18-Exhibit C Environmental Report.pdf
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This is a Hazardous Materials Survey Report prepared by ACER Associates, LLC for the City of Chester Police Department located at 160 East 7th Street in Chester, Pennsylvania. The survey was conducted on March 4, 2026, by accredited environmental professionals to identify potentially hazardous materials on the 2nd Floor prior to planned renovation activities. The inspection included comprehensive testing for asbestos-containing building materials (ACBMs), lead-containing paint (LCP), polychlorinated biphenyls (PCBs), mercury, and other hazardous storage containers and equipment. Thirty-one bulk samples were collected and analyzed for asbestos content using polarized light microscopy (PLM) in accordance with EPA and OSHA standards. Lead paint testing was performed using X-ray fluorescence (XRF) technology on representative painted components throughout the facility.
The survey findings indicate that all 31 asbestos bulk samples tested negative for asbestos content, and no painted components showed detectable levels of lead. However, the inspection identified 73 PCB-containing ballasts and 81 fluorescent light bulbs throughout the 2nd Floor that are assumed to contain PCBs and potentially mercury. These fixtures are classified as Universal Waste Lamps under EPA regulations and require processing or disposal in accordance with the Universal Waste Rule. No other hazardous or potentially hazardous storage containers or equipment were identified during the inspection. The report notes that ongoing monitoring by the building owner may be necessary and that the survey procedures were consistent with prevalent environmental and industrial hygiene standards, with all reasonable efforts made to identify hazardous materials within the inspected areas.
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HAZARDOUS MATERIALS SURVEY REPORT
Prepared for: Prepared by:
334 W Front Street Media, Pennsylvania 19063
1012 Industrial Drive West Berlin, New Jersey 08091
ACER Project Number: 20260164
City of Chester Police Department
160 East 7th Street
Chester, Pennsylvania
March 16, 2026
1012 Industrial Drive, West Berlin, New Jersey, 08091 Tel. (856) 809-1202 Fax. (856) 809-1203
ACER ASSOCIATES, LLC
TABLE OF CONTENTS
1.0 INTRODUCTION
2.0 SURVEY
2.1 Asbestos Containing Building Materials (ACBMs)
2.2 Lead-Containing Paint (LCP)
2.3 Polychlorinated Biphenyls (PCBs)
2.4 Hazardous/Potentially Hazardous Storage Containers & Equipment
3.0 FINDINGS & RECOMMENDATIONS
3.1 Asbestos Containing Building Materials (ACBMs)
3.2 Lead-Containing Paint (LCP)
3.3 Polychlorinated Biphenyls (PCBs)
3.4 Hazardous/Potentially Hazardous Storage Containers & Equipment
3.5 Limitations
3.6 Disclaimer
4.0 SIGNATURES OF ENVIRONMENTAL PROFESSIONALS
5.0 APPENDICES
Appendix A Asbestos Bulk Sample Survey Logs & Certificates of Analysis Appendix B Lead XRF Data Sheets
ACER ASSOCIATES, LLC
1.0 INTRODUCTION
Acer Associates, LLC (ACER) was retained by MG Engineering to perform a hazardous materials survey of the2nd Floor of the City of Chester Police Department Building at 160 East 7th Street in Chester, Pennsylvania. The intent of the survey was to identify potentially hazardous materials prior to planned renovation activities to the building.
This report, and the supporting data, findings, conclusions, opinions, and the recommendations it contains, represents the result of ACER’s efforts. This report is not a hazardous materials abatement specification and should not be used for specifying removal methods or techniques.
The results, assessments, conclusions, and recommendations stated in this report are factually representative of the conditions observed at this location on the date of the survey. ACER cannot assume responsibility for any change in conditions that occurred after the survey.
END OF SECTION
ACER ASSOCIATES, LLC
2.0 SURVEY
On March 4, 2026, Mr. J. Chuck Wilkins and Ms. Cassandra Finley of ACER, both of whom are accredited Asbestos Hazard Emergency Response Act (AHERA) Building Inspectors and licensed Pennsylvania Lead Risk Assessors conducted the survey at the site.
2.1 Asbestos Containing Building Materials (ACBMs)
Visual inspection and bulk sample collection were performed utilizing protocols and guidelines outlined in the United States Environmental Protection Agency (EPA) document #560/5-85-024 – Guidance for Controlling Asbestos Containing Materials in Buildings, the USEPA Asbestos Hazard Emergency Response Act (AHERA) of 1987, and the Occupational Safety and Heath Administration (OSHA) 1910.1101 Asbestos General Industry Standard (August 10, 1994). The facility was inspected physically, functional space by functional space, and homogeneous area by homogeneous area to determine the presence or absence of asbestos-containing materials.
The survey was characterized by close visual inspection of all accessible areas.
Observations were made for friable and non-friable miscellaneous building materials.
Suspected asbestos containing building materials (ACBMs) were identified by visual inspection and bulk sampling in accordance with all applicable regulations and requirements. Materials were inventoried and examined for evidence of deterioration, damage and/or exposed friable material.
Random bulk material samples were collected of all suspected asbestos containing materials. Thirty-one (31) bulk samples were collected of potential ACBMs. The bulk samples collected were placed in zip-lock bags, labeled with an identifying code, and logged onto survey logs. Representative samples of each sampling area were then submitted to the laboratory to be analyzed for asbestos content. Sampling included collection of samples of each suspect material chosen at representative locations as specified by USEPA and OSHA standards, regulations, and/or guidelines. Due to the inconsistencies of installation contractor methods and other factors, materials of similar type may have varying quantities of asbestos.
The bulk samples were submitted to EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL analyzed the samples by polarized light microscopy (PLM) with dispersion staining, using the “Test Method – Method for the determination of Asbestos in Bulk Building Materials,” EPA/600/R-93/116, July 1993. This is a standard method of analysis in optical mineralogy, and a definitive method for the determination of asbestos in bulk samples. PLM is the method required by the EPA for the analysis of asbestos bulk samples.
ACER ASSOCIATES, LLC
EMSL is a participant in the National Voluntary Laboratory Accreditation Program (NVLAP) for the analysis of asbestos containing materials via PLM.
2.2 Lead Containing Paint (LCP)
The building at the subject property is planned for renovation. The purpose of the inspection was to identify building components with lead-containing paint to support renovation planning, waste characterization, and appropriate worker protection measures. The inspection was performed using modified industry guidelines (i.e., Housing and Urban Development [HUD] Guidelines) appropriate for pre-renovation conditions.
A SciAps X-550 X-ray fluorescence lead paint analyzer was used for the determination of lead content in paint. The calibration of the SciAps X-550 was performed in accordance with the instrument’s Performance Characteristic Sheets (PCS). Calibration checks were conducted at the beginning and end of the day’s testing. Each calibration check consisted of the average of three (3) readings taken from the nominal 1.0 mg/cm² paint film and three (3) readings taken from the 0 mg/cm² paint film.
Because the structure is scheduled for renovation, a streamlined inspection protocol was implemented. Representative painted components were selected based on substrate type, condition, color, and presumed paint history. The inspection consisted of collecting test readings from all identified substrate types, with a minimum of one (1) test point per painted component. The location of each sample collected was recorded as A, B, C, or D, as depicted in the accompanying figure, where “A” corresponds to the front of the structure.
XRF data sheets from this inspection are included in Appendix B.
ACER ASSOCIATES, LLC
2.3 Polychlorinated Biphenyls (PCBs)
ACER conducted an inspection for any polychlorinated biphenyl- (PCB) and mercury-containing equipment throughout the structure. Older transformers and other electrical equipment can contain PCBs at a level that subjects them to regulation by the United States Environmental Protection Agency (U.S. EPA). PCBs in electrical equipment are controlled by United States Environmental Protection Agency regulations 40 CFR, Part
761. Under the regulations, there are three categories into which electrical equipment can be classified:
• Less than 50 parts per million (PPM) of PCBs – “Non-PCB” transformer
• 50 ppm-500 ppm – “PCB-Contaminated” electrical equipment
• Greater than 500 ppm – “PCB” transformer
PCBs can also be present in hydraulic equipment such as elevators, auto lifts and dock levelers. Fluorescent light bulbs are known to historically contain mercury.
2.4 Hazardous/Potentially Hazardous Storage Containers & Equipment
ACER completed a visual inspection for hazardous and potentially hazardous materials including:
• Chlorofluorocarbons
• Explosive Gases
• Flammable Liquids and Solids
• Oxidizing Agents & Organic Peroxides
• Microbial Contaminants
• Corrosive Substances
• Toxic Substances
• Radioactive Substances
• Ozone Depleting Substances
ACER ASSOCIATES, LLC
3.0 FINDINGS & RECOMMENDATIONS
3.1 Asbestos Containing Building Materials (ACBMs)
The analytical results for the bulk samples collected were none detected for asbestos content.
3.2 Lead Containing Paint (LCP)
None of the painted components tested had detectable levels of lead.
3.3 Polychlorinated Biphenyls (PCBs) and Mercury
Fluorescent light fixtures were observed throughout the structure. The fixtures and associated ballasts should be assumed to contain PCBs. In addition, the fluorescent light bulbs have the potential to contain mercury. Fluorescent lighting fixtures are considered Universal Waste Lamps by the EPA Universal Waste Rule and require processing in accordance with the rule. ACER recommends all lighting fixtures and bulbs be recycled or disposed in accordance with the Universal Rule.
Table 1 presents an inventory of the fluorescent lighting fixtures identified at the time of the inspection.
Table 1 – Inventory of Fluorescent Light Fixtures
Room Ballasts PCB-Containing Bulbs
Throughout 2nd Floor 73 Assumed 81
3.4 Hazardous/Potentially Hazardous Storage Containers & Equipment
No hazardous/potentially hazardous storage containers or equipment were identified.
3.5 Disclaimer
The inspection and sample procedures used to complete this inspection are consistent with prevalent environmental and industrial hygiene standards for asbestos containing materials. All reasonable efforts were made to identify the presence of asbestos containing materials within the inspected areas. Materials not identified in this report should be considered as not sampled. ACER cannot assume responsibility for any change in conditions that occurred after the inspection. Ongoing monitoring by the owner is usually necessary. No other environmental concerns were addressed during this inspection.
ACER ASSOCIATES, LLC
4.0 SIGNATURES OF ENVIRONMENTAL PROFESSIONALS
Sincerely, Acer Associates, LLC
Prepared By: Reviewed By:
Kristen Masotes Matthew J. DePalma Project Manager Vice President
5.0 Appendices
Appendix A
Asbestos Bulk Sample Survey Logs & Certificates of Analysis
EMSL Analytical, Inc.
200 Route 130 North Cinnaminson, NJ 08077
Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com
042603862EMSL Order:
Customer ID: ACER63
Customer PO:
Project ID:
Attention: Phone:Cassandra Shank (856) 809-1202
Fax:ACER Associates, LLC (856) 809-1203
Received Date:1012 Industrial Drive 03/04/2026 2:55 PM
Analysis Date:West Berlin, NJ 08091 03/05/2026 - 03/11/2026
Collected Date: 03/04/2026
Project: Project #: 20260164 / Chester Police Department
Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E
Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy
Sample Description Appearance % Fibrous % Non-Fibrous
Non-Asbestos Asbestos
% Type
Bulk-1
042603862-0001
None DetectedQuartz
Non-fibrous (Other)
35%
65%
Gray
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Window Sill Mortar
HA: 1
Bulk-2
042603862-0002
None DetectedNon-fibrous (Other)100%Gray
Non-Fibrous
Homogeneous
Detective Division
(3rd Fl) - Window Sill
Mortar
HA: 1
Bulk-3
042603862-0003
None DetectedNon-fibrous (Other)35%Cellulose
Min. Wool
25%
40%
White
Fibrous
Homogeneous
Lobby Area (2nd Fl) -
2'x4' Ceiling Tile -
Fissured
HA: 2
Bulk-4
042603862-0004
None DetectedNon-fibrous (Other)40%Cellulose
Min. Wool
30%
30%
Brown/Gray/White
Fibrous
Homogeneous
File Storage (2nd Fl) -
2'x4' Ceiling Tile -
Fissured
HA: 2
Bulk-5
042603862-0005
None DetectedNon-fibrous (Other)100%Yellow
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Carpet Mastic
HA: 3
Bulk-6
042603862-0006
None DetectedNon-fibrous (Other)100%Yellow
Non-Fibrous
Homogeneous
Detective Division
(3rd Fl) - Carpet
Mastic
HA: 3
Bulk-7
042603862-0007
None DetectedNon-fibrous (Other)100%Tan
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Drywall Wall
HA: 4
Bulk-8
042603862-0008
None DetectedNon-fibrous (Other)95%Cellulose5%Brown
Fibrous
Homogeneous
Detective Division
(3rd) - Drywall Wall
HA: 4
Bulk-9
042603862-0009
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Bulk-10
042603862-0010
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Bulk-11
042603862-0011
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Bulk-12
042603862-0012
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Initial report from: 03/11/2026 17:56:40
Page 1 of 3ASB_PLM_0008_0002 - 2.31 Printed: 3/11/2026 5:56 PM
Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com
042603862EMSL Order:
Customer ID: ACER63
Customer PO:
Project ID:
Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E
Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy
Sample Description Appearance % Fibrous % Non-Fibrous
Non-Asbestos Asbestos
% Type
Bulk-13
042603862-0013
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
File Storage (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Bulk-14
042603862-0014
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
Lobby Area (2nd Fl) -
Joint Compound a/w
Drywall Wall
HA: 5
Bulk-15
042603862-0015
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
Office Off of Hall 204
(2nd) - Joint
Compound a/w
Drywall Wall
HA: 5
Bulk-16
042603862-0016
None DetectedCa Carbonate
Non-fibrous (Other)
60%
40%
White
Non-Fibrous
Homogeneous
Detective Division
Suite (3rd) - Joint
Compound a/w
Drywall Wall
HA: 5
Bulk-17
042603862-0017
None DetectedCa Carbonate
Mica
Non-fibrous (Other)
65%
15%
20%
White
Non-Fibrous
Homogeneous
Lounge (4th) - Joint
Compound a/w
Drywall Wall
HA: 5
Bulk-18
042603862-0018
None DetectedNon-fibrous (Other)100%Yellow
Non-Fibrous
Homogeneous
File Storage (2nd) -
Cove Base Mastic
HA: 6
Bulk-19
042603862-0019
None DetectedNon-fibrous (Other)100%Brown
Non-Fibrous
Homogeneous
Juvenile Large Office
(3rd) - Cove Base
Mastic
HA: 6
Bulk-20
042603862-0020
None DetectedQuartz
Non-fibrous (Other)
5%
85%
Cellulose10%Gray/Black
Non-Fibrous
Homogeneous
File Storage (2nd) -
Window Sill
HA: 7
Bulk-21
042603862-0021
None DetectedNon-fibrous (Other)100%Gray/Black
Non-Fibrous
Homogeneous
Juvenile Large Office
(3rd) - Window Sill
HA: 7
Bulk-22
042603862-0022
None DetectedNon-fibrous (Other)100%Gray
Non-Fibrous
Homogeneous
File Storage (2nd) -
Window Caulk
HA: 8
Bulk-23
042603862-0023
None DetectedNon-fibrous (Other)95%Fibrous (Other)5%Gray/Black
Non-Fibrous
Homogeneous
Detective Div. Suite
(3rd) - Window Caulk
HA: 8
Bulk-24
042603862-0024
None DetectedNon-fibrous (Other)100%White
Non-Fibrous
Homogeneous
Juvenile Div. Large
Office (3rd) - FRP
Mastic
HA: 9
Bulk-25-Mastic
042603862-0025
None DetectedNon-fibrous (Other)100%White
Non-Fibrous
Homogeneous
Chief's Office (4th) -
FRP Mastic
HA: 9
Bulk-25-Joint
Compound
042603862-0025A
None DetectedCa Carbonate
Mica
Non-fibrous (Other)
65%
15%
20%
White
Non-Fibrous
Homogeneous
Chief's Office (4th) -
Joint Compound
HA: 9
Page 2 of 3ASB_PLM_0008_0002 - 2.31 Printed: 3/11/2026 5:56 PM
Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com
042603862EMSL Order:
Customer ID: ACER63
Customer PO:
Project ID:
Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E
Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy
Sample Description Appearance % Fibrous % Non-Fibrous
Non-Asbestos Asbestos
% Type
Bulk-26
042603862-0026
None DetectedNon-fibrous (Other)100%White
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - CMU Mortar
HA: 10
Bulk-27
042603862-0027
None DetectedNon-fibrous (Other)100%Gray
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - CMU Mortar
HA: 10
Bulk-28-Floor Tile
042603862-0028
None DetectedMatrix
Non-fibrous (Other)
90%
7%
Cellulose3%Tan
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - 12"x12" Floor
Tile
HA: 11
Bulk-28-Mastic
042603862-0028A
None DetectedNon-fibrous (Other)95%Cellulose5%Black
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - Black Mastic
HA: 12
Bulk-29-Floor Tile
042603862-0029
None DetectedQuartz
Non-fibrous (Other)
40%
60%
Tan
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - 12"x12" Floor
Tile
HA: 11
Bulk-29-Mastic
042603862-0029A
None DetectedNon-fibrous (Other)100%Black
Non-Fibrous
Homogeneous
Bike Storage/Biohaz.
(2nd) - Black Mastic
HA: 12
Bulk-30
042603862-0030
None DetectedNon-fibrous (Other)25%Cellulose
Min. Wool
25%
50%
White
Fibrous
Homogeneous
Lobby (2nd) - 2x4 CT
- Dotted
HA: 13
Bulk-31
042603862-0031
None DetectedPerlite
Non-fibrous (Other)
15%
10%
Cellulose
Min. Wool
30%
45%
Gray/White
Fibrous
Homogeneous
File Storage (2nd Fl) -
2x4 CT - Dotted
HA: 13
Analyst(s)
Megan Peters (10)
Rachel-Mae Hunter (20)
Will DiBella (4)
Samantha Sweeney, Laboratory Manager or Other Approved Signatory
EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . The report reflects the samples as received.
Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non- friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.
Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA LAP, LLC-IHLAP Lab 100194, PA ID# 68-00367, LA #04127
Page 3 of 3ASB_PLM_0008_0002 - 2.31 Printed: 3/11/2026 5:56 PM
O r d e r I D
P a g e f r d e r I D
P a g e f
OrderID: 042603862
Appendix B
XRF Data Sheet
Chester Police Department, 2nd Floor 3/4/2026 Acer Project #20260164 COMPONENT SUBSTRATE COLOR CONDITION SIDE ROOM FLOOR Results PbC Calibration 1.1 Calibration 1.1 Calibration 1.1 Calibration 1.1 Calibration 0 Calibration 0 Calibration 0 Calibration 0 Wall Drywall Tan Intact A File Storage Second Negative 0 Wall Drywall Tan Intact C File Storage Second Negative 0 Wall Drywall Tan Intact A Lobby Second Negative 0 Wall Drywall Tan Intact A Evidence Supplies Second Negative 0 Wall Drywall Tan Intact D Evidence Supplies Second Negative 0 Wall Drywall Tan Intact A Bike Storage 2-205 Second Negative 0 Wall Cmu Tan Intact B Bike Storage 2-205 Second Negative 0 Wall Cmu Tan Intact C Bike Storage 2-205 Second Negative 0 Wall Cmu Tan Intact D Bike Storage 2-205 Second Negative 0 Door Metal Tan Intact A Bike Storage 2-205 Second Negative 0 Door Metal Tan Intact A Telephone Closet Second Negative 0 Door Metal Tan Intact A Telephone Closet Second Negative 0 Door Metal Tan Intact A Bike Storage 2-205 Second Negative 0 Door Metal Brown Intact B Evidence Related Storage Second Negative 0 Door Metal Brown Intact A Fire Arm Storage Second Negative 0 Door Metal Tan Intact A Lobby Second Negative 0 Door Metal Tan Intact A Lobby Second Negative 0 Door Metal Tan Intact C Lobby Second Negative 0 Door Metal Tan Intact C Lobby Second Negative 0
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