B09_Amendment_3_MALU_293291_MLK_Mold_and_RBM_Survey_Report_Attachment_12_0003.pdf

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MOLD/IAQ AND REGULATED BUILDING

MATERIALS SURVEY REPORT

Rehabilitate Visitor Center and Headquarters

Martin Luther King, Jr. National Historic Park 450 Auburn Avenue NE Atlanta, GA 30312

Mabbett Project No. R2023106 PMIS Number: MALU 293291

Prepared For:

900 S. Broadway, Suite 300 Denver, CO 80209

Mabbett & Associates, Inc. www.mabbett.com 105 Central Street, Suite 4100 Stoneham, MA 02180-1260 T. 781-275-6050 F: 781-954-5155 Massachusetts | Virginia | Rhode Island | New York

© 2023, Mabbett & Associates, Inc.

MOLD/IAQ AND REGULATED BUILDING MATERIALS SURVEY REPORT

Martin Luther King Jr. National Historic Park ꟾ Atlanta, GA

© 2023, Mabbett & Associates, Inc. Page i September 14, 2023 Project No. R2023106.000 DHM MLK Mold and RBM Survey Report

ACKNOWLEDGEMENT

This Mold/IAQ and Regulated Building Materials Survey Report has been prepared by Mabbett & Associates, Inc.

(Mabbett®) for the rehabilitate visitor center and headquarters project at the Martin Luther King Jr. National Historic Park located in Atlanta, Georgia. The information presented herein is based on the facts and information conveyed to or received by Mabbett during the preparation of this report. If any of the information provided to Mabbett that was used in preparing this report is incorrect, incomplete, or subject to change, Mabbett would wish to alter its opinion(s) accordingly. In addition, the professional opinions and information contained in this report are based solely on the requirements of the applicable regulations and technical data as known to Mabbett as of the date of this report and considered applicable to this report.

Mabbett has conducted this assessment with reasonable care and has performed this project in accordance with industry standards. There can be no assurances, and Mabbett makes no assurances, that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported herein.

The attached Regulated Building Materials Survey Report was prepared by Mr. Jacob T. Walsh, Regulated Building Materials Technician of Mabbett & Associates, Inc.

This report has been reviewed and approved by:

Michael F. Delaney Director, Building Sciences Group

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© 2023, Mabbett & Associates, Inc. Page ii September 14, 2023 Project No. R2023106.000 DHM MLK Mold and RBM Survey Report

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION

1.1 Summary of Survey Results

1.2 Purpose and Objectives

2.0 ACM SURVEY

2.1 Sampling Methodology

2.2 Analytical Methodology

2.3 Summary of Asbestos Containing Materials Findings

3.0 LCP SURVEY

3.1 Screening Survey and Sampling Methodology

3.2 Summary of Lead Paint Chip Screening Survey Findings

4.0 MOLD/IAQ ASSESMENT

4.1 results and interpretations

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 ACM Survey

5.2 LCP Survey

5.3 Mold/IAQ Assessment

6.0 LIMITATIONS

TABLES

Table 1 Summary of Lead in Paint Chip Sampling Results Table 2 Summary of Air-O-Cell Sample Results

APPENDICES

Appendix A GLE Associates, Inc. Asbestos Containing Materials Survey Report and CoC, August 30, 2023 Appendix B Lead Paint Chip Laboratory Report and Chain of Custody Appendix C GLE Associates, Inc. Limited Mold Assessment Survey Report and CoC, August 30, 2023

© 2023, Mabbett & Associates, Inc. Page 1 September 14, 2023 Project No.R2023106.000 DHM MLK Mold and RBM Survey Report

1.0 INTRODUCTION

This report presents the results of the Mold/IAQ (indoor air quality) and Regulated Building Materials Survey (the Survey) completed by Mabbett and Associates, Inc. (Mabbett®) and GLE Associates, Inc. (GLE), at the Martin Luther King Jr. National Park Visitors Center at 450 Auburn Avenue Atlanta, Georgia. The Survey was conducted by Mabbett as a subcontractor to the DHM under the terms and conditions of the Task Order Agreement dated July 19, 2023, Dayton Martin Luther King Jr. Visitor Center Rehabilitation – AE Design Services for Construction Documents. The objective of the Survey was to identify asbestos containing materials (ACM), lead containing paint (LCP) and conduct a Mold/IAQ assessment within the interior and exterior of the Martin Luther King Jr. Visitors Center so that an abatement scope can be incorporated into the client’s design documents being developed for building rehabilitation.

1.1 Summary of Survey Results

Bulk samples of suspected Asbestos Containing Materials (ACM) were collected and submitted to a certified analytical laboratory for asbestos analysis by polarized light microscopy (PLM) using stop positive methodology.

The Survey also included the collection of Lead Containing Paint (LCP) chip samples for submittal for lead analysis by an AIHA accredited analytical laboratory. Additionally, the Survey included an indoor mold assessment in limited areas of concern in the Martin Luther King Jr. National Historic Park Visitor Center.

The Survey involved the collection or screening of the following samples, resulting in the following conclusions:

Sixty-nine (69) bulk samples for suspect ACM were collected. Based on laboratory analysis of suspect ACM, none of the collected samples contained asbestos. The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) defines ACM as any material that contains greater than one percent (>1%) asbestos.

Five (5) paint chip samples from building surfaces were collected. Based on laboratory analysis of paint chips, none of the collected samples revealed concentrations of lead in paint that exceeded the U.S.

Department of Housing and Urban Development (HUD) threshold of 0.5 percent by weight.

Visual assessment of the areas of concern identified water and/or mold impacted building materials. Five

(5) interior fungal spore trap air samples were collected. One (1) interior air sample indicated a total mold spore concentration that was greater than the outdoor concentration.

1.2 Purpose and Objectives

The Survey was comprised of three primary tasks Including:

Evaluation of existing site conditions and formulation of a sampling plan;

Sampling to collect building material samples for laboratory analysis; and Development of this Mold/IAQ and Regulated Building Materials Survey Report.

The Survey was designed to accomplish three primary objectives: conduct a limited assessment for mold; collect a representative number of building materials for laboratory analysis and reporting; and use data from the laboratory analysis efforts to estimate the volume of hazardous materials present within the building’s interior and exterior for subsequent use in development of an abatement scope. These three objectives were met through a combination of a site visit and inspection to collect building material samples for laboratory analysis; and interpretation of qualitative data collected in the field; and the quantitative laboratory data generated from analysis of the building materials as summarized in this survey report.

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2.0 ACM SURVEY

The ACM Survey was completed on August 17, 2023, by Mr. Jeremy Jordan of GLE Associates, Inc., an Environmental Protection Agency/Asbestos Hazard Emergency Response Act (EPA/AHERA) accredited inspector (No. AI19367).

The two-story facility was constructed in 1996 and consists of drywall, a concrete slab on grade floor, a built-up system, and a brick/stucco façade.

2.1 Sampling Methodology

The asbestos sampling activities were completed in accordance with the proposed scope of work. Suspect ACM’s were collected using EPA National Emissions Standards for Hazardous Air Pollutants (NESHAP), 40 CFR Part 763 and Asbestos Hazard Emergency Response Act (AHERA) protocols. Bulk samples of suspect ACM were collected in accordance with AHERA and was conducted according to the following sampling plan:

Surfacing material:

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

At least five bulk samples shall be collected from each homogeneous area that is greater than

1,000 ft2 but less than or equal to 5,000 ft2.

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

Thermal system insulation:

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

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

Sufficient samples shall be collected from elbows and fittings to determine if they contain ACM.

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

Miscellaneous material:

At least one bulk sample shall be collected from each homogeneous area that is less than 100 ft2.

At least three bulk samples shall be collected from each homogeneous area that is greater than

100 ft2.

2.2 Analytical Methodology

The bulk samples were submitted under chain of custody procedures to GLE’s National Voluntary Laboratory Accreditation Program (NVLAP) for analysis. The samples were analyzed by Polarized Light Microscopy (PLM) coupled with dispersion staining, in general accordance with EPA-600/R-93/116.

The PLM analysis results are further discussed in Appendix A – GLE Associates, Inc. Asbestos Containing Materials Survey Report. The EPA, Occupational Safety and Health Administration (OSHA), and Regulations of the State of Georgia defines any material that contains greater than one percent (>1%) asbestos as being an ACM. As such, the analytical laboratory results indicated that none of the sampled suspect materials contained greater than one percent (>1%) asbestos. Laboratory reports and CoC documentation are provided in Appendix A of this report.

2.3 Summary of Asbestos Containing Materials Findings

GLE identified twenty-three (23) types of homogenous materials and collected sixty-nine (69) representative bulk ACM samples. All sixty-nine (69) samples were analyzed by PLM. The laboratory reported analytical data indicated

© 2023, Mabbett & Associates, Inc. Page 3 September 14, 2023 Project No.R2023106.000 DHM MLK Mold and RBM Survey Report that none of the homogenous materials sampled contained asbestos and two (2) materials were not accessible for sampled and are assumed to contain asbestos;

Mirror Mastic, approximately 120 square feet Exterior Portico Stucco, 500 square feet

ACM sampling methodologies and procedures are further discussed in Appendix A.

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3.0 LCP SURVEY

As part of the Survey, a visual inspection of interior and exterior painted surfaces was conducted by Mr. Jacob T.

Walsh of Mabbett. Additionally, the LCP survey included the collection of paint chip samples for submittal for lead analysis by an AIHA accredited analytical laboratory.

3.1 Screening Survey and Sampling Methodology

Mabbett conducted a LCP sampling program to measure lead concentrations in selected painted surfaces of the Martin Luther King Jr. National Historic Park Visitors Center and collected five (5) paint chip samples for submittal to Scientific Analytical Institute (SAI) of Greensboro, North Carolina for analysis of lead content. The collected samples were analyzed in accordance with EPA Method SW846-3050B/7000B. A copy of the laboratory analytical report and chain of custody is provided in Appendix B.

3.2 Summary of Lead Paint Chip Screening Survey Findings

TABLE 1

Summary of Lead Paint Chip Analytical Results

Martin Luther King Junior National Historic Park Visitor Center Atlanta, GA

Sample I.D. Location Substrate and Component Results

(% wt.)

L1 1st Floor Theater White Gypsum Wall 0.0036% L2 1st Floor Projection Room Black Gypsum Wall <0.0078% L3 1st Floor Corridor Tan Metal Door <0.0064% L4 Women’s Room 1st Floor White Gypsum Wall <0.0053% L5 2nd Floor Mechanical Room White Gypsum Wall 0.0056%

The Occupational Safety & Health Administration (OSHA) does not recognize a “safe” level of lead in paint.

Depending on the method of removal used, even trace amounts of lead in paint may result in airborne concentrations of lead during removal. An employer or contractor who disturbs or removes lead paint must comply with OSHA Standard 29 CFR 1926.62, “Lead Exposure in Construction; Interim Final Rule.”

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4.0 MOLD/IAQ ASSESMENT

Mabbett & Associates, Inc. (Mabbett®) was requested by DHM to perform an indoor mold assessment in limited areas along the north side of the Martin Luther King Jr. National Historic Park Visitor Center. The objective of the assessment was to determine if there is a concern for indoor mold in suspect areas of the visitor center. The assessment was conducted by Mr. Jeremy Jordan of GLE on August 17, 2023, and included the following components:

Limited Visual Assessment and Moisture Measurements;

Temperature and Relative Humidity Measurements; and Bio-Aerosol Microbial Air Sampling.

This report summarizes observations, measurements of fungal spore trap air sample collection, data interpretation, and recommendations for the areas assessed. A visual inspection was conducted in areas of the building for evidence of historic water intrusion, suspected fungal growth, and unusual odors.

In order for mold to grow in any environment, they need a food source, moisture, proper temperature and humidity, and a source of light. There will always be some fungi in any indoor environment due to a variety of reasons, including traffic in and out of a building, air intrusion through doors and windows, and the building’s HVAC system. The one factor that can be controlled in the building is moisture. As such, indoor fungal investigations typically focus on sources of water loss inside the building (e.g., from plumbing and operational processes), and sources of water intrusion from outside the building (e.g., roof/window leaks).

GLE performed a walkthrough visual assessment of accessible areas of concern within the scope of work. The assessment identified water and/or mold impacted materials including but limited to, building materials exhibiting water staining, water damage, and/or mold growth. Musty odors were noted throughout the areas of the theater, store, projector room, and storage room. The analytical results of the air samples are summarized in Table 2.

TABLE 2

Air-O-Cell Sample Results

Martin Luther King Jr. National Historic Park Visitor Center Atlanta, GA

Sample # Location Type of Spore Raw Count Count (Spores) % of Total

36261206 Theater

Ascospores 1 20 2.6 Aspergillus/Penicillium 30 660 84.6

Basidiospores 6 100 12.8 Total Fungi 37 780 100

36261214 Theater

Ascospores 2 40 6.2 Aspergillus/Penicillium 18 400 61.8

Basidiospores 8 200 30.9 Pithomyces++ 1* 7* 1.1

Total Fungi 29 647 100

36261262 Projector Room

Ascospores 1 20 3.5 Aspergillus/Penicillium 16 350 61.4

Basidiospores 5 100 17.5 Cladosporium 6 100 17.5

Total Fungi 28 570 100

36261210 Storage Ascospores 5 100 9.9 Aspergillus/Penicillium 19 420 41.6

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TABLE 2

Air-O-Cell Sample Results

Martin Luther King Jr. National Historic Park Visitor Center Atlanta, GA

Sample # Location Type of Spore Raw Count Count (Spores) % of Total Basidiospores 22 490 48.5

Total Fungi 46 1010 100

36261209 Store

Ascospores 2 40 0.9 Aspergillus/Penicillium 193 4260 97.1

Basidiospores 2 40 0.9 Cladosporium 2 40 0.9 Pithomyces++ 1* 7* 0.2

Total Fungi 200 4387 100

36261215 Outside

Ascospores 46 1000 36.6 Aspergillus/Penicillium 6 100 3.7

Basidiospores 66 1500 54.9 Bipolaris++ 1 20 0.7

Cladosporium 2 40 1.5 Ganoderma 1* 7* 0.3

Myxomyces++ 1 20 0.7 Pithomyces++ 3* 20* 0.7

Rust 1* 7* 0.3 Sporidesmium++ 1 20 0.7

Total Fungi 128 2734 100

36261225 Outside

Ascospores 53 1200 35.5 Basidiospores 88 1900 56.1 Cladosporium 7 200 5.9 Ganoderma 1 20 0.6

Myxomycetes++ 2 40 1.2 Pithomyces++ 2* 10* 0.3

Rust 1* 7* 0.2 Spegazzinia 1* 7* 0.2 Total Fungi 155 3384 100

4.1 RESULTS AND INTERPRETATIONS

The interior air sample analytical results indicate that four (4) samples with mold spore concentrations less than the average total exterior concentration. However, air sample analytical results identified an individual spore type concentration significantly greater than the corresponding exterior concentrations. The interior air sample analytical results also indicated that one (1) sample had mold spore concentrations that were greater than the average total exterior concentration. In addition, air sample analytical results identified an individual spore type concentration significantly greater than the corresponding exterior average concentrations. Mold sampling procedures and interpretations are further discussed in Appendix C.

© 2023, Mabbett & Associates, Inc. Page 7 September 14, 2023 Project No.R2023106.000 DHM MLK Mold and RBM Survey Report

5.0 CONCLUSIONS AND RECOMMENDATIONS

This section presents the conclusions generated from the regulated building materials survey and sampling event conducted by Mabbett and GLE, at the Martin Luther King Jr. National Historic Park Visitor Center.

5.1 ACM Survey

Results of our sampling efforts for ACM included the collection of sixty-nine (69) bulk samples for laboratory analysis and reporting. Results of this effort are summarized above in section 2.3 which indicated two materials that were inaccessible for sampling were assumed ACM. Mabbett recommends sampling of these materials prior to disturbance.

Any suspect ACM encountered during demolition activities that is not identified in this report as being non-ACM should be assumed to be ACM unless laboratory analytical data for bulk samples prove otherwise. Suspect ACM that may be present within the walls, above inaccessible hard ceilings, or in other inaccessible locations, and that accordingly were not inspected should be assumed to contain asbestos if discovered until otherwise verified, as previously described. If ACM must be disturbed, the ACM must be removed by a licensed asbestos abatement contractor and be performed in accordance with applicable regulations. If proposed work activities will not disturb intact ACM, continuous monitoring of ACM should be conducted throughout work activities to ensure the ACM remains in an intact condition. Additionally, prior to commencing work activities, personnel involved with the work activities should be made aware of the location of ACM, within the building in which they will be working.

5.2 LCP Survey

The purpose of the LCP screening survey was to identify building materials coated with lead-containing paint. For the purpose of this LCP screening survey, representative interior building components were tested from the building. The regulations addressing LCP in non-residential buildings are focused on protecting workers involved with paint-disturbing activities and related waste-disposal activities.

A concentration of lead greater than or equal to 0.5 percent by weight exceeds the U.S. HUD residential standards and is an indicator of risk. OSHA does not specify a safe concentration of LCP. For the purposes of this LCP screening survey, lead concentrations greater than 0.5 percent by weight have been utilized as a threshold for areas where possible worker exposures may occur.

OSHA’s lead regulations will apply to any demolition operation (i.e., sanding, scraping, cutting, and welding) that would disturb painted surfaces which contain lead. Occupational exposure to lead is regulated by OSHA (29CFR 1910.1025) as well as applicable state regulations. These regulations involve air monitoring of workers to determine exposure levels when disturbing paint containing measurable lead. An LCP determination cannot determine a safe level of lead but is intended to provide guidance to the locations where LCP is present. Employers and contractors may use this information to better determine worker exposure to airborne lead by understanding the different concentrations of lead paint on representative components and surfaces. Worker exposure controls can then be implemented, and air monitoring can be performed during activities that disturb LCP.

Disposal of materials coated with paint containing lead is subject to the USEPA RCRA regulations. At the present time, federal and state regulations do not necessarily require that materials coated with LCP be removed prior to demolition. However, wastes generated are required to be characterized prior to disposal. Mabbett recommends that TCLP testing be performed on the waste stream generated during the planned demolition of the building.

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5.3 Mold/IAQ Assessment

The objective of this assessment was to conduct a screening of the potential presence and concentration of airborne fungal spores in select areas of concern within the Martin Luther King Jr. National Historic Park Visitor Center. Visual assessment of the areas of concern identified water and/or mold impacted building materials.

Interior fungal spore trap air samples were collected and indicated a total mold spore concentration that was greater than the outdoor concentration in the Storage Room sample. Water and mold impacted building materials should be remediated in accordance with federal, state, and local regulations and ordinances using experienced and trained personnel. additional information and recommendations are further detailed in Appendix C.

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6.0 LIMITATIONS

This Report is the result of a diligent search of select areas of the Martin Luther King Jr. National Historic Park for asbestos, lead, and mold. Although a comprehensive inspection was performed, Mabbett does not claim to have identified all of the materials that may be present at/in the building. Mabbett has conducted this assessment with reasonable care and has performed this project within generally accepted industry standards. Mabbett makes no assurances that the information, research, and technology used to prepare this report may not change in the future, thus affecting the results reported here.

© 2023, Mabbett & Associates, Inc. APPENDIX A September 14, 2023

APPENDIX A

GLE Associates, Inc. Asbestos Containing Material Survey Report and COC

1100 Spring Street NW, Suite 820

Atlanta, Georgia 30309 404-373-3844 • Fax 404-373-3427

LIMITED RENOVATION ASBESTOS SURVEY REPORT

Martin Luther King Jr. National Park Visitors Center 450 Auburn Avenue NE Atlanta, Georgia 30312

GLE Project No.: 23000-28262

Prepared for:

Mr. Michael Delaney Mabbett & Associates, Inc.

Stoneham, Massachusetts 02180

August 30, 2023

Prepared by:

GLE Associates, Inc.

1100 Spring Street NW, Suite 820 | Atlanta, Georgia 30309 | 404-373-3844| Fax: 404-373-4327 Orlando | Ft. Lauderdale | Miami | Jacksonville | Gainesville | Tampa | Nashville

Architecture AA 0002369 • Engineer CA 5483 • Asbestos ZA 0000034 • Geology GB 0000297

105 Central Street, Suite 4100 Stoneham, Massachusetts 02180

RE: Limited Renovation Asbestos Survey Report

Martin Luther King Jr. National Park Visitors Center

Dear Mr. Delaney:

GLE Associates, Inc. (GLE) performed a limited renovation survey for asbestos-containing materials (ACM) on August 17, 2023, at Martin Luther King Jr. National Park Visitors Center, located in Atlanta, Georgia. The survey was performed by Mr. Jeremy Jordan with GLE. This report outlines the sampling and testing procedures, and presents the results along with our conclusions and recommendations.

GLE appreciates the opportunity to serve as your consultant on this project. If you should have any questions, or if we can be of further service, please do not hesitate to call.

Sincerely, Jeremy Jordan Robert B. Greene, PE, PG, CIH, LEED AP Senior Project Manager President

JEJ/RBG/jl

\\atlsvr\sys\Work\Asb\23000\23000-28262 Mabbett - MLK Jr NP Visitors Center Env Cons Srvcs\Report, Invoice\ACM\MLK Jr NP Visitors Center ACM Survey.doc

TABLE OF CONTENTS

1.0 INTRODUCTION 1

1.1 Introduction 1

1.2 Facility Description 1

2.0 RESULTS 2

2.1 Asbestos Survey Procedures 2

2.2 Identified Suspect Asbestos-Containing Materials 3

Table 2.2-1 — Summary of Homogeneous Sampling Areas

3.0 CONCLUSIONS AND RECOMMENDATIONS 6

3.1 General 6

3.2 Specific 7

4.0 LIMITATIONS AND CONDITIONS 7

APPENDICES

Appendix A – Analytical Results and Chain of Custody Appendix B – Personnel and Laboratory Certifications Appendix C – Asbestos Sample Location Plans Appendix D – Photographs

1.0 INTRODUCTION

1.1 INTRODUCTION

The purpose of this limited renovation survey was to identify accessible asbestos-containing materials (ACMs) and their general locations within Martin Luther King Jr. National Park Visitors Center, located at 450 Auburn Avenue NE in Atlanta, Georgia. The survey was performed during regular operational hours and materials were identified by the Client’s onsite representative, Mr. Jacob Walsh. As a result mirror materials in restrooms were not disturbed and are assumed to contain asbestos in the mastics that adhere them to the wall. Additionally, exterior stucco on the exterior portico was inaccessible with the provided ladder. These stucco materials are also assumed to contain asbestos. The survey was conducted pursuant to National Emission Standards for Hazardous Air Pollutants (NESHAP, 40 CFR 61) requirements, associated with the scheduled renovation plans. The survey was performed on August 17, 2023, by Mr. Jeremy Jordan, an Environmental Protection Agency/Asbestos Hazard Emergency Response Act (EPA/AHERA) accredited inspector. The scope of this survey did not include demolition of any building components, evaluation of architectural plans, or the quantification of materials for abatement purposes, or removal cost estimating.

1.2 FACILITY DESCRIPTION

A summary of the facility investigated is outlined in the table below. A representative view of the facility is shown in Appendix D.

Facility Type: Commercial Construction Date: 1996 Number of Floors: Two

Exterior Floor Support: Concrete Slab on Grade Wall Support: Metal Framing Exterior Finish: Paint, Stucco, Brick Roof System Type: Built Up (Modified Bitumen)

Interior Wall Substrate: Drywall and Joint Compound Wall Finishes: Paint, Cove Base Floor Finishes: Vinyl Floor Tile, Ceramic Tile, Carpet Ceiling System: Suspended Ceiling System Ceiling Finishes: Suspended Ceiling Tiles

2.0 RESULTS

2.1 ASBESTOS SURVEY PROCEDURES

The survey was performed by visually observing accessible areas within the scope of work. An EPA/AHERA accredited inspector performed the visual observations (refer to Appendix B for personnel qualifications).

After the overall visual survey was completed, representative sampling areas were determined.

The surveyor delineated homogeneous areas of suspect materials and samples of each material were obtained, in general accordance with regulations as established by the Occupational Safety and Health Administration (OSHA) and NESHAP. The field surveyor determined sample locations based on previous experience. Both friable and non-friable materials were sampled. A friable material is one that can be crushed when dry by normal hand pressure. This survey did not include the demolition of building components to access suspect material.

The survey was performed during regular operational hours and materials were identified by the Client’s onsite representative, Mr. Jacob Walsh. As a result mirror materials in restrooms were not disturbed and are assumed to contain asbestos in the mastics that adhere them to the wall.

Additionally, exterior stucco on the exterior portico was inaccessible with the provided ladder.

These stucco materials are also assumed to contain asbestos.

After completion of the fieldwork, the samples were delivered to GLE’s National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory for analysis. The samples were analyzed by Polarized Light Microscopy (PLM) coupled with dispersion staining, in general accordance with EPA-600/R-93/116. Utilizing this procedure, the various asbestos minerals (chrysotile, amosite, crocidolite, actinolite, tremolite, and anthophyllite) can be determined. The percentages of asbestos minerals in the samples were visually determined by the microscopist. Please note that the EPA designates all materials containing greater than one percent asbestos as an “asbestos-containing material” (ACM).

Regulated Asbestos-Containing Material (RACM) is defined as (a) Friable asbestos materials,

(b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Category I and Category II non-friable ACM, as defined by the EPA:

Category I non-friable ACM means asbestos-containing packings, gaskets, resilient floor covering, asphalt roofing products, and pliable sealants and mastics that are in good condition and not friable, containing more than one percent asbestos, as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM.

Category II non-friable ACM means any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos as determined using the methods specified in Appendix E, Subpart E, 40 CFR Part 763 Section 1, PLM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

2.2 IDENTIFIED SUSPECT ASBESTOS-CONTAINING MATERIALS

A total of 69 samples of suspect building materials were collected from the facility during the survey, representing 23 different identified homogeneous areas. The results of the laboratory analyses are included in Appendix A, and approximate sample locations are indicated on the Asbestos Sample Location Plans in Appendix C. Photographs of the assumed materials are included in Appendix D.

Due to the damage that could be caused by destructive sampling techniques and restricted accessibility, the following materials were assumed to contain asbestos minerals and were not sampled.

1. Mirror mastics;

2. Exterior portico stucco.

A summary of the homogenous sampling areas of suspect ACM determined to be present is outlined in the following table.

ASBESTOS CONTENT

Expressed as percent

* = The facility owner has the option of point-counting by Polarized Light Microscopy (PLM) those RACM whose asbestos content is less than 10% in order to more accurately determine the asbestos content therein.

FRIABILITY F = Friable Material NF = Non-Friable Material ACM CATEGORY RACM = Regulated ACM CAT I = Category I non-friable ACM CAT II = Category II non-friable ACM

ABBREVIATIONS:

PC = Results based on Point-Count analysis TEM NOB = Transmission Electron Microscopy of Non-Friable Organically Bound Material NA = Not Applicable ND = None Detected NIS = Not in Scope C = Chrysotile A = Amosite HA = Homogeneous Area SF = Square Feet LF = Linear Feet CF = Cubic Feet

TABLE 2.2-1: SUMMARY OF HOMOGENEOUS SAMPLING AREAS

MARTIN LUTHER KING JR. NATIONAL PARK VISITORS CENTER – ATLANTA, GEORGIA

HA # HOMOGENEOUS MATERIAL

DESCRIPTION

HOMOGENEOUS MATERIAL

LOCATION

FRIABILITY

(F /NF) % ASBESTOS* # OF SAMPLES

COLLECTED

APPROXIMATE

QUANTITY

ACM

CATEGORY

CT01 White Pindot/Fissure 2’x2’ Ceiling Tile Throughout F ND 3 NIS NA

FT01 White with Black Specks 12”x12” Floor Tile with Black Mastic 1st Floor Projector Room NF ND 3 NIS NA

FT02 White with Black Specks 12”x12” Floor Tile with Yellow Adhesive

2nd Floor Break Room and Data Closet NF ND 3 NIS NA

VB01 3” Black Vinyl Cove Base with Yellow Adhesive Throughout NF ND 3 NIS NA

VB02 3” Tan Vinyl Cove Base with Yellow Adhesive

1st Floor Projector Room and 2nd Floor Office Areas NF ND 3 NIS NA

VB03 3” Brown Vinyl Cove Base with Yellow Adhesive 2nd Floor Mechanical Room NF ND 3 NIS NA

MAS01 Green Carpet Adhesive Throughout NF ND 3 NIS NA MAS02 White Duct Seam Mastic Throughout NF ND 3 NIS NA MAS03 White Pipe Mastic Throughout NF ND 3 NIS NA

M01 Red Sidewalk Expansion Caulk Exterior Portico Sidewalk NF ND 3 NIS NA M02 White Column Expansion Caulk Exterior Portico Columns NF ND 3 NIS NA M03 White Ceramic Tile Grout Restrooms NF ND 3 NIS NA M04 White Sink Caulk Restrooms NF ND 3 NIS NA M05 White Sprinkler Pipe Thread Sealant Throughout NF ND 3 NIS NA M06 Gray Sink Coat 2nd Floor Break Room NF ND 3 NIS NA M07 Black Roof Penetration Sealant Roof NF ND 3 NIS NA M08 White Roof Penetration Sealant Roof NF ND 3 NIS NA M09 White Fiberboard Ceiling Panel 2nd Floor Roof Deck NF ND 3 NIS NA

DW01 White Drywall and Joint Compound Theater NF ND 3 NIS NA DW02 White Drywall and Joint Compoiund 1st Floor Throughout NF ND 3 NIS NA

ASBESTOS CONTENT

Expressed as percent

* = The facility owner has the option of point-counting by Polarized Light Microscopy (PLM) those RACM whose asbestos content is less than 10% in order to more accurately determine the asbestos content therein.

FRIABILITY F = Friable Material NF = Non-Friable Material ACM CATEGORY RACM = Regulated ACM CAT I = Category I non-friable ACM CAT II = Category II non-friable ACM

ABBREVIATIONS:

PC = Results based on Point-Count analysis TEM NOB = Transmission Electron Microscopy of Non-Friable Organically Bound Material NA = Not Applicable ND = None Detected NIS = Not in Scope C = Chrysotile A = Amosite HA = Homogeneous Area SF = Square Feet LF = Linear Feet CF = Cubic Feet

TABLE 2.2-1: SUMMARY OF HOMOGENEOUS SAMPLING AREAS

MARTIN LUTHER KING JR. NATIONAL PARK VISITORS CENTER – ATLANTA, GEORGIA

HA # HOMOGENEOUS MATERIAL

DESCRIPTION

HOMOGENEOUS MATERIAL

LOCATION

FRIABILITY

(F /NF) % ASBESTOS* # OF SAMPLES

COLLECTED

APPROXIMATE

QUANTITY

ACM

CATEGORY

DW03 White Drywall and Joint Compound 2nd Floor Throughout NF ND 3 NIS NA RBU01 Roof Core Roof NF ND 3 NIS NA RF01 Roof Flashing Roof NF ND 3 NIS NA

MAS04 Mirror Mastic 1st Floor Restrooms NF Assumed 0 120 SF CAT I M10 White Stucco Exterior Portico NF Assumed 0 500 SF CAT II

3.0 CONCLUSIONS AND RECOMMENDATIONS

Asbestos-containing materials (ACMs) were presumed in the scope of this survey. General and specific conclusions and recommendations are provided below.

The EPA, OSHA and the State of Georgia have promulgated regulations dealing with asbestos.

For commercial building owners, the EPA NESHAP (40 CFR 61) regulations require removal of RACM, prior to conducting activities which might disturb the material. They also deal with notification, handling and disposal of asbestos.

The EPA recommends that an Operations and Maintenance (O&M) Program be developed for any facilities with ACM, and this Program should address all ACM (known and/or assumed) present. The O&M Program establishes notification and training requirements along with special procedures for working around the ACM. The O&M Program would remain in effect until all asbestos is removed.

Category I and Category II non-friable materials, as defined by the EPA, may remain within a facility during demolition with no potential cessation of work, provided they remain non-friable and the appropriate engineering controls (i.e., wet methods) are utilized, with the resulting waste disposed of as asbestos-containing waste. However, there is no guarantee that these materials will remain non-friable. If the materials become friable, then they are classified as RACM.

Additionally, local jurisdictions may have more stringent interpretations regarding classification of these materials.

RACM, as defined by the EPA, must be removed prior to renovation or demolition activities that may disturb the materials.

The OSHA regulations deal with employee exposure to airborne asbestos fibers. The regulations restrict employee exposure, and require special monitoring, training and handling procedures when dealing with asbestos. Additionally, OSHA has regulations that may supersede the EPA regulations. In order to protect the worker, OSHA has established a permissible exposure limit (PEL), which limits employee exposure to airborne fiber concentrations. OSHA requires objective evidence that the PEL will not be exceeded, as justification that personal air monitoring and engineering controls will not be required. OSHA has also established rules requiring the containerization and labeling of asbestos waste.

The State regulations require that anyone involved in asbestos consulting activities be a licensed asbestos consultant and that anyone involved in asbestos abatement, with the exception of roofing materials, be a licensed asbestos abatement contractor.

3.2 SPECIFIC

Assumed Materials MAS04: Mirror Mastic M10: White Stucco

Suspect mirror mastic and white stucco were observed within the facility appeared to be in generally good condition and do not present a significant issue, as observed, at the time of the survey. We recommend that these materials be maintained as part of an O&M Program and periodically monitored for any changes in condition. Additionally, should planned renovation and/or demolition activities involve the disturbance of these materials, we recommend that they be sampled and analyzed for asbestos content, and if determined to be ACM, be properly removed and disposed by a licensed asbestos abatement contractor prior to conducting such activities.

4.0 LIMITATIONS AND CONDITIONS

As a result of previous renovations, there may be hidden materials, such as floor tile, sheet vinyl flooring, insulation, etc. These materials may be found in various areas hidden under existing flooring materials or in wall cavities. Any materials found during construction activities, either not addressed in this survey report, or similar to the ACM identified in this survey report should be assumed to be ACM until sampling and analysis documents otherwise.

Because of the hidden nature of many building components (i.e. within mechanical chases), it may be impossible to determine if all of the suspect building materials have been located and subsequently tested. Destructive testing in some instances is not a viable option. We cannot, therefore, guarantee that all potential ACM has been located. For the same reasons, estimates of quantities and/or conditions are subject to readily apparent situations, and our findings reflect this condition. We do warrant, however, that the investigations and methodology reflect our best efforts based upon the prevailing standard of care in the environmental industry.

The information contained in this report was prepared based upon specific parameters and regulations in force at the time of this report. The information herein is only for the specific use of the Client and GLE. GLE accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless prior written authorization has been obtained from GLE.

Analytical Results and Chain of Custody

SUMMARY OF BULK SAMPLE ANALYSIS

Mabbett; MLK Jr NP Visitor Center Theater 23000-28268

Sample Sample Type Fiber Type

CT-01A 2' X 2' White Pindot &

Fissure Ceiling Tile 100% Mineral Wool

CT-01B 2' X 2' White Pindot &

Fissure Ceiling Tile 100% Mineral Wool

CT-01C-QC 2' X 2' White Pindot &

Fissure Ceiling Tile 100% Mineral Wool

FT-01A 12" X 12" White & Black

Specks Floor Tile & Black

Mastic

100% Polymer, Quartz, Calcite, Clay, Mica

FT-01B 12" X 12" White & Black

Specks Floor Tile & Black

Mastic

100% Polymer, Quartz, Calcite, Clay, Mica

FT-01C 12" X 12" White & Black

Specks Floor Tile & Black

Mastic

100% Polymer, Quartz, Calcite, Clay, Mica

FT-02A 12" X 12" White & Black

Specks Floor Tile &

Yellow Adhesive

100% Polymer, Quartz, Calcite, Clay, Mica

FT-02B 12" X 12" White & Black

Specks Floor Tile &

Yellow Adhesive

100% Polymer, Quartz, Calcite, Clay, Mica

FT-02C 12" X 12" White & Black

Specks Floor Tile &

Yellow Adhesive

100% Polymer, Quartz, Calcite, Clay, Mica

VB-01A 3" Black Vinyl Cove Base

& Yellow Adhesive 100% Polymer

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

Feedback regarding laboratory performance should be addressed to lab@gleassociates.com.

Report Date: 8/22/2023

23000-28268

Sample Sample Type Fiber Type

VB-01B 3" Black Vinyl Cove Base

& Yellow Adhesive 100% Polymer

VB-01C 3" Black Vinyl Cove Base

& Yellow Adhesive 100% Polymer

VB-02A-QC 3" Tan Vinyl Cove Base &

Yellow Adhesive 100% Polymer

VB-02B 3" Tan Vinyl Cove Base &

Yellow Adhesive 100% Polymer

VB-02C 3" Tan Vinyl Cove Base &

Yellow Adhesive 100% Polymer

VB-03A 3" Brown Vinyl Cove

Base & Yellow Adhesive 100% Polymer

VB-03B 3" Brown Vinyl Cove

Base & Yellow Adhesive 100% Polymer

VB-03C 3" Brown Vinyl Cove

Base & Yellow Adhesive 100% Polymer

MAS-01A Green Carpet Adhesive 100% Polymer

MAS-01B Green Carpet Adhesive 100% Polymer

MAS-01C Green Carpet Adhesive 100% Polymer

MAS-02A White Duct Seam Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

MAS-02B-QC White Duct Seam Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

23000-28268

Sample Sample Type Fiber Type

MAS-02C White Duct Seam Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

MAS-03A White Pipe Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

MAS-03B White Pipe Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

MAS-03C White Pipe Mastic 100% Polymer, Quartz, Calcite, Clay, Mica

M-01A Red Sidewalk Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-01B Red Sidewalk Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-01C Red Sidewalk Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-02A White Column Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-02B White Column Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-02C-QC White Column Expansion

Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-03A White Ceramic Tile Grout 100% Quartz, Calcite, Clay, Mica

M-03B White Ceramic Tile Grout 100% Quartz, Calcite, Clay, Mica

M-03C White Ceramic Tile Grout 100% Quartz, Calcite, Clay, Mica

M-04A White Sink Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

23000-28268

Sample Sample Type Fiber Type

M-04B White Sink Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-04C White Sink Caulk 100% Polymer, Quartz, Calcite, Clay, Mica

M-05A White Sprinkler Pipe

Thread Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

M-05B White Sprinkler Pipe

Thread Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

M-05C White Sprinkler Pipe

Thread Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

M-06A-QC Gray Sink Coat 100% Polymer, Quartz, Calcite, Clay, Mica

M-06B Gray Sink Coat 100% Polymer, Quartz, Calcite, Clay, Mica

M-06C Gray Sink Coat 100% Polymer, Quartz, Calcite, Clay, Mica

M-07A Black Roof Penetration

Sealant 100% Bitumen, Quartz, Calcite, Mica

M-07B Black Roof Penetration

Sealant 100% Bitumen, Quartz, Calcite, Mica

M-07C Black Roof Penetration

Sealant 100% Bitumen, Quartz, Calcite, Mica

M-08A White Roof Penetration

Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

M-08B White Roof Penetration

Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

23000-28268

Sample Sample Type Fiber Type

M-08C White Roof Penetration

Sealant 100% Polymer, Quartz, Calcite, Clay, Mica

M-09A White Fiberboard Ceiling

Panel 100% Cellulose/paper

M-09B-QC White Fiberboard Ceiling

Panel 100% Cellulose/paper

M-09C White Fiberboard Ceiling

Panel 100% Cellulose/paper

DW-01A Theater White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-01B Theater White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-01C Theater White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-02A 1st Floor White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-02B 1st Floor White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-02C 1st Floor White Drywall &

Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-03A 2nd Floor White Drywall

& Joint Compound 100% Gypsum, Quartz, Calcite, Clay

DW-03B 2nd Floor White Drywall

& Joint Compound 100% Gypsum, Quartz, Calcite, Clay

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

23000-28268

Sample Sample Type Fiber Type

DW-03C-QC 2nd Floor White Drywall

& Joint Compound 100% Gypsum, Quartz, Calcite, Clay

RBU-01A Roof Core 100% Bitumen, Quartz, Calcite, Mica

RBU-01B Roof Core 100% Bitumen, Quartz, Calcite, Mica

RBU-01C Roof Core 100% Bitumen, Quartz, Calcite, Mica

RFO-01A Roof Flashing 100% Bitumen, Quartz, Calcite, Mica

RFO-01B Roof Flashing 100% Bitumen, Quartz, Calcite, Mica

RFO-01C Roof Flashing 100% Bitumen, Quartz, Calcite, Mica

Darryl Neldner

* Polarized Light Microscopy coupled with dispersion is the technique used for identification in accordance with EPA 600/M4-82-020 as found in App. E to Sub.

E of 40 CFR Part 763, EPA 600/R-93/116, and NIOSH Method 9002.

** The percentage of each component is visually estimated. The result of this analysis relate only to the material tested.

The report shall not be used to claim product endorsement by NVLAP or any agency of the U.S. Government.

(>1% greater than one percent, <1% less than one percent) QC - Sample reanalyzed for QA/QC.

Analysis performed by GLE Associates, Inc. NVLAP Code 102003-0, CO AL-17485, TX 30-0337

*** This report shall not be reproduced except in full, without the written approval of the laboratory. GLE Report # 28628

Analyst / Approved

Signatory:

APPENDIX B

Personnel and Laboratory Certifications

APPENDIX C

Asbestos Sample Location Plans

APPENDIX D

Photographs

August 17, 2023

MLK Jr. NP Visitors Center

Job No.

23000-28262

Photograph Date:

Prepared By:

Upper Photo: Photo #1 View of the Facility Lower Photo: Photo #2 View of MAS04

Figure

August 17, 2023

MLK Jr. NP Visitors Center

Job No.

23000-28262

Photograph Date:

Prepared By:

Upper Photo: Photo #3 View of M10

Figure

© 2023, Mabbett & Associates, Inc. APPENDIX B September 14, 2023

Lead Paint Chip Laboratory Report and Chain-of-Custody

Analysis for Lead Concentration in Paint Chips by Flame Atomic Absorption Spectroscopy

EPA SW-846 3050B/6010C/7000B

Lab Order ID:Attn: 10030738Customer: Mabbett & Associates, Inc.

105 Central Street Suite 4100

Analysis:

Date Received:

Mike Delaney

PBP

08/22/2023

Project: R2023106 DHM MLK Date Reported: 08/23/2023

Sample ID

Lab Sample ID

Description

Lab Notes

Concentration (ppm)

Co…