EN257341 Ralph H Johnson VA Medical Center Canteen Hazmat Phase 2.pdf

1800 Reynolds Avenue

North Charleston, SC 29405

D (843) 884-1234

Terracon.com

November 25, 2025

Atriax, PLLC

703 Main Ave SW Hickory, NC 28602

Attn: Todd Beck

E: todd.beck@atriaxgroup.com

Re: Limited Hazardous Materials Survey Report Update

Ralph H. Johnson VA Medical Center

109 Bee St, Charleston, SC 29401

Project No. EN257341

Dear Mr. Beck:

Terracon Consultants, Inc. (Terracon) is pleased to present the results of the hazardous materials survey update of the canteen kitchen area located in the Ralph H. Johnson VA Medical Center located at 109 Bee

Street, Charleston, South Carolina. This survey was limited to the exhaust hood and duct, and the path of the new one. Terracon’s inspection was conducted on November 13, 2025, by Mr. Zach Harrell, a South

Carolina Department of Environmental Services (SCDES) licensed building inspector (BI-002447) in general accordance with our proposal, dated October 06, 2025.

Previous Survey

Terracon previously conducted a hazardous materials survey, EN157096, on July 10, 2015. The previous survey identified the following materials as ACM:

▪ Gray/white HVAC mastic associated with the HVAC system

▪ 12” x 12” White speckled vinyl floor tile and associated mastic(s)

▪ TSI Elbows

▪ Tan HVAC mastic associated with the HVAC system

Update Survey

Terracon understands that Atriax, PLLC plans to replace the exhaust vent hood and associated duct in the canteen service area. During November 13, 2025, walkthrough, minor interior finishes were observed from documentation, including equipment updates. No painted surfaces or other hazardous materials were observed associated with the exhaust hood and duct, and the path of the new one. A black mastic associated with the HVAC insulation observed above the ceiling tiles in the canteen serving area was sampled for analysis.

Additionally, previously reported asbestos containing TSI elbows and Gray/white as well as tan HVAC mastic associated with the HVAC system were observed. All previously sampled materials were observed present or have since been removed.

Interior finishes consist of plaster wall systems over gypsum wallboards with a painted finish. The ceilings consisted of a suspended ceiling containing 2’x2’ lay-in ceiling panels. HVAC duct work was present above the ceiling tiles. The floors consisted of concrete painted, or covered with vinyl sheet flooring and mastic, and ceramic tiles and grout. The other portions of the hospital were not part of the area of work and were not observed. Additionally, Terracon was not authorized to sample the roof by Ralph H. Johnson VA Medical

Limited Hazardous Materials Survey Update Report

RHJ VA Medical Center- Canteen ■ Charleston, South Carolina

November 25, 2025 ■ Terracon Project No. EN257341

Facilities | Environmental | Geotechnical | Materials 2

Center. Terracon recommends the roof, and associated materials, be considered asbestos containing unless confirmed through bulk sampling by an SCDES licensed asbestos inspector.

Bulk samples were submitted under chain of custody to EMSL Laboratories (EMSL) of Pineville, North

Carolina for analysis by Polarized Light Microscopy (PLM) with dispersion staining techniques per EPA

EPA/600/R-93/116. The percentage of asbestos, where applicable, was determined by microscopical visual estimation. EMSL is accredited under the National Voluntary Laboratory Accreditation Program.

Layered analysis of samples was conducted by the lab to separate the tile and ceramic tile, grout, and mortar.

Per the SCDES Regulation 61-86.1 Standards of Performance for Asbestos Projects, negative results for non-friable organically bound (NOB) materials such as flooring, mastics, and roofing shall be verified with at least one TEM analysis. The additional analysis was performed by TEM in accordance with EPA/600/R-

93/116 Section 2.5.5.1.

Based on the results of laboratory analysis, the black HVAC insulation seam mastic was reported to not contain asbestos in detectable concentrations:

Table 1 summarizes the results of the visual inspection, estimated quantities, and laboratory analyses.

Asbestos laboratory analytical reports are included in Appendix B. Additionally, materials previously identified as asbestos containing materials were observed were observed to be present within the scope of work area, identified in Appendix D.

Recommendations

Terracon recommends that any identified asbestos-containing materials to be disturbed by planned renovation activities, be removed by a South Carolina licensed asbestos abatement contractor prior to commencement of said renovations.

A copy of this report must be submitted to SCDES at least ten (10) working days prior to demolition when applying for an abatement permits.

Additionally, Terracon recommends following the recommendations outlined in 2015 survey report attached in Appendix D.

Limited Hazardous Materials Survey Update Report

RHJ VA Medical Center- Canteen ■ Charleston, South Carolina

November 25, 2025 ■ Terracon Project No. EN257341

Facilities | Environmental | Geotechnical | Materials 3

Terracon appreciates the opportunity to provide environmental consulting services for the Atriax PLLC. If you should have any questions regarding this survey, please contact the undersigned at (732)-598-2552.

Sincerely, Terracon Consultants, Inc.

Zach Harrell Norman E. (Gene) Partin, Jr., CHMM Senior Staff Industrial Hygienist Operations Manager

Attachments:

TABLES

Table 1 – Asbestos Sample Summary

FIGURES

Sample Location Diagram

APPENDIX A – PHOTO DOCUMENTATION

APPENDIX B - LABORATORY REPORT

APPENDIX C – INSPECTOR CREDENTIALS

APPENDIX D – PREVIOUS REPORT

HA Sample #

Approx.

Quantity*

Samples

Collected Description Material Location Lab Result Category Condition

1 01/03 250 SF 3 Black HVAC Duct Seam Mastic Canteen Service Area NAD Misc. F, Good

Notes

* Quantities should not be used for bidding purposes.

Materials hidden and not observed due to access restrictions and/or enclosed spaces can change actual quantities. Contractors are strongly encouraged to collect their own measurements prior to submitting bids to verify quantities provided above.

Negative PLM results were confirmed with TEM analyses.

Refer to Exhibit 1 for approximate sample locations

HA Homogeneous Area

NAD No Asbestos Detected

Surf. Surfacing Material

Misc. Miscellaneous Material

F Friable NF Non-Friable

LF Linear Feet SF Square Feet

Cat. I asbestos-containing packings, gaskets, asphaltic roofing products, resilient flooring, pliable sealants and pliable mastics

Cat. II non-friable materials other than Category I

RACM Regulated Asbestos-Containing Material

Homogeneous Materials 1 are NOB materials.

TABLE 1 - Asbestos Sample Summary

109 Bee Street

Charleston, South Carolina

Project No. EN257341

Due to planned renovation and demolition all materials have a high potential for disturbance

FIGURES

Project No.

Scale:

File Path:

Date:

PM:

Drawn By:

Checked By:

Approved By: 1800 Reynolds Avenue

Phone: (843) 277 8461

North Charleston, SC 29405

Fax: (843) 884 9234

Sample Location Diagram Figure

Ralph H. Johnson VA Medical Center 109 Bee Street, Charleston, South Carolina

11/13/2025GP

GP

ZDH

ZDH

N.T.S

EN257341Asbestos Sample (Positive) Asbestos Sample (Negative)

01/03

APPENDIX A- PHOTO DOCUMENTATION

Ralph H. Johnson VA Medical Center- Canteen Terracon Project No. EN257341 Date Photos Taken: 11/13/25

#1 View of Non-ACM Black HVAC Insulation Seam Mastic

APPENDIX B- LABORATORY REPORTS

EMSL Analytical, Inc.

10801 Southern Loop Blvd Pineville, NC 28134

Tel/Fax: (704) 525-2205 / (704) 525-2382 http://www.EMSL.com / charlottelab@emsl.com

412512329EMSL Order:

Customer ID: WPCE62

Customer PO: EN257314

Project ID:

Attention: Phone:Zach Harrell (732) 598-2552

Fax:Terracon Consultants, Inc. (843) 884-9234

Received Date:1800 Reynolds Avenue 11/17/2025 10:30 AM

Analysis Date:North Charleston, SC 29405 11/18/2025 - 11/19/2025

Collected Date:

Project: EN 257314 Ralph H. Johnson VA Medical Center HazMat Canteen Kitchen Phase 2 Inspection

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

412512329-0001

None DetectedNon-fibrous (Other)68%Cellulose

Glass

30%

2%

Black/Silver/Beige

Fibrous

Heterogeneous

Canteen Service Area -

Black HVAC Duct

Insulation Seam

Mastic

Result includes a small amount of inseparable attached wrap.

412512329-0002

None DetectedNon-fibrous (Other)60%Cellulose

Glass

30%

10%

Brown/Black/Silver

Non-Fibrous

Heterogeneous

Canteen Service Area -

Black HVAC Duct

Insulation Seam

Mastic

Result includes a small amount of inseparable attached wrap.

Analyst(s)

David Zalewski (1)

Mikayla Harlowe (1)

Lee Plumley, 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. Pineville, NC NVLAP Lab Code 200841-0, VA 3333 00312

Initial report from: 11/19/2025 11:56:25

Page 1 of 1ASB_PLM_0008_0002 - 2.31 Printed: 11/19/2025 11:56 AM

10801 Southern Loop Blvd Pineville, NC 28134

Tel/Fax: (704) 525-2205 / (704) 525-2382 http://www.EMSL.com / charlottelab@emsl.com

EMSL Order: 412512329

Customer ID: WPCE62

Customer PO: EN257314

Project ID:

Attention: Zach Harrell Phone: (732) 598-2552

Terracon Consultants, Inc. Fax: (843) 884-9234

1800 Reynolds Avenue Received Date: 11/17/2025 10:30 AM

North Charleston, SC 29405 Analysis Date: 11/18/2025

Collected Date:

EN 257314 Ralph H. Johnson VA Medical Center HazMat Canteen Kitchen Phase 2 InspectionProject:

Test Report: Asbestos Analysis of Non-Friable Organically Bound Materials by TEM via

EPA/600/R-93/116 Section 2.5.5.1

Sample ID Description Appearance % Matrix Material % Non-Asbestos Fibers Asbestos Types

412512329-0003

Canteen Service Area -

Black HVAC Duct

Insulation Seam Mastic

Tan/Black

Non-Fibrous

Heterogeneous

100.0 None No Asbestos DetectedOther

Analyst(s)

Sarah Breneman (1) Lee Plumley, 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. EMSL recommends that samples reported as none detected or <1% undergo additional analysis via PLM to avoid the possibility of false negatives.

Samples analyzed by EMSL Analytical, Inc. Pineville, NC

Initial report from: 11/19/2025 11:56:24

ASB_PLMEPANOB_0012_0002 Printed 11/19/2025 11:57:52AM Page 1 of 1

OrderID: 412512329

APPENDIX C- INSPECTORS CREDENTIALS

APPENDIX D- PREVIOUS REPORT

Hazardous Materials Survey Report Ralph H. Johnson VAMC Canteen Kitchen Renovation

109 Bee Street

Charleston, South Carolina July 10, 2015

Terracon Project No. EN157096

Prepared for:

Atriax Group

Hickory, North Carolina

Prepared by:

North Charleston, South Carolina

Inspected by:

Charlie Carter (SC BI-01361)

T errac on C ons ul tants , Inc . 1450 F i fth Street, Wes t N or th C har les ton , South C arol ina 29 405

P [ 843] 884 1234 F [ 843] 884 9234 ter rac on. c om

July 10, 2015

Atriax Group

102 3rd Avenue, NE

Hickory, North Carolina 28603

Attn: C William Bevins, FAIA

P: (704) 650-5621

Re: Hazardous Materials Survey Report

Ralph H. Johnson VAMC Canteen Kitchen Renovation

109 Bee Street

Charleston, South Carolina

Survey Conducted: June 16, 2015

Dear Mr. Bevins:

Terracon Consultants, Inc. (Terracon) is pleased to present the results of the asbestos and lead paint survey performed on the above referenced site. We understand that this survey was requested due to the planned renovation of the Canteen Kitchen area.

Terracon appreciates the opportunity to provide environmental consulting services for the

Atriax Group. If you should have any questions regarding this report, or if you need assistance with bid documents or project oversight during the area renovation, please contact the undersigned at charlie.carter@terracon.com or (843) 884-1234.

Sincerely, Charlie Carter Jeffrey A Gurrie Field Professional Senior Project Industrial Hygienist for

TABLE OF CONTENTS

EXECUTIVE SUMMARY .....................................................................................................i

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTION

3.0 ASBESTOS SURVEY

3.1 Regulatory Overview

3.2 Visual Assessment

3.3 Physical Assessment

3.4 Sample Collection

3.5 Sample Analysis

3.6 Findings and Recommendations

4.0 LEAD-BASED PAINT SURVEY

4.1 Regulatory Overview

4.2 Sampling and Analytical Protocol

4.3 Sample Collection

4.4 Findings and Recommendations

5.0 ADDITIONAL SERVICES

5.1 PCBs, Mercury, and Refrigerants

6.0 LIMITATIONS / GENERAL COMMENTS

LIST OF APPENDICES

APPENDIX A - TABLES

Table 1 - Asbestos Survey Sample Summary Table 2 - Lead Based Paint Sample Summary

APPENDIX B – SITE DIAGRAM WITH SAMPLE LOCATIONS

APPENDIX C – PHOTO DOCUMENTATION

APPENDIX D – LABORATORY REPORTS

Asbestos Analytical Laboratory Data Lead Paint Analytical Laboratory Data

APPENDIX E – INSPECTOR LICENSE

Ralph H. Johnson VAMC Canteen Kitchen Renovation ■ Charleston, South Carolina July 10, 2015 ■ Terracon Project No. EN157096

Responsive ■ Resourceful ■ Reliable i

EXECUTIVE SUMMARY

This executive summary is intended as an overview for the convenience of the reader. The report should be reviewed in its entirety prior to making any decisions regarding this site.

Terracon Consultants Inc. (Terracon) conducted a hazardous materials survey at the Ralph H.

Johnson VA Medical Center building located at 109 Bee Street, in Charleston, South Carolina.

The site consists of an approximately 1,300 square-foot kitchen area inside the building, reportedly constructed in 1962. It was our understanding that Atriax Group plans to renovate the canteen kitchen area. The purpose of this survey was to sample and identify suspect hazardous materials and provide information regarding the identity, location, condition and approximate quantities of ACM in interior building components.

The survey was performed on June 16, 2015 by a South Carolina Department of Health and

Environmental Control (SCDHEC) licensed asbestos inspector in general accordance with our proposal dated April 28, 2015 and the sampling protocols established in EPA 40 CFR 763

(Asbestos Hazard Emergency Response Act, AHERA) and the SCDHEC Regulation 61-86.1

Standards of Performance for Asbestos Projects. Seventy five (75) bulk samples were collected from homogeneous areas of suspect ACM.

Based on the results of laboratory analysis, the following materials were confirmed to contain asbestos at concentrations greater than one percent (>1%):

Gray/white HVAC mastic;

Black mastic under 12”x12” White speckled VFT;

Thermal System Insulation (TSI) on pipe elbows and fittings; and

Tan HVAC mastic

If the above materials may be disturbed during renovation activit ies, Terracon recommends removal of the asbestos-containing materials by a South Carolina licensed asbestos abatement contractor prior to renovation of the building. Material remaining in place should be managed through a maintenance plan. Renovation contractors must be notified of any materials remaining in place to prevent disturbance.

Removal of TSI on piping elbows and pipe fittings will require third-party clearance air monitoring to meet SCDHEC regulation 61-86.1.

Five (5) paint-chip samples were collected from the components of the structure on the site.

Laboratory analysis detected lead concentrations above detection levels in the following samples:

Khaki door trim, Canteen office;

Blue floor, Canteen storage.

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Workers performing work on surfaces which have any lead concentrations should be notified to comply with OSHA requirements. The full OSHA lead standard should be referenced for compliance. The lead concentrations are below the threshold for SCDHEC regulations concerning lead paint disposal. Paints containing less than 0.06% lead do not meet SCDHEC waste requirements for lead-based paint.

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HAZARDOUS MATERIALS SURVEY REPORT

RALPH H. JOHNSON VAMC CANTEEN KITCHEN RENOVATION

109 BEE STREET

CHARLESTON, SOUTH CAROLINA

Project No. EN157096

INSPECTION DATE: June 16, 2015

REPORT DATE: July 10, 2015

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a hazardous materials survey of building materials at the Ralph H. Johnson VA Medical Center located at 109 Bee Street in Charleston, South Carolina. The survey was conducted on June 16, 2015 by a South Carolina Department of

Health and Environmental Control (SCDHEC) licensed building inspector in general accordance with our Proposal No PEN150214 dated April 28, 2015.

We understand the hazardous materials survey was requested due to the planned interior renovation of the canteen kitchen area. Environmental Protection Agency (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 renovation/demolition activities.

NESHAP requires that potentially regulated asbestos-containing building materials be identified, classified and quantified prior to planned disturbances or demolition activities. The SCDHEC defines a renovation as, “altering a facility or one or more facility components in any way, including the stripping or removal of RACM from any facility component.” A demolition is defined as, “Wrecking or taking out any load-supporting structural member of a facility together with any related handling operations, the burning of any facility, or moving of a structure.”

Suspect ACM was sampled in general accordance with the sampling protocols outlined in EPA

Regulation 40 CFR 763 Subpart E763.86 (Asbestos Hazard Emergency Response Act, AHERA) and SCDHEC Regulation 61-86.1 Standards of Performance for Asbestos Projects. Interior and exterior building components were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented. Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids or in other concealed areas. Samples were delivered to an accredited laboratory for analysis by Polarized Light Microscopy (PLM) and Transmission Electron

Microscopy (TEM), as required.

The objective of the lead paint evaluation was to identify lead based paint systems on building components that may require special handling and disposal considerations upon renovation of the structure. SCDHEC regulates solid waste disposal under Regulation 61-107.19. Testing was performed to meet specific State disposal requirements and does not comply with all parts of the

Occupational Health and Safety Administrations (OSHA) lead regulations. Testing to comply with

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OSHA regulations are not covered in our scope of work since it is the responsibility of the contractor to protect its employees.

Paint samples were collected from visible and accessible building components and paint systems and submitted to an Environmental Laboratory Accreditation Program (ELAP) approved laboratory for analysis of lead.

2.0 BUILDING DESCRIPTION

The section of the building undergoing renovation is an approximately 1,300 square-foot canteen kitchen area on the first floor of a five story hospital building reportedly constructed in

1962. The building has a concrete and metal structure frame. Interior finishes consist of plaster wall systems over gypsum wallboards with a painted finish and walls with ceramic tiles and grout. The ceilings consisted of a suspended ceiling containing 2’x2’ lay-in ceiling panels.

HVAC duct work was present above the ceiling tiles. There were three types of HVAC mastic observed: gray/white, black, and tan. The gray/white mastic was observed above the canteen office. The black and tan HVAC mastic was observed throughout the area of work. The floors consisted of concrete covered with vinyl sheet flooring and mastic, vinyl floor tiles and mastic, and ceramic tiles and grout. The canteen storage room had residual floor mastic with a blue paint painted over it, plaster walls and a ceiling with a metal lath and plaster with a painted finish. The other portions of the hospital were not part of the area of work and were not observed.

3.0 ASBESTOS SURVEY

The asbestos survey was conducted by SCDHEC licensed Asbestos Building Inspector Mr.

Charlie Carter (License No. BI-01361, exp. 8/13/15). The survey was conducted on June 16, 2015, in general accordance with the sampling protocols established by EPA Regulation 40 CFR

763 Subpart E 763.86, AHERA and SCDHEC R61-86.1. A summary of survey activities is provided below.

3.1 Regulatory Overview

An ACM is defined as any material containing asbestos of any type in an amount greater than one percent (1%). The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under

NESHAP, asbestos-containing building materials are classified as either friable, Category I non-friable or Category II non-friable ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Category I non friable ACM includes packing materials, gaskets, resilient floor coverings and asphalt roofing products containing more than 1 percent (%) asbestos. Category II non-friable ACM are non-friable materials other than Category I materials that contain more than 1% asbestos.

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Friable ACM, Category I and Category II non-friable ACM which is in poor condition and has become friable or which will be subjected to drilling, sanding, grinding, cutting or abrading and which could be crushed or pulverized during anticipated renovation/demolition activities are considered regulated ACM (RACM). RACM must be removed prior to renovation or demolition activities.

In the state of South Carolina, asbestos activities are regulated by the SCDHEC under the

SCDHEC Regulation 61-86.1 Standards of Performance for Asbestos Projects. The SCDHEC require that any asbestos-related activity conducted in a public building be performed by personnel licensed by the SCDHEC. The owner or operator must provide the SCDHEC with written notification of planned abatement and removal activities prior to the commencement of those activities. The SCDHEC requires 4 day notification for non-friable projects and 10 day notification for RACM projects. Asbestos abatement must be performed by SCDHEC-licensed asbestos abatement contractors. A SCDHEC-licensed Project Designer shall prepare a written abatement design for each abatement renovation project involving the removal of greater than

3,000 square, 1,500 linear, or 656 cubic feet of RACM. Third-party air monitoring must be conducted during the abatement of friable (regulated) ACM. The SCDHEC asbestos regulations can be found online at www.scdhec.gov.

The Occupational Safety and Health Administration (OSHA) Asbestos Standard for Construction

Industry (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc). The OSHA standard classifies construction and maintenance activities, which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work. A full copy of the

OSHA asbestos standard for general industry may be found at OSHA’s website (www.osha.gov) and should be referenced for specific information.

3.2 Visual Assessment

Our survey activities began with visual observation of the interior and exterior of the building to identify apparent homogeneous areas of suspect ACM. A homogeneous area consists of building materials, which appear similar throughout in terms of color, texture and date of application.

Building materials which were not identified as concrete, glass, wood, masonry, metal or rubber were considered suspect ACM.

Terracon lifted floor coverings in several areas, where possible, and did not observe additional flooring layers unless mentioned in this report; however, as Terracon could not assess beneath all floor covering in all areas, there may be isolated areas of additional suspect material p resent beneath existing flooring.

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3.3 Physical Assessment

A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material, which can be crumbled, pulverized or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.4 Sample Collection

Based on the results of the visual sampling, bulk samples of suspect ACM were collected in general accordance with AHERA sample collection protocols. Random samples of suspect materials were collected in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

The selection of sample locations and frequency of sampling was based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content.

Seventy five (75) bulk samples were collected from nineteen (21) homogeneous areas of suspect

ACM in the buildings. A summary of the suspect ACM samples collected during the survey is presented in Table 1 in Appendix A. Sample locations are depicted on a Site Diagram in

Appendix B.

3.5 Sample Analysis

Bulk samples were submitted under chain of custody to EMSL Analytical Inc. (EMSL) of Charlotte, North Carolina for analysis by Polarized Light Microscopy (PLM) with dispersion staining techniques per EPA EPA/600/R-93/116. The percentage of asbestos, where applicable, was determined by microscopical visual estimation. EMSL is accredited under the National Voluntary

Laboratory Accreditation Program NVLAP (#200841-0). Layered analysis of samples was conducted by the lab to separate the layers of vinyl sheet flooring, cove base and mastic, and vinyl floor tile and mastic. As a result of the layered analysis described above a total of eighty nine (89) sample layers were analyzed.

The laboratory was instructed to analyze samples from each non-friable homogeneous area until the first sample containing asbestos was identified. Subsequent samples within the same HA are not analyzed and assumed to contain asbestos in similar content.

Per the SCDHEC Regulation 61-86.1 Standards of Performance for Asbestos Projects, negative results for non-friable organically bound (NOB) materials such as flooring and roofing shall be verified with at least one TEM analysis. The additional analysis was performed by TEM in accordance with EPA/600/R-93/116 Section 2.5.5.1.

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Fourteen (14) of the sampled materials are considered NOBs and thus were submitted and analyzed by TEM analysis. Samples requiring TEM analysis are identified on Table 1 in Appendix

A.

3.6 Findings and Recommendations

Based on the results of laboratory analyses, the following materials tested positive for asbestos:

Gray/white HVAC mastic;

Black mastic under 12”x12” White speckled VFT;

Thermal System Insulation (TSI) on pipe elbows and fittings; and

Tan HVAC mastic

The HVAC mastic tested negative for asbestos content when analyzed by PLM. Per SCDHEC regulations, floor tile and mastic are considered NOBs and therefore also have a sample analyzed by TEM, a more sensitive method. TEM analysis indicated a concentration of 3.1% Chrysotile.

Therefore, this material is considered ACM and must be abated prior to disturbance by renovation/demolition activities.

Table 1 in the Appendix A summarizes the results of the visual inspection, estimated quantities, and laboratory analyses. Asbestos laboratory analytical reports are included in Appendix D.

If the above materials may be disturbed during renovation activit ies, Terracon recommends removal of the asbestos-containing materials by a South Carolina licensed asbestos abatement contractor prior to renovation of the building. Material remaining in place should be managed through a maintenance plan. Renovation contractors must be notified of any materials remaining in place to prevent disturbance.

Removal of TSI on piping elbows and pipe fittings will require third-party clearance air monitoring to meet SCDHEC regulation 61-86.1.

A copy of this report must be submitted to SCDHEC at least four (4) working days prior to renovation when applying for a asbestos removal permit. Federal, state and local regulations should be referred to in order to verify compliance before any actions are initiated on an ACM.

In accordance with OSHA's Asbestos Standard, the employer shall notify affected employees and contractors of the presence and location of asbestos-containing materials and test results. A full copy of the OSHA asbestos standard for general industry may be found at OSHA’s website

(www.osha.gov) and should be referenced for specific information.

It should be noted that suspect materials, other than those identified during the June 16, 2015 survey may exist within the structure. Should suspect materials other than those which were identified during this survey be uncovered during or prior to the abatement and demolition

Responsive ■ Resourceful ■ Reliable 6 process, those materials should be assumed asbestos-containing until sampling and analysis can confirm or refute their asbestos content. Should future sampling indicate that the other material is asbestos containing, Terracon recommends removal of the asbestos-containing materials by a

South Carolina licensed asbestos abatement contractor prior to renovation/demolition of the building.

Terracon could provide Client with a proposal for developing asbestos abatement specifications and for performing abatement oversight and air monitoring upon request.

4.0 LEAD-BASED PAINT SURVEY

4.1 Regulatory Overview

Lead is regulated by the EPA, SCDHEC and OSHA. The EPA and SCDHEC regulate lead use, removal, and disposal, and OSHA regulates lead exposure to workers. The EPA defines LBP as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 mg/cm2, 5,000 mg/kg, or 0.5% by dry weight as determined by laboratory analysis. The

SCDHEC regulations 61-107.19 require that painted demolition debris with a lead concentration greater than 0.06% by weight be disposed in a permitted Class II landfill. For the purpose of the

OSHA lead standard, lead includes metallic lead, all inorganic lead compounds, and organic lead soaps. The complete OSHA standard for compliance can be found on OSHA’s website

(www.osha.gov). A synopsis of the OSHA regulations (29 CFR 1926.62) and the applicability are as follows:

The OSHA Interim Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions. Under this standard, construction includes, but is not limited to, the following:

Demolition or salvage of structures where lead or materials containing lead are present

Removal or encapsulation of materials containing lead

New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead

Installation of products containing lead

Lead contamination/emergency clean-up

Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed

Maintenance operations associated with construction activities described above

Responsive ■ Resourceful ■ Reliable 7

4.2 Sampling and Analytical Protocol

Mr. Charlie Carter of Terracon conducted the lead based paint (LBP) sampling on June 16, 2015. The LBP sampling was conducted by collecting paint chip samples. The paint chip samples were collected from painted or lacquered surfaces of building components likely to contain LBP, based on apparent date of application. The paint samples were collected down to the surface substrate so as to include any underlying paint systems in the analysis. The random paint chip samples were selected based on current paint schemes and may not be inclusive of old paint systems covered with paneling, or existing painted systems. The paint chip samples were submitted to an ELAP approved laboratory for analysis of lead by NIOSH Method

7082M (atomic absorption).

4.3 Sample Collection

Four (4) paint samples were collected from interior painted surfaces on the building. Paint sampled included:

Khaki door trim, Canteen Office

White wall, Canteen Office

Tan wall, Chief Canteen Service

Blue floor, Canteen Storage

4.4 Findings and Recommendations

Lead was detected above the laboratory detection limits in the khaki door trim (0.043%) in the

Canteen Office, and the blue floor paint (0.016%) in the Canteen Storage room. None of the concentrations were above the EPA threshold for lead based paint (0.5% by weight) or

SCDHEC lead based paint of 0.06%. The lead concentrations are below the threshold for

SCDHEC regulations concerning lead paint disposal. Paints containing less than 0.06% lead do not meet SCDHEC waste requirements for lead-based paint.

Workers performing work on surfaces which have any lead concentrations should be notified to comply with OSHA requirements. The full OSHA lead standard should be referenced for compliance.

Responsive ■ Resourceful ■ Reliable 8

5.0 ADDITIONAL SERVICES

5.1 PCBs, Mercury, and Refrigerants

A survey of the area under study was conducted to determine the quantity of polychlorinated biphenyls (PCBs) containing light ballasts. The area was also surveyed to determine the presence of mercury containing bulbs, thermostats, switches, and equipment containing refrigerants. The inspection for PCBs included the dismantling of at least one light fixture of each type to determine from the labels and markings on the ballasts if they are likely to contain

PCBs. Each type of thermostat and light switch was disassembled as applicable to determine by visual inspection if mercury was used in these items. The type of refrigerants used on site was determined based on interviews with hospital personnel knowledgeable of the refrigerants used on the site.

Terracon disassembled one of each type of florescent light fixture observed throughout the canteen kitchen area. The ballasts observed contained labeling indicating no-PCBs were present. Because only one of each type of florescent light fixture was disassembled, there may be PCB containing ballasts in the canteen kitchen area that were not identified.

Labeling indicating the presence of mercury on the light switches was not observed. Typically, light switches that contain mercury have little physical resistance when activated. The light switches observed throughout the buildings contained a distinctive click when activated, which indicates that mercury is not likely part of the operational components of the light switches in the buildings. Florescent tubes commonly contain mercury. If lighting is to be changed, the light tubes should be removed intact, packaged to prevent breakage and transferred to an approved recycling facility that recovers mercury.

Based on conversations with staff knowledgeable of the type of refrigerants used on the site, it was determined that refrigerants used in the “walk in” freezer and refrigerator consist of R-404a.

The refrigerant used in the “reach in” refrigerators is R-134a. According to the National

Refrigerants, Inc website, R-404a is a non-hazardous refrigerant that is generally used for large units for low to medium temperatures and was used to replace R-22 refrigerant. According to the National Refrigerants, Inc website, R-134a is a non-hazardous material that is generally used in smaller units for medium temperatures and was used to replace R-12 refrigerant. If systems containing refrigerants are to be replaced during renovation activities, they should be removed by a qualified recycling firm that recovers refrigerants.

Responsive ■ Resourceful ■ Reliable 9

6.0 LIMITATIONS / GENERAL COMMENTS

Terracon did not perform sampling which required demolition or destructive activities such as knocking holes in walls, ceiling and dismantling of equipment or removal of protective coverings.

Reasonable efforts to access suspect materials within known areas of restricted access (e.g.

crawl spaces and attics) were made; however, confined spaces or areas which may pose a health or safety risk to Terracon personnel were not sampled. Sampling did not include materials which could not be safely reached with available ladders.

This survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the Canteen Kitchen area. The information contained in this report is relevant to the date on which this survey was performed, and should not be relied upon to represent conditions at a later date.

The results included herein apply to the renovation areas only and not the entire Ralph H.

Johnson VA Medical Center building. Based on the project scope of work, Terracon cannot make conclusions about asbestos content in the remainder of the building. If the renovation scope of work changes to include areas or materials other than sampled here, additional investigations will be necessary.

This report has been prepared on behalf of and exclusively for use by the Atriax Group for specific application to their project as discussed. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information, which may have been used in the preparation of this report. No warranty, express or implied is made.

This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary.

APPENDIX A

1-WB3-1-7 7 PLM None detected Plaster wall system 1 Surfacing Friable Good PD 800

2-WB2-1-3 3 PLM None detected Gypsum behind plaster 2 Miscellaneous Friable Good PD 800

3-CT3-1-3 3 PLM None detected 2'x2' Ceiling tile 3 Miscellaneous Non-Friable Good PD 300

4-HP1-1-7 7 PLM None detected Single layer wall plaster above ceiling 4 Surfacing Non-Friable Good PD 500

5-MG5-1-2 2 PLM None detected

5-MG5-3 1 TEM 3.1% Chrysotile

6-FT5,MG5-1-2 2 PLM

Sheet flooring - none detected

Mastic - none detected

6-FT5,MG5-3 1 TEM

Sheet flooring - none detected

Mastic - none detected

7-FC3,MG3-1-2 2 PLM

Cove base - none detected

Mastic - none detected

7-FC3,MG3-3 1 TEM

Cove base - none detected

Mastic - none detected

8-CA5-1-2 2 PLM None detected

8-CA5-3 1 TEM None detected

9-PI5-1-3 3 PLM None detected 1" Pipe TSI 9 Miscellaneous Friable Good PD 150 (Linear Feet)

10-MG5-1-2 2 PLM None detected

10-MG5-3 1 TEM None detected

11-CT5-1-3 3 PLM None detected 2'x2' Gypsum ceiling tile 11 Miscellaneous Friable Good PD 700

PD 300

Gray/white HVAC mastic 5 Miscellaneous Non-Friable Good PD 100

Wood grain 6"x24" sheet flooring & mastic 6 Miscellaneous Non-Friable Good

PD 70

4" Brown cove base & mastic 7 Miscellaneous Non-Friable Good PD 50

Red fire caulk 8 Miscellaneous Non-Friable Good

Black HVAC mastic 10 Miscellaneous Non-Friable Good PD 200

TERRACON PROJECT NO. EN157096

Estimated

Quantity

(Square Feet)

TABLE 1

ASBESTOS RESULTS SAMPLE SUMMARY

RALPH H. JOHNSON VAMC

109 BEE STREET

CHARLESTON, SOUTH CAROLINA

Number of

Samples

Classification Friable /

Non-Friable Current Condition

Potential for

Disturbance Sample Number

Analysis

Method Analytical Results Sample Description

Homogeneous

Area

TERRACON PROJECT NO. EN157096

Estimated

Quantity

(Square Feet)

TABLE 1

ASBESTOS RESULTS SAMPLE SUMMARY

RALPH H. JOHNSON VAMC

109 BEE STREET

CHARLESTON, SOUTH CAROLINA

Number of

Samples

Classification Friable /

Non-Friable Current Condition

Potential for

Disturbance Sample Number

Analysis

Method Analytical Results Sample Description

Homogeneous

Area

12-SC5-1-3 3 PLM None detected CMU coating 12 Surfacing Non-Friable Good PD 100

13-FT2,MG2-1-2 2 PLM

VFT - none detected

Black mastic - 3% Chrysotile

Tan mastic - none detected

Leveler - none detected

13-FT2,MG2-3 1 TEM

VFT - none detected

Black mastic - 3% Chrysotile

Tan mastic - none detected

Leveler - none detected

14-FC3,MG3-1-2 2 PLM

Cove base - none detected

Mastic - none detected

14-FC3,MG3-3 1 TEM

Cove base - none detected

Mastic - none detected

15-PI5-1-3 3 PLM 3% Chrysotile TSI elbow 15 Miscellaneous Friable Good PD 50 (Linear Feet)

16-PI5-1-3 3 PLM None detected 4" Pipe TSI 16 Miscellaneous Friable Good PD 150 (Linear Feet)

17-HP2-1-5 5 PLM None detected Gray ceiling plaster rough coat 17 Surfacing Friable Good PD 200

18-MG5-1-2 2 PLM None detected

18-MG5-3 1 TEM None detected

19-FC3,MG3-1-2 2 PLM

Cove base - none detected

Mastic - none detected

19-FC3,MG3-3 1 TEM

Cove base - none detected

Mastic - none detected

20-MG5-1-2 2 PLM 2% Chrysotile

20-MG5-3 1 TEM Not analyzed

21-HP2-1-3 5 PLM None detected White ceiling plaster skim coat 21 Surfacing Non-Friable Good PD 200

PD 100

12"x12" White speckled VFT

& mastic 13 Miscellaneous Non-Friable Good

PD 200

Beige cove base & mastic 14 Miscellaneous Non-Friable Good PD 25

Floor mastic with blue paint 18 Miscellaneous Non-Friable Good

Good PD 200

4" Tan cove base & mastic 19 Miscellaneous Non-Friable Good PD 50

PLM - Polarized Light Microscopy

TEM - Transmission Electron Microscopy

VFT - Vinyl Floor Tile

1) Quantities listed above are estimates to be used for inspection purposes only and should be field-verified for all other uses.

2) Highlited samples were found to be positive for asbestos.

3) Please refer to Apendix B for sample locations.

LPD - Low potential for disturbance

PD - Potential for disturbance

PSD - Potential of significant disturbance

Tan HVAC mastic 20 Miscellaneous Non-Friable

APPENDIX B

SITE DIAGRAM WITH SAMPLE LOCATIONS

Project No.

Scale:

File Path:

Date:

PM:

Drawn By:

Checked By:

Approved By: 1450 Fifth Street, West

Phone: (843) 884 1234

North Charleston, SC 29405

Fax: (843) 884 9234

Site Sample Diagram

Charleston County South Carolina

EXHIBIT NO.

Ralph H. Johnson VAMC Canteen Kitchen Renovation Charleston

Legend

EN157096

6/29/15 NEP

NEP

CFC

CFC

N.T.S

Sample locations are approximated

Paint Sample (< 0.01%) Lead-Containing Paint Sample (> 0.01%) Asbestos Sample (Negative) Asbestos Sample (Positive)

1-WB3-2

4-HP1-4

1-WB3-1

2-WB2-1

3-CT3-1

4-HP1-1-3

8-CA5-1-2

9-PI5-1-3

1-WB3-7

1-WB3-6

2-WB2-3

3-CT3-3

1-WB3-5

2-WB2-2

3-CT3-2

4-HP1-6

8-CA5-3

1-WB3-4

1-WB3-3

4-HP1-5

4-HP1-7

LP-1

LP-4

LP-3

LP-2

10-MG5-2

15-PI5-1-3

16-PI5-1-3

13-FT2,MG2-3

14-FC3,MG3-3

13-FT2,MG2-1-2

14-FC3,MG3-1-2

5-MG5-1-2

5-MG5-3

6-FT5,MG5-1-2

7-FC3,MG3-1-2

6-FT5,MG5-3

7-FC3,MG3-3

10-MG5-1

11-CT5-3

20-MG5-1

10-MG5-3

17-HP2-1-3

20-MG5-3

11-CT5-2

11-CT5-1

12-SC5-1-3

18-MG5-1

19-FC3,MG3-1

18-MG5-2

19-FC3,MG3-2

18-MG5-3

19-FC3,MG3-3

21-HP2-1

21-HP2-2

21-HP2-3

21-HP2-4

21-HP2-5

20-MG5-1

Shaded area represents the extent of the survey area.

APPENDIX C

PHOTO DOCUMENTATION

Date Photos Taken: 6/16/15

Photo #1 View of HA-1, plaster wall system, and HA-2 gypsum behind plaster Photo #2 View of HA-3 2’x2’ ceiling tiles

Photo #3 View of HA-5 Gray/white HVAC mastic Photo #4 View of HA-6 wood grain vinyl sheet flooring and mastic

Photo #5 View of HA-7 4” brown cove base and mastic

Photo #6 View of HA-8 red fire caulk

Photo #7 View of HA-9 1” pipe TSI Photo #8 View of HA-10 black HVAC mastic and HA-20 tan HVAC mastic

Photo #9 View of HA-13 12”x12” White speckled VFT and mastic Photo #10 View of HA-15 Elbow TSI and HA-

16 4” pipe TSI

Photo #11 View of HA-17 rough coat ceiling plaster Photo #12 View of HA-18 floor mastic with blue paint

Photo #13 View of ballast in Canteen Office “No

PCBs” Photo #14 View of ballast in Prep and Storage area “No PCBs”

Photo #15 View of ballast in Canteen Storage “No PCBs”

APPENDIX D

LABORATORY REPORTS

376 Crompton Street, Charlotte, NC 28273

Phone/Fax: (704) 525-2205 / (704) 525-2382 http://www.EMSL.com charlottelab@emsl.com

411504139

CustomerID: WPCE62

CustomerPO:

ProjectID:

EMSL Order:

Attn: Charlie Carter

Terracon, Inc.

1450 Fifth Street West

North Charleston, SC 29405

Received: 06/18/15 10:05 AM

Ralph H. Johnson VAMC

Fax: (843) 884-9234

Phone: (843) 884-1234

Project:

6/18/2015Analysis Date:

6/16/2015Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

1-WB3-1-Skim Coat

411504139-0001

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-2-Skim Coat

411504139-0002

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-2-Rough

Coat

411504139-0002A

- Plaster Wall

System

Gray None Detected

Non-Fibrous

Homogeneous

Quartz30%

Ca Carbonate5%

Non-fibrous (other)65%

1-WB3-3-Skim Coat

411504139-0003

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-3-Rough

Coat

411504139-0003A

- Plaster Wall

System

Gray None Detected

Non-Fibrous

Homogeneous

Quartz30%

Ca Carbonate5%

Non-fibrous (other)65%

1-WB3-4-Skim Coat

411504139-0004

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-5-Skim Coat

411504139-0005

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-5-Rough

Coat

411504139-0005A

- Plaster Wall

System

Gray None Detected

Non-Fibrous

Homogeneous

Quartz30%

Ca Carbonate5%

Non-fibrous (other)65%

1Test Report PLM-7.28.9 Printed: 7/7/2015 12:52:18 PM

Lee Plumley, Laboratory Manager or other approved signatory

Analyst(s)

EMSL maintains liability limited to cost of analysis. This report relates only to the samples reported 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. Interpretation and use of test results are the responsibility of the client. 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. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Charlotte, NC NVLAP Lab Code 200841-0, VA 3333 00312

Report Amended: 07/07/2015 12:26:55 Replaces Report Amended: 07/07/2015 11:03:19. Reason Code: Data Entry-Change to Appearance

Erin Guzowski (36) Eric Loomis (47)

Phone/Fax: (704) 525-2205 / (704) 525-2382 http://www.EMSL.com charlottelab@emsl.com

411504139

CustomerID: WPCE62

CustomerPO:

ProjectID:

EMSL Order:

Attn: Charlie Carter

Terracon, Inc.

1450 Fifth Street West

North Charleston, SC 29405

Received: 06/18/15 10:05 AM

Ralph H. Johnson VAMC

Fax: (843) 884-9234

Phone: (843) 884-1234

Project:

6/18/2015Analysis Date:

6/16/2015Collected:

Sample Description Appearance % Type

AsbestosNon-Asbestos

% Fibrous % Non-Fibrous

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

1-WB3-6-Skim Coat

411504139-0006

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-6-Rough

Coat

411504139-0006A

- Plaster Wall

System

Gray None Detected

Non-Fibrous

Homogeneous

Quartz25%

Ca Carbonate5%

Non-fibrous (other)70%

1-WB3-7-Skim Coat

411504139-0007

- Plaster Wall

System

White None Detected

Non-Fibrous

Homogeneous

Ca Carbonate5%

Non-fibrous (other)95%

1-WB3-7-Rough

Coat

411504139-0007A

- Plaster Wall

System

Gray None Detected

Non-Fibrous

Homog…