S06 A003 Bldg 42 - Asbestos Survey Report (Final).pdf

IIHHII

E N V I R O N M E N T A L

ASBESTOS SURVEY REPORT

Bob Stump Veterans Affairs Medical Center Building 42

Prescott, Arizona

Order Number VA649-C10326

March 16, 2012

Prepared for:

Richard Trevino Northern Arizona Veterans Affairs Health Care System

500 North Highway 89 Prescott, Arizona 85723

Prepared by: Reviewed by:

Amir Karamati, MSPH

AHERA Certified Asbestos Inspector Randy McClure, CSP IHI Project Manager

Project # 11P-A3138

640 EAST WILMINGTON AVE SALT LAKE CITY UT 84106 TELEPHONE: 801-466-2223 FAX: 801-466-9616 E-MAIL: IHI@IHI-ENV.COM

SALT LAKE CITY SAN FRANCISCO PHOENIX DENVER SEATTLE

Executive Summary During January 2011, IHI Environmental conducted a comprehensive asbestos survey of Building 42, at the Bob Stump Veterans Affairs Medical Center in Prescott, Arizona. Mr.

Eric Towles was the Contract Officer Technical Representative for this project. The objective of this inspection was to determine the presence and condition of all accessible asbestos-containing building materials (ACBM) and to recommend response actions for the materials identified.

Hazard Rank Codes – All of the ACBM materials, including those that contain less than 1% but greater than none detected, were assigned a Hazard Rank Code of 1, 2, 3, or 4. A Hazard Rank Code of 1 requires an immediate response action. Materials assigned a Hazard Rank Code 4 are those ACBMs that do not pose a significant health risk and do not require immediate response. Hazard Rank Codes were determined by assessing the material condition, accessibility, and potential for future disturbance. There were no ACBMs identified in this building.

Operations and Maintenance Plan – The VA should implement the Operations and Maintenance Plan provided with this project. This plan assigns responsibility for program management and coordination and institutes a formal system for coordinating building construction or maintenance activities so that asbestos-containing materials are not inadvertently disturbed.

Cost Estimates for Removal – The estimated cost to remove all of the ACBM from this building in a single planned abatement project is $0. The Material Removal Unit Cost Estimate (Table 6) in Appendix A outlines the estimated removal costs associated with each of the various homogeneous materials identified during this survey.

The report that follows this Executive Summary should be read in its entirety because it includes detailed information, such as material descriptions and locations, regulatory requirements, and building-specific recommended response actions, contained in other sections and appendices.

Bob Stump VAMC – Building 42 i IHI Environmental Asbestos Survey Report Project # 11P-A3138

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Scope of Work

2.0 SURVEY PROCEDURES

2.1 Building Inspection

2.2 Bulk Sampling

2.3 Bulk Sample Analysis

3.0 SURVEY FINDINGS

3.1 ACBM

3.2 Non-ACBM

3.3 Damage and Hazard Assessment

3.3.1 Hazard Rank Codes

3.4 Special Considerations

3.4.1 Roofing Materials

3.5 Inaccessible Areas

4.0 APPLICABLE RULES AND REGULATIONS

4.1 Renovation and Demolition (EPA and OSHA)

5.0 COST ESTIMATES FOR REMOVAL

6.0 PROJECT LIMITATIONS

APPENDICES

Appendix A - Summary Tables

Table 1: Summary of Asbestos-Containing Building Materials (ACBM) Table 2: Summary of Non-ACBM Table 3: Room-by-Room Inspection and Assessment Findings Table 4: Bulk Sample Log Table 5: Homogeneous Materials with Room-by-Room Inspection and Assessment

Findings Table 6: ACBM Removal Cost Estimates

Appendix B: Building Description & Floor Plans Appendix C: Laboratory Analytical Results Appendix D: Inspector Certificates

Bob Stump VAMC – Building 42 TOC-1 IHI Environmental

ABBREVIATIONS AND DEFINITIONS

Asbestos: A group of naturally occurring minerals that separate into fibers. Asbestos fibers are incombustible, are chemically resistant, and are characterized by the properties of thermal and electrical insulation. There are six asbestos minerals used commercially: chrysotile, amosite, crocidolite, tremolite, anthophyllite, and actinolite. This includes any of these minerals that have been chemically treated and/or altered.

Asbestos abatement: Procedures to remove ACBM from buildings with the simultaneous control of the release of asbestos fibers. Additionally, this includes activities focused on the encapsulation, encasement, repair, and enclosure of ACBM.

Asbestos Containing Building Material (ACBM): Surfacing ACBM, TSI ACBM, or miscellaneous ACBM found in or on interior structural members or other parts of a building.

This definition is used in the AHERA regulations for school buildings.

Asbestos abatement contractor: An Arizona-licensed asbestos removal company.

Asbestos-Containing Materials (ACM): The US EPA and OSHA define this as a material containing more than 1% by weight of the regulated asbestos minerals.

Asbestos Coordinator: The designated VA Facilities Service employee is the single contact point for all ACBM issues on the VA campus.

Asbestos Hazard Emergency Response Act (AHERA): The federal Asbestos Hazard Emergency Response Act of 1986 and the Environmental Protection Agency implementing regulations, 40 CFR Part 763, Subpart E - Asbestos-Containing Materials in Schools. The passage of AHERA by Congress led to the promulgation by EPA of two additional regulations:

the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) and the Model Accreditation Plan (MAP), which outlines the requirements for accreditation of inspectors and personnel conducting asbestos activities in schools.

Asbestos inspection: Any activity undertaken to determine the presence or location, or to assess the condition, of asbestos-containing material or suspected asbestos-containing material, whether by visual or physical examination, or by taking samples of the material. This term includes reinspections of the type described in AHERA, 40 CFR 763.85(b), of known or assumed asbestos-containing material which has been previously identified.

Asbestos project: Any activity involving the removal, renovation, repair, demolition, salvage, disposal, cleanup, or other disturbance of regulated asbestos-containing material greater than small scale short duration.

Demolition: The wrecking, salvage, or removal of any load-supporting structural member of a structure together with any related handling operations, or the intentional burning of any structure. This includes the moving of an entire building.

Disturb: To disrupt the matrix of ACM or regulated asbestos-containing material, crumble, or pulverize ACM or regulated asbestos-containing material, or generate visible debris from ACM or regulated asbestos-containing material.

Bob Stump VAMC – Building 42 TOC-2 IHI Environmental

Bob Stump VAMC – Building 42 TOC-3 IHI Environmental

Friable Asbestos-Containing Material: Friable asbestos-containing material refers to materials which are capable of being crumbled, pulverized, or reduced to powder by hand pressure when dry. Friable asbestos-containing materials are usually found on overhead surfaces, including steel beams, pipes, and ceilings. This may also include previously non-friable material which becomes broken or damaged by mechanical force.

Inaccessible: Physically restricted or obstructed area or covered in such a way that detection or removal is prevented or severely hampered.

Miscellaneous ACM: Interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles. This does not include surfacing material or TSI.

Non-friable ACM: Material of greater than 1 percent asbestos into which the fibers have been locked by a bonding agent, coating, binder, or other material in order to prevent the release of fibers during any appropriate use, handling, storage, transportation, or processing.

Non-friable asbestos-containing materials are usually found in the form of roofing, flooring, and siding materials. When previously non-friable asbestos becomes damaged to the extent that when dry it may be crumbled, pulverized or reduced to a powder during the removal, renovation, or demolition process, it should now be categorized as friable material. This material is considered hazardous during removal and disposal procedures.

Operations and Maintenance (O&M) Plan: A plan of safe work practices and procedures intended to maintain ACBM in good condition and minimize asbestos exposure to building occupants and VA employees, while complying with federal, state, and local regulations.

Presumed Asbestos-Containing Material (PACM): Thermal system insulation and surfacing material found in buildings constructed no later than 1980. OSHA requires that building owners identify PACM in their buildings and treat the PACM as asbestos-containing materials (ACM) until the materials are proven not to contain asbestos. Although not defined strictly as PACM, both OSHA standards also require asphalt and vinyl flooring material installed no later than 1980 be "considered" and "treated" as asbestos-containing, until the building owner proves the flooring is not ACM. This includes not only the flooring material, but associated mastics and backings.

Regulated Asbestos-Containing Material (RACM): Friable asbestos material, Category I non-friable ACM that has become friable, Category I non-friable ACM (vinyl asbestos tile, roofing felts, gaskets and packing) that will be or has been subjected to sanding, grinding, cutting, or abrading, or Category II non-friable ACM (asbestos board, transite, and asbestos shingles) that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Surfacing material: Material that is sprayed, troweled, or otherwise applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes).

Thermal System Insulation (TSI): Asbestos-containing material applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss/gain or water condensation.

1.0 INTRODUCTION

In January 2011, IHI Environmental conducted an asbestos survey of Building 42 on the Bob

Stump Veterans Affairs Medical CenterBob Stump Veterans Affairs Medical Center

(VAMC) campus located at 500 North Highway 89 in Prescott, Arizona. Mr. Eric Towles was the Contract Officer Technical Representative for this project.

1.1 Scope of Work

The objective of this inspection was to determine the presence and condition of all ACBM and to recommend response actions for the materials identified. The scope of work for this inspection was outlined in solicitation VA-258-11-RP-0424.

To accomplish this survey, IHI identified all accessible areas in each building by name, functional space, and room number, and then collected bulk samples of each suspect material according to AHERA sampling protocols and protocols outlined in the VA solicitation.

Tables 3 and 5 (Appendix A) identify the building, functional spaces, rooms, materials, quantities, condition, hazard rank, and any recommended response actions.

2.0 SURVEY PROCEDURES

The asbestos survey was performed using the inspection protocol developed for schools under Asbestos Hazard Emergency Response Act (AHERA). Some deviations in standard sampling protocol were required by the Statement of Work.

2.1 Building Inspection

The building inspections were conducted by EPA-accredited inspectors. Inspections consisted of a detailed visual inspection and assessment of the condition and potential for disturbance of suspect ACBM. The specific components of the inspection and assessment included:

• Room-by-room identification and inspection of materials. Summaries of the suspect materials identified in each building are presented in the Data Tables included in Appendix A.

• An assessment of suspect, known, or assumed ACBM.

• Identification of suspect ACBMs, by material type, with a unique identifier. The material types are thermal system insulation (TSI), surfacing materials, and miscellaneous materials.

Bob Stump VAMC – Building 42 1 IHI Environmental

IHI uses a standardized numbering system to identify homogeneous materials during the survey. Letters T, F, S, or M designate material types as follows:

− Thermal System Insulation (pipe insulation, fittings, etc.): T01 - T10 (example:

T02.2 Hard Pipe Insulation)

− Floor Covering (floor tile, sheet vinyl, mastics and adhesives, floor leveling compounds, cove base, etc.): F01 - F07 (example: F04.4: 9”x9” Floor Tile – Gray)

− Surfacing Materials (texturing and fire-proofing): S01 - S02 − Miscellaneous Materials (roofing, sink undercoating, gypsum board, roofing, etc.): M01 – M17 (example: M10.1: Gray Window Caulk)

2.2 Bulk Sampling

Inspectors collected bulk samples of suspect ACBM and submitted the samples to an accredited laboratory for analysis. Bulk sample numbers are included in Table 4 (Appendix

A: Bulk Sample Log).

• IHI conducted its sampling in a manner that minimized damage to the building, did not leave unsightly marks, and did not create a health hazard for the inspector or building occupants.

• The number of samples collected from each homogeneous area was based on AHERA rules as modified by the requirements from the Statement of Work.

• Friable surfacing materials were sampled using the random sampling scheme given in the EPA publication 560/5-85-030a, titled, “Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials.”

• Unique sample numbers were assigned to each sample collected during the inspection. These numbers were entered on the chain-of-custody forms that accompanied the bulk samples to the analytical laboratory.

• Locations of bulk samples and confirmed ACM are identified on the Building Floor Plans (Appendix B).

2.3 Bulk Sample Analysis

Bulk samples were analyzed using polarized light microscopy (PLM) and visual estimation according to the EPA Interim Method for the Determination of Asbestos in Bulk Insulation

Samples, EPA-600/M4-82-020. The quantification of asbestos in a sample is intended to be an estimate only, and the limit of detection for this method is approximately 1% by weight, based on visual estimation.

Bob Stump VAMC – Building 42 2 IHI Environmental

Samples were analyzed by EMLab P&K offices in San Diego and San Bruno, California, and

Phoenix, Arizona. EMLab P&K is accredited under the National Institute of Standards and

Technology, National Voluntary Laboratory Accreditation Program (NIST-NVLAP) for bulk asbestos sample analysis, and is also accredited by the American Industrial Hygiene

Association (AIHA).

EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) and AHERA regulations define ACM as material containing greater than 1% asbestos by weight; materials containing 1% or less asbestos are not considered regulated ACM by the EPA. Further, the

NESHAP regulations state that any sample of friable material found to contain less than 10% asbestos but greater than “none detected,” by the visual estimation method used during PLM analysis, must be assumed to contain greater than 1% asbestos unless confirmed by NESHAP point counting analysis. The Statement of Work (SOW) for this project required that all materials sampled and determined to contain less than 3% asbestos shall be point counted.

The SOW further stipulated that non-friable organically bound materials such as vinyl floor tile, mastic, and roofing materials, containing less than 1% asbestos, shall be confirmed by transmission electron microscopy (TEM).

The laboratory reports are included in Appendix C.

3.0 SURVEY FINDINGS

3.1 ACBM

All ACBM is identified in Tables 1 and 5 (Appendix A). These tables describe the type of material, visual appearance, condition, friability, potential for disturbance, and identify any materials that require immediate actions. Locations of these materials are shown on the

Building Floor Plans (Appendix B).

3.2 Non-ACBM

Suspect materials are identified as non-ACBM if the material contains no detectable asbestos. Tables 2 and 3 (Appendix A) identify the non-ACBM materials.

3.3 Damage and Hazard Assessment

Each ACBM was assessed for damage, accessibility, and the potential for future damage.

This information is presented in Table 3 in Appendix A.

Bob Stump VAMC – Building 42 3 IHI Environmental

3.3.1 Hazard Rank Codes

Hazard Rank Codes were determined by assessing the material condition, accessibility, and potential for future disturbance. ACBM materials, including those that contain less than 1% but greater than none detected, were assigned a Hazard Rank Code 1, 2, 3 or 4. A Hazard

Rank Code of 1 requires some immediate response action. Materials assigned a Hazard Rank

Code 4 do not pose a significant risk and do not require immediate response. The Executive

Summary Table outlines the recommended response actions that accompany Hazard Rank

Codes 1 through 3.

• Hazard Rank Code 1 Materials – These materials are damaged or significantly damaged ACBM with a high fiber release potential. These materials require immediate isolation, removal, repair, encapsulation and/or enclosure by an Arizona-licensed asbestos abatement contractor.

• Hazard Rank Code 2 Materials – These materials are damaged or significantly damaged ACBM with a low to moderate fiber release potential. These materials require removal, repair, encapsulation and/or enclosure by an Arizona-licensed asbestos abatement contractor.

• Hazard Rank Code 3 Materials – These materials are intact (in good condition) but present a high potential for disturbance. These materials may be removed, enclosed, and/or labeled, or they may be managed in place in the Operations and Maintenance Plan. IHI recommends that any intentional contact with ACBM be performed by an Arizona-licensed asbestos abatement contractor.

• Hazard Rank Code 4 Materials – These materials are intact (in good condition), present a low to moderate potential for disturbance and can be managed under the Operations and Maintenance Plan. They should be inspected periodically, however, to ensure they do not deteriorate.

3.4 Special Considerations

Materials with peculiar configurations and materials assumed to be asbestos-containing are identified in Table 3 (Appendix A).

3.4.1 Roofing Materials

Roofing materials were sampled in accordance with the Summary of Work and when it was clear that such sampling would not compromise the integrity of the roof.

The roofing materials on this building were included in this survey.

Bob Stump VAMC – Building 42 4 IHI Environmental

3.5 Inaccessible Areas

Some building structures may have been constructed after the application of ACBM and, therefore, may have obscured these materials from visual examination during this inspection.

Typical scenarios include thermal system insulation inside hardened mechanical chases, floor tile and mastic under walls, and sprayed-on texturing and/or fireproofing behind structural supports or architectural features. Suspect materials that were hidden or inaccessible may not have been characterized by this inspection. Therefore, any material not identified in this report as having been tested should be treated as suspect ACBM until it has been properly sampled.

4.0 APPLICABLE RULES AND REGULATIONS

In Arizona, EPA asbestos regulations are administered by the State of Arizona, Department of Environmental Quality, Air Quality Compliance Section (Asbestos NESHAP Program).

The Arizona Division of Occupational Safety and Health (ADOSH) has adopted the Federal

OSHA regulations.

4.1 Renovation and Demolition (EPA and OSHA)

NESHAP regulations require the removal of friable ACBM and non-friable ACBM that could become friable during demolition activities. Despite EPA rules exempting building materials containing 1% or less asbestos from stringent regulation, OSHA regulations outline specific precautionary work practices when employees work with materials containing any detectable amount of asbestos. Compliance by building owners with the OSHA asbestos regulations may result in response actions not required by the EPA for certain unregulated materials.

5.0 COST ESTIMATES FOR REMOVAL

The estimated cost to remove all of the ACBM from this building is $0. This estimate assumes that all of the materials will be removed during a single planned abatement project.

A list of the costs associated with each of the various homogeneous materials identified during this survey is included in Table 6 (Appendix A).

These cost estimates are provided for the use of long-term budgeting and planning only and do not have a level of accuracy sufficient to be used as construction design cost estimates.

Bob Stump VAMC – Building 42 5 IHI Environmental

Bob Stump VAMC – Building 42 6 IHI Environmental

The actual cost of asbestos removal is highly dependent on the size of the project or quantity of materials removed in a single abatement project. The unit costs associated with small-scale emergency projects will typically be significantly greater than the costs associated with larger, planned projects. The removal costs shown in the Material Removal Unit Cost table attempt to capture the range of costs associated with a variety of removal scenarios.

Material replacement and consultant abatement management costs are not included in these estimates.

6.0 PROJECT LIMITATIONS

This project was performed using, as a minimum, practices consistent with standards acceptable within the industry at this time, and a level of diligence typically exercised by

EH&S consultants performing similar services.

The procedures used attempt to establish a balance between the competing goals of limiting investigative and reporting costs and time, and reducing the uncertainty about unknown conditions. Therefore, because the findings of this report were derived from the scope, costs, time and other limitations, the conclusions should not be construed as a guarantee that all universal, toxic and/or hazardous wastes have been identified and fully evaluated.

Furthermore, IHI assumes no responsibility for omissions or errors resulting from inaccurate information, or data, provided by sources outside of IHI or from omissions or errors in public records.

It is emphasized that the final decision on how much risk to accept always remains with the client since IHI is not in a position to fully understand all of the client's needs. Clients with a greater aversion to risk may want to take additional actions while others, with less aversion to risk, may want to take no further action.

Appendix A

Summary Tables

Summary of Asbestos-containing Building Materials

Building No.: 42 (Warehouse)

Table 1

No Asbestos-Containing Building Materials (ACBMs) were identified in

Warehouse.

3/2/2012 Page 1 of 1Printed: Northern Arizona Veterans Affairs Health Care System

Summary of Non-Asbestos-containing Building Materials

Table 2

QuantityHomogeneous Material Description ACM Designation(2)(1)

3850 sq. ft.Asphalt shingle core, slate pattern None DetectedM01.01

3840 sq. ft.Stucco None DetectedM14.01

3840 sq. ft.Brick mortar None DetectedM16.01

1280 sq. ft.Concrete (foundation) None DetectedM16.02

1144 ln. ft.Window glazing None DetectedM16.03

308 sq. ft.Concrete (Exterior stairs and loading dock) None DetectedM16.04

(1) Material Codes: T - Thermal Systems Insulation; S - Surfacing Material (Sprayed or Troweled-on); M - Miscellaneous Material; F - Miscellaneous Material (Floor Covering)

(2) ACM Designation: None Detected - No asbestos was detected and therefore the material is not regulated under EPA, State air quality regulations, or OSHA (for asbestos concerns).

Room-by-Room Inspection and Assessment Findings

Table 3

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

101 (Warehouse)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 3840 sq. ft.

ND None Detected PLMM16.01 (Brick mortar) None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 3840 sq. ft.

ND None Detected PLMM16.01 (Brick mortar) None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

EX (Exterior)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 1144 ln. ft.

ND None Detected PLMM16.03 (Window glazing) None

Detected

Hazard Assessment Comments: On exterior of windows

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 3840 sq. ft.

ND None Detected PLMM14.01 (Stucco) None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

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Table 3

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

EX (Exterior)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 3840 sq. ft.

ND None Detected PLMM14.01 (Stucco) None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 3840 sq. ft.

ND None Detected PLMM14.01 (Stucco) None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 1280 sq. ft.

ND None Detected PLMM16.02 (Concrete

(foundation))

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 1280 sq. ft.

ND None Detected PLMM16.02 (Concrete

(foundation))

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 1144 ln. ft.

ND None Detected PLMM16.03 (Window glazing) None

Detected

Hazard Assessment Comments: On exterior of windows

Sample Comments:

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Table 3

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

EX (Exterior)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 1144 ln. ft.

ND None Detected PLMM16.03 (Window glazing) None

Detected

Hazard Assessment Comments: On exterior of windows

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 1280 sq. ft.

ND None Detected PLMM16.02 (Concrete

(foundation))

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

LD1 (East Loading Dock)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 90 sq. ft.

M16.04 (Concrete

(Exterior stairs and loading dock))

None

Detected

Hazard Assessment Comments: Loading dock on east side of building.

Sample Comments:

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Table 3

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

R (Roof)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 3850 sq. ft.

ND None Detected PLMM01.01 (Asphalt shingle core, slate pattern)

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 3850 sq. ft.

ND None Detected PLM

ND None Detected TEM

M01.01 (Asphalt shingle core, slate pattern)

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Quantity: 3850 sq. ft.

ND None Detected PLMM01.01 (Asphalt shingle core, slate pattern)

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

Stair 1 (Stair 1)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 128 sq. ft.

M16.04 (Concrete

(Exterior stairs and loading dock))

None

Detected

Hazard Assessment Comments:

Sample Comments:

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Table 3

Hazard

RankAccessibility

Disturbance

Potential ACM? Homogeneous Material

Friability

Category

Analytical

Result

Type of

Asbestos

Analytical

Method Condition

Clean/Repair

Needed?

Labeling

Needed?

Stair 2 (Stair 2)Room #:

(1) (2) (3) (4) (5) (6) (7) (8) (9) (10)

Quantity: 90 sq. ft.

M16.04 (Concrete

(Exterior stairs and loading dock))

None

Detected

Hazard Assessment Comments:

Sample Comments:

N/A N/A N/A N/AN/A N/A N/A

(1) Material Codes: T - Thermal Systems Insulation; S - Surfacing Material (Sprayed or Troweled-on); M - Miscellaneous Material; F - Miscellaneous Material (Floor Covering)

(2) Analytical Result: ND - No asbestos detected

(3) Analytical Method: PLM - Polarized Light Microscopy; Point Count - NESHAP point counting using Polarized Light Microscopy; TEM - Transmission Electron Microscopy

(4) ACM Designation: >1% Asbestos - Asbestos-containing materials that contain greater than 1% asbestos and are regulated under EPA and State air quality regulations, and have requirements for worker protection under OSHA. <=1% Asbestos - Asbestos-containing materials that contain less than or equal to 1% asbestos and are NOT regulated under EPA or State air quality regulations, but have requirements for worker protection under OSHA.

(5) Friability Category: Friable - “Friable ACM” is any material containing more than 1% asbestos (as determined by PLM) that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure and also includes non-friable ACM that may become friable during building demolition. Category 1 Non-Friable - “Category I non-friable ACM” are asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile (VAT)), asphalt roofing products, packings, and gaskets. Category 2 Non-Friable - “Category II non-friable ACM” encompasses all other non-friable ACM.

(6) Condition: Good - Undamaged, no visible damage, or extremely minor damage or surface maring. Damaged - Material has visible damage evenly distributed over less than 10% of its surface, or localized over less than 25% of its surface. Significantly Damaged - Material has visible damage that is evenly distributed over 10% or more of its surface, or localized over 25% or more of its surface.

(7) Accessibility: Inaccessible - Materials in locations that people have no reason to enter and that cannot be accessed without specific measures, such as demolition. Rarely - Rarely accessed identifies a material in a location that is infrequently accessed for a specific need. Periodically - Periodically accessed identifies a material in an area that is not occupied full time, but is accessed on a routine basis. Continuously - Continuously accessed identifies materials in an occupied location and within reach of the occupants, or subject to direct disturbance.

(8) Disturbance Potential: Low - Materials that are inaccessible or rarely accessed. Moderate - Materials that are periodically accessed, but which do not require direct handling. High - Materials in periodically or continuously accessed locations with a high probability of being disturbed.

(9) Labeling Needed: Yes - Affix a placard or signage identifying the material as ACM.

(10) Hazard Rank: 1 - Damaged or significantly damaged ACBM with a high disturbance potential. These materials require immediate isolation, removal, repair, encapsulation and/or enclosure.

2 - Damaged or significantly damaged ACBM with a low to moderate disturbance potential. These materials require removal, repair, encapsulation and/or enclosure. 3 - Intact (good condition)

ACMB with a high disturbance potential. These materials require removal or enclosure, or increased O and M Plan inspection frequency. 4 - Intact (good condition) ACMB with a low to moderate disturbance potential. These materials require maintenance under the O and M Plan.

N/A - Not applicable. Asbestos was not detected in the Homogeneous Material.

3/2/2012 Page 5 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Bulk Sample Log sorted by Sample Number

Table 4

Ht.Floor # S E W

Reference

Corner NRoom # Homogeneous Material

Analytical

Result

Type of

Asbestos

Analytical

MethodSample #

Distance (feet) Composite

Sample?

Sample Identification Sample Location Sample Analytical Results

(1) (2) (3) (4)

G

Brick mortar

ND None Detected PLM42-001101 SE 8 No0

Ground

Floor

M16.01 3

Sample Location Comments:

G

Brick mortar

ND None Detected PLM42-002101 SE 64 No0

Ground

Floor

M16.01 3

Sample Location Comments:

G

Brick mortar

ND None Detected PLM42-003101A SW 2 No0

Ground

Floor

M16.01 3

Sample Location Comments:

G

Stucco

ND None Detected PLM42-004EX SE 0 No1

Ground

Floor

M14.01 4

Sample Location Comments:

G

Stucco

ND None Detected PLM42-005EX NE No22 0

Ground

Floor

M14.01 5

Sample Location Comments:

G

Stucco

ND None Detected PLM42-006EX SW 36 No0

Ground

Floor

M14.01 5

Sample Location Comments:

3/2/2012 Page 1 of 4Printed: Northern Arizona Veterans Affairs Health Care System

Table 4

Ht.Floor # S E W

Reference

Corner NRoom # Homogeneous Material

Analytical

Result

Type of

Asbestos

Analytical

MethodSample #

Distance (feet) Composite

Sample?

Sample Identification Sample Location Sample Analytical Results

(1) (2) (3) (4)

G

Concrete (foundation)

ND None Detected PLM42-007EX SE 1 No0

Ground

Floor

M16.02 2

Sample Location Comments:

G

Concrete (foundation)

ND None Detected PLM42-008EX NE No0 0

Ground

Floor

M16.02 2

Sample Location Comments:

G

Concrete (foundation)

ND None Detected PLM42-009EX NW No65 0

Ground

Floor

M16.02 3

Sample Location Comments:

G

Window glazing

ND None Detected PLM42-010EX SE 0 No3

Ground

Floor

M16.03 4

Sample Location Comments:

G

Window glazing

ND None Detected PLM42-011EX NE No63 0

Ground

Floor

M16.03 6

Sample Location Comments:

G

Window glazing

ND None Detected PLM42-012EX SW 15 No0

Ground

Floor

M16.03 5

3/2/2012 Page 2 of 4Printed: Northern Arizona Veterans Affairs Health Care System

Table 4

Ht.Floor # S E W

Reference

Corner NRoom # Homogeneous Material

Analytical

Result

Type of

Asbestos

Analytical

MethodSample #

Distance (feet) Composite

Sample?

Sample Identification Sample Location Sample Analytical Results

(1) (2) (3) (4)

G

Concrete (Exterior stairs and loading dock)

ND None Detected PLM42-013EX SE 66 No8

Ground

Floor

M16.04 0

Sample Location Comments:

Loading dock 1

G

Concrete (Exterior stairs and loading dock)

ND None Detected PLM42-014EX SW 24 No0

Ground

Floor

M16.04 0

Sample Location Comments:

Stair 2

G

Concrete (Exterior stairs and loading dock)

ND None Detected PLM42-015EX SW 63 No0

Ground

Floor

M16.04 0

Sample Location Comments:

Stair 1

R

Asphalt shingle core, slate pattern

ND None Detected PLM

ND None Detected TEM

42-016R NW No1 1

Roof

M01.01 0

Sample Location Comments:

R

Asphalt shingle core, slate pattern

ND None Detected PLM42-017R NW No36 1

Roof

M01.01 0

Sample Location Comments:

R

Asphalt shingle core, slate pattern

ND None Detected PLM42-018R SW 1 No1

Roof

M01.01 0

3/2/2012 Page 3 of 4Printed: Northern Arizona Veterans Affairs Health Care System

Table 4

(1) Material Codes: T - Thermal Systems Insulation; S - Surfacing Material (Sprayed or Troweled-on); M - Miscellaneous Material; F - Miscellaneous Material (Floor Covering)

(2) Analytical Result: ND - No asbestos detected

(3) Analytical Method: PLM - Polarized Light Microscopy; Point Count - NESHAP point counting using Polarized Light Microscopy; TEM - Transmission Electron Microscopy

(4) Composite samples contain greater than one suspect material.

3/2/2012 Page 4 of 4Printed: Northern Arizona Veterans Affairs Health Care System

Homogeneous Materials with Room-by-Room Inspection and Assessment Findings

Table 5

Building 42 Entire Building Functional Space:

Homogeneous Material : M01.01 (Asphalt shingle core, slate pattern)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

3850 sq. ft. N/AND None Detected PLMR N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

3850 sq. ft. N/AND None Detected PLM

ND None Detected TEM

R N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

3850 sq. ft. N/AND None Detected PLMR N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

Homogeneous Material : M14.01 (Stucco)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

3840 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

3/2/2012 Page 1 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Table 5

Building 42 Entire Building Functional Space:

Homogeneous Material : M14.01 (Stucco)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

3840 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

3840 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

Homogeneous Material : M16.01 (Brick mortar)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

3840 sq. ft. N/AND None Detected PLM101 N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

3840 sq. ft. N/AND None Detected PLM101 N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

3/2/2012 Page 2 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Table 5

Building 42 Entire Building Functional Space:

Homogeneous Material : M16.02 (Concrete (foundation))

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

1280 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

1280 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

1280 sq. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

Homogeneous Material : M16.03 (Window glazing)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

1144 ln. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments: On exterior of windows

3/2/2012 Page 3 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Table 5

Building 42 Entire Building Functional Space:

Homogeneous Material : M16.03 (Window glazing)

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

1144 ln. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments: On exterior of windows

Sample Comments:

1144 ln. ft. N/AND None Detected PLMEX N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments: On exterior of windows

Sample Comments:

Homogeneous Material : M16.04 (Concrete (Exterior stairs and loading dock))

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

90 sq. ft. N/ALD1 N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments: Loading dock on east side of building.

Sample Comments:

128 sq. ft. N/AStair 1 N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

3/2/2012 Page 4 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Table 5

Building 42 Entire Building Functional Space:

Homogeneous Material : M16.04 (Concrete (Exterior stairs and loading dock))

Room # Quantity Units

Analytical

Result

Type of

Asbestos

Analytical

Method

(1)

(2) (3) Hazard

RankAccessibility

Disturbance

Potential ACM?

Friability

Category Condition

Clean/Repair

Needed?

Labeling

Needed? (4) (5) (6) (7) (8) (9) (10)

90 sq. ft. N/AStair 2 N/A N/A N/ANone

Detected

N/A N/A N/A

Hazard Assessment Comments:

Sample Comments:

(1) Material Codes: T - Thermal Systems Insulation; S - Surfacing Material (Sprayed or Troweled-on); M - Miscellaneous Material; F - Miscellaneous Material (Floor Covering)

(2) Analytical Result: ND - No asbestos detected

(3) Analytical Method: PLM - Polarized Light Microscopy; Point Count - NESHAP point counting using Polarized Light Microscopy; TEM - Transmission Electron Microscopy

(4) ACM Designation: >1% Asbestos - Asbestos-containing materials that contain greater than 1% asbestos and are regulated under EPA and State air quality regulations, and have requirements for worker protection under OSHA. <=1% Asbestos - Asbestos-containing materials that contain less than or equal to 1% asbestos and are NOT regulated under EPA or State air quality regulations, but have requirements for worker protection under OSHA.

(5) Friability Category: Friable - “Friable ACM” is any material containing more than 1% asbestos (as determined by PLM) that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure and also includes non-friable ACM that may become friable during building demolition. Category 1 Non-Friable - “Category I non-friable ACM” are asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile (VAT)), asphalt roofing products, packings, and gaskets. Category 2 Non-Friable - “Category II non-friable ACM” encompasses all other non-friable ACM.

(6) Condition: Good - Undamaged, no visible damage, or extremely minor damage or surface maring. Damaged - Material has visible damage evenly distributed over less than 10% of its surface, or localized over less than 25% of its surface. Significantly Damaged - Material has visible damage that is evenly distributed over 10% or more of its surface, or localized over 25% or more of its surface.

(7) Accessibility: Inaccessible - Materials in locations that people have no reason to enter and that cannot be accessed without specific measures, such as demolition. Rarely - Rarely accessed identifies a material in a location that is infrequently accessed for a specific need. Periodically - Periodically accessed identifies a material in an area that is not occupied full time, but is accessed on a routine basis. Continuously - Continuously accessed identifies materials in an occupied location and within reach of the occupants, or subject to direct disturbance.

(8) Disturbance Potential: Low - Materials that are inaccessible or rarely accessed. Moderate - Materials that are periodically accessed, but which do not require direct handling. High - Materials in periodically or continuously accessed locations with a high probability of being disturbed.

(9) Labeling Needed: Yes - Affix a placard or signage identifying the material as ACM.

(10) Hazard Rank: 1 - Damaged or significantly damaged ACBM with a high disturbance potential. These materials require immediate isolation, removal, repair, encapsulation and/or enclosure.

2 - Damaged or significantly damaged ACBM with a low to moderate disturbance potential. These materials require removal, repair, encapsulation and/or enclosure. 3 - Intact (good condition)

ACMB with a high disturbance potential. These materials require removal or enclosure, or increased O and M Plan inspection frequency. 4 - Intact (good condition) ACMB with a low to moderate disturbance potential. These materials require maintenance under the O and M Plan.

N/A - Not applicable. Asbestos was not detected in the Homogeneous Material.

3/2/2012 Page 5 of 5Printed: Northern Arizona Veterans Affairs Health Care System

Table 6 Material Removal Unit Cost Estimates

Material Removal Cost Estimate Sheet Vinyl Only $2 -$20 per SF Sheet Vinyl & Adhesive $4 -$50 per SF Floor Tile Only $1 -$20 per SF Floor Tile & Mastic $2 -$40 per SF Floor Tile Mastic Only $1.75 -$35 per SF Ceramic Tile Grout &Adhesive $1.50 -25 per SF Roof Tar Sealant $25 per SF Layered Roofing Material $6 -$10 per SF Plaster Patch (Caulking) $40 per SF Transite Wall Panels $2 per SF Exterior Surfacing $10 -$60 per SF Interior textured Surfacing (wall) $4 -$40 per SF Interior Textured Surfacing (ceiling) $5 -$60 per SF Gypsum Wallboard System $2 - $30 per SF Ceiling Tile $2 -$40 per SF Window Caulking $3 -$40 per LF Fire Door Insulation $200 -$300 EA Light Fixture Electrical Wiring $15 -$150 EA Sink Undercoating (remove sink) $40 -$300 EA Cork Insulation with Black Tar Layer $5 -$40 per SF Duct Sealant $6 -$25 per SF Duct Insulation $12 -$100 per SF Duct Vibration Isolator $150 EA Laboratory Countertop $200 - $300 EA Pipe-Fitting Insulation $8 - $400 EA Pipe Saddle Insulation $8 - $400 EA Straight Pipe Insulation $6 - $30 per LF

*SF – square foot; LF – linear foot; EA – each

Cost Estimate Limitations

These cost estimates are provided for the use of long-term budgeting and planning only and do not have a level of accuracy sufficient to be used as construction design cost estimates.

The actual cost of asbestos removal is highly dependent on the size of the project or quantity of materials removed in a single abatement enclosure. The unit costs associated with small-scale emergency projects will typically be significantly greater than the costs associated with larger, planned projects. The removal costs shown in the Material Removal Unit Cost table attempt to capture the range of costs associated with a variety of removal scenarios.

Material replacement and consultant abatement management costs are not included in these estimates.

Appendix B

Building Description & Floor Plans

Building Information

Building Number: 42 Building Name: Warehouse

Address 1:

Address 2:

City / State / Zip:

Construction Date: 1903

Building Type / Use: Storage facility/warehouse

Building Renovations (Scopes and Dates):

Unknown

Building Area (sq ft): 3900

Structural System: Wood

Exterior Wall Construction:

Block

Exterior Finishes: Stucco

Floor Deck Construction:

Concrete

Floor Construction / Finishes:

No finish (Exposed)

Wall Construction / Finishes:

Block, plaster, gypsum board.

Ceiling Finishes: No finishes

Roof Construction: Asphalt shingle roofing.

Heating Plant: N/A

Heating Distribution

N/A

Cooling Plant: N/A

Cooling Distribution / AC:

N/A

Notes:

V

Pr oj ec ts

\V A

M C

\1 1P

-A

V

A M

C P re sc ot t A sb -L

B P

In sp ii\ D ra w in gs

\S R

_V A

As be st os

S ur ve y

C A

D \2

4\

P-

A

-B ld g

.d w g, F 1_

SL

M

L, /5 /2

1:

:2

PM

, m ik eb

Asbestos Sample Numbers and Locationsxxx

Explanation:

012014 006015009

005 011

002 001

016 017

No asbestos-containing materials identified

WAREHOUSE

101A

FIRE EQUIP

EXCESS / SCRAP / STORAGE

Stair 1 Stair 2

Main Level

Roof Level

LD1

Loading Dock 1

PROJECT No:

SHEET:

DRAWN BY:

REVIEWED BY:

A sb es to s Sa m pl e an d M at er ia l L oc at io ns

M ai n

Le ve l a nd

R oo f

DATE:

DATE:

DATE:

REVISED BY:

0 8' 16'

11P-A3138

1 SL

MBradley 2-17-12

D ep ar tm en t o f V et er an s Af fa irs

N or th er n Ar iz on a Ve te ra ns A ffa irs

H ea lth C ar e

S ys te m

(N

AV

AH

C

S) B ui ld in g

(W ar eh ou se

P re sc ot t, A riz on a

Appendix C

Laboratory Analytical Results

EMLab P&K

Approved by:

Technical Manager Brandon Iledan

Report for:

Mr. Rod Pawloski IHI Environmental, Phoenix 4527 N. 16th Street Suite 105 Phoenix, AZ 85016

Regarding: Project: 11P-A3138; NAVAHCS-Bldg 42

EML ID: 876572

EMLab P&K

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 items tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data can be provided when requested.

EMLab P&K ("the Company") 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.

Document Number: 200091 - Revision Number: 5

Dates of Analysis:

Asbestos-EPA Method 600/R-93/116: 01-19-2012

Service SOPs: Asbestos-EPA Method 600/R-93/116 (EPA-600/M4-82-020 (SOP 01264))

EMLab ID: 876572, Page 1 of 5EMLab P&K, LLC

9089 Clairemont Mesa Blvd, Suite 106, San Diego, CA 92123

(866) 465-6653 Fax (858) 569-5806 www.emlab.com Client: IHI Environmental, Phoenix C/O: Mr. Rod Pawloski Re: 11P-A3138; NAVAHCS-Bldg 42

Date of Sampling: 01-13-2012 Date of Receipt: 01-16-2012 Date of Report: 01-19-2012

ASBESTOS PLM REPORT: EPA-600/M4-82-020 & EPA METHOD 600/R-93-116

Total Samples Submitted: 15 Total Samples Analysed: 15

Total Samples with Layer Asbestos Content > 1%: 0

Location: 42-001 Lab ID-Version‡: 3890566-1

Sample Layers Asbestos Content Gray Rock ND

Sample Composite Homogeneity: Good

Location: 42-002 Lab ID-Version‡: 3890567-1

Sample Layers Asbestos Content Gray Rock ND

Sample Composite Homogeneity: Good

Location: 42-003 Lab ID-Version‡: 3890568-1

Sample Layers Asbestos Content Gray Rock ND

Sample Composite Homogeneity: Good

Location: 42-004 Lab ID-Version‡: 3890569-1

Sample Layers Asbestos Content Beige Compound with Paint ND