Att. 3 - Limited Asbestos and LBP Survey Update R1.pdf

Prepared by:

Terracon Consultants, Inc.

Tucson, Arizona

Prepared for:

Atriax, PLLC PO Box 1629 Hickory, NC 28603

Limited Asbestos Survey, Lead Based Paint Screening and Update to a Previous Inspection Revision 1

Sampling Location:

Veterans Affairs Consolidated Mail Outpatient Pharmacy

3675 East Britannia Drive, Tucson, AZ 85706

April 22, 2025 | Terracon Project No. 63247164

355 South Euclid Avenue, Suite 107

Tucson, AZ 85719

P (520) 770-1789 F (913) 599-0547

Terracon.com

April 22, 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: Limited Asbestos Survey, Lead Based Paint Screening and

Update to a Previous Inspection Revision 1 Veterans Affairs Consolidated Mail Outpatient Pharmacy

3675 E Britannia Dr, Tucson, AZ 85706 Terracon Project No. 63247164

Dear Mr. Collar:

As requested by Atriax PLLC, Terracon Consultants, Inc. (Terracon), recently conducted a limited asbestos-containing material (ACM) survey and update to previous inspections at the Veterans Affairs Consolidated Mail Outpatient Pharmacy located at 3675 East Britannia Drive in Tucson, Arizona (the site). The limited survey and update to a previous inspection was conducted by Terracon personnel on March 5, 2025 and was limited to suspect materials that may be impacted during the EHRM Infrastructure upgrades project at the site. Terracon made return visit to the site on April 15, 2025 to conduct a Lead Based Paint (LBP) screening of the site. The project involves renovations of the Veterans Affairs Consolidated Mail Outpatient Pharmacy building. The scope of work was requested by Mr. Stephen Collar, Project Manager, for Atriax, PLLC.

Based on Laboratory analysis, asbestos was not identified in the samples collected from the site. Asbestos containing mirror mastic was identified in the previous inspection report conducted by others, some of this material was removed during a water leak remediation, but some of it is still located on site. Additionally, materials associated with the roof and new ceramic tiles were assumed to be asbestos as we were directed by the building owner to not sample the roofing or ceramic tiles that were new. Painted surfaces were tested by X-ray fluorescence (XRF) to see if lead based paint (LBP) is present. LBP was not detected in the surfaces tested.

Limited ACM Survey, LBP Screening and Update to Previous Inspections R1

Veterans Affairs Consolidated Mail Outpatient Pharmacy ■ Tucson, Arizona April 22, 2025 ■ Terracon Project No. 63247164

Facilities | Environmental | Geotechnical | Materials

We appreciate the opportunity to be of service to you on this project. If there are any questions regarding this report or if we may be of further assistance, please do not hesitate to contact us.

Sincerely, Terracon Consultants, Inc.

Andrew DiBernardo Matt Valenti Assistant Scientist Senior Associate Authorized Project Reviewer

Andrew DiBernardo

355 South Euclid Avenue, Suite 107

Tucson, AZ 85719

P (520) 770-1789 F (913) 599-0547

Terracon.com

TABLE OF CONTENTS

1.0 Introduction

1.1 Project Objective

1.2 General Conditions and Limitations

1.3 Reliance

2.0 Building Description

3.0 Field Activities

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

4.0 Regulatory Overview

5.0 Findings and Recommendations

General Comments

APPENDICES

Appendix A Sampling Summary Tables Including Previous Survey and XRF Testing Results & Performance Characteristic Sheet

Appendix B Sample Location Diagram

Appendix C Laboratory Analytical Data

Appendix D Licenses and Certifications

Appendix E Previous Report by Others

Facilities | Environmental | Geotechnical | Materials 1

1.0 Introduction

Terracon conducted a limited asbestos survey, Lead Based Paint (LBP) screening and an update to previous inspection by others for the Veterans Affairs Consolidated Mail Outpatient Pharmacy (VACMOP) infrastructure project located at 3675 East Britania Drive in Tucson, Arizona. The limited asbestos survey, LBP screening and Update to Previous Inspections included materials that would be disturbed during the EHRM infrastructure upgrade project. Previous report by others can be found in the appendices. The limited asbestos survey and update was conducted on March 5 and April 15, 2025, by Mr. Matt Valenti and Mr. Kyle Johnson, both Environmental Protection Agency (EPA)-certified Asbestos Hazard Emergency Response Act (AHERA) building inspectors for asbestos and EPA certified Lead Inspectors and or Risk Assessors. This work was conducted in general accordance with Professional Service Order dated October 23, 2024.

The scope of the project included materials and painted and/or coated surfaces that may be disturbed during the EHRM infrastructure upgrade project. Homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in Environmental Protection Agency (EPA) regulation 40 CFR 763, AHERA. Samples were delivered to Cates Laboratory (Cates) in Dallas, Texas, a National Voluntary Laboratory Accreditation Program (NVLAP) - accredited laboratory for analysis by Polarized Light Microscopy (PLM).

1.1 Project Objective

We understand this limited asbestos survey and update to a previous inspection was requested due to the planned EHRM infrastructure upgrades project located at 3675 East Britannia Drive in Tucson, Pima County, Arizona. We understand the purpose of this survey was to identify and quantify ACM. 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 or demolition activities. The asbestos NESHAP requires that potentially regulated asbestos-containing materials be identified, classified, and quantified prior to planned disturbances or demolition activities.

Additionally, Terracon conducted an LBP XRF screening to determine if the painted surfaces contain lead based paint.

1.2 General Conditions and Limitations

The limited asbestos survey, XRF screening, and update was based on information provided to Terracon regarding building conditions. The level of effort and associated tasks performed for this service was limited to the scope of services outlined in Terracon’s Proposal. Terracon

Facilities | Environmental | Geotechnical | Materials 2 did not attempt to identify every potential exposure or hazard present in the surveyed structure.

1.3 Reliance

This report is prepared for the exclusive use and reliance of Atriax, PLLC. Use or reliance by any other party is prohibited without the written authorization of Atriax, PLLC and Terracon.

2.0 Building Description

The building is single-story slab on grade structure. The warehouse area consists of concrete flooring and drywall. The offices contained various floor tiles and drywall systems throughout the office space and bathrooms. Acoustical ceiling tiles were throughout the building office space.

3.0 Field Activities

The asbestos survey, LBP XRF screening, and update to previous inspections was conducted by Matt Valenti and Kyle Johnson, both AHERA-accredited asbestos Building Inspectors. Mr.

Johnson and Mr. Valenti are also an EPA certified Lead Based Paint Inspector or Risk Assessor. Copies of their certifications are included in Appendix D. The limited asbestos survey was conducted in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, AHERA. A summary of sampling activities is provided below.

3.1 Visual Assessment

Asbestos

Our sampling activities began with a visual assessment of the proposed work areas to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout in terms of color, texture, and date of application.

The assessment was for only those materials that may be disturbed during the infrastructure renovation project.

Building materials identified as glass, wood, metal, or rubber were not considered suspect ACM, as per EPA regulation.

Lead Paint Screening by XRF

Terracon visually inspected the painted surfaces to identify color/substrate combinations to be tested by XRF field analysis.

Facilities | Environmental | Geotechnical | Materials 3

3.2 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 that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

Lead Paint Screening by XRF

A physical assessment was not performed on painted surfaces.

3.3 Sample Collection

Asbestos

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with EPA AHERA sampling protocols. Random samples of suspect materials were collected in each homogeneous area. Terracon personnel collected bulk samples 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.

Eighteen (18) bulk samples were collected from six (6) homogeneous areas (HAs) of suspect ACM from the building surveyed and five materials were assumed to be asbestos containing do to the owner not wanting the materials sampled. A summary table of suspect ACM samples collected and/or assumed during the limited survey is listed in Appendix A.

Lead Paint Screening by XRF

The U.S. Department of Housing and Urban Development (HUD) lead-based paint (LBP) style limited inspection was conducted by an Environmental Protection Agency (EPA) certified LBP inspectors in a manner similar to the 1997 revision of HUD Guidelines, Chapter 7: Lead- Based Paint Inspection with a portable X-ray fluorescence (XRF), SciAps X-550 Pb HUD/EPA Lead Paint Analyzer – Rh, unit on the painted surfaces of interior and exterior building components present. The X-550 Pb utilizes miniaturized, rugged Rh tube (40kv, 100uA, 4W) and Silicon Drift Detector for measurement of lead-based paint in units of mg/cm2. The X-550 Pb is a handheld XRF accepted by HUD and EPA for testing residential, daycare, schools, and other such properties via a published Performance Characteristics Sheet (PCS). It provides analysis of lead (Pb) loadings for both surface and deeply covered lead in paint.

Calibrations checks for the XRF unit are performed before the start of the day and additionally at 4-hour intervals or whenever the unit is turned off/on during the inspection. A final calibration check is performed at the end of the day.

Terracon measured eighty-two(82) individual painted surfaces throughout the renovation work areas in the limited LBP survey.

Facilities | Environmental | Geotechnical | Materials 4

3.4 Sample Analysis

Asbestos

Bulk samples were submitted under chain of custody to Cates Laboratories (Cates) in Dallas, Texas for analysis by polarized light microscopy with dispersion staining techniques per USEPA methodology 600/R-93/116. The percentage of asbestos where applicable was determined by microscopic visual estimation. Cates is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) Accreditation No. 200569-0. A copy of Cates certification is attached to this report.

4.0 Regulatory Overview

Asbestos

The Asbestos NESHAP program in Arizona is enforced by federal, state, and county Asbestos NESHAP Coordinators.

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. All friable ACM is considered regulated asbestos containing material (RACM).

The asbestos NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II non-friable ACM that has become friable, will be or has been subjected to sanding, grinding, cutting, or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

For all demolitions (even when no asbestos is present), the Asbestos NESHAP agency overseeing the project site must be provided with a written NESHAP notification at least 10 working days prior to the commencement of asbestos abatement activities related to the demolition. Some counties have fees for their notification process. Some cities may have separate permit fees as well. RACM must be removed by a licensed asbestos abatement contractor prior to renovation or demolition activities which will disturb the materials.

Facilities | Environmental | Geotechnical | Materials 5

The United States Occupational Safety and Health Administration (USOSHA) asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos.

The USOSHA standard requires that employee exposure to airborne asbestos must not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time weighted average (TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30-minute time period known as an excursion limit (EL). The TWA and EL are known as USOSHA’s asbestos permissible exposure limits (PELs). The USOSHA 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.

Lead

The Resource Conservation and Recovery Act (RCRA) gave the EPA authority to regulate the waste status of demolition or renovation debris, including Lead-Containing materials.

Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-Containing wastes are considered hazardous waste under RCRA if results from samples analyzed after TCLP preparation exceed five milligrams per liter (mg/L).

Detectable lead quantities may constitute a lead dust hazard during renovation and demolition activities. Personnel performing renovation and demolition activities that may disturb painted components and building surfaces with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure. OSHA defines lead paint as a paint, which contains lead, regardless of the concentration. Currently, any proposed renovation or demolition is subject to the OSHA regulations (29 CFR 1926.62 – Lead Exposure in Construction). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard. Occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to the OSHA “Interim” Lead Exposure in Construction standard.

Construction work covered by 29 CFR 1926.62 includes any repair or renovation activities or other activities that disturb in-place lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m³) averaged over an eight-hour period without adequate protection. The OSHA Standard also establishes an action level of 30 g/m³ which, if exceeded, triggers the requirement for medical monitoring.

The above overview is not intended to be inclusive of all potentially pertinent regulatory information. The relevant EPA and OSHA standards should be consulted prior to undertaking

Facilities | Environmental | Geotechnical | Materials 6 activities involving the demolition, renovation, or maintenance of surfaces coated with lead paints.

5.0 Findings and Recommendations

Asbestos

The summary table of the suspect materials sampled at the site, and their corresponding results, are presented in Appendix A. A sample location diagram is presented in Appendix B, Copies of the laboratory analytical reports are included in Appendix C.

The tables below and on the following page list the asbestos-containing materials identified by laboratory analysis and or assumed to contain asbestos:

Asbestos Containing Materials – Previous Report By Others

August 16, 2023

Asbestos was not identified in any other materials sampled in this survey or in materials verified in previous surveys.

Assumed Asbestos Containing Materials March 5, 2025

Sample No. Description Material Location

Quantity

NESHAP

Category

Lab Results

16, 17, 18 Mirror Mastic, Black

Room 155 20 Sq.

Ft.

Category II Non-Friable

8% Chrysotile

Note: S.F. = Square Feet

Homogeneous Area

Sample No. Description Material Location

Lab Results

07 07A, 07B, 07C Asphaltic Rolled Roofing, White

Roof ASSUMED

08 08A, 08B, 08C Ceramic Tile and

Grout, Tan, 16”x16”

Room 153 ASSUMED

09 09A, 09B, 09C Ceramic Tile and

Grout, Tan, 12”x24”

Rooms 155 and

ASSUMED

10 10A, 10B, 10C Ceramic Tile and Grout, Off-White, 3”x6”

Rooms 155 and

ASSUMED

Facilities | Environmental | Geotechnical | Materials 7

The above materials were assumed to be asbestos containing because the building owner did not want to damage them. They also indicated that they would not be disturbed during the EHRM project.

Lead Paint Screening by XRF

The U.S. HUD guidelines define LBP as paint or other surface coatings that contain lead equal to or exceeding 1.0 milligram per square centimeter (mg/cm2) of surface area, 0.5 percent by weight or 5,000 parts per million (ppm). Lead-containing paint with a lead concentration above the laboratory detection limit, but below the HUD LBP threshold limit is regulated by OSHA. LBP was not detected by XRF field analysis.

A summary of painted components field tested, and their corresponding results are presented in Appendix A.

Homogeneous Area

Sample No. Description Material Location

Lab Results

11 11A, 11B, 11C Ceramic Tile and

Grout, Blue/Green, 3”x6”

Rooms 155 and

Facilities | Environmental | Geotechnical | Materials 8

General Comments

This limited asbestos survey, LBP screening and update to previous asbestos surveys were 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 limited sampling activities at the site. The information contained in this report is relevant to the date on which this limited 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 the client 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.

APPENDIX A

SAMPLING SUMMARY TABLES

Veterans Affairs Consolidated Mail Outpatient Pharmacy 3675 East Britannia Drive

Tucson, Arizona Terracon Project No. 63247164

Homogeneous Area

Sample No. Description Material Location

Lab Results

01 01A, 01B, 01C Floor Tile and

Mastic, Off-White, 12”x12”

Room 130 Non-Detect

02 02A, 02B, 02C Raised Panel

Flooring, White/Black, 2’x2’

Room 122 Non-Detect

03 03A, 03B, 03C Concrete Slab, Grey Throughout Non-Detect

04 04A, 04B, 04C Fiberglass Pipe Insulation End

Cap, White Room 153 Non-Detect

05 05A, 05B, 05C Pinch Seam

Sealant, Grey Room 152-157 Non-Detect

06 06A, 06B, 06C HVAC Mastic, White/Grey

Exterior Square Ducts North Side of Bldg.

Non-Detect

07 07A, 07B, 07C Asphaltic Rolled Roofing, White

Roof ASSUMED

08 08A, 08B, 08C Ceramic Tile and

Grout, Tan, 16”x16”

Room 153 ASSUMED

09 09A, 09B, 09C Ceramic Tile and

Grout, Tan, 12”x24”

Rooms 155 and

ASSUMED

10 10A, 10B, 10C Ceramic Tile and Grout, Off-White, 3”x6”

Rooms 155 and

ASSUMED

11 11A, 11B, 11C Ceramic Tile and

Grout, Blue/Green, 3”x6”

Rooms 155 and

SAMPLING SUMMARY

Previous Report by Others

August 16, 2023

Sample # Material Functional

Space ACM Condition

1 Ceiling Tile Room 157 No Good

2 Ceiling Tile Room 157 No Good

3 Flex Duct Insulation Room 157 No Good

4 Flex Duct Insulation Room 157 No Good

5 Texture Drywall Room 157-A No Good

6 Texture Drywall Room 157-A No Good

6” Ceramic Cove Base, Adhesive Room 157-A No Good

6” Ceramic Cove Base, Adhesive Room 157-A No Good

16x16 Tan Floor Tile

Thinset Room 157-A No Good

16x16 Tan Floor Tile

Thinset Room 157-A No Good

16x16 Tan Floor Tile

Thinset Room 157-A No Good

12 2x2 Wall Tile Adhesive Room 155 No Good

13 2x2 Wall Tile Adhesive Room 155 No Good

14 12x12 Floor Tile Thinset Room 155 No Good

15 12x12 Floor Tile Thinset Room 155 No Good

16 Mirror Mastic Room 155 8%

Chrysotile Good

17 Mirror Mastic Room 155 8%

Chrysotile Good

Sample # Material Functional

Space ACM Condition

18 Mirror Mastic Room 155 7%

Chrysotile Good

19 Sink Caulking Room 155 No Good

20 Sink Caulking Room 155 No Good

21 Countertop Caulking Room 157 No Good

22 Countertop Caulking Room 157 No Good

Countertop Laminate

Adhesive Room 157 No Good

Countertop Laminate

Adhesive Room 157 No Good

Countertop Laminate

Adhesive Room 157 No Good

26 Texture Drywall Room 157 No Good

27 Window Frame Caulking Room 157 No Good

28 Window Frame Caulking Room 157 No Good

29 Sink Coating Room 157 No Good

30 Sink Coating Room 157 No Good

2x2 Blue Carpet Square

Adhesive Room 102 No Good

2x2 Blue Carpet Square

Adhesive Room 102 No Good

6” Brown Cove Base, Adhesive Room 102 No Good

6” Brown Cove Base, Adhesive Room 102 No Good

35 Beige Wallpaper Room 102 No Good

36 Beige Wallpaper Room 102 No Good

Space ACM Condition

37 12x12 Floor Tile Thinset Room 152 No Good

38 12x12 Floor Tile Thinset Room 152 No Good

39 Texture Drywall Room 152 No Good

40 Wall Insulation Room 110 No Good

41 Wall Insulation Room 110 No Good

42 2x2 Ceiling Tile Room 110 No Good

6” Brown Cove Base

Adhesive Room 110 No Good

6” Brown Cove Base

Adhesive Room 110 No Good

2x2 Blue Carpet Square

Adhesive Room 110 No Good

2x2 Blue Carpet Square

Adhesive Room 110 No Good

47 Window Frame Caulking Room 110 No Good

48 Window Frame Caulking Room 110 No Good

Countertop Laminate

Adhesive Room 148 No Good

Countertop Laminate

Adhesive Room 148 No Good

51 Texture Drywall Room 148 No Good

52 Texture Drywall Room 148 No Good

53 Sink Coating Room 148 No Good

54 Sink Coating Room 148 No Good

55 Construction Adhesive Room 127 No Good

Space ACM Condition

56 Construction Adhesive Room 127 No Good

57 Construction Adhesive Room 127 No Good

58 Door Frame Caulking Room 127 No Good

59 Door Frame Caulking Room 127 No Good

60 Door Frame Caulking Room 127 No Good

6” Beige Cove Base

Adhesive Room 130 No Good

62 6” Beige Cove Base Mastic Room 130 No Good

6” Beige Cove Base

Adhesive Room 130 No Good

64 Texture Drywall Room 130 No Good

65 Texture Drywall Room 130 No Good

66 Texture Drywall Room 130 No Good

12x12 White Floor Tile

Mastic Room 130 No Good

12x12 White Floor Tile

Mastic None Detected <1% Chrysotile

No Good

12x12 White Floor Tile

Adhesive Room 130 No Good

70 2x2 Ceiling Tile Room 130 No Good

71 2x2 Ceiling Tile Room 130 No Good

72 Duct Sealant Room 201 No Good

73 Duct Sealant Room 201 No Good

74 Duct Sealant Room 201 No Good

Space ACM Condition

75 Floor Caulking Room 201 No Good

76 Floor Caulking Room 201 No Good

77 Floor Coating Room 201 No Good

78 Floor Coating Room 201 No Good

79 Floor Coating Room 201 No Good

80 Fire Stop Room 201 No Good

81 Fire Stop Room 201 No Good

82 Fire Stop Room 201 No Good

Joint Compound

Drywall Tape Room 201 No Good

Joint Compound

Drywall Tape Room 201 No Good

85 Texture, Drywall Room 201 No Good

86 Texture, Drywall Room 201 No Good

87 Air Handler Caulking Roof No Good

88 Air Handler Caulking Roof No Good

89 Air Handler Caulking Roof No Good

Joint Compound

Drywall Tape Drywall

West Wall No Good

91 Door Frame Caulking West Wall No Good

92 Door Frame Caulking West Wall No Good

Space ACM Condition

6” Beige Cove Base

Adhesive West Wall No Good

94 Fiberglass Panel Adhesive West Wall No Good

95 Fiberglass Panel Adhesive West Wall No Good

96 Stucco SEC Exterior No Good

97 Stucco SWC Exterior No Good

98 Stucco East Exterior No Good

99 Expansion Joint SEC Exterior No Good

100 Expansion Joint SWC Exterior No Good

101 Expansion Joint East Exterior No Good

102 Window Frame Caulking SEC Exterior No Good

103 Window Frame Caulking SWC Exterior No Good

104 Window Frame Caulking East Exterior No Good

105 Concrete South Exterior No Good

106 Concrete South Exterior No Good

Notes:

1. ACM = Asbestos Containing Material

2. Good = Little to no visible deterioration or damage

APPENDIX A CONTINUED

XRF FIELD RESULTS AND

PERFORMANCE CHARACTERISTIC SHEET

Limited Asbestos Survey and XRF and Update to Previous Inspections

XRF Survey Conducted on 4/17/25 ■ Terracon Project No. 63247164

Test # Location Color Component Substrate Side* Pb

(mg/cm2) Lead-based

Calibration Calibration 1.05 Positive

Calibration Calibration 1.03 Positive

Calibration Calibration 1.09 Positive

Calibration Calibration 1.04 Positive

Calibration Calibration 1.06 Positive

1 Entry Orange Wall Drywall D 0.00 Negative

2 Entry Tan Wall Drywall A 0.00 Negative

3 Hall White Wall Drywall B 0.00 Negative

4 Bath Tan Wall Drywall A 0.00 Negative

5 Hall Blue Wall Drywall B 0.00 Negative

6 148 Break White Wall Drywall A 0.00 Negative

7 148 Break White Wall Drywall A 0.00 Negative

8 145 White Wall Drywall A 0.00 Negative

9 Hall To Warehouse White Wall Drywall D 0.00 Negative

10 Hall To Warehouse White Door Metal D 0.00 Negative

11 Warehouse White Door Metal B 0.00 Negative

12 Warehouse White Wall Drywall B 0.00 Negative

13 Warehouse White Wall Drywall C 0.00 Negative

14 Warehouse Office White Wall Drywall D 0.00 Negative

15 Warehouse Office White Wall Drywall B 0.00 Negative

16 Warehouse Office White Pipe Metal B 0.00 Negative

17 Warehouse Office Red Pipe Metal B 0.00 Negative

18 Warehouse Office White Beam Metal C 0.00 Negative

19 Warehouse Office White Pipe Metal C 0.00 Negative

20 Warehouse Office White Wall Concrete C 0.00 Negative

21 Warehouse White Wall Concrete C 0.00 Negative

22 Warehouse White Pipe Metal C 0.00 Negative

23 Warehouse White Pipe Metal C 0.00 Negative

24 Warehouse White Pipe Metal C 0.00 Negative

25 Warehouse White Beam Metal C 0.00 Negative

26 Warehouse White Door Metal C 0.00 Negative

27 Warehouse White Door Metal C 0.00 Negative

28 Warehouse White Wall Concrete C 0.00 Negative

29 Warehouse White Wall Drywall A 0.00 Negative

30 Warehouse Electrical White Door Metal C 0.00 Negative

31 Warehouse Electrical White Door Metal C 0.00 Negative

April 17, 2025

XRF Field Results

XRF Survey Conducted on 4/17/25 ■ Terracon Project No. 63247164

Test # Location Color Component Substrate Side* Pb

(mg/cm2) Lead-based

April 17, 2025

XRF Field Results

32 Warehouse Electrical Red Beam Metal A 0.00 Negative

33 Warehouse Electrical Red Railing Metal A 0.00 Negative

34 Warehouse Loading Yellow Pipe Metal A 0.00 Negative

35 Warehouse Loading Red Pipe Metal A 0.00 Negative

36 Warehouse Loading White Door Concrete A 0.00 Negative

37 Warehouse Loading White Door Metal C 0.00 Negative

38 Warehouse Loading White Door Metal C 0.00 Negative

39 Warehouse Loading Yellow Pipe Metal C 0.00 Negative

40 Warehouse Loading White Door Metal B 0.00 Negative

41 Warehouse Loading White Door Metal B 0.00 Negative

42 Warehouse Loading White Window Metal B 0.00 Negative

43 Warehouse Loading White Wall Drywall C 0.00 Negative

44 Warehouse Grey Railing Metal A -0.01 Negative

45 Warehouse Grey Stairs Metal A 0.00 Negative

46 Warehouse Grey Beam Metal A 0.00 Negative

47 Warehouse Grey Stairs Metal A 0.00 Negative

48 Warehouse Red Beam Metal Room Center 0.00 Negative

49 Warehouse White Pipe Plastic Room Center 0.00 Negative

50 Warehouse Yellow Pipe Plastic Room Center 0.00 Negative

51 Warehouse White Pipe Metal B 0.00 Negative

52 Warehouse White Pipe Metal B 0.00 Negative

53 Warehouse White Electrical Panel Metal B 0.00 Negative

54 Training Room Green Wall Drywall A 0.00 Negative

55 Training Room White Wall Drywall B 0.00 Negative

56 N Hall Blue Wall Drywall A 0.00 Negative

57 N Hall White Wall Drywall D 0.00 Negative

58 120 White Wall Drywall C 0.00 Negative

59 Conference Tan Wall Drywall C 0.00 Negative

60 Hall Orange Wall Drywall D 0.00 Negative 61 Hall White Wall Drywall D 0.00 Negative 62 Hall White Wall Drywall D 0.00 Negative 63 Entry White Window Metal B 0.00 Negative 64 Entry White Wall Drywall A 0.00 Negative 65 Entry White Wall Drywall C 0.00 Negative 66 Exterior Grey Fence Metal C 0.00 Negative 67 Exterior White Wall Concrete C 0.00 Negative 68 Exterior Tan Wall Concrete C 0.00 Negative 69 Exterior Tan Door Metal C 0.00 Negative 70 Exterior Tan Door Metal C 0.00 Negative

XRF Survey Conducted on 4/17/25 ■ Terracon Project No. 63247164

Test # Location Color Component Substrate Side* Pb

(mg/cm2) Lead-based

April 17, 2025

XRF Field Results

71 Exterior White Gutter Metal C 0.00 Negative 72 Exterior White Pipe Plastic C 0.00 Negative 73 Exterior Black Pipe Plastic C 0.00 Negative 74 Exterior Tan Wall Brick B 0.00 Negative 75 Exterior Tan Wall Concrete B 0.00 Negative 76 Exterior White Wall Concrete B 0.00 Negative 77 Exterior White Wall Concrete A 0.00 Negative 78 Exterior White Gutter Metal A 0.00 Negative 79 Exterior White Beam Metal A 0.00 Negative 80 Exterior Tan Railing Metal A 0.00 Negative 81 Exterior Yellow Railing Metal A 0.00 Negative 82 Exterior Yellow Railing Metal A 0.00 Negative

Calibration Calibration 1.09 Positive Calibration Calibration 1.04 Positive Calibration Calibration 1.06 Positive Calibration Calibration 1.01 Positive Calibration Calibration 1.04 Positive

* Side A is the North wall. Subsequent walls follow a clockwise rotation.

mg/cm2 = milligrams per square centimeter

SciAps X-550 PCS February 2022 Action Level: 1.0 mg/cm2

Performance Characteristic Sheet

EFFECTIVE DATE: February 1, 2022

MANUFACTURER AND MODEL:

Make: SciAps

Models: Model X-550

X-Ray Source: Rhodium (Rh) or Gold (Au) Anode

FIELD OPERATION GUIDANCE

ACTION LEVEL SETTING:

1.0 mg/cm2

OPERATING PARAMETERS:

Timed mode: fixed 10-second reading.

Quick mode: variable-time reading (approximately 2-6 seconds).

XRF CALIBRATION CHECK LIMITS:

0.8 to 1.2 mg/cm2 (inclusive) on NIST SRM 2579 (1.02 mg/cm2)/NIST SRM 2573, or equivalent

SUBSTRATE CORRECTION:

Not applicable

INCONCLUSIVE RANGE OR THRESHOLD:

Au Anode (quick)

READING DESCRIPTION

SUBSTRATE THRESHOLD (mg/cm2)

Results not corrected for substrate bias on any substrate

Brick 1.0 Concrete 1.0 Drywall 1.0 Metal 1.0

Plaster 1.0 Wood 1.0

Rh Anode (Timed or Quick), Au Anode (Timed)

READING DESCRIPTION

SUBSTRATE THRESHOLD (mg/cm2)

Results not corrected for substrate bias on any substrate

Brick 0.9 Concrete 0.9 Drywall 0.9 Metal 0.9

Plaster 0.9 Wood 0.9

BACKGROUND INFORMATION

EVALUATION DATA SOURCE AND DATE:

This sheet is supplemental information to be used in conjunction with Chapter 7 of the HUD Guidelines for the

Evaluation and Control of Lead-Based Paint Hazards in Housing, 2012 Edition ("HUD Guidelines"). Performance parameters shown on this sheet are calculated using test results on building components in the HUD archive.

Testing was conducted on 146 test samples in February 2022, with two separate instruments of each Anode type, operated in both Timed and Quick modes.

OPERATING PARAMETERS

Performance parameters shown in this sheet are applicable only when properly operating the instrument using the manufacturer's instructions and procedures described in Chapter 7 of the HUD Guidelines.

XRF CALIBRATION CHECK:

The calibration of the XRF instrument should be checked using the paint film nearest 1.0 mg/cm2 in the NIST

Standard Reference Material (SRM) used (e.g., for NIST SRM 2579, use the 1.02 mg/cm2 film; for NIST SRM

2579a, use film 2573 (1.04 mg/cm2).

If the average (rounded to 1 decimal place) of three readings is outside the acceptable calibration check range, follow the manufacturer's instructions to bring the instrument into control before XRF testing proceeds.

EVALUATING THE QUALITY OF XRF TESTING:

Randomly select ten testing combinations for retesting from each house or from two randomly selected units in multifamily housing.

Conduct XRF re-testing at the ten testing combinations selected for retesting.

Determine if the XRF testing in the units or house passed or failed the test by applying the steps below. Compute the Retest Tolerance Limit by the following steps:

Determine XRF results for the original and retest XRF readings. In single-family and multi-family housing, a result is defined as a single reading. Therefore, there will be ten original and ten retest XRF results for each house or for the two selected units.

Calculate the average of the original XRF result and the retest XRF result for each testing combination.

Square the average for each testing combination.

Add the ten squared averages together. Call this quantity C.

Multiply the number C by 0.0072. Call this quantity D.

Add the number 0.032 to D. Call this quantity E.

Take the square root of E. Call this quantity F.

Multiply F by 1.645. The result is the Retest Tolerance Limit.

Compute the average of all ten original XRF readings.

Compute the average of all ten re-test XRF readings.

Find the absolute difference of the two averages.

If the difference is less than the Retest Tolerance Limit, the inspection has passed the retest. If the difference of the overall averages equals or exceeds the Retest Tolerance Limit, this procedure should be repeated with ten new testing combinations. If the difference of the overall averages is equal to or greater than the Retest Tolerance Limit a second time, then the inspection should be considered deficient.

Use of this procedure is estimated to produce a spurious result approximately 1% of the time. That is, results of this procedure will call for further examination when no examination is warranted in approximately 1 out of 100 dwelling units tested.

TESTING TIMES:

The reading time in Archive tests was 10 seconds in Timed mode and from 2-6 seconds in Quick mode, for both the Rh Anode and Au Anode.

CLASSIFICATION OF RESULTS:

XRF results for the Au Anode in Quick mode are classified as positive if they are greater than or equal to 1.0 mg/cm2 and negative if they are less than to 1.0 mg/cm2. XRF results for the Au Anode in Timed mode and for the Rh Anode in Timed or Quick mode are classified as positive if they are greater than or equal to 0.9 mg/cm2 and negative if they are less than to 0.9 mg/cm2

DOCUMENTATION:

A report titled Methodology for XRF Performance Characteristic Sheets (EPA 747-R-95-008) provides an explanation of the statistical methodology used to develop Performance Characteristic Sheets at the Federal standard (Action Level) of 1.0 mg/cm2 and provides empirical results from using the recommended inconclusive ranges or thresholds for specific XRF instruments. The report may be downloaded at http://www2.epa.gov/lead/methodology-xrf-performance-characteristic-sheets-epa-747-r-95-008-september-

1997.

http://www2.epa.gov/lead/methodology-xrf-performance-characteristic-sheets-epa-747-r-95-008-september-1997 http://www2.epa.gov/lead/methodology-xrf-performance-characteristic-sheets-epa-747-r-95-008-september-1997

APPENDIX B

Sample Location Diagram

City, State

Veterans Affairs Consolidated Mail Outpatient Pharmacy Limited Asbestos Survey

3675 East Britannia Drive

Tucson , Arizona 85706 4685 South Ash Avenue, Suite H-4 Tempe, AZ 85282 www.Terracon.comPH. (480) 897-8200 FAX. (480) 897-1133

Explore with us as shown see left margin

03/31/2025

Project No.:

Date:

File No.:

Scale:

63247164

Project Mngr:

Approved By:

Checked By:

Drawn By:

D.K.

AD

MSV

MSV

LEGEND:

APPROXIMATE SUSPECTED ASBESTOS SAMPLE LOCATION

EXHIBIT

SAMPLE LOCATION DIAGRAM

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APPENDIX C

Laboratory Analytical Data

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): Veterans Affairs Consolidated Mail Outpatient Pharmacy Set No.: 58014

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ Report Date: 3/17/2025

Project No: 63247164 Sample Date: 3/5/2025

Identification: Asbestos, Bulk Sample Analysis

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

EPA Method 600/R-93/116 Page 1 of 3

On 3/10/2025, eighteen (18) bulk samples were submitted by Mr. Kyle Johnson 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.

CL1356679

01A

Floor Tile & Mastic, 12" X 12", Off-white

None Detected - Floor Tile

None Detected - Yellow Mastic

CL1356680

01B

CL1356681

01C

CL1356682

02A

Raised Panel Flooring, 24" X 24", White/Black

None Detected - Flooring

CL1356683

02B

CL1356684

02C

CL1356685

03A

Concrete, Grey

None Detected

CL1356686

03B

CL1356687

03C

CL1356688

04A

Pipe Insulation End Cap, White

None Detected - White Mastic

None Detected - Wrap

None Detected - Insulation

CL1356689

04B

None Detected - Wrap

CL1356690

04C

CL1356691

05A

Pinch Seam Sealant, Grey

CL1356692

05B

CL1356693

05C

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ Report Date: 3/17/2025

Project No: 63247164 Sample Date: 3/5/2025

Identification: Asbestos, Bulk Sample Analysis

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

EPA Method 600/R-93/116 Page 2 of 3

On 3/10/2025, eighteen (18) bulk samples were submitted by Mr. Kyle Johnson 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.

CL1356694

06A

HVAC Mastic, White

CL1356695

06B

CL1356696

06C

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ Report Date: 3/17/2025

Project No: 63247164 Sample Date: 3/5/2025

Identification: Asbestos, Bulk Sample Analysis

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

EPA Method 600/R-93/116 Page 3 of 3

On 3/10/2025, eighteen (18) bulk samples were submitted by Mr. Kyle Johnson 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:

Kevin Bowman

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): Veterans Affairs Consolidated Mail Outpatient Pharmacy Set #: 58014

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356679

Field ID #: 01A Page 1 of 1

Sample Description: Floor Tile & Mastic, 12" X 12", Off-white

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356679 kkkx Layer 1 Floor Tile Stereoscopic Examination 1 1356679 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Off White Hard Yes ND ND 99 PLM Examination:

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

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

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356679 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow Rubbery Yes ND ND 1 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356680

Field ID #: 01B Page 1 of 1

Sample Description: Floor Tile & Mastic, 12" X 12", Off-white

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356680 kx Layer 1 Floor Tile Stereoscopic Examination 1 1356680 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Off White Hard Yes ND ND 99 PLM Examination:

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

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

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356680 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow Rubbery Yes ND ND 1 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356681

Field ID #: 01C Page 1 of 1

Sample Description: Floor Tile & Mastic, 12" X 12", Off-white

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356681 kx Layer 1 Floor Tile Stereoscopic Examination 1 1356681 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Off White Hard Yes ND ND 99 PLM Examination:

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

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

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356681 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow Rubbery Yes ND ND 1 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356682

Field ID #: 02A Page 1 of 1

Sample Description: Raised Panel Flooring, 24" X 24", White/Black

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356682 kx Layer 1 Flooring Stereoscopic Examination 1 1356682 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 White/Black Hard No 50 ND 95 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 50 ribbons high 1 1 Vinyl Binders 50 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356682 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow-Tan Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356683

Field ID #: 02B Page 1 of 1

Sample Description: Raised Panel Flooring, 24" X 24", White/Black

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356683 kx Layer 1 Flooring Stereoscopic Examination 1 1356683 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 White/Black Hard No 50 ND 95 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 50 ribbons high 1 1 Vinyl Binders 50 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356683 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow-Tan Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356684

Field ID #: 02C Page 1 of 1

Sample Description: Raised Panel Flooring, 24" X 24", White/Black

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356684 kx Layer 1 Flooring Stereoscopic Examination 1 1356684 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample 0 White/Black Hard No 50 ND 95 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Cellulose Fibers 50 ribbons high 1 1 Vinyl Binders 50 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Layer 2 Yellow Mastic Stereoscopic Examination 2 1356684 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Yellow-Tan Rubbery Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Glue Binders 100 Non-fibrous 2 1

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

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356685

Field ID #: 03A Page 1 of 1

Sample Description: Concrete, Grey

Comments: Analyst: Kevin Bowman Date Analyzed: 3/17/2025

Lab Job #: PLM-40155 Sample #: CL1356685 kx Layer 1 Concrete Stereoscopic Examination 1 1356685 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Grey Cementitious Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Aggregate 60 Non-fibrous 1 1 Cement Binders 40 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Project (Line 2): 3675 East Britannia Dr., Tucson, AZ

Project #: 63247164 Sample #: CL1356686

Field ID #: 03B Page 1 of 1

Sample…