DRAFT_Crownpoint_Phase_II_ESA_Attachments_D_and_E_0002.pdf

ATTACHMENT D

Survey Report for Asbestos-Containing Materials and Lead Based Paint

SURVEY REPORT FOR ASBESTOS-CONTAINING MATERIALS, LEAD-BASED PAINTS,

AND OTHER HAZARDOUS MATERIALS

BIA CROWN POINT COMMUNITY SCHOOL

MCKINLEY COUNTY, NEW MEXICO

ATC PROJECT NO. 90.75440.0016

Prepared for:

MILLENIUM SCIENCE & ENGINEERING, INC.

1555 SHORLINE DRIVE, SUITE 150

BOISE, IDAHO 83702

Prepared by:

ATC ASSOCIATES INC.

11121 CANAL ROAD

CINCINNATI, OHIO 45241

JULY 3, 2012

11121 Canal Road Cincinnati, Ohio 45241 www.atcassociates.com Tel: 513-771-2112 Fax: 513-782-6908 i

July 3, 2012

Richard Kelsey Sr. Engineer, Program Manager Millennium Science & Engineering, Inc.

1555 Shoreline Drive, Suite 150 Boise, Idaho 83702

Re: Survey Report for Asbestos-Containing Materials, Lead Based Paint, and General Hazardous Materials BIA Crown Point Community School

McKinley County, New Mexico ATC Project Number 90.75440.0016

ATC Associates Inc. (ATC) has completed the Asbestos-Containing Materials (ACMs), Lead Based Paint and General Hazardous Materials Survey at the referenced MSE project site. The project included assessment, sampling and analysis for the presence of asbestos and lead in accessible building materials in buildings on the property. Our findings and conclusions are included herein.

We appreciate the opportunity to be of service to Millennium Science & Engineering, Inc. on this project. If you have questions or comments regarding the information presented in this report, please contact us at (513) 771-2112.

Sincerely, ATC ASSOCIATES INC.

Jason R. Gregory Brian Britain, PE, CSP Industrial Hygiene Technician New Mexico Sr. Project Manager

Jasen M. Holton, MS, CSP Dale M. Allison National Project Manager Director, National Client Management http://www.atcassociates.com/

Survey Report for Asbestos, Lead, and General Hazardous Materials BIA Crown Point Community School McKinley County, New Mexico

ATC Project Number 090.75440.0016 ii

EXECUTIVE SUMMARY

ATC Associates Inc. (ATC) performed an inspection of 13 structures associated with the BIA Crown

Point Community School campus for asbestos-containing building materials, Lead-Based Paint

(LBP) and other hazardous, regulated materials. The inspection was performed on behalf of

Millennium Science & Engineering, Inc. (MSE) from May 29, 2012 through June 8, 2012, to identify materials that may possibly impact the environment or cause unnecessary worker exposure as a result of demolition or renovation activities to the subject buildings. Other hazardous, regulated materials evaluated as part of this portion of the inspection included but were not limited to: mercury thermostats, smoke detectors, radioactive exit signs, PCB ballasts, fluorescent light tubes (FLTs), compact FLTs, HVAC units with CFCs/HCFCs, mercury vapor lights, and cleaning/maintenance supplies.

Asbestos-containing materials were identified on site and included (but are not limited to) floor tiles, mastics, Gypsum wallboard/joint compound, roof flashings, hard cementitious fittings, tank insulation, boiler insulation, window caulking/glazing, Transite panels, etc. In accordance with the

EPA, all regulated asbestos-containing materials (RACM) must be removed prior to demolition or renovation activities. Category I and II asbestos-containing materials may also need to be removed prior to demolition/renovation activities in the event these activities have the potential to be damaged or rendered friable during those activities.

The cursory LBP inspection was conducted as part of this project to alert bidders, the abatement contractor, and/or other trades engaged in renovation/demolition work so that they may properly execute their activities in accordance with applicable provisions of the OSHA lead standard for construction and any other applicable lead regulations. All of the structures inspected at the project site contain building materials coated with LBP.

The visual inspection for hazardous/regulated materials identified building components and materials aside from ACM and LBP within the structures. Materials identified included: PCB-containing ballasts, fluorescent light bulbs, mercury-vapor bulbs, incandescent light bulbs, smoke detectors, computer equipment, and various cleaning chemicals. These materials will need to be properly handled, recycled or disposed of according to appropriate State and Federal regulations depending upon client goals.

ATC Project Number 090.75440.0013 iii

TABLE OF CONTENTS

LETTER OF TRANSMITTAL ........................................................................................................... i

EXECUTIVE SUMMARY ................................................................................................................ ii

1. INTRODUCTION

2. ASBESTOS INSPECTION

2.1. BULK SAMPLE COLLECTION

2.2. LABORATORY ANALYSIS

2.3. ANALYTICAL RESULTS

3. LEAD BASED PAINT SURVEY

4. GENERAL HAZARDOUS MATERIALS SURVEY

5. CONCLUSIONS AND RECOMMENDATIONS

5.1. ASBESTOS SURVEY

5.2. LEAD SURVEY

5.3. HAZARDOUS MATERIALS SURVEY

6. LIMITATIONS

TABLES

Table 1 Asbestos Bulk Sample Data Sheet Table 2 Inventory of Asbestos-Containing Materials Table 3 Summary of Lead-Based Paint Table 4 Inventory of Hazardous Materials Table 5 TCLP Analytical Results

APPENDICES

Appendix A Certifications and Licenses Appendix B PLM Laboratory Analytical Report and Chain of Custody Records Appendix C TCLP Analytical Reports and Chain of Custody Records

FIGURES

Sample Location Sketches

BIA Crown Point Community School Campus

McKinley County, New Mexico

ATC Project Number 090.75440.0016

1. INTRODUCTION

From May 29, 2012 through June 8, 2012, ATC Associates Inc. (ATC) performed a survey of the BIA Crown Point Community School campus to identify asbestos-containing materials

(ACM), lead-based paint (LBP) on predominantly painted surfaces, as well as inventoried other hazardous or otherwise regulated materials that may need to be removed prior to the planned demolition/renovation activities. The work was performed on behalf of the Millennium Science &

Engineering, Inc. (MSE) in general accordance with ATC Proposal No. 072-2012-0164.

The purpose of the asbestos inspection was to identify asbestos-containing materials (ACM) in the subject buildings. Accordingly, the scope of study consisted of: 1) inspection of the 13 structures to identify those materials that may contain asbestos, 2) collection and analysis of bulk samples in accordance with EPA guidelines, 3) compilation of an inventory of the locations and quantities of ACM, and 4) project documentation.

The purpose of the cursory lead paint survey was to identify the presence of lead-containing paint on predominantly painted surfaces within each structure to alert bidders, the abatement contractor, and/or other trades engaged in renovation/demolition work so that they may properly execute their activities in accordance with applicable provisions of the OSHA lead standard for construction and any other applicable lead regulations.

The purpose of the general hazardous/regulated material inspection was to identify building components and materials besides regulated ACM and LBP that may need to be removed and disposed, reclaimed, or recycled before the structures undergo renovation/demolition. The materials identified included, but were not limited to: mercury thermostats, smoke detectors, , PCB ballasts, fluorescent bulbs, mercury vapor lights, and various cleaning/maintenance supplies.

Mr. Karl Jensen and Mr. Jason Gregory, AHERA-trained Asbestos Building Inspectors

(Certification Numbers 121164 and 118805, respectively) conducted the asbestos, lead, and hazardous material survey. Copies of Mr. Jensen’s and Mr. Gregory’s asbestos inspector accreditations are contained in Attachment A.

This report documents and summarizes the procedures and findings of the inspection.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

2. ASBESTOS INSPECTION

Upon arrival at the site, the inspectors conducted a walk-through inspection of each structure.

Accessible areas were visually evaluated for the presence of building materials with the potential to contain asbestos. During the inspection, the inspectors looked for suspect materials on building components such as pipes, tanks, ceilings, etc. that could contain asbestos.

Suspect materials were touched to determine if they were friable, and sampling areas containing homogeneous materials were identified. A homogeneous area is defined by the U.S.

Environmental Protection Agency (EPA) as an area of surfacing material, thermal system insulation, or miscellaneous material that is uniform in color and texture (Asbestos Hazard

Emergency Response Act [AHERA] 40 CFR 763 Subpart E). Quantities of suspect materials identified were determined using visual estimation techniques. The EPA and Occupational

Safety and Health Administration (OSHA) defines friable materials as those materials that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure.

Per our authorized proposal, ATC did not utilize destructive methods of inspection to confirm the presence or absence of suspect ACM concealed behind intact finished surfaces (e.g., plaster or drywall-enclosed wall chases and ceiling plenums). Additional quantities of ACM may be located within these inaccessible areas.

2.1. Bulk Sample Collection

During the asbestos inspection, samples of suspect materials were randomly collected from each structure in accordance with AHERA Section 763.86. For friable surfacing materials, three bulk samples were collected for each homogeneous area less than or equal to 1,000 square feet. If the homogeneous area was greater than 1,000 square feet but less than 5,000 square feet, five bulk samples were collected. For homogeneous areas that were greater than 5,000 square feet, seven bulk samples were collected. Sample locations for each homogeneous area of suspect surfacing material were determined by the inspectors during the initial inspection.

Three samples were randomly collected from homogeneous areas of thermal system insulation such as pipe or duct insulation. Miscellaneous materials such as floor tile or ceiling tile were sampled in a manner sufficient to determine whether the material in question contained asbestos.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

To avoid disturbing the material more than necessary and potentially cause the release of asbestos fibers, bulk sampling of suspect materials was performed in accordance with generally accepted procedures outlined in current EPA Guidance Documents and in EPA-approved

Asbestos Building Inspector certification course manuals. Each sample was collected with a clean sampling tool and placed in a clean, sealable container and labeled with a unique sample identification number. This sample number was recorded on a Bulk Sample Log Sheet and on the sample container to permit easy identification of the sample. Supplemental information was also recorded on the Bulk Sample Log Sheet, including date of inspection, name of the inspector, the building name (or number), a brief description and location of the sample, and type of material sampled (e.g., thermal insulation, floor tile, construction mastic, etc.). Upon completion of the inspection, bulk samples were submitted to ATC’s NVLAP-accredited Bulk

Asbestos Laboratories in Cincinnati, Ohio and Centennial, Colorado. Table 1 and Figures 1 through 14 present a summary of the sampling locations. Table 1 also contains the analytical results for the suspect materials tested.

2.2. Laboratory Analysis

The bulk samples were analyzed for asbestos content by polarized-light microscopy (PLM) and dispersion staining methods (Method Reference: EPA 600/R-93/116, July 1993). This analytical method, which the EPA currently accepts for the determination of asbestos in bulk samples, can be used for qualitative identification of six morphologically different types of asbestos fibers:

chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite asbestos.

The method specifies that the asbestos content in a bulk sample be estimated and reported as a finite percentage (rounded to the nearest percent) within the range of 0 and 100. Minute quantities of asbestos in bulk samples may be reported as "trace" or less than 1 percent (<1%).

The analytical method determines the "area percent" asbestos or the percentage of the area of a microscopic field of view that is occupied by asbestos fibers.

The results of bulk sample analyses are reported in a standard written laboratory report. This written report includes the client name, the laboratory identification numbers assigned to each bulk sample upon receipt by the laboratory sample custodian, and the field number assigned to each bulk sample during the building inspection. The composition of the bulk sample is reported in percentage of asbestos (i.e., chrysotile, amosite, crocidolite, or other) and non-

McKinley County, New Mexico

ATC Project Number 090.75440.0016 asbestos (i.e., cellulose, fiberglass, synthetic, or other) components. Table 2 (attached) presents an inventory of the ACM located within the accessible areas of the 13 structures.

Additional quantities of ACM may be located within inaccessible areas (i.e. wall cavities, ceiling plenums, etc.). Copies of the laboratory reports from ATC’s asbestos laboratory and completed chain-of-custody forms are presented in Attachment B.

The EPA defines an ACM as any material or product, which contains greater than 1 percent

(>1%) asbestos by weight. When the visual estimate of a sample is less than 10 percent (10%) asbestos, the sample may be reanalyzed using the PLM point-count method. The PLM point-count method is a systematic, objective method that more accurately determines the percentage of small amounts of asbestos in a given sample. None of the samples collected were analyzed using the point-count method. However, point-count analysis could be performed upon request to possibly reduce abatement requirements and therefore demolition costs.

2.3. Analytical Results

A total of 363 bulk samples were collected from 160 homogeneous areas of suspect ACM found within and on the 13 structures. The results of the analyses of all samples that were suspected to contain asbestos are summarized in the Bulk Sample Data Summary (Table 1). This table lists:

a description of the material sampled, the location sampled, the identification number assigned to the sample by the inspector in the field, the percentage and type of asbestos present in the sample, if identified, and the homogeneous area from which the sample was collected.

The following building materials were analyzed and found to contain asbestos concentrations greater than one percent (>1.0%). A complete breakdown of the location and quantities of ACM within each structure is summarized on Table 2. NOTE: No asbestos-containing materials were identified in Buildings 3005 and 3011.

Interior Building Materials

9-in.2 Floor Tile and Underlying Mastic – (Buildings 3001, 3002, 3003, 3006, 3008, 3010, 3012)

12-in.2 Floor Tile and Underlying Mastic – (Buildings 3001, 3008, 3012)

McKinley County, New Mexico

ATC Project Number 090.75440.0016

Hard Cementitious Fittings – (Buildings 3001, 3002, 3003, 3006, 3008, 3009, 3010, 3012)

Transite Panels – (Building 3007)

Window Glaze – (Buildings 3003, 3008, 3009)

Door Caulking – (Building 3008)

Boiler Paper – (Buildings 3003, 3010)

Boiler Brick and Mortar – (Building 3012)

Tank Insulation – (Buildings 3002, 3003, 3012)

Gypsum wallboard/joint compound – (Building 3003)

Exterior Building Materials:

Roof Flashing – (Buildings 3001, 3003, 3006, 3008, 3012)

Roof Exhaust Caulking – (Building 3012)

Window Caulking – (Buildings 3001, 3003, 3009)

McKinley County, New Mexico

ATC Project Number 090.75440.0016

3. LEAD BASED PAINT SURVEY

ATC Associates, Inc. (ATC) conducted a cursory survey for lead-based paint (LBP) in each of the 13 structures located at the BIA Crown Point Community School Campus using a portable

Niton XL Spectrum XRF lead-based paint (LBP) analyzer.

The LBP sampling strategy was based on the procedures outlined by the U.S. Department of

Housing and Urban Development (HUD) "Guidelines for the Evaluation and Control of Lead-

Based Paint Hazards in Housing," but was not a comprehensive survey and is not compliant with the HUD sampling requirements. Specifically, the LBP screening consisted of measuring lead concentrations of interior and exterior painted surface that were predominate at each building. Paint was considered predominate when it covered approximately 80% or more of the total interior or exterior building finish surface.

The XRF nondestructively analyzes for the presence of lead on painted surfaces. Portable XRF instruments expose a painted building component to X-rays, which cause lead to fluoresce with a characteristic frequency or energy. The instrument’s internal microprocessor and software then measure the intensity of this radiation. LBP is defined as paint having a lead content >1.0 mg/cm2 as determined by XRF, or > 0.5 percent by weight (5,000 ppm) as determined by laboratory analysis. OSHA does not define lead-containing paint or materials, or specify a minimum lead content for materials that could cause occupational airborne exposures to lead above permissible limits.

The XRF is considered an excellent screening instrument that can detect relatively high concentrations of lead in paint. The XRF, however, cannot always accurately detect lead in paint at concentrations below 0.5 percent by weight (5,000 ppm). ATC conducted XRF tests at

682 different locations and the results of these tests are presented in Table 3

The findings of the investigation revealed that all of the buildings contained components/materials which are considered lead-based paint or are lead-containing.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

4. GENERAL HAZARDOUS MATERIALS SURVEY

ATC has conducted a survey of each structure to identify and inventory heavy metal-containing fluorescent lamps, PCB-containing ballasts, CFC-containing refrigeration and air conditioning equipment, containers of chemical products and other hazardous/regulated or potentially hazardous building components that may need to be removed and properly disposed, reclaimed, or recycled as required by current EPA regulations and best environmental practices if the materials will be adversely impacted by the future renovation/demolition plans.. These materials include:

Fluorescent lamps (mercury-containing)

Incandescent bulbs (heavy-metal containing)

Mercury-vapor bulbs (mercury-containing)

Light ballasts (possible PCB-containing)

Smoke detectors (possible radiological sources)

Computer equipment (heavy-metal containing)

Various containers of cleaners, solvents, oils, and paints

A detailed breakdown of this inventory by building is presented as Table 4 (attached) and could change if any of these items are removed by the Property Owner or others prior to the start of renovation/demolition activities. If any of the materials identified on Table 4 will be adversely impacted by the planned renovation/demolition activity, they should be properly removed, transported, recycled, and/or disposed in accordance with all applicable regulations.

In addition to compiling an inventory of hazardous or otherwise regulated materials as discussed above, ATC collected composite bulk samples of building materials from each of the structures and submitted them to Hygeia Laboratories Inc. in Sierra Madre, California, for analyses in accordance the EPA’s Toxicity Characteristic Leaching Procedure. The analytical results of the15 bulk samples submitted for analyses are summarized on Table 5 (attached). A copy of the Hygeia analytical reports and completed Chain-of Custody forms are located in

Appendix C.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

The analytical results indicate that the debris generated during the eventual demolition of the structures do not exceed the TCLP regulatory thresholds and should be able to be handled as a non-hazardous waste stream.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

5. CONCLUSIONS AND RECOMMENDATIONS

5.1. Asbestos Survey

Although not required by state or federal regulatory agencies, ATC recommends that all the

ACMs identified in this report be maintained under a written O&M program, by suitably trained personnel, until renovation necessitates removal or until the buildings are demolished.

Subcontractors and employees working within the structures at the site should be made aware of the locations of the ACMs and the possibility of concealed ACMs that could be found during renovation/demolition activities.

Non-Friable and undamaged ACM are classified as NESHAP Category I or Category II, non-friable ACMs by the EPA. In accordance with the NESHAP, as long as such materials remains in a non-friable state and are not subjected to mechanical drilling, sanding, abrading, grinding, or sawing during renovation and/or demolition activities, they do not have to be removed, provided no visible emissions are generated during the demolition process.

The following recommendations should be followed for demolition projects including contracting the services of an environmental consultant to monitor/document that the demolition contractor activities comply with the New Mexico Department of Environmental Quality, OSHA, EPA, and

NESHAP requirements:

The non-friable ACMs shall not be subjected to abrasion, grinding, sanding or any other processes during demolition, which will render these non-friable materials friable.

Subcontractors and employees working within the structures at the site should be made aware of the locations of the ACMs and the possibility of concealed ACMs that could be found during renovation/demolition activities.

Friable and Category I and Category II Non-friable materials (such as resilient floor coverings) that have a propensity to become friable during renovation/demolition, are recommended for removal by New Mexico-licensed personnel in accordance with applicable regulations, prior to building renovation/demolition. Any Person intending to either abate asbestos-containing materials in any amount, or demolish a structure shall, on a form supplied by the New Mexico Environment Department of Air Quality Bureau, McKinley County, New Mexico

ATC Project Number 090.75440.0016 provide a written notice of the intent to conduct asbestos abatement or demolition. No person shall commence an abatement project in which the amount of friable asbestos-containing material exceeds any amount without first obtaining a permit from the New

Mexico Environment Department of Air Quality Bureau. Permit fees will be required for asbestos abatement projects.

If the substrate (such as concrete) on which non-friable ACMs are installed are intended for recycling, the non-friable ACMs should be removed prior to the recycling process, by a state licensed asbestos abatement contractor prior to initiating substrate recycling activities.

5.2. Lead Survey

The survey for lead-based paint was conducted as part of this project to alert bidders, the abatement contractor, and/or other trades engaged in renovation/demolition work so that they may properly execute their activities in accordance with applicable provisions of the OSHA lead standard for construction and any other applicable lead regulations.

Lead-based paint has been found in a majority of the buildings associated with the project. Any planned renovation/demolition work (e.g., manual demolition of or modifications to building components coated with lead-containing paint) must be conducted in accordance with all applicable requirements of the OSHA lead standard. The OSHA lead standard has specific training requirements and work practices for activities involving the disturbance of lead paint, and requires that the contractor(s) that disturb lead-containing materials conduct exposure assessments of their employees during disturbance and/or manual demolition of lead-containing materials to determine worker exposures to lead.

The applicability of specific sections of the standard and the need to comply with specific requirements depend on the actual levels of exposure that employees experience when performing renovation/demolition activities in or on buildings where lead-containing materials are present. Therefore, OSHA requires that the Contractor performing operations covered by this standard conduct exposure assessments to determine if their employees are exposed to lead above the action level (AL, 30μg/m3) or the permissible exposure limit (PEL, 50 μg/m3).

Worker exposures above the AL and PEL trigger specific actions that the Contractor must take to control and limit exposures to lead and to comply with OSHA requirements.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

Until lead exposure assessments have been conducted and the results evaluated, the standard requires the Contractor to treat their employees as though they are being exposed to lead in excess of the PEL, and to provide [per 29 CFR 1926.62(d)(2)(v)(A-F)]:

Respiratory protection

Protective work clothing and equipment

Change areas and hand washing facilities

Biological monitoring

Training

If the exposure assessments indicate that no employee is exposed above the AL, the Contractor may discontinue monitoring. Further exposure testing is not required unless there is a change in processes or controls that may result in additional employees being exposed to lead at or above the AL, or may result in employees already exposed at or above the AL being exposed above the PEL. The Contractor must keep a written record of the determination, including the date, location within the work site, and the name and social security number of each monitored employee.

5.3. Hazardous Materials Survey

ATC has conducted a survey of each building to identify and inventory heavy metal-containing fluorescent lamps, PCB-containing ballasts, CFC-containing refrigeration and air conditioning equipment, containers of chemical products and other hazardous/regulated or potentially hazardous building components. This inventory is presented as Table 4 (attached) and could change if any of these items are removed by the Property Owner or others prior to the start of renovation/demolition activities. If any of the materials identified on Table 4 will be adversely impacted by the planned renovation/demolition activity, they should be properly removed, transported, recycled, and/or disposed in accordance with all applicable regulations.

Fluorescent Lamps, Incandescent Bulbs and Mercury Vapor Bulbs

Contractors responsible for the removal and recycling of fluorescent lamps, incandescent bulbs and mercury vapor bulbs shall handle and manage them in accordance with the Environmental Protection Agency’s “Universal Waste Rules” as well as applicable State and Local regulations. Some guidelines for the proper handling and recycling of fluorescent lamps include:

McKinley County, New Mexico

ATC Project Number 090.75440.0016

Carefully remove lamps and bulbs from fixtures. Lamps and bulbs shall remain intact (unbroken) and shall be carefully placed into cardboard containers designed to hold them (preferably original boxes obtained from the manufacturer or special boxes obtained from a lamp recycler).

Broken lamps and bulbs should still be recycled. However, if they are not acceptable to the recycling facility, they must be evaluated to determine if they are hazardous waste. Remove and discard residues from broken lamps and bulbs promptly. Personnel cleaning up spills should have appropriate training and cleanup equipment, and wear appropriate personal protective equipment.

Acceptable storage for broken, damaged, or leaking lamps and bulbs include a closed 55-gallon steel drum or a closed wax fiberboard drum.

Store boxed lamps and bulbs in a secure area and limit access to personnel qualified to handle them.

Contact an EPA-approved lamp recycler and arrange for transport of the properly packaged and labeled lamps and bulbs to the recycler.

Submit copies of the original shipment records documenting proper transport, recycling, and proper disposal of any unrecycled components to the Property

Owner upon project completion.

PCB-Containing Ballasts

A limited visual inspection of ballast labels indicates that some of the fluorescent fixtures contain PCB ballasts. The Contractor should be required to inspect all ballasts in each fixture and visually verify that all ballasts are labeled “No PCBs” or if the ballast is unlabeled it should be presumed to contain PCBs.

Any PCB-containing ballast removed from light fixtures should be placed into a 55-gallon steel drum (17C or 17H) or other DOT-approved container appropriately labeled in accordance with EPA and DOT regulations. Any leaking PCB-containing ballasts should be wrapped and sealed in 6-mil plastic disposal bags and placed in a separate steel drum or other approved container. Each disposal drum or container should have a

McKinley County, New Mexico

ATC Project Number 090.75440.0016 sufficient amount of oil-absorbent material placed in the bottom to absorb any oil from ballasts that are leaking or may leak during transport.

The Contractor should then arrange for the transport of all properly containerized PCB-containing ballasts to an EPA-approved ballast recycling facility. Copies of completed original waste shipment records/manifests documenting the proper transport, recycling, or incineration of unrecycled components should be provided to the

Property Owner upon project completion. The Contractor should also be required to obtain and provide documentation to the Property Owner that the ballast and lamp recycling facility has all the required permits and approvals necessary for operations involving recycling mercury-containing lamps and disposing of PCB-containing light ballasts.

Paint Cans and Chemical Containers

The Contractor should be required remove from the premises all paint cans, fire extinguishers, pressurized containers, and other containers containing chemicals or products and arrange to have them properly containerized, transported, and disposed in accordance with applicable local, state, and federal regulations. Empty containers (e.g., cans, bottles, buckets, drums, etc.) that once may have contained liquids or solids shall also be removed. The Contractor should provide to the Property Owner documentation demonstrating that all paint cans, fire extinguishers, and chemical containers have been properly removed, transported, and disposed.

In addition to compiling an inventory of hazardous or otherwise regulated materials as discussed above, ATC collected composite bulk samples of building materials from each of the structures and submitted them for analyses in accordance the EPA’s Toxicity Characteristic

Leaching Procedure. The analytical results indicate that the debris generated during the eventual demolition of the structures do not exceed the TCLP regulatory thresholds and should be able to be handled as a non-hazardous waste stream.

McKinley County, New Mexico

ATC Project Number 090.75440.0016

6. LIMITATIONS

This report is intended for the sole use of Millennium Science & Engineering, Inc. unless reliance is extended to a third party with the permission of ATC. ATC selection of sample locations and frequency of sampling was based on ATC observations and the assumption that like materials in the same area are homogeneous in content. Destructive investigation in the building was not authorized as part of this limited assessment. All unsampled suspect asbestos materials should be treated as assumed ACM in accordance with 40 CFR 763.

This report is not intended to serve as a bidding document or as a project specification document. Actual site conditions may change over time and quantities are general estimates and should be field verified prior to making cost assumptions. 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 or conclusions herein is at the risk of said user.

Although reasonable efforts have been made to identify suspect asbestos in the areas identified, the limits of the scope of work and inspection technique used is inherently limited in the sense that only full demolition procedures will reveal all building materials of a structure.

Our professional services have been performed, our findings obtained, and our conclusions prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated. The results, findings and conclusions expressed in this report are based only on conditions that were observed during ATC's inspection of the Site.

ATC Project Number 090.75440.0013

TABLE 1

ASBESTOS BULK SAMPLE DATA SHEET

TABLE 1: BULK SAMPLE DATA SUMMARY

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

BUILDING 3000

White paint on roof vents Roof 2 3000-001 12B-08194 None Detected (Miscellaneous)

Roof flashing Roof 3 3000-002 12B-08195 None Detected (Miscellaneous)

Roof flashing Upper roof 3 3000-003 12B-08196 20% Chrysotile (Miscellaneous) perimeter

Roof flashing West wing roof 3 3000-004 12B-08197 Sample not analyzed per (Miscellaneous) positive stop

Roofing South wing 1 3000-005 12B-08198 None Detected (Miscellaneous)

Roofing Center Wing 1 3000-006 12B-08199 None Detected (Miscellaneous)

Roofing Above library 1 3000-007 12B-08200 None Detected (Miscellaneous)

Chalkboard Room 156 9 3000-008 12B-08201 15% Chrysotile (Miscellaneous)

Janitor's fire door insulation Janitor's closet 10 3000-009 12B-08202 None Detected (Miscellaneous)

Woven wire insulation Mechanical room 6 3000-010 12B-08203 None Detected (Miscellaneous) Elec. panel

Tank Insulation Mechanical room 4 3000-011 12B-08204 20% Chrysotile (Thermal system insulation)

Boiler insulation Mechanical room 5 3000-012 12B-08205 40% Chrysotile (Thermal system insulation) Boiler #1

Boiler insulation Mechanical room 5 3000-013 12B-08206 Sample not analyzed per (Thermal system insulation) Boiler #2 positive stop

Boiler insulation Mechanical room 5 3000-014 12B-08207 Sample not analyzed per (Thermal system insulation) Boiler #3 positive stop

Blue covebase West hall 14 3000-015 12B-08208 None Detected (Miscellaneous) corridor and underlying mastic Blue covebase North wing hall 14 3000-016 12B-08209 None Detected (Miscellaneous) Corridor and underlying mastic

TABLE 1 - Page 1

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Blue covebase North hall at 14 3000-017 12B-08210 None Detected (Miscellaneous) intersection - corridor and underlying mastic 12"x12" Gray floor tile Room 122 (RR) 16 3000-018 12B-08211 None Detected (Tile) and underlying black mastic 5% Chrysotile (Mastic) (Miscellaneous)

12"x12" Gray floor tile Room 121 (RR) 16 3000-019 12B-08212 Sample not analyzed per and underlying black mastic positive stop

(Miscellaneous) 12"x12" Gray floor tile Rooom 119 (RR) 16 3000-020 12B-08213 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

Hard Fitting South wing 8 3000-021 12B-08214 None Detected (Thermal system insulation)

Hard Fitting North corridor 8 3000-022 12B-08215 7% Chrysotile (Thermal system insulation)

Hard Fitting South corridor 8 3000-023 12B-08216 Sample not analyzed per (Thermal system insulation) positive stop

Gypsum substrate for GCT North corridor 18 3000-024 12B-08217 None Detected (Miscellaneous)

Gypsum substrate for GCT South wing hall 18 3000-025 12B-08218 None Detected (Miscellaneous)

Gypsum substrate for GCT North wing hall 18 3000-026 12B-08219 None Detected (Miscellaneous)

Exterior texture Southside of library 7 3000-027 12B-08220 None Detected (Surfacing)

Exterior texture Northeast corridor 7 3000-028 12B-08221 None Detected (Surfacing)

Exterior texture Library upper 7 3000-029 12B-08222 None Detected (Surfacing)

GCT mastic on F/G tiles Room 121 19 3000-030 12B-08223 None Detected (Miscellaneous)

GCT mastic on F/G tiles Room 156 19 3000-031 12B-08224 None Detected (Miscellaneous)

GCT mastic on F/G tiles Room 141 19 3000-032 12B-08225 None Detected (Miscellaneous)

Plaster (RR) North corridor 20 3000-033 12B-08226 None Detected (Surfacing)

TABLE 1 - Page 2

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Plaster (RR) Room 121 ceiling 20 3000-034 12B-08227 None Detected (Surfacing)

Plaster (RR) Library 20 3000-035 12B-08228 None Detected (Surfacing)

Exterior window caulk North wing 11 3000-036 12B-08229 5% Chrysotile (Miscellaneous)

GCT - hallway Hallway 21 3000-037 12B-08230 None Detected (Miscellaneous) north corridor

GCT - hallway Hallway 21 3000-038 12B-08231 None Detected (Miscellaneous) North wing

GCT - hallway Hallway 21 3000-039 12B-08232 None Detected (Miscellaneous) South wing

9"x9" Brown floor tile Room 120 15 3000-040 12B-08233 5% Chrysotile (Tile) and underlying black mastic 5% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Brown floor tile Room 154 15 3000-041 12B-08234 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

9"x9" Brown floor tile Room 143 15 3000-042 12B-08235 Sample not analyzed per and underlying black mastic positive stop

(Miscellaneous) Black coverbase Room 124 13 3000-043 12B-08236 None Detected (Miscellaneous)

Black coverbase Room 156 13 3000-044 12B-08237 None Detected (Miscellaneous)

Black coverbase Room 146 13 3000-045 12B-08238 None Detected (Miscellaneous)

9"x9" Green floor tile North corridor 12 3000-046 12B-08239 5% Chrysotile (Tile) and underlying black mastic 5% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Green floor tile North-south corridor 12 3000-047 12B-08240 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

9"x9" Gray floor tile Room 147 17 3000-048 12B-08241 5% Chrysotile (Tile) and underlying black mastic 5% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Gray floor tile Room 136 17 3000-049 12B-08242 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

TABLE 1 - Page 3

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

BUILDING 3001

Hard fitting Mechanical room 15 3001-001 0014657-001 20% Chrysotile (Thermal system insualtion)

Hard fitting North apartment 15 3001-002 0014657-002 Sample not analyzed per (Thermal system insualtion) positive stop

Tank insulation Mechanical Room 14 3001-003 0014657-003 25% Amosite (Thermal system insualtion) 10% Chrysotile

Boiler caulk Mechanical room 13 3001-004 0014657-004 None Detected (Miscellaneous) Boiler #1

Boiler caulk Mechanical room 13 3001-005 0014657-005 None Detected (Miscellaneous) Boiler #2

Roofing Roof 1 3001-006 0014657-006 None Detected (Miscellaneous)

Roof flashing Roof (random) 2 3001-007 0014657-007 20% Chrysotile (Miscellaneous)

Roof vent caulk Roof - vents 3 3001-008 0014657-008 None Detected (Miscellaneous)

Exterior texture East wing 8 3001-009 0014657-009 None Detected (Surfacing)

Exterior texture West wing 8 3001-010 0014657-010 None Detected (Surfacing)

Exterior texture South wing 8 3001-011 0014657-011 None Detected (Surfacing)

Window caulk South exterior 16 3001-012 0014657-012 3% Chrysotile (Miscellaneous)

Window caulk South wing 16 3001-013 0014657-013 Sample not analyzed per (Miscellaneous) exterior positive stop

Window glaze East wing 7 3001-014 0014657-014 None Detected (Miscellaneous)

Window glaze Living room 7 3001-015 0014657-015 None Detected (Miscellaneous)

Brown covebase South wing 5 3001-016 0014657-016 None Detected (Miscellaneous) and underlying beige mastic

TABLE 1 - Page 4

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Brown covebase Living room 5 3001-017 0014657-017 None Detected (Miscellaneous) and underlying beige mastic Brown covebase North wing 5 3001-018 0014657-018 None Detected (Miscellaneous) and underlying beige mastic GCT mastic Living room 9 3001-019 0014657-019 None Detected

(Miscellaneous)

GCT mastic Office of 9 3001-020 0014657-020 None Detected (Miscellaneous) living room

GCT mastic Living room 9 3001-021 0014657-021 None Detected (Miscellaneous)

12"x12" Gray floor tile West hall 4 3001-022 0014657-022 None Detected (Tile) and underlying black mastic 10% Chrysotile (Mastic)

(Miscellaneous) 12"x12" Gray floor tile West hall 4 3001-023 0014657-023 None Detected (Tile) and underlying black mastic 10% Chrysotile (Mastic) (Miscellaneous)

12"x12" Gray floor tile West hall 4 3001-024 0014657-024 None Detected (Tile) and underlying black mastic 10% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Brown floor tile Living room 6 3001-025 0014657-025 5% Chrysotile (Tile) and underlying black mastic 10% Chrysotile (Mastic) (Miscellaneous)

9"x9" Brown floor tile Living room 6 3001-026 0014657-026 Sample not analyzed per and underlying black mastic positive stop

(Miscellaneous) 9"x9" Brown floor tile Kitchen area 6 3001-027 0014657-027 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

12"x12" White floor tile Southwest entry 11 3001-028 0014657-028 2% Chrysotile (Tile) and underlying black mastic 10% Chrysotile (Mastic)

(Miscellaneous) 12"x12" White floor tile East apartment 11 3001-029 0014657-029 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

12"x12" White floor tile Southwest apartment 11 3001-030 0014657-030 Sample not analyzed per and underlying black mastic positive stop

(Miscellaneous) Smooth plaster North apartment 10 3001-031 0014657-031 None Detected

(Surfacing)

Smooth plaster North wing 10 3001-032 0014657-032 None Detected (Surfacing) restroom

Smooth plaster South wing 10 3001-033 0014657-033 None Detected (Surfacing) apartment

TABLE 1 - Page 5

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Textured plaster Dividing wall 12 3001-034 0014657-034 None Detected (Surfacing) south wing

Textured plaster Dividing wall 12 3001-035 0014657-035 None Detected (Surfacing) east wing

Textured plaster Dividing wall 12 3001-036 0014657-036 None Detected (Surfacing) north wing

BUILDING 3002

Brown exterior texture East side 2 3002-001 12B-08161 None Detected (Surfacing)

Brown exterior texture West side 2 3002-002 12B-08162 None Detected (Surfacing)

Brown exterior texture South side 2 3002-003 12B-08163 None Detected (Surfacing)

Black Covebase Lobby 1 3002-004 12B-08164 None Detected (Miscellaneous)

Black Covebase Stage area 1 3002-005 12B-08165 None Detected (Miscellaneous)

Black Covebase Gym area 1 3002-006 12B-08166 None Detected (Miscellaneous)

Hard Fitting Mechanical chase 9 3002-007 12B-08167 10% Chrysotile (Thermal system insulation) Boys' locker room

Hard Fitting Mechanical chase 9 3002-008 12B-08168 Sample not analyzed per (Thermal system insulation) Girls' locker room positive stop

Hard Fitting Mechanical room 9 3002-009 12B-08169 Sample not analyzed per (Thermal system insulation) positive stop

Tank insulation Mechanical room 8 3002-010 12B-08170 10% Chrysotile (Thermal system insulation) 10% Amosite

Black tar paper Mechanical chase 4 3002-011 12B-08171 None Detected (Miscellaneous) Girls' locker room

Black tar paper Mechanical chase 4 3002-012 12B-08172 None Detected (Miscellaneous) Girls' locker room

Black tar paper Mechanical chase 4 3002-013 12B-08173 None Detected (Miscellaneous) Boys' locker room

TABLE 1 - Page 6

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

White plaster Boys' locker room 3 3002-014 12B-08174 None Detected (Surfacing)

White plaster Lobby 3 3002-015 12B-08175 None Detected (Surfacing)

White plaster Stage area 3 3002-016 12B-08176 None Detected (Surfacing)

9"x9" Tan floor tile East stairwell 5 3002-017 12B-08177 7% Chrysotile (Tile) and underlying black mastic 3% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Tan floor tile East stairwell 5 3002-018 12B-08178 Sample not analyzed per and underlying black mastic positive stop (Miscellaneous)

9"x9" Tan floor tile Boys' laundry room 5 3002-019 12B-08179 Sample not analyzed per and underlying black mastic positive stop

(Miscellaneous) 12"x12" Tan floor tile Lobby 7 3002-020 12B-08180 None Detected

(Miscellaneous)

12"x12" Tan floor tile Lobby 7 3002-021 12B-08181 None Detected (Miscellaneous)

12"x12" Tan floor tile Lobby 7 3002-022 12B-08182 None Detected (Miscellaneous)

12"x12" White floor tile Girls' laundry room 6 3002-023 12B-08183 None Detected (Miscellaneous)

12"x12" White floor tile Girls' laundry room 6 3002-024 12B-08184 None Detected (Miscellaneous)

12"x12" White floor tile Girls' laundry room 6 3002-025 12B-08185 None Detected (Miscellaneous)

BUILDING 3003

Roofing Roof 1 3003-001 0014658-001 None Detected (Miscellaneous)

Brown boiler paper (Interior) Interior of 10 3003-002 0014658-002 60% Chrysotile (Miscellaneous) boiler

Brown boiler paper (Interior) Interior of 10 3003-003 0014658-003 Sample not analyzed per (Miscellaneous) boiler positive stop

White tank insulation Mechanical room 11 3003-004 0014658-004 35% Amosite (Thermal system insulation)

TABLE 1 - Page 7

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Roof flashing Roof (random) 3 3003-005 0014658-005 20% Chrysotile (Miscellaneous)

Roof vent caulk Roof - vents 2 3003-006 0014658-006 None Detected (Miscellaneous)

Gray window glaze Northside 13 30003-007 0014658-007 2% Chrysotile (Miscellaneous) Exterior

Brown window caulk West side 14 3003-008 0014658-008 3% Chrysotile (Miscellaneous) Exterior

Gypsum wallboard/Joint Compound Rear room 5 3003-009 0014658-009 None Detected (Wallboard) (Miscellaneous) 2% Chrysotile (Joint Compound)

Gypsum wallboard/Joint Compound East wing office 5 3003-010 0014658-010 None Detected (Wallboard) (Miscellaneous) 2% Chrysotile (Joint Compound)

Gypsum wallboard/Joint Compound Dividing wall 5 3003-011 0014658-011 None Detected (Wallboard) (Miscellaneous) Maintenance shop 2% Chrysotile (Joint Compound)

Exterior texture Living area 8 3003-012 0014658-012 None Detected (Surfacing)

Exterior texture North wing 8 3003-013 0014658-013 None Detected (Surfacing)

Exterior texture South wing 8 3003-014 0014658-014 None Detected (Surfacing)

Hard fitting Mechanical room 12 3003-015 0014658-015 15% Chrysotile (Thermal system insulation)

Hard fitting Maintenance shop 12 3003-016 0014658-016 Sample not analyzed per (Thermal system insulation) positive stop

Hard fitting South wing 12 3003-017 0014658-017 Sample not analyzed per (Thermal system insulation) positive stop

9"x9" Brown floor tile South office 9 3003-018 0014658-018 10% Chrysotile (Tile) and underlying brown/black mastic 10% Chrysotile (Mastic)

(Miscellaneous) 9"x9" Brown floor tile North wing 9 3003-019 0014658-019 Sample not analyzed per and underlying brown/black mastic Hallway positive stop (Miscellaneous)

9"x9" Brown floor tile South wing 9 3003-020 0014658-020 Sample not analyzed per and underlying brown/black mastic Hallway positive stop

(Miscellaneous) Smooth wall plaster South wing 4 3003-021 0014658-021 None Detected

(Surfacing) Restroom

TABLE 1 - Page 8

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Smooth wall plaster North wing 4 3003-022 0014658-022 None Detected (Surfacing) Restroom

Smooth wall plaster West wing 4 3003-023 0014658-023 None Detected (Surfacing) Restroom

Rough plaster South wing 7 3003-024 0014658-024 None Detected (Surfacing) Office

Rough plaster South wing 7 3003-025 0014658-025 None Detected (Surfacing) Office

Rough plaster East wing 7 3003-026 0014658-026 None Detected (Surfacing) Office

Black covebase South wing 6 3003-027 0014658-027 None Detected and underlying yellow mastic

(Miscellaneous) Black covebase North wing 6 3003-028 0014658-028 None Detected and underlying yellow mastic (Miscellaneous) Black covebase Maintenance office 6 3003-029 0014658-029 None Detected and underlying yellow mastic (Miscellaneous)

BUILDING 3004

Roofing Roof 4 3004-001 12B-08243 None Detected (Miscellaneous)

Roof flashing Roof (random) 2 3004-002 12B-08244 20% Chrysotile (Miscellaneous)

Roof vent paint Roof (vents) 1 3004-003 12B-08245 None Detected (Miscellaneous)

Boiler paper Mechanical room 3 3004-004 12B-08246 35% Chrysotile (Miscellaneous) Boiler #1

Boiler paper Mechanical room 3 3004-005 12B-08247 Sample not analyzed per (Miscellaneous) Boiler #2 positive stop

Exterior window glaze North wing 9 3004-006 12B-08248 None Detected (Miscellaneous)

Exterior window glaze North wing 9 3004-007 12B-08249 None Detected (Miscellaneous)

Exterior window glaze South wing 9 3004-008 12B-08250 None Detected

TABLE 1 - Page 9

McKinley County, New Mexico

SAMPLE SAMPLE H.A. SAMPLE LAB ASBESTOS

DESCRIPTION LOCATION NO. I.D. NO. I.D. NO. CONTENT

Exterior window caulk South wing 8 3004-009 12B-08251 5% Chrysotile (Miscellaneous)

Exterior window caulk East wing 8 3004-010 12B-08252 Sample not analyzed per (Miscellaneous) positive stop

Exterior window caulk East wing 8 3004-011 12B-08253 Sample not analyzed per (Miscellaneous) positive stop

Exterior texture West wing 6 3004-012 12B-08254 None Detected (Surfacing)

Exterior texture South wing 6 3004-013 12B-08255 None Detected (Surfacing)

Exterior texture East wing 6 3004-014 12B-08256 None Detected (Surfacing)

Gypsum substrate behind GCT Living room office 19 3004-015 12B-08257 None Detected (Miscellaneous)

Gypsum substrate behind GCT Living room office 19 3004-016 12B-08258 None Detected (Miscellaneous)

Gypsum substrate behind GCT Living room office 19 3004-017 12B-08259 None Detected (Miscellaneous)

Textured plaster Office dividing wall 10 3004-018 12B-08260 None Detected (Surfacing)

Textured plaster Office…