Att. 2 - Asbestos Roof Sampling Supplemental Report.pdf

June 3, 2025

Atriax, PLLC PO Box 1629 Hickory, NC 28603

Attn: Mr. Stephen Collar, Project Manager C: 828.979.2133 O: 828.315.9962 E: steve.collar@atriaxgroup.com

RE: Additional Asbestos Roof Sampling Supplemental Report Veteran Affairs Consolidated Outpatient Pharmacy 3675 East Britannia, Tucson, Arizona 85705 Terracon Project No. 63247164

Dear Mr. Collar:

Terracon Consultants, Inc. (Terracon), recently conducted additional asbestos roof sampling at the Veteran Affairs Consolidated Outpatient Pharmacy located at 3675 East Britannia, Tucson, Arizona. The sampling was conducted by Terracon personnel on May 19, 2025, and was limited to sampling the roof. This roof was not sampled in Terracon’s Limited Asbestos Survey, Lead Based Paint Screening and Update to a Previous Inspection Revision 1 (Terracon Project No. 63247164 dated April 22, 2025). This Additional Asbestos Roof Sampling report will supplement Terracon’s Limited Asbestos Survey, Lead Based Paint Screening and Update to a Previous Inspection Revision 1.

Executive Summary

Terracon’s sampling was conducted by Mr. Gabriel Baca, an Environmental Protection Agency (EPA)-certified Asbestos Hazard Emergency Response Act (AHERA) Building Inspector for asbestos. Three (3) asbestos bulk samples from one (1) Homogenous Areas (HA’s) were collected during this limited sampling.

The limited asbestos sampling was conducted using procedures similar to EPA AHERA regulations, 40 CFR 763. The asbestos bulk samples were submitted to Cates Laboratories (Cates) in Dallas, Texas. Cates is accredited by the National Institute for Science and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP) for bulk-asbestos sample analysis administered by NIST. A copy of Cates’ certification is attached to this report.

Additional Roof Sampling

Veteran Affairs Consolidated Outpatient Pharmacy ■ Tucson, AZ June 3, 2025 ■ Terracon Project No. 63247164

Asbestos

According to laboratory analysis, the samples collected and analyzed were non-detect for asbestos and as such, are not considered ACM.

Sample Assessment and Collection

The suspect ACM was designated into distinct homogeneous areas, which are defined as a single material, uniform in texture and appearance, installed at one time, and unlikely to consist of more than one type or formulation of material. During the limited survey, the suspect materials were physically touched to determine friability.

A sufficient number of samples were collected of the suspect materials, within the designated project area, to satisfy the Occupational Safety and Health Administration (OSHA) and National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements for the determination of asbestos content. The results for the limited survey are not meant to apply to the site as a whole and are limited to the project area only.

Findings and Recommendations

Asbestos

The suspect materials sampled, and the analytical results are listed in the following table:

Table 1: Veteran Affairs Consolidated Outpatient Pharmacy Additional Roof Sampling, May 19, 2025

Sample # Material Functional Space ACM Condition

01A 01B 01C

Roof Core Roof No Good

Notes:

1. ACM = Asbestos Containing Material

2. Good = Little to no visible deterioration or damage

According to laboratory analysis, the samples collected and analyzed were non-detect for asbestos, as such, are not considered ACM.

The Asbestos NESHAP program in Arizona is enforced by federal, state, and county Asbestos NESHAP Coordinators. For projects occurring in Pima County, the County has been delegated authority from the EPA to enforce the Asbestos NESHAP within its respective jurisdictional boundaries, excluding tribal lands.

June 3, 2025 ■ Terracon Project No. 63247164

If new suspect materials are discovered that may be disturbed during renovation, all work should immediately stop, and additional samples shall be collected.

Terracon appreciates the opportunity to provide environmental services to Gorman USA. If you have any questions regarding this report, please contact the undersigned at 480-897- 8200.

Sincerely, Terracon Consultants, Inc.

Gabriel Baca Matt Valenti Assistant Scientist Senior Associate Authorized Project Reviewer

Enclosures: Limitations/General Comments Sample Location Diagram and Photo Analytical Report and Chain of Custody Terracon Certifications Analytical Lab Certifications

June 3, 2025 ■ Terracon Project No. 63247164

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

Reasonable efforts to access suspect materials within known areas of restricted access (e.g., crawl spaces) 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 suspect materials which could not be safely reached with available ladders/man-lifts.

This Additional Limited Asbestos Sampling 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 sampling of the site. The information contained in this report is relevant to the date on which this sampling was performed and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by Atriax PLCC for specific application to their project as discussed. 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. 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.

EXHIBITProject Mngr:

Drawn By:

Checked By:

Approved By:

Project No.:

Scale:

File No.:

Date:

LEGEND:

APPROXIMATE SUSPECTED ASBESTOS SAMPLE LOCATION

SAMPLES CONTAINING ACM

SAMPLE LOCATION DIAGRAM

K.J G.B M.V M.V

63247164

05/27/2025

Veteran's Affairs Consolidated Mail Outpatient Pharmacy Limited Asbestos Survey

3675 E. Britannia Tuscon, AZ

01A, 01B, 01C

Baca, Gabe Arrow

Baca, Gabe Arrow

Johnson, Kyle Arrow

Johnson, Kyle Arrow

Johnson, Kyle Arrow

EXHIBITProject Mngr:

Drawn By:

Checked By:

Approved By:

Project No.:

Scale:

File No.:

Date:

LEGEND:

APPROXIMATE SUSPECTED ASBESTOS SAMPLE LOCATION

SAMPLES CONTAINING ACM

SAMPLE LOCATION DIAGRAM

K.J G.B M.V M.V

63247164

05/27/2025

Veteran's Affairs Consolidated Mail Outpatient Pharmacy Limited Asbestos Survey

3675 E. Britannia Tuscon, AZ

Baca, Gabe Text Box 01A

Baca, Gabe Text Box 01B

Baca, Gabe Text Box 01C

Baca, Gabe Arrow

Baca, Gabe Arrow

Baca, Gabe Arrow

Baca, Gabe Arrow

Baca, Gabe Arrow

PLM REPORT SUMMARY

Cates Laboratories NVLAP Lab No. 200569-0

1339 Motor Circle TDSHS License No. 30-0287

Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-40155

Project (Line 1): Britannia Roof Core Asbestos Survey Set No.: 58918

Project (Line 2): 3675 East Britannia Dr. Report Date: 5/28/2025

Project No: 63247164 Sample Date: 5/19/2025

Identification: Asbestos, Bulk Sample Analysis

Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 1 of 2

On 5/20/2025, three (3) bulk samples were submitted by Mr. Gabe Baca of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab

Sample No.

Client

Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing

Materials (RACM) – materials that are friable or may become friable – be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced except in full.

CL1376701

01A

Roof Core

None Detected - White Sealant

None Detected - Roofing Membrane

None Detected - Roofing Foam

None Detected - Roofing Insulation

CL1376702

01B

CL1376703

01C

PLM REPORT SUMMARY

Cates Laboratories NVLAP Lab No. 200569-0

Client: Terracon Lab Job No.: PLM-40155

Project (Line 1): Britannia Roof Core Asbestos Survey Set No.: 58918

Project (Line 2): 3675 East Britannia Dr. Report Date: 5/28/2025

Project No: 63247164 Sample Date: 5/19/2025

Identification: Asbestos, Bulk Sample Analysis

Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 2 of 2

On 5/20/2025, three (3) bulk samples were submitted by Mr. Gabe Baca of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein.

STATEMENT OF LABORATORY ACCREDITATION

The samples were analyzed in general accordance with the procedures outlined in the U.S. EPA Interim Method for the Determination of Asbestos in Bulk Insulation Samples as found in 40 CFR, Part 763, Subpart E, Appendix E (formerly Subpart F, Appendix A), or the current U.S. EPA method (EPA Method 600/R-93/116) for the analysis of asbestos in building materials, by polarized light microscopy. The results of each bulk sample relate only to the material tested and the results shall not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government.

Specific questions concerning bulk sample results shall be directed to the Laboratory Director.

Analyst:

John R. Cates

Laboratory Director: John R. Cates, P.G.

Approved Signatory:

TESTING

NVLAP LAB CODE 200569-0

Bulk Asbestos Analysis Sheet

Cates Laboratories EPA Method 600/R-93/116 NVLAP Lab No. 200569-0

Client: Terracon Lab Proj #: PLM-40155

Project (Line 1): Britannia Roof Core Asbestos Survey Set #: 58918

Project (Line 2): 3675 East Britannia Dr.

Project #: 63247164 Sample #: CL1376701

Field ID #: 01A Page 1 of 1

Sample Description: Roof Core

Comments: Analyst: John R. Cates Date Analyzed: 5/28/2025

Lab Job #: PLM-40155 Sample #: CL1376701 kkkx Layer 1 White Sealant Stereoscopic Examination 1 1376701 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Roofing Membrane Stereoscopic Examination 2 1376701 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 Black Asphaltic No 20 ND 55 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glass Fibers 20 straight none none 2 1 Aggregate/Tar Binders 80 Non-fibrous 2 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 3 Roofing Foam Stereoscopic Examination 3 1376701 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Blocky Yes ND ND 15 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Poly Foam 100 Closed cells 3 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 4 Roofing Insulation Stereoscopic Examination 4 1376701 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Tan Fibrous Yes 95 ND 25 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 95 ribbons high 4 1 Tar Binders 5 Non-fibrous 4 1

Prep/treatment: mechanical separation Asbestos Content: None Detected zzz

Project (Line 2): 3675 East Britannia Dr.

Project #: 63247164 Sample #: CL1376702

Field ID #: 01B Page 1 of 1

Sample Description: Roof Core

Comments: Analyst: John R. Cates Date Analyzed: 5/28/2025

Lab Job #: PLM-40155 Sample #: CL1376702 kx Layer 1 White Sealant Stereoscopic Examination 1 1376702 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Roofing Membrane Stereoscopic Examination 2 1376702 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 Black Asphaltic No 20 ND 55 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glass Fibers 20 straight none none 2 1 Aggregate/Tar Binders 80 Non-fibrous 2 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 3 Roofing Foam Stereoscopic Examination 3 1376702 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Blocky Yes ND ND 15 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Poly Foam 100 Closed cells 3 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 4 Roofing Insulation Stereoscopic Examination 4 1376702 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Tan Fibrous Yes 95 ND 25 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 95 ribbons high 4 1 Tar Binders 5 Non-fibrous 4 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Project (Line 2): 3675 East Britannia Dr.

Project #: 63247164 Sample #: CL1376703

Field ID #: 01C Page 1 of 1

Sample Description: Roof Core

Comments: Analyst: John R. Cates Date Analyzed: 5/28/2025

Lab Job #: PLM-40155 Sample #: CL1376703 kx Layer 1 White Sealant Stereoscopic Examination 1 1376703 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Roofing Membrane Stereoscopic Examination 2 1376703 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 Black Asphaltic No 20 ND 55 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glass Fibers 20 straight none none 2 1 Aggregate/Tar Binders 80 Non-fibrous 2 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 3 Roofing Foam Stereoscopic Examination 3 1376703 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Blocky Yes ND ND 15 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Poly Foam 100 Closed cells 3 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 4 Roofing Insulation Stereoscopic Examination 4 1376703 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Tan Fibrous Yes 95 ND 25 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 95 ribbons high 4 1 Tar Binders 5 Non-fibrous 4 1

Prep/treatment: mechanical separation Asbestos Content: None Detected