Attachment 0003E - Hazardous Materials Survey_Sep 25 2024.pdf

AEI Consultants 4255 Wade Green Road, Suite 510 Kennesaw, GA 30144 www.aeiconsultants.com

September 25, 2024

Mr. Alexandar Boucher Davenergy Solutions 4801 Glenwood Avenue, Suite 200 Raleigh, North Carolina 27612

Subject: Limited NESHAP Asbestos Survey and Lead-Based Paint Screening Report Joseph Maxwell Cleland Atlanta VA Medical Center Replace Air Handler Units (AHU) No. 2, 3, 5, 17,19, 24 & 28 Mechanical Room No. BA101, 1A147, 4A105 & 6A104 1670 Clairmont Road Decatur, Georgia 30033 Project No. 498637

Dear Mr. Boucher, This report is to summarize the findings of the limited NESHAP asbestos survey and lead-based paint screening of Joseph Maxwell Cleland Atlanta VA Medical Center, located at 1670 Clairmont Road, Decatur, Georgia (Site). AEI Consultants (AEI) was contracted by Davenergy Solutions (Client) to conduct the survey of the above referenced Site. The objective of the survey was to identify, as far as practicable, visible, and accessible suspect asbestos-containing materials (ACM) used in association with the planned replacement of existing AHU # 2, 3, 5, 17, 19, 24 & 28 in Mechanical Rooms BA101, 1A147, 4A105 & 6A104. Identification of asbestos materials is required so that appropriate actions may be taken, if necessary, to protect site workers and to properly handle asbestos materials in accordance with all applicable regulations.

On September 11, 2024, on behalf of AEI, Mr. Gabriel Hansen, a certified U.S. Environmental Protection Agency (EPA) asbestos building inspector of BCP Environmental, LLC, conducted the survey for the purpose of identifying visible, accessible suspect asbestos-containing building materials. Investigation of roof and below-grade structures or foundation walls where suspect asbestos-containing materials (i.e. waterproofing) may exist was not included in this scope of work.

The asbestos inspection was conducted for compliance with the current US EPA and Georgia Environmental Protection Division (GAEPD) asbestos regulations regarding the identification of suspect asbestos materials prior to renovations.

Asbestos Information

The Code of Federal Regulations (CFR), 40 CFR 61, Subpart M, National Emissions Standards for Hazardous Air Pollutants (NESHAP), classifies ACM as any material or product that contains greater than 1% asbestos. As suspect ACM is identified, it is classified as either friable or non-friable.

Friable materials are considered to be more hazardous than non-friable materials since they are more likely to release fibers into the air. Friable is defined as any ACM that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACM is classified as either Category 1 or Category 2 material as follows:

• Category 1 – Asbestos-containing packings, gaskets, resilient floor coverings and asphalt roofing products; and

• Category 2 – All remaining types of non-friable asbestos-containing material not included in Category 1 that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated asbestos-containing materials (RACM), a regulated waste when friable, is classified as any manufactured material that contains greater than 1% asbestos and is:

1. Friable – The material can be crumbled, pulverized, or reduced to powder by hand pressure.

2. Category 1 that are subjected to sanding, grinding, cutting, or abrading.

3. Category 1 material that has become friable during renovation activities, or

4. Category 2 material that has become friable during renovation activities.

Materials containing greater than 1% asbestos are subject to the NESHAP regulations (40 CFR Part 61, Subpart M). RACM (friable ACM and non-friable ACM that will become friable during renovation/demolition operations) must be removed from structures prior to renovations or demolitions. Certain non-friable ACM and materials containing 1% or less asbestos may remain in structures during renovations/demolitions.

Asbestos Summary of Findings A total of thirty-three (33) samples of suspect materials were collected from the subject property tenant space during the inspection, which layered out seventy (70) samples after analysis.

None of the sampled material was identified to contain asbestos.

Lead Paint Screening Summary A total of eight (8) paint chips were taken from the painted surfaces where suspect lead paint may be disturbed in the scope of work. The United States Department of Housing and Urban Development (HUD) standard for ‘lead-based paint’ (LBP) is 1.0 mg/cm2).

Based on the results of the screening, the samples collected are not considered lead-based paint.

The following painted building components are considered lead-containing paint (LBP):

Sample ID# Component Type

Color Sample Location Concentration % by Weight

1A147-L2

6A104-L5

Metal AHU

Metal AHU

White

White

Mech. Room 1A147

Mech. Room 6A104

0.016%

0.013%

Note: All remaining paint chip samples lab results were below detectable limits. See attached lab results in the appendix for details.

RECOMMENDATIONS

Based on the results of the survey, AEI makes the following recommendations;

Asbestos Containing Materials Survey

1. If suspect materials that are not referenced in this report are identified during demolition activities, AEI recommends that the materials be sampled and analyzed to confirm or deny the presence of asbestos prior to disturbance of the materials.

2. AEI recommends that all identified ACMs be removed by a GA state licensed asbestos abatement contractor prior to renovation/demolition activities. Asbestos abatement should be monitored and inspected by a licensed asbestos consultant to confirm the appropriate removal activities and to clear containment areas in accordance with applicable regulations.

Lead-Based Paint

Where lead is present at any level on concentration (LCP), the Federal regulation (Occupational Safety and Health Administration 29 CFR 1910.62) requires employers to perform assessment exposure monitoring during any demolition that might create lead dust.

If no employee is exposed to the action level during this initial assessment, further monitoring can be suspended. Worker exposure to lead, a common concern during renovation, is not typically a concern during wholesale demolition provided that components are not individually treated.

When lead-based painted components are removed and disposed or when lead-based painted structures are demolished (non-residential buildings), the wastes generated from such activities are regulated as solid wastes under the Resource Conservation and Recovery Act

(RCRA).

In order to determine whether solid wastes are hazardous under the RCRA, the Toxicity Characteristic Leaching Procedure (TCLP) (analytical lab procedure) is used. Under RCRA, solid wastes containing 5 mg/L or greater lead as determined by TCLP analysis are regulated hazardous wastes and must be treated and disposed of accordingly. Non-residential wastes that do not exceed the regulatory threshold of 5 mg/L lead as determined by TCLP, this waste may be disposed of in a permitted Municipal Solid Waste (MSW) landfill or a permitted Construction & Demolition (C&D) landfill.

Using the “Rule of 20” as it pertains to TCLP analysis, it is not possible for any of the painted components tested by BCP Environmental to fail the TCLP test. For a painted component to possibly fail the TCLP test it must have a total concentration of 0.25% by weight or greater.

This means that the expected waste stream is non-hazardous and may be treated as C&D waste.

The Occupational Safety & Health Administration (OSHA) standards require protection for all workers when working with paint containing lead, regardless of the concentration. Paints that are below the threshold for lead-based paint may have lower concentrations of lead and would be considered “lead-containing paint” (LCP) by OSHA if detectable lead is identified. A contractor performing paint removal work should follow the OSHA lead standard for the construction industry.

This assessment was performed at the request of Davenergy Solutions its successors and assigns ("Client") utilizing methods and procedures consistent with good commercial or customary practices designed to conform with acceptable industry standards. This report may be distributed to and relied upon by Client and its current and future wholly and partially owned subsidiaries, affiliates, successors and assigns. The independent conclusions represent AEI Consultants’ best professional judgment based on the conditions that existed and the information and data available to us during the course of this assignment. Factual information regarding operations, conditions, and test data provided to Client, Reliant Party, or their representative has been assumed to be correct and complete.

This report has been prepared on behalf of and for the exclusive use of the Client and is subject to and issued in connection with the Agreement and the provisions thereof.

The recommendations and conclusions presented as a result of this study apply strictly to the environmental regulations and property conditions existing at the time the study was performed. The sample analytical results are only valid for the time and place of collection and AEI does not warrant that these results will be repeatable or are representative of past or future conditions.

Prepared By:

Charles Yoon Senior Project Manager AEI Consultants 4255 Wade Green Road, Suite 510

Reviewed By:

Fadi Malakieh

4514 Cole Avenue, Suite 600 Dallas, Texas 75205 Phone: 469-486-0100 Email: fmalakieh@aeiconsultants.com

Attachments

Attachment A: BCP Environmental, LLC Limited NESHAP Asbestos Survey & Lead Paint Screening Report

Attachment A

BCP Environmental, LLC Limited NESHAP Asbestos Survey & Lead Paint

Screening Report

Phone (770) 841-7090 (Cell) Email: bcpenviro@gmail.com

Limited NESHAP Asbestos Survey & Lead Paint Screening Report

September 23, 2024

Joseph Maxwell Cleland Atlanta VA Medical Center Replace Air Handler Units (AHU) No. 2, 3, 5, 17,19, 24 & 28 Mechanical Room Numbers BA101, 1A147, 4A105 & 6A104

1670 Clairmont Road Decatur, GA 30033-4004

AEI Project # 498637

Prepared For:

Mr. Charles Yoon

AEI Consultants

4255 Wade Green Road Suite 510

P. O. Box 871, Braselton, Georgia 30517

BCP Environmental, LLC P.O. Box 871

Braselton, Georgia 30517

Phone: 770.841.7090 Email: bcpenviro@gmail.com

September 23, 2024

Mr. Charles Yoon Senior Project Manager AEI Consultants 4255 Wade Green Road Suite 510 Kennesaw, GA 30144

Subject: Limited NESHAP Asbestos Survey & Lead Paint Screening Report Joseph Maxwell Cleland Atlanta VA Medical Center Replace Air Handler Units (AHU) No. 2, 3, 5, 17,19, 24 & 28 Mechanical Room No. BA101, 1A147, 4A105 & 6A104 1670 Clairmont Road Decatur, GA 30033-4004

Introduction:

This report presents the results of the limited National Emission Standards for Hazardous Air Pollutants (NESHAP) asbestos survey & lead paint screening at the above referenced site.

This inspection was performed by Mr. Gabriel Hansen, a current trained Asbestos Hazard Emergency Response Act (AHERA) accredited asbestos building inspector.

BCP Environmental, LLC conducted the site investigation on September 11, 2024.

Purpose:

The purpose of this limited NESHAP asbestos survey (limited to scope of work) was to identify, and locate asbestos-containing materials (ACM) and conduct lead paint screening in regard to planned replacement of existing AHU # 2, 3, 5, 17, 19, 24 & 28.

The observed suspect asbestos-containing materials (ACM) were

• Spray-Applied Fireproofing

• Gypsum Wallboard & Associated Joint Compound (WBJC)

• Fiberglass Insulated Duct Wrap

• AHU Seam Caulk (Outside AHU)

• AHU Insulation Pin Mastic (Inside AHU)

• Fiberglass Panel Glue (Inside AHU)

• Fiberglass Pipe Wrap & Mastic on Various Piping (Glycol, Steam, Condensate &

Chilled Water)

The observed suspect lead painted building components were:

• Gray Paint on Concrete Slabs

• White Paint on Metal AHUs

• White Paint on Concrete Walls

This inspection was conducted in general accordance with Environmental Protection Agency (EPA) AHERA guidelines and will satisfy the Georgia Environmental Protection Division (GAEPD) requirements for pre-renovation and pre-demolition inspections.

EPA Regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during demolition and renovation activities. The asbestos NESHAP requires that potentially regulated ACM be identified, classified and quantified prior to demolition activities.

Bulk Samples Survey Protocol:

1. During the inspection, the various building construction materials were categorized into “homogeneous areas” based upon material types, approximate dates of construction, building system/function and appearance.

2. Conducted an interview with Mr. Kai Ha (Site Contact) to elicit information regarding the survey.

3. No construction plans were available for review. The scope of work (SOW) was to conduct limited asbestos survey as part of the medical center’s AHU Replacement Design to identify visible, accessible suspect asbestos-containing materials (ACM) in the mechanical rooms housing the AHUs & ERCs. The investigation of any interior area outside the mechanical rooms, including the exterior, roof, and below-grade structures or foundation walls where suspected ACM (i.e., waterproofing) may exist, is not included in this scope of work (SOW).

4. A brief walk through of the target areas to be surveyed allowed conclusions to be made concerning the number of samples needed and the location of the bulk to be collected.

5. A visual inspection was conducted to identify the locations of suspect asbestos containing materials and physically touched the material to determine if it was to be classified as friable (easily crumbled with hand pressure and reduced to powder form) or non-friable. Suspect materials were catalogued according to their intended use. These categories include surfacing materials, thermal system insulation (TSI) and/or miscellaneous.

6. Bulk sampling was conducted in accordance with the procedures outlined in AHERA (40 CFR 763.86 Sampling). These procedures required a random sampling method, which was used to select sampling locations from each homogeneous sampling area. A homogeneous area is defined as an area of surfacing, TSI or miscellaneous material that is uniform in color and texture.

7. The bulk samples were wetted to minimize the release of fibers into the air, sealed within a sample baggie and labeled with an identification number.

Analytical Laboratory Information:

All bulk samples were analyzed by Polarized Light Microscopy (PLM). The Chain of Custody form and asbestos bulk analysis results are attached. The bulk samples were analyzed by an independent third party accredited laboratory. Eurofins is accredited by the National Institute of Standards and Technology (NIST) National Voluntary Accreditation Program (NVLAP) for laboratories analyzing bulk materials by PLM. SAI conducted the paint chips by Flame AA.

Limited NESHAP Asbestos Survey Results:

Any building materials that contain 1% or more asbestos are considered asbestos-containing material (ACM). A total of thirty-three (33) bulk sample were collected from eleven (11) homogeneous areas (HA) groups suspect for ACM in regard to the scope of work identified per attached construction drawings.

The following building materials are considered ACM:

Sample

ID#

Material

Type Location Type of ACM

Concentration

NESHAP/GAEPD

Category

Estimated Quantity

NONE NONE NONE NONE

NONE NONE

Note: No asbestos detected in all bulk samples.

Lead Paint Screening Results:

BCP Environmental, LLC collected eight (8) paint chip samples from areas where suspect lead paint may be disturbed in the scope of work.

BCP performed a limited lead-based paint (LBP) screening by collecting paint chip samples for analysis by flame atomic absorption Spectrophotometer (Flame AAS). Paint chip sampling was performed as a “screening” tool to determine if lead exists in painted surfaces at the site so that appropriate precautions and personnel protection may be taken during demolition activities. Further waste stream testing may be recommended upon the LBP screening completion before waste disposal during renovation activities.

The EPA defines lead-based paint (LBP) as “paint or other surface coatings that contain lead equal to or exceeding 1.0 milligram per square centimeter or 0.5 percent by weight or 5000 parts per million (ppm) by weight.”

The following painted building components are considered LBP:

Sample ID

Components Type Color Location Concentration % by Weight

NONE NONE NONE NONE NONE

The following painted building components are considered lead-containing paint

(LCP):

Sample ID # Component Type

Color Sample Location Concentration % by Weight

1A147-L2 6A104-L5

Metal AHU Metal AHU

White White

Mech. Room 1A147 Mech. Room 6A104

0.016% 0.013%

Note: All remaining paint chip samples lab results were below detectable limits.

See attached lab results in the appendix for details.

Regulatory Overview & Recommendations (LBP):

Where lead is present at any level on concentration (LCP), the Federal regulation (Occupational Safety and Health Administration 29 CFR 1910.62) requires employers to perform assessment exposure monitoring during any demolition that might create lead dust. If no employee is exposed to the action level during this initial assessment, further monitoring can be suspended. Worker exposure to lead, a common concern during renovation, is not typically a concern during wholesale demolition provided that components are not individually treated.

When lead-based painted components are removed and disposed or when lead-based painted structures are demolished (non-residential buildings), the wastes generated from such activities are regulated as solid wastes under the Resource Conservation and Recovery Act (RCRA).

In order to determine whether solid wastes are hazardous under the RCRA, the Toxicity Characteristic Leaching Procedure (TCLP) (analytical lab procedure) is used. Under RCRA, solid wastes containing 5 mg/L or greater lead as determined by TCLP analysis are regulated hazardous wastes and must be treated and disposed of accordingly.

Non-residential wastes that do not exceed the regulatory threshold of 5 mg/L lead as determined by TCLP, this waste may be disposed of in a permitted Municipal Solid Waste (MSW) landfill or a permitted Construction & Demolition (C&D) landfill.

Using the “Rule of 20” as it pertains to TCLP analysis, it is not possible for any of the painted components tested by BCP Environmental to fail the TCLP test. For a painted component to possibly fail the TCLP test it must have a total concentration of 0.25% by weight or greater. This means that the expected waste stream is non-hazardous and may be treated as C&D waste.

Limitations & Conclusions:

This survey was conducted with the best information available at the time. The UGA Facilities Management Division (FMD) Asbestos “Blue Book” was also reviewed for past abatements and surveys. Hidden ACM may still be present behind structures. All such unidentified materials should be treated as assumed ACM. The assumed ACM should be sampled to confirm the presence of asbestos prior to the demolition activities.

Subcontractors and employees working within the target areas at the site should be aware of the locations of the ACM and the possibility of concealed suspect ACMs that could be found during renovation/demolition activities. We cannot, guarantee that all potential ACM & LBP and other hazardous materials, including quantities, has been located. We do warrant, however, that the investigations and methodology reflect our best efforts based upon the prevailing standard of care in the environmental industry.

This report is not intended to serve as a bidding document and should be field verified.

This survey pertains only to scope of work identified in this report, not the entire building.

Acknowledgement:

BCP Environmental, LLC appreciates the opportunity to work with you on this project and if you have any questions, please contact me @ (770) 841-7090.

Sincerely, Brad Pickerel Brad Pickerel Project Industrial Hygienist

Photographs Log

1. Atlanta VA Medical Center

2. AHU #2 in Mech. Room 1A147

3. AHU #3 in Mech. Room BA101

4. AHU #5 in Mech. Room 1A147

Project Number: 498637

5. AHU #19 (No photo available of AHU #17) in Mech. Room 4A105

6. AHU #24 in Mech. Room 6A104

7. AHU #28 in Mech. Room 6A104

8. No ACM detected in typical spray-applied fireproofing in target mech. rooms (HA1)

9. No ACM detected in typical gypsum WBJC (HA2) in target mech. rooms

10. No ACM detected in typical duct wrap in target mech. rooms

(HA3)

11. No ACM detected in AHU black seam mastic

12. No ACM detected in white AHU seam caulk (HA4)

13. No ACM detected in typical AHU fiberglass panel mastic

(HA6)

14. No ACM detected in typical AHU fiberglass duct pin mastic

(HA5)

15. No ACM detected in typical interior AHU seam mastic (HA7)

16. No ACM detected in typical chilled water (HA11) and steam pipe insulation (HA9) to target

AHU

17. No ACM detected in CW pipe insulation (HA11) to target AHU

18. No ACM detected in typical glycol (HA8) & condensate pipe insulation (HA10) to target AHU

19. No ACM detected on various AHU duct mastic

20. No ACM detected in various duct seam mastic on AHUs

No Photo No Photo

21. White LCP on typical AHU in Mech. Room 1A147

22. White LCP on typical AHU in Mech. Room 6A104

23. 24.

Laboratory Results

Approved by:

Approved Signatory Danny Li

Report for:

Charles Yoon AEI Consultants 2207 W 190th St Torrance, CA 90504

Regarding:

Eurofins EPK Built Environment Testing, LLC Project: 498637; Davenergy Solutions/Decatur, Ga

EML ID: 3780245

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received and tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins EPK Built Environment Testing, LLC ("the Company"), a member of the Eurofins Built Environment Testing group of companies, shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 09-18-2024

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 200757-0

EMLab ID: 3780245, Page 1 of 14Eurofins EPK Built Environment Testing, LLC

Eurofins EPK Built Environment Testing, LLC 2841 Dow Avenue, Suite 300, Tustin, CA 92780

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

Summary of Samples with Asbestos Detected

Total Samples Submitted: 33 Total Samples Analyzed: 33 Total Layers Analyzed: 70

Total Samples with Layer Asbestos Content > 1%: 0

Total Samples with Layer Asbestos Content < 1%: 0

EMLab ID: 3780245, Page 2 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-5, Fireproofing Lab ID-Version‡: 18655052-1

Sample Layers Asbestos Content Gray Fireproofing ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: BA101-6, Fireproofing Lab ID-Version‡: 18655053-1

Sample Layers Asbestos Content Gray Fireproofing ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 6A104-13, Fireproofing Lab ID-Version‡: 18655054-1

Sample Layers Asbestos Content Gray Fireproofing ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 1A147-15, Wall Board Joint Compound Lab ID-Version‡: 18655055-1

Sample Layers Asbestos Content White Joint Compound ND

Cream Tape ND White Joint Compound ND

White Drywall with Brown Paper ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 3 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 6A104-18, Wall Board Joint Compound Lab ID-Version‡: 18655056-1

Sample Layers Asbestos Content White Joint Compound ND

Cream Tape ND White Joint Compound ND

White Drywall with Brown Paper ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 4 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-28, Wall Board Joint Compound Lab ID-Version‡: 18655057-1

Sample Layers Asbestos Content White Joint Compound ND

White Drywall with Brown Paper ND Composite Non-Asbestos Content: 5% Cellulose Sample Composite Homogeneity: Poor

Location: 6A104-12, Fiberglass Duct Wrap Lab ID-Version‡: 18655058-1

Sample Layers Asbestos Content White Wrap with Silver Foil ND

Yellow Insulation ND Composite Non-Asbestos Content: 15% Cellulose

15% Glass Fibers Sample Composite Homogeneity: Moderate

Location: 4A105-29, Fiberglass Duct Wrap Lab ID-Version‡: 18655059-1

Sample Layers Asbestos Content White Wrap with Silver Foil ND

Yellow Insulation ND Composite Non-Asbestos Content: 15% Cellulose

15% Glass Fibers Sample Composite Homogeneity: Moderate

Location: 1A147-30, Fiberglass Duct Wrap Lab ID-Version‡: 18655060-1

Sample Layers Asbestos Content White Wrap with Silver Foil ND

Yellow Insulation ND Composite Non-Asbestos Content: 15% Cellulose

15% Glass Fibers Sample Composite Homogeneity: Moderate

EMLab ID: 3780245, Page 5 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: BA101-8, AHU Seam Caulk Lab ID-Version‡: 18655061-1

Sample Layers Asbestos Content Tan Caulk ND

Sample Composite Homogeneity: Good

Location: 6A104-17, AHU Seam Caulk Lab ID-Version‡: 18655062-1

Sample Layers Asbestos Content Tan Caulk ND

Sample Composite Homogeneity: Good

Location: 4A105-23, AHU Seam Caulk Lab ID-Version‡: 18655063-1

Sample Layers Asbestos Content Black Caulk ND

Sample Composite Homogeneity: Good

Location: 6A104-11, Pin Mastic (Fiberglass Panel) Lab ID-Version‡: 18655064-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

EMLab ID: 3780245, Page 6 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-31, Pin Mastic (Fiberglass Panel) Lab ID-Version‡: 18655065-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

Location: 1A147-34, Pin Mastic (Fiberglass Panel) Lab ID-Version‡: 18655066-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

Location: BA101-7, Fiberglass Panel Glue Lab ID-Version‡: 18655067-1

Sample Layers Asbestos Content Gray Glue ND

Yellow Insulation ND Composite Non-Asbestos Content: 80% Glass Fibers Sample Composite Homogeneity: Good

Location: 4A105-16, Fiberglass Panel Glue Lab ID-Version‡: 18655068-1

Sample Layers Asbestos Content Gray Glue ND

Yellow Insulation ND Composite Non-Asbestos Content: 80% Glass Fibers Sample Composite Homogeneity: Good

EMLab ID: 3780245, Page 7 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 6A104-19, Fiberglass Panel Glue Lab ID-Version‡: 18655069-1

Sample Layers Asbestos Content Gray Glue ND

Yellow Insulation ND Composite Non-Asbestos Content: 80% Glass Fibers Sample Composite Homogeneity: Good

Location: BA101-1, AHU Seam Mastic Lab ID-Version‡: 18655070-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

Location: 6A104-14, AHU Seam Mastic Lab ID-Version‡: 18655071-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

Location: 1A147-20, AHU Seam Mastic Lab ID-Version‡: 18655072-1

Sample Layers Asbestos Content Gray Mastic ND

Sample Composite Homogeneity: Good

EMLab ID: 3780245, Page 8 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-21, Pipe Wrap with Mastic Lab ID-Version‡: 18655073-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: 4A-105-22, Pipe Wrap with Mastic Lab ID-Version‡: 18655074-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: 4A105-32, Pipe Wrap with Mastic Lab ID-Version‡: 18655075-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 9 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: BA101-2, Pipe Wrap with Mastic Lab ID-Version‡: 18655076-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 10 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: BA101-3, Pipe Wrap with Mastic Lab ID-Version‡: 18655077-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: 4A105-33, Pipe Wrap with Mastic Lab ID-Version‡: 18655078-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: BA101-10, Pipe Wrap with Mastic Lab ID-Version‡: 18655079-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 11 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-25, Pipe Wrap with Mastic Lab ID-Version‡: 18655080-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 12 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-27, Pipe Wrap with Mastic Lab ID-Version‡: 18655081-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: BA101-4, Pipe Wrap with Mastic Lab ID-Version‡: 18655082-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

Location: 1A147-24, Pipe Wrap with Mastic Lab ID-Version‡: 18655083-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 13 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(833) 465-5857 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 498637; Davenergy Solutions/Decatur, Ga

Date of Sampling: 09-11-2024 Date of Receipt: 09-13-2024 Date of Report: 09-18-2024

ASBESTOS PLM REPORT

Location: 4A105-26, Pipe Wrap with Mastic Lab ID-Version‡: 18655084-1

Sample Layers Asbestos Content White Wrap ND

Yellow Insulation ND White Mastic ND

Composite Non-Asbestos Content: 10% Cellulose 10% Glass Fibers 5% Mineral Fibers

Sample Composite Homogeneity: Poor

EMLab ID: 3780245, Page 14 of 14Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in…