36C78619B0015-011.pdf

23 - View of A Self Storage Facility to the North of the Subject Property and George Washington Highway

24 - Additional View of Residential Properties to the North of the Subject Property and George Washington Highway

November 27, 2017 ECS Mid-Atlantic, LLC

ECS Project # 47:5010

25 - View of Grass Covered and Wooded Land on the East Adjacent Property

26 - View of Wooded Land on the South Adjacent Property

27 - View of a Residential Property to the West of the Subject Property

28 - View of the Pruntytown Correctional Facility to the West of the Subject Property

Appendix VI: Statement of Qualifications

ENVIRONMENTAL SITE ASSESSMENT

QUALIFICATIONS

ECS Mid-Atlantic, LLC (ECS) has performed more than seven thousand Phase I ESAs during the past fifteen years for a variety of local, regional and national clients. We employ five environmental professionals as defined by ASTM and AAI. Our personnel have an average of eight years of experience performing site assessments. ECS has developed and implemented a company-wide in-house Site Assessment Training Program to ensure that employees are familiar with the requirements of ASTM E 1527- and EPA All Appropriate

Inquiry. Environmental services available from ECS include:

ENVIRONMENTAL STUDIES:

Real estate transactions/environmental site assessments (Phases I, II, and III)

Environmental impact studies and risk assessments

Wetland delineation and mitigation investigations

Radon investigations

Third-party review

HAZARDOUS MATERIALS ASSESSMENTS:

Asbestos surveys

Lead Paint surveys

Sample collection and analysis

Preparation of plans and specifications

UNDERGROUND STORAGE TANK MANAGEMENT:

Monitoring of tank removals

Site investigations and assessments

Contaminant plume evaluations

Long- and short-term environmental site monitoring

Development of corrective actions plans (CAP's)

Regulatory permitting

Ground water recovery system design

HYDROGEOLOGICAL AND GEOPHYSICAL SERVICES:

Development and implementation of ground water resource and evaluation plans

Design and implementation of ground water monitoring networks, including drilling and well installation

Ground water modeling

Aquifer testing (pumping tests, slug tests and bail-down tests)

Contaminant plume investigations

Electromagnetic and resistivity surveys

Design of ground water recovery and treatment systems

Seismic refraction and ground-probing radar studies

ENVIRONMENTAL ENGINEERING:

Design and implementation of site remediation measures

Preparation of closure plans and other hazardous facility permitting

Design of new landfill and lagoon facilities

Design of pumping and treatment systems for contaminated ground water

Design of water/waste water treatment systems

Permitting and regulatory negotiation

Martin Ackley

Environmental Scientist

EDUCATION

Bachelor of Science, 2011, Earth Sciences, Pennsylvania State University

CERTIFICATIONS

OSHA 40 Hour HAZWOPER

EPA AHERA Asbestos Building Inspector Certification (multiple states)

EPA AHERA Asbestos Management Planner Certification (multiple states)

WV Asbestos Air Clearance Monitor

Mr. Ackley serves as an Environmental Scientist in the Pittsburgh, Pennsylvania office. His responsibilities include Phase I and II Environmental Site Assessments, Hazardous Materials Surveys, and Asbestos Surveys.

ENVIRONMENTAL SITE ASSESSMENTS – Mr. Ackley has performed Phase I and Transaction Screen Environmental Site Assessments consisting of observation/research/inquiry studies to identify potential environmental liabilities. He has experience performing preliminary assessments to evaluate on-site and off-site concerns that may impact the site soil and/or groundwater, and assisting with Phase II subsurface investigations. Types of assessments include leaking underground storage tanks (USTs), oil and hazardous material spills, and wastewater discharges. On-site activities include locating and drilling soil borings, collecting and screening soil samples, installing monitoring wells, and collecting groundwater samples.

Project types range from residential developments to commercial business properties, industrial facilities, and publicly owned facilities. Clientele includes buyer/seller private owners and developers, commercial developers, trucking companies, industrial entities, insurance companies, banks, realtors, and legal firms.

ASBESTOS SURVEYS & ABATEMENT OVERSIGHT - Mr. Ackley is experienced in performing bulk sampling asbestos surveys for a variety of property types and structures.

Additionally, Mr. Ackley has performed small to large scale abatement projects which include oversight, post-removal air monitoring services, and post-removal project reporting. He has completed these projects in accordance with industry standards and applicable regulations in collaboration with the contractor’s schedule and client’s budget.

SAMPLE PROJECT EXPERIENCE

• Industrial Building, Solon, OH

• PNC Dayton Facility, Dayton, OH

• Proposed PNC Bank, Shaler, PA

• Executive Centre Portfolio, Springdale, OH

• Sweeney’s Irish Pub, Millvale, PA

• Proposed Retail Development, Ellwood City, PA

• Cheswick Shopping Center, Cheswick, PA

• Proposed Advance Auto Parts, Glenville, WV

• Southpointe Town Center, Canonsburg, PA

• Steel Fabrication Facility, Erie, PA plf Ryan J. Croyle, REM

Regional Environmental Manager

EDUCATION

Bachelors of Science, 1998, Environmental Science/Biology, Edinboro University, Edinboro, PA

CERTIFICATIONS

National Registry of Environmental Professionals, Registered Environmental Manager

38‐Hour Army Corps of Engineers Wetland Delineation Training Program

OSHA HAZWOPER 40 Hour Certification & Refreshers

New Jersey DEP Subsurface Evaluator License, Reg. No.

207176

EPA AHERA Asbestos Building Inspector Certification (Multiple states)

NIOSH 582 Certification (Collecting and Analyzing Asbestos Air Samples)

Mr. Croyle is the Regional Environmental Manager/ Principal Reviewer for the ECS Mid‐Atlantic Northern Region. His responsibilities include managing the environmental staff, as well as coordinating, preparing, and reviewing environmental programs and services.

ENVIRONMENTAL MANAGER – Mr. Croyle provides principal review of Phase I and II Environmental Site Assessments, site characterization and remedial investigation reports, underground storage tank removal and remediation, State Voluntary Cleanup Programs, wetland determinations, risk assessments and hazardous materials surveys, health and safety plans (HASPs) environmental impact statements, and wetlands delineation studies.

SAMPLE PROJECT EXPERIENCE

Department of the Navy, Polychlorinated Biphenyl (PCB) Impacted Soil Removal, Mechanicsburg, PA

Fairpoint Communications, ACT 2, Bentleyville, PA

Direct To You Gas, ACT 2, Adams County, PA

United States Postal Service, Asbestos Containing Materials Roofing Surveys, Multiple Locations, US

Excela Health, Phase I ESA, Phase II ESA, ACT 2, Multiple Locations, PA

Butler Veteran Affairs, Phase I ESA, Asbestos Abatement, Phase II ESA, Butler, PA

Tanger Property, ACT 2, Hanover PA

PNC Financial Services Group, Environmental, National Account Manager, Multiple Locations, US

Wells Fargo RETECHs, National Account Manager, Multiple Locations, US

Cintas West Philadelphia Brownfields Redevelopment, Philadelphia, PA

Bank of America, Environmental, Multiple Locations, PA

Tractor Supply Company, Multiple Locations, MD, PA, NJ, MA

AutoZone, Multiple Locations, PA, NJ, NH, MA, ME

Proposed Grocery Store Sites, Phase I ESA, Asbestos Surveys, Phase II ESA, ACT 2, PA, MD, VA

BELCO Corporate Headquarters, Harrisburg, PA

Proposed Medical Facility, Phase I ESA, Geophysical Survey, Phase II ESA, USTs Removal, Oil Water Separator and Hydraulic Lift System Removal and construction oversight, York, PA

Direct To You Gas, UST Release & USTIF Project, Gettysburg, PA

Appendix VII: Acronyms

List of Common Acronyms

AULs Activity and Use Limitations ASTM Aboveground Storage Tank ASTM American Society for Testing and Materials ACM Asbestos Containing Materials BER Business Environmental Risk CORRACTS CERCLA Corrective Action List NPL CERCLA National Priorities List NFRAP CERCLA No Further Remedial Action Planned CERCLA Comprehnsive Environmental Response Cleanup Liability Act CESQG Conditionally Exempt Small Quantity Generator CREC Controlled Recognized Environmental Condition ERNS Emergency Response Notification System EC Engineering Controls HIST LF Historical Landfill HREC Historical Recognized Environmental Condition IC Institutional Controls LQG Large Quantity Generator LBP Lead Based Paint LTANKS Leaking Tanks LUST Leaking Underground Storage Tank REC Recognized Environmental Condition RCRA Resource Conservation and Recovery Act RCRIS Resource Conservation and Recovery Information System SQG Small Quantity Generator SWF/LF Solid Waste Facility/Landfill SHWS State Hazardous Waste Sites UST Underground Storage Tank USGS United States Geological Survey

Appendix C Waters of the U.S. Delineation Report

THIS PAGE INTENTIONALLY LEFT BLANK FOR DOUBLE SIDED PRINTING

WATERS OF THE U.S. DELINEATION REPORT

WEST VIRGINIA NATIONAL CEMETERY

42 VETERANS MEMORIAL LANE

GRAFTON, TAYLOR COUNTY, WEST VIRGINIA

ECS PROJECT NO. 47:5010

FOR

WILLIAM H. GORDON ASSOCIATES, INC.

DECEMBER 1, 2017

December 1, 2017

Mr. Mr. Chad Wallen, PLA William H. Gordon Associates, Inc.

301 N Mildred St Charles Town, West Virginia 25414

ECS Project No. 47:5010

Reference: Waters of the U.S Delineation Report, West Virginia National Cemetery, 42 Veterans Memorial Lane, Grafton, Taylor County West Virginia

Dear Mr. Wallen:

ECS Mid-Atlantic, LLC (ECS) is pleased to provide you with the results of our Waters of the U.S. (WOUS) Delineation Report for the referenced site. ECS services were provided in general accordance with the Task Order issued by William H. Gordon Associates, Inc., dated October 19, 2017 and generally meet the requirements of the 1987 U.S. Army Corps of Engineers (USACE) Wetlands Delineation Manual, and on the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont Region, Version 2.0 dated April 2012.

If there are questions regarding this report, or a need for further information, please contact the undersigned.

Sincerely, ECS Mid-Atlantic, LLC

Martin Ackley Adam Meurer, CHMM, PWS Environmental Scientist Principal, Environmental Services mackley@ecslimited.com ameurer@ecslimited.com 412-206-1470 804-353-6333

ECS Mid-Atlantic, LLC

1.0 INTRODUCTION

This report presents the findings of a wetland and stream delineation conducted by ECS Mid-Atlantic, LLC (ECS) for William H. Gordon Associates, Inc. at the West Virginia National Cemetery project located at 42 Veterans Memorial Lane, Grafton, Taylor County, West Virginia (Latitude: 39.33452778 N, Longitude: -80.07277778 W), and is identified by the Taylor County Web Parcel Viewer as a portion of Parcel 05 4003000010000. The site includes approximately 5.0-acres, as shown on the Site Location Map (Appendix I). The site generally consists of unimproved grass covered and partially wooded land.

An access road, identified as Veterans Memorial Lane, bisects the subject property. A single structure, identified as an administration and maintenance building, is also located within the study area.

ECS conducted the wetland and stream delineation on November 6, 2017. The purpose of this study was to identify and delineate potentially jurisdictional Waters of the U.S. (WOUS) within the subject property. ECS identified two palustrine emergent (PEM) wetlands, one perennial stream, and one intermittent stream within the project site which, in our professional opinion, would be considered jurisdictional by the U.S. Army Corps of Engineers.

December 1, 2017 ECS Mid-Atlantic, LLC

ECS Project # 5010

2.0 METHODOLOGY

This wetland delineation is based on ECS’ professional judgment and application of the technical criteria presented in the 1987 U.S. Army Corps of Engineers (USACE) Wetlands Delineation Manual, and on the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont Region, Version 2.0 dated April 2012. Wetland boundaries were delineated using the routine onsite determination method described in the USACE Manual and Regional Supplement, in conjunction with the Eastern Mountains and Piedmont 2016 Regional Wetland Plant List, and the USDA Soil Survey. Field work was completed on November 6, 2017 by Vince Humenay and Martin Ackley.

ECS completed the following tasks to identify and delineate potentially jurisdictional wetland boundaries onsite:

Desktop Review: ECS wetland scientists reviewed the U.S. Geological Survey (USGS) topographic map, U.S. Department of Agriculture Natural Resource Conservation Service (USDA-NRCS) Soil Survey of Harrison and Taylor Counties, West Virginia, U.S. Fish & Wildlife Service (USFWS) National Wetlands Inventory (NWI) maps, and available aerial photographs to identify potentially jurisdictional Waters of the U.S. (i.e., streams, wetlands, natural ponds, lakes). Please reference Appendix I for the above-mentioned maps.

Field Investigation: ECS performed onsite wetland delineations as described above. First, site hydrology was observed and the plant community within the data plot was characterized. The dominant plant species within each community were then identified, and it was determined whether or not hydrophytic (wetland) plants dominated the plant community. The USFWS has defined five wetland plant indicator categories including:

Obligate wetland (OBL) – has >99% probability of occurring in wetlands Facultative wetland (FACW) – has 66% to 99% chance of occurring in wetlands Facultative (FAC) – has 33% to 66% chance of occurring in wetlands Facultative upland (FACU) – has 1 to 33% chance of occurring in wetlands Upland (UPL) – has <1% chance of occurring in wetlands No Indicator (NI) – no wetland indicator for the specified species

Plants identified as OBL, FACW, or FAC are considered wetland plants (or hydrophytes) by USACE.

In areas determined to have hydrophytic vegetation and potential wetland hydrology, an approximately 16-20 inch soil test hole was completed with a hand auger to determine if hydric soils were present. The soil boring was also inspected to determine if indicators of wetland hydrology (inundation, soil saturation, etc.) were present.

Once an area is determined to be a wetland, further testing was performed to locate the wetland/ upland (non-wetland) boundary. A second test hole was completed in the upland area to document non-wetland conditions. Wetland boundaries were marked with consecutively numbered surveyor’s ribbon flags. The wetland flags were surveyed as part of this assessment.

December 1, 2017 ECS Mid-Atlantic, LLC

Data forms specified in the Regional Supplement were completed for each wetland and non-wetland testhole location, referred to as data points. The data forms recorded the vegetation, soils, and hydrology observations used in making the wetland determinations. ECS did identify wetland areas during the site reconnaissance which, in our professional opinion, would be considered jurisdictional by the USACE.

2.1 Methodology for Delineating Streams

During the field evaluation for wetlands, ECS observed the site for streams that would potentially be considered jurisdictional by state and federal regulatory agencies. ECS used field indicators such as the presence of an ordinary high water mark (OHWM) and continuous bed and banks to delineate stream channels and also observed characteristics such as flow, substrate composition, presence/ absence of defined bed and banks, origin of hydrologic source, presence/absence of vegetation in the stream channel, and composition and relative abundance of resident benthic macroinvertebrates to classify onsite streams into three stream types: ephemeral, intermittent, and perennial.

Two streams were identified during our assessment. Streams located onsite are depicted on the Waters of the U.S. Delineation Map (Appendix IV). The individual stream lengths and classifications are summarized on Table 1. Photographs of the streams are presented in Appendix III.

December 1, 2017 ECS Mid-Atlantic, LLC

3.0 FINDINGS

3.1 Desktop Review

The NWI map depicted Otter Creek within the subject property boundaries. The USGS Grafton, West Virginia quadrangle map indicates that the subject property drains to the north towards Otter Creek, a stream depicted on the northern portion of the site. Elevations across the wetland study area range from approximately 1,120 to 1,200 feet above mean sea level (MSL). The weather at the time of the site reconnaissance was approximately 50 degrees and rainy.

3.2 Site Soils

A review of the USDA Soil Survey for the project site identified three mapping units within the site boundaries. These soil mapping units are the Gilpin silt loam (15 to 25% slopes and 25 to 35% slopes) and Udifluvents & Fluvaquents. Udifluvents & Fluvaquents is identified as a hydric soil by the NRCS.

3.3 Waters of the U.S.

Two potentially jurisdictional wetland areas totaling 0.02-acres and two potentially jurisdictional streams totaling 730-linear feet were identified and delineated within the study area. Their size and USFWS Cowardin classifications are summarized below (Table 1), and their locations are illustrated on the Waters of the U.S. Delineation Map (Appendix IV).

Hydrologic features within the ESL are governed primarily by site topography. The primary hydrological sources for the wetland areas are seeps originating upslope or within wetland areas as well as topography, which concentrates surfacewater flows.

Table 1: WOUS Summary Table

WOUS

Cowardin

Classification Onsite Linear

Feet (LF) Onsite

Acreage (AC) Onsite Square

Footage (Sq. Ft.)

Wetland A PEM - 0.017 761

Wetland B PEM - 0.003 126

Stream 1 (Otter Creek)

Perennial 691 - -

Stream 2 Intermittent 39 - -

3.3.1 Wetland Summary

Wetland A: Wetland A is a 0.017-acre PEM wetland located on the northern portion of the subject property near Otter Creek. The wetland appears to be fed by seeps originating on the adjoining slope. The wetland appears to drain to Stream 1 (Otter Creek). Wetland A is dominated by OBL and FAC vegetative species in the herbaceous stratum. Hydrological indicators included saturation, a high water table, drainage patterns, and oxidized rhizospheres on living roots. Soils within the

December 1, 2017 ECS Mid-Atlantic, LLC wetland at data point one (DP-1) consisted of low chroma, silty clay soils with redoximorphic features characterized as depleted matrix soils.

Wetland B: Wetland B is a 0.003-acre PEM wetland located on the northern portion of the subject property near Otter Creek. The wetland appears to be fed by seeps originating on the adjoining slope or within the wetland area. Wetland A is dominated by OBL vegetative species in the herbaceous stratum. Hydrological indicators included saturation, a high water table, drainage patterns, and oxidized rhizospheres on living roots. Soils within the wetland at data point two (DP-2) consisted of low chroma, silty clay soils with redoximorphic features characterized as depleted matrix soils.

3.3.2 Stream Summary

Stream 1: Stream 1, identified as Otter Creek, is a perennial stream which bisects the northern portion of the project site. The stream enters the subject property from the west and flows through a box culvert beneath Veterans Memorial Lane. The stream continues through the subject property and exits to the east. The stream channel high water mark ranged from 0.5 to 3.0 feet deep and 4 to 7 feet across. The stream travels 691 feet on the subject site before flowing off-site to the east.

Stream 2: Stream 2 is an intermittent stream which originates from a culvert on the northern portion of the project site and appears to convey runoff from upland areas farther south up the slope. The stream travels approximately 39 feet before joining Otter Creek. The stream channel high water mark was approximately 0.5 deep and 2 feet across.

December 1, 2017 ECS Mid-Atlantic, LLC

4.0 REGULATORY DISCUSSION

The WOUS are regulated by Sections 401 and 404 of the Clean Water Act. State and Federal law dictates that any disturbance to WOUS must be permitted through the appropriate agencies.

Upon your request, we will contact the USACE to schedule a field meeting to conduct a wetlands and Waters boundary confirmation and preliminary jurisdictional determination. This process takes an average of one to two months months depending on the availability of USACE personnel.

If jurisdictional wetlands and streams are present at the site, planned land disturbance in these areas would likely require a permit from the U.S. Army Corps of Engineers and/or the West Virginia Department of Environmental Protection (WVDEP). ECS recommends conducting a Jurisdictional Determination with the USACE. If any potential impacts are proposed, ECS recommends a Pre-Application meeting with the USACE and the WVDEP at that time to coordinate follow-up efforts after the field visit in order to obtain the issuance of a JD letter from the USACE and begin the permitting process. In the interim, we recommend further review of state and federal agency records pertaining to Section 7 (Federal Endangered Species Act) and Section 106 (National Historic Preservation Act). These reviews will generally be required to verify compliance for General or Joint Permit conditions.

December 1, 2017 ECS Mid-Atlantic, LLC

5.0 CONCLUSIONS

Two potentially jurisdictional wetland areas totaling 0.02-acres and two potentially jurisdictional streams totaling 730-linear feet were identified and delineated within the study area. The locations and boundaries of potentially jurisdictional Waters are illustrated on the attached Waters of the U.S.

Delineation Map (Appendix IV).

The flagged WOUS boundaries are subject to change during the jurisdictional determination meeting with the USACE. ECS cannot guarantee that field conditions and/or WOUS boundaries will not change over time.

December 1, 2017 ECS Mid-Atlantic, LLC

Appendix I: Figures

WETLAND DELINEATION REPORT

FOR: GORDON

NOVEMBER 2017

SOURCE: BING MAPS

ECS MID-ATLANTIC, LLC

145 LAKE DRIVE

SUITE 102

WEXFORD, PA 15090

412-206-1470

FIGURE I: SITE LOCATION MAP

PROJECT #47:5010—WEST VIRGINIA NATIONAL

CEMETERY

42 VETERANS MEMORIAL LANE, GRAFTON, TAYLOR

COUNTY

NOT TO SCALE

MAckley Polyline

NOVEMBER 2017

SOURCE: THE USGS MAP STORE

ECS MID-ATLANTIC, LLC

145 LAKE DRIVE

SUITE 102

NOT TO SCALE

FIGURE II: USGS TOPOGRAPHIC MAP

PROJECT #47:5010—WEST VIRGINIA NATIONAL

CEMETERY

42 VETERANS MEMORIAL LANE, GRAFTON, TAYLOR

COUNTY

MAckley Textbox Approximate Wetland Study Area

MAckley Arrow

40cad Polygonal Line

NOVEMBER 2017

SOURCE: USFWS WETLANDS MAPPER

ECS MID-ATLANTIC, LLC

145 LAKE DRIVE

SUITE 102

FIGURE III: NATIONAL WETLAND INVENTORY MAP

PROJECT #47:5010—WEST VIRGINIA NATIONAL

CEMETERY

42 VETERANS MEMORIAL LANE, GRAFTON, TAYLOR

COUNTY

NOVEMBER 2017

SOURCE: NRCS WEB SOIL SURVEY

ECS MID-ATLANTIC, LLC

145 LAKE DRIVE

SUITE 102

FIGURE IV: USDA SOILS MAP

PROJECT #47:5010—WEST VIRGINIA NATIONAL

CEMETERY

42 VETERANS MEMORIAL LANE, GRAFTON, TAYLOR

COUNTY

NOVEMBER 2017

SOURCE: FEMA

ECS MID-ATLANTIC, LLC

145 LAKE DRIVE

SUITE 102

FIGURE V: FEMA FLOODPLAIN MAP

PROJECT #47:5010—WEST VIRGINIA NATIONAL

CEMETERY

42 VETERANS MEMORIAL LANE, GRAFTON, TAYLOR

COUNTY

Appendix II: USACE Wetland Data Forms and Stream Data

Forms

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

WETLAND DETERMINATION DATA FORM – Eastern Mountains and Piedmont

Project/Site: West Virginia National Cemetery City/County: Grafton/Taylor County Sampling Date: 11/6/2017

Applicant/Owner: William H. Gordon Associates, Inc. State: WV Sampling Point: DP-1

Investigator(s): Vince Humenay/Marty Ackley Section, Township, Range: Grafton

Landform (hillslope, terrace, etc.): Toe of Slope Local relief (concave, convex, none): Concave Slope (%): 5

Subregion (LRR or MLRA): LRR N Lat: Long: Datum:

Soil Map Unit Name: Udifluvents and Fluvaquents NWI classification: PEM

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No

Hydric Soil Present? Yes No

Wetland Hydrology Present? Yes No

Is the Sampled Area within a Wetland? Yes No

Remarks:

This data plot describes a PEM wetland (Wetland A) located on the northern portion of the property adjacent to Stream 1. The wetland appears to be fed by seeps originating on the adjoining slope and drains to Stream 1.

HYDROLOGY

Wetland Hydrology Indicators: Secondary Indicators (minimum of two required)

Primary Indicators (minimum of one is required; check all that apply) Surface Soil Cracks (B6)

Surface Water (A1) True Aquatic Plants (B14) Sparsely Vegetated Concave Surface (B8) High Water Table (A2) Hydrogen Sulfide Odor (C1) Drainage Patterns (B10) Saturation (A3) Oxidized Rhizospheres on Living Roots (C3) Moss Trim Lines (B16) Water Marks (B1) Presence of Reduced Iron (C4) Dry-Season Water Table (C2) Sediment Deposits (B2) Recent Iron Reduction in Tilled Soils (C6) Crayfish Burrows (C8) Drift Deposits (B3) Thin Muck Surface (C7) Saturation Visible on Aerial Imagery (C9) Algal Mat or Crust (B4) Other (Explain in Remarks) Stunted or Stressed Plants (D1) Iron Deposits (B5) Geomorphic Position (D2) Inundation Visible on Aerial Imagery (B7) Shallow Aquitard (D3) Water-Stained Leaves (B9) Microtopographic Relief (D4) Aquatic Fauna (B13) FAC-Neutral Test (D5)

Field Observations:

Surface Water Present? Yes No Depth (inches):

Water Table Present? Yes No Depth (inches): surface

Saturation Present? Yes No Depth (inches): surface (includes capillary fringe)

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

VEGETATION (Five Strata) – Use scientific names of plants. Sampling Point: DP-1

Tree Stratum (Plot size: 30') 1.

2.

3.

4.

5.

6.

7.

Sapling Stratum (Plot size: 15')

2.

3.

4.

5.

Shrub Stratum (Plot size: 15')

2.

3.

4.

5.

Herb Stratum (Plot size: 5')

1. Typha latifola

2. Sedge sp.

3. Solidago canadensis 4.

5.

6.

7.

8.

9.

10.

11.

12.

Woody Vine Stratum (Plot size: )

2.

3.

4.

5.

Absolute % Cover

Dominant Species?

= Total Cover

Y

N

Indicator Status

OBL

FAC

FACU

Dominance Test worksheet:

Number of Dominant Species That Are OBL, FACW, or FAC: 2 (A)

Total Number of Dominant Species Across All Strata: 2 (B)

Percent of Dominant Species That Are OBL, FACW, or FAC: 100 (A/B)

Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species 60 x 1 = 60 FACW species x 2 = FAC species 30 x 3 = 90 FACU species 2 x 4 = 8 UPL species x 5 = Column Totals:92 (A) 158 (B) Prevalence Index = B/A = 1.72 Hydrophytic Vegetation Indicators:

1 - Rapid Test for Hydrophytic Vegetation

2 - Dominance Test is >50%

3 - Prevalence Index is ≤3.01

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet)

Problematic Hydrophytic Vegetation1

(Explain) 1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic.

Definitions of Five Vegetation Strata:

Tree – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and 3 in.

(7.6 cm) or larger in diameter at breast height (DBH).

Sapling – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and less than 3 in. (7.6 cm) DBH.

Shrub – Woody plants, excluding woody vines, approximately 3 to 20 ft (1 to 6 m) in height.

Herb – All herbaceous (non-woody) plants, including herbaceous vines, regardless of size, and woody plants, except woody vines, less than approximately 3 ft (1 m) in height.

Woody vine – All woody vines, regardless of height.

Remarks: (Include photo numbers here or on a separate sheet.)

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

SOIL Sampling Point: DP-1

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

0-3

3-12

2.5Y 3/2

10YR 4/6

Silty Clay

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Hydric Soil Indicators: Indicators for Problematic Hydric Soils3:

Histosol (A1) Dark Surface (S7) 2 cm Muck (A10) (MLRA 147) Histic Epipedon (A2) Polyvalue Below Surface (S8) (MLRA 147, 148) Coast Prairie Redox (A16) Black Histic (A3) Thin Dark Surface (S9) (MLRA 147, 148) (MLRA 147, 148) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Piedmont Floodplain Soils (F19) Stratified Layers (A5) Depleted Matrix (F3) (MLRA 136, 147) 2 cm Muck (A10) (LRR N) Redox Dark Surface (F6) Red Parent Material (TF2) Depleted Below Dark Surface (A11) Depleted Dark Surface (F7) Very Shallow Dark Surface (TF12) Thick Dark Surface (A12) Redox Depressions (F8) Other (Explain in Remarks) Sandy Mucky Mineral (S1) (LRR N, Iron-Manganese Masses (F12) (LRR N, MLRA 136) MLRA 147, 148) Umbric Surface (F13) (MLRA 136, 122)

Sandy Gleyed Matrix (S4) Piedmont Floodplain Soils (F19) (MLRA 148) Sandy Redox (S5) Stripped Matrix (S6)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Restrictive Layer (if observed):

Type: Rock

Depth (inches): 12" Hydric Soil Present? Yes No

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

Project/Site: West Virginia National Cemetery City/County: Grafton/Taylor County Sampling Date: 11/6/2017

Applicant/Owner: William H. Gordon Associates, Inc. State: WV Sampling Point: DP-2

Investigator(s): Vince Humenay/Marty Ackley Section, Township, Range: Grafton

Landform (hillslope, terrace, etc.): Toe of Slope Local relief (concave, convex, none): Concave Slope (%): 2

Subregion (LRR or MLRA): LRR N Lat: Long: Datum:

Soil Map Unit Name: Udifluvents and Fluvaquents NWI classification: PEM

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydric Soil Present? Yes No

This data plot describes a PEM wetland (Wetland B) located on the northern portion of the property near Stream

1. The wetland appears to be fed by seeps originating within the wetland or on the adjoining slope.

Primary Indicators (minimum of one is required; check all that apply) Surface Soil Cracks (B6)

Surface Water (A1) True Aquatic Plants (B14) Sparsely Vegetated Concave Surface (B8) High Water Table (A2) Hydrogen Sulfide Odor (C1) Drainage Patterns (B10) Saturation (A3) Oxidized Rhizospheres on Living Roots (C3) Moss Trim Lines (B16) Water Marks (B1) Presence of Reduced Iron (C4) Dry-Season Water Table (C2) Sediment Deposits (B2) Recent Iron Reduction in Tilled Soils (C6) Crayfish Burrows (C8) Drift Deposits (B3) Thin Muck Surface (C7) Saturation Visible on Aerial Imagery (C9) Algal Mat or Crust (B4) Other (Explain in Remarks) Stunted or Stressed Plants (D1) Iron Deposits (B5) Geomorphic Position (D2) Inundation Visible on Aerial Imagery (B7) Shallow Aquitard (D3)

Water Table Present? Yes No Depth (inches): surface

Saturation Present? Yes No Depth (inches): surface

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

VEGETATION (Five Strata) – Use scientific names of plants. Sampling Point: DP-2

2.

3.

4.

5.

2.

3.

4.

5.

2.

3.

4.

5.

1. Eleocharis palustris

2. Sedge sp.

3. Solidago canadensis 4.

5.

6.

7.

8.

9.

10.

2.

3.

OBL

FAC

That Are OBL, FACW, or FAC: 1 (A)

Total Number of Dominant Species Across All Strata: 1 (B)

Percent of Dominant Species That Are OBL, FACW, or FAC: 100 (A/B)

Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species 60 x 1 = 60 FACW species x 2 = FAC species 10 x 3 = 30 FACU species 10 x 4 = 40 UPL species x 5 = Column Totals:80 (A) 130 (B) Prevalence Index = B/A = 1.63

3 - Prevalence Index is ≤3.01

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet)

Problematic Hydrophytic Vegetation1

(Explain) 1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic.

Definitions of Five Vegetation Strata:

Tree – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and 3 in.

(7.6 cm) or larger in diameter at breast height (DBH).

Sapling – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and less than 3 in. (7.6 cm) DBH.

Shrub – Woody plants, excluding woody vines, approximately 3 to 20 ft (1 to 6 m) in height.

Herb – All herbaceous (non-woody) plants, including herbaceous vines, regardless of size, and woody plants, except woody vines, less than approximately 3 ft (1 m) in height.

Woody vine – All woody vines, regardless of height.

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

SOIL Sampling Point: DP-2

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

(inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

0-3

3-9

10YR 4/6

With

Gravel

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Black Histic (A3) Thin Dark Surface (S9) (MLRA 147, 148) (MLRA 147, 148) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Piedmont Floodplain Soils (F19) Stratified Layers (A5) Depleted Matrix (F3) (MLRA 136, 147) 2 cm Muck (A10) (LRR N) Redox Dark Surface (F6) Red Parent Material (TF2) Depleted Below Dark Surface (A11) Depleted Dark Surface (F7) Very Shallow Dark Surface (TF12) Thick Dark Surface (A12) Redox Depressions (F8) Other (Explain in Remarks) Sandy Mucky Mineral (S1) (LRR N, Iron-Manganese Masses (F12) (LRR N, MLRA 136) MLRA 147, 148) Umbric Surface (F13) (MLRA 136, 122)

Sandy Gleyed Matrix (S4) Piedmont Floodplain Soils (F19) (MLRA 148)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Type: Rock

Depth (inches): 9"

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

Project/Site: West Virginia National Cemetery City/County: Grafton/Taylor County Sampling Date: 11/6/2017

Applicant/Owner: William H. Gordon Associates, Inc. State: WV Sampling Point: DP-3

Investigator(s): Vince Humenay/Marty Ackley Section, Township, Range: Grafton

Landform (hillslope, terrace, etc.): Hillslope Local relief (concave, convex, none): Convex Slope (%): 25

Subregion (LRR or MLRA): LRR N Lat: Long: Datum:

Soil Map Unit Name: Gilpin silt loam (15-25% slopes) NWI classification:

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydric Soil Present? Yes No

This data plot describes an upland area to the south of Wetland A and B.

Primary Indicators (minimum of one is required; check all that apply) Surface Soil Cracks (B6)

Surface Water (A1) True Aquatic Plants (B14) Sparsely Vegetated Concave Surface (B8) High Water Table (A2) Hydrogen Sulfide Odor (C1) Drainage Patterns (B10) Saturation (A3) Oxidized Rhizospheres on Living Roots (C3) Moss Trim Lines (B16) Water Marks (B1) Presence of Reduced Iron (C4) Dry-Season Water Table (C2) Sediment Deposits (B2) Recent Iron Reduction in Tilled Soils (C6) Crayfish Burrows (C8) Drift Deposits (B3) Thin Muck Surface (C7) Saturation Visible on Aerial Imagery (C9) Algal Mat or Crust (B4) Other (Explain in Remarks) Stunted or Stressed Plants (D1) Iron Deposits (B5) Geomorphic Position (D2) Inundation Visible on Aerial Imagery (B7) Shallow Aquitard (D3)

Water Table Present? Yes No Depth (inches):

Saturation Present? Yes No Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

VEGETATION (Five Strata) – Use scientific names of plants. Sampling Point: DP-3

1. Pinus strobus 2.

3.

4.

5.

2.

3.

4.

5.

2.

3.

4.

5.

1. Rubus allegheniensis

2. Athyrium filix-femina

3. Solidago canadensis 4.

5.

6.

7.

8.

9.

10.

2.

3.

UPL

That Are OBL, FACW, or FAC: 0 (A)

Total Number of Dominant Species Across All Strata: 4 (B)

Percent of Dominant Species That Are OBL, FACW, or FAC: 0 (A/B)

Prevalence Index worksheet:

Total % Cover of: Multiply by:

OBL species x 1 = FACW species x 2 = FAC species x 3 = FACU species 65 x 4 = 260 UPL species 15 x 5 = 75 Column Totals:80 (A) 335 (B) Prevalence Index = B/A = 4.19

3 - Prevalence Index is ≤3.01

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet)

Problematic Hydrophytic Vegetation1

(Explain) 1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic.

Definitions of Five Vegetation Strata:

Tree – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and 3 in.

(7.6 cm) or larger in diameter at breast height (DBH).

Sapling – Woody plants, excluding woody vines, approximately 20 ft (6 m) or more in height and less than 3 in. (7.6 cm) DBH.

Shrub – Woody plants, excluding woody vines, approximately 3 to 20 ft (1 to 6 m) in height.

Herb – All herbaceous (non-woody) plants, including herbaceous vines, regardless of size, and woody plants, except woody vines, less than approximately 3 ft (1 m) in height.

Woody vine – All woody vines, regardless of height.

US Army Corps of Engineers Eastern Mountains and Piedmont – Final

SOIL Sampling Point: DP-3

Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

(inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

0-6

2.5Y 4/3

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains. 2Location: PL=Pore Lining, M=Matrix.

Black Histic (A3) Thin Dark Surface (S9) (MLRA 147, 148) (MLRA 147, 148) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Piedmont Floodplain Soils (F19) Stratified Layers (A5) Depleted Matrix (F3) (MLRA 136, 147) 2 cm Muck (A10) (LRR N) Redox Dark Surface (F6) Red Parent Material (TF2) Depleted Below Dark Surface (A11) Depleted Dark Surface (F7) Very Shallow Dark Surface (TF12) Thick Dark Surface (A12) Redox Depressions (F8) Other (Explain in Remarks) Sandy Mucky Mineral (S1) (LRR N, Iron-Manganese Masses (F12) (LRR N, MLRA 136) MLRA 147, 148) Umbric Surface (F13) (MLRA 136, 122)

Sandy Gleyed Matrix (S4) Piedmont Floodplain Soils (F19) (MLRA 148)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Type: Rock

Depth (inches): 6"

Appendix III: Photographic Log

1 - View to the South Across the Wetland Study Area

2 - General View of the Administration/Maintenance Building Located Onsite

December 1, 2017 ECS Mid-Atlantic, LLC

3 - View of Stream 1 (Otter Creek) Facing West

4 - View of Stream 1 (Otter Creek) and Box Culvert Beneath Veterans Memorial Lane

5 - Additional View of Stream 1 (Otter Creek) Facing East

6 - View of Stream 2 Near Otter Creek

7 - General View of Wetland A

8 - General View of Wetland 2

Appendix IV: Waters of the U.S.

Delineation Map

Appendix D Asbestos Containing Materials Sampling & Lead-Based

Paint Screening

THIS PAGE INTENTIONALLY LEFT BLANK FOR DOUBLE SIDED PRINTING

ASBESTOS CONTAINING MATERIALS SAMPLING

AND LEAD-BASED PAINT SCREENING

WEST VIRGINIA NATIONAL CEMETERY

42 VETERANS MEMORIAL LANE

GRAFTON, WEST VIRGINIA 26354

ECS PROJECT NO. 47:5010

FOR

WILLIAM H. GORDON ASSOCIATES, INC.

NOVEMBER 27, 2017

November 27, 2017

Mr. Chad Wallen William H. Gordon Associates, Inc.

301 N Mildred St Suite 1 Charles Town, West Virginia 25414

ECS Project No. 47:5010

Reference: Asbestos Containing Materials Sampling and Lead-Based Paint Screening, West Virginia National Cemetery, 42 Veterans Memorial Lane, Grafton, West Virginia

Dear Mr. Wallen:

ECS Mid-Atlantic, LLC (ECS) is pleased to provide William H. Gordon Associates, Inc. with the results of the above referenced Asbestos Containing Materials Sampling and Lead-Based Paint Screening performed at West Virginia National Cemetery located at 42 Veterans Memorial Lane in Grafton, West Virginia. This report summarizes our observations, analytical results, findings, and recommendations related to the work performed. The work described in this report was performed by ECS in general accordance with the Task Order issued by William H. Gordon Associates, Inc., dated October 19, 2017 and the terms and conditions of the agreement authorizing those services.

ECS appreciates this opportunity to provide William H. Gordon Associates, Inc. with our services. If we can be of further assistance to you, please do not hesitate to contact us.

Sincerely, ECS Mid-Atlantic, LLC

Ginger L. Randall Michael K. Smith Environmental Department Manager Senior Project Manager grandall@ecslimited.com mksmith@ecslimited.com 412-206-1470 717-767-4788

PAGETABLE OF CONTENTS

1.0 SITE DESCRIPTION

2.0 PURPOSE

3.0 METHODOLOGY

3.1 Asbestos-Containing Materials

3.2 Lead in Paint and Surface Coatings

4.0 RESULTS

4.1 Asbestos-Containing Materials

4.2 Suspect or Assumed Asbestos-Containing Materials

4.3 Lead in Paint and Surface Coatings

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

5.1 Asbestos-Containing Materials

5.2 Lead in Paint and Surface Coatings

6.0 LIMITATIONS

TABLE OF APPENDICES

Appendix II: Site Photographs

Appendix III: Asbestos Bulk Sample Results

Appendix IV: XRF Lead-Based Paint Readings

Appendix V: Certifications/Licenses

1.0 SITE DESCRIPTION

The approximately 79-acre subject property is occupied by the West Virginia National Cemetery located at 42 Veterans Memorial Lane in Grafton, West Virginia. Four structures are present on the subject property and are identified as Committal Shelter A, Committal Shelter B, Administration/ Maintenance Building, and Cold Storage Building. The Administration/Maintenance Building contains office and kitchen space, as well as, a maintenance garage. The maintenance garage is utilized for oil changes and small engine repairs. The Cold Storage Building is utilized for the storage of heavy equipment, vehicles, and lawnmowers. The onsite committal shelters provide a location for interment services away from grave sites. The balance of the subject property generally consists of grave sites, wooded land, and grass covered land. ECS understands the subject buildings are proposed for renovation.

ECS understands that the West Virginia National Cemetery was dedicated in 1987. The existing Administration/Maintenance building and Committal Shelter A were reportedly constructed in 1991.

Committal Shelter B was reportedly constructed in 2003. By 2011, the existing Cold Storage Building was located on the subject property.

2.0 PURPOSE

The purpose of the Asbestos Containing Materials Sampling and Lead-Based Paint Screening was to identify asbestos-containing materials (ACMs) and lead-based paint (LBP) which may require special handling and/or disposal if removed during construction activities. The identification of ACMs may require trained labor, regulated work practices, and special disposal. The identification of LBP or other lead hazards may require disclosure to contractors and monitoring of lead exposure.

3.0 METHODOLOGY

ECS performed the authorized Scope of Services in general accordance with our proposal, standard industry practice(s) and methods specified by regulation(s) for the identification of ACMs and LBPs.

3.1 Asbestos-Containing Materials

The non-destructive asbestos survey was performed by asbestos inspectors who have received EPA accredited training and are licensed by the State of West Virginia. Samples of suspect ACMs were collected utilizing hand tools and placed into individual, labeled plastic bags. Unique bulk suspect ACM samples were submitted to EMSL Analytical, Inc. in Cinnaminson, New Jersey for analysis via Polarized Light Microscopy (PLM) in accordance with current EPA-600 methodology. Materials consisting of additional layers were analyzed separately. EMSL Analytical, Inc. is listed as an accredited laboratory by the National Voluntary Laboratory Accreditation Plan (NVLAP) managed by the National Institute of Standards and Technology (NIST) for bulk sample analysis by currently approved EPA methodology by PLM.

During the survey, ECS attempted to identify suspect ACMs in readily accessible areas. However, due to the destructive means required to identify some materials, certain areas were deemed inaccessible (i.e. behind walls or sub grade materials) and were not surveyed for suspect ACMs. The attic crawl space within the Administration/Maintenance building was inaccessible. Unidentified suspect ACMs may be located in this and/or other inaccessible areas.

Samples were collected in general accordance with EPA Standard 40 CFR 763 Subpart E, Asbestos Hazard Emergency Response Act (AHERA) and OSHA Standard 29 CFR 1926.1101 Inspection Protocol.

Multiple samples of each unique material were submitted.

3.2 Lead in Paint and Surface Coatings

The LBP survey was performed by a West Virginia licensed Lead Inspector using a X-Ray Fluorescence (XRF) Spectrometer to identify lead concentrations in painted and glazed surfaces.

The survey was conducted utilizing the U.S. EPA definition of LBP. Under this definition, painted surfaces which contain lead in concentrations equal to or greater than 1.0 milligrams per square centimeter (≥ 1.0 mg/cm2) are classified as coated with LBP. Paints with concentrations of lead detectable by the XRF are considered lead-containing paints. Additionally, fixtures or components that are manufactured with a factory applied glazing (i.e., sinks, toilets, ceramic tiles, etc.) are tested as these factory-applied finishes often contain lead. Activities which disturb lead-containing paints and glazing (while not lead-based paints by the U.S. EPA definition) are regulated by OSHA (29 CFR 1926.62).

Because the current or proposed use of the property is not residential or child-occupied, the scope of the LBP survey was not conducted in accordance with HUD Chapter 7 requirements. This representative survey included taking readings from walls, windows, doors, and miscellaneous components. Walls are listed by letter with wall “A” being the entrance of the subject building, proceeding clockwise to “B, C, D”, etc.

4.0 RESULTS

The following is a summary of laboratory results, findings and observations.

4.1 Asbestos-Containing Materials

In total, 22 bulk samples from 8 homogeneous areas were submitted to the laboratory of which 26 layers were analyzed.

An Asbestos-Containing Material (ACM) is defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, PLM. Materials are categorized by the U.S. EPA in the following categories:

• Friable ACMs are defined as any ACM that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Non-friable ACMs are defined as any ACM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

• Category I non-friable ACM are listed as following: packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than one percent (>1%) asbestos.

• Category II non-friable ACM are listed as any material, excluding Category I non-friable ACM, containing more than one percent (>1%) asbestos.

Regulated Asbestos Containing Materials (RACM) are friable ACM or non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading or has crumbled, been pulverized, or reduced to powder in the course of renovation and/or demolition operations.

EMSL Analytical, Inc. submitted signed final laboratory report to ECS on November 15, 2017 and November 20, 2017. None of the bulk samples submitted for analysis were reported to contain asbestos in detectable concentrations.

None of the materials submitted for analysis to EMSL Analytical, Inc. were reported to contain asbestos. Asbestos-Containing Material (ACMs) are defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, PLM. A list of materials sampled and submitted for analysis and their reported analytical results can be found in the Appendix.

4.2 Suspect or Assumed Asbestos-Containing Materials

Due to the inaccessibility or the destructive means that asbestos sampling requires, additional suspect ACMs may remain within the building hidden behind inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, sub-grade sealants, flooring located below underlayments, areas behind exterior walls, pipe trenches, and subsurface utilities, etc.

These areas were deemed inaccessible and were not assessed.

If these materials are discovered during construction activities, they should be presumed to contain asbestos and be treated as ACMs or be sampled immediately upon discovery and prior to disturbance for asbestos content by a certified asbestos inspector in accordance with 29 CFR 1926.1101.

4.3 Lead in Paint and Surface Coatings

Paint and surface coatings which contain detectable concentrations of lead considered “lead-containing paints”. Since OSHA has no specific action level for lead in paint, all paint on the site found to have a measurable concentration of lead should be assumed to be lead containing. Work performed which may disturb lead-containing paint is regulated under OSHA as referenced under 29 CFR 1926.62.