located at 9000 Commerce Parkway, Suite B in Mount Laurel, New Jersey for direct microscopic analysis to identify fungal spores and particulates.

The following table presents the microbial sampling results.

Table 1: Microbial Surface Sample Analysis

Sample Number

B2376384 – North Wall B2376383 – East Wall B2376382 – West Wall

Genera Type(s)

Loading Loading Loading

Stachybotrys High High High

High = Most of the observed debris on the tape is comprised of mold spores/hyphae

4.0 MOLD VISUAL ASSESSMENT

On April 12, 2022, B2E performed a visual assessment to determine areas of visible suspect mold growth and areas of past and/or present moisture intrusion. B2E identified the following areas of concern. Please refer to Appendix B for a photographic log.

Table 2: Mold Visual Assessment

Location Description of Area Quantity Photographic

Reference

Men’s Shower Room Drywall Walls – evidence of moisture intrusion (staining) and visible suspect mold growth

100 sf 1,2,3,4,5,6

Men’s Shower Room Wood Trim (doors and floors) – evidence of moisture intrusion (staining)

150 lf 4,5,6 sf-square feet lf-linear feet N/A-Not Applicable

5.0 CONCLUSIONS AND RECOMMENDATIONS

1. B2E did not detect off-odors but did identify evidence of moisture intrusion and visible suspect mold growth at the time of the assessment. It is B2E’s opinion that the visible mold growth in the basement on the drywall walls is the result of a leaking sink over an extended period of time in the Men’s Shower Room.

Based on the microbial assessment performed on April 12, 2022, B2E recommends the guidance set forth in the following mold remediation work plan.

6.0 REMEDIATION WORK PLAN

6.1 Introduction

The purpose of this work plan is to assist in remediating the fungal impact at Monument Fire Center-Barracks located at 3751 Mount Herman Road in Monument, Colorado. The intent of the report is to aid the building owner, architect, construction manager, general contractors, and potential demolition and abatement contractors in locating fungal growth (mold). Actual site conditions and quantities should be field verified. B2E performed a cursory assessment to locate suspect fungal growth in the areas identified. The techniques used are inherently limited in the sense that only full demolition procedures will reveal all building materials of a structure and, therefore, all areas of potential fungal growth. The size of the area impacted by fungal growth is based on professional judgment and practicality. Additionally, other possible building material hazards such as asbestos and lead-based paint were not included as part of this evaluation and may require proper sampling for identification prior to disturbance. Other unidentified fungal impact may be located within walls, ceiling cavities, below flooring or grade, and other non-accessible areas. Caution should be used during any remediation activities.

Additionally, the passage of time may result in a change in the environmental characteristics at this site. This report does not warrant against future operations or conditions that could affect the recommendations made. The results, findings, conclusions, and recommendations expressed in this report are based only on conditions that were observed during B2E’s assessment of the site.

This work plan addresses worker exposure to mold, worker protection requirements, work area containment, methods of cleaning, methods of removal, waste disposal and regulatory compliance required by the Occupational Safety and Health Administration (OSHA).

The quantities of materials to be remediated are approximates. It is the contractor's responsibility to verify the material quantities. During removal of insulation, if other contaminated building materials are discovered, the contractor shall also remove and/or clean these areas of contamination.

The owner shall provide water and an electric supply from existing sources where the contractor's use is not excessive and does not interfere with the building's normal use.