S06_Amendment-0003_Attach-1_Hazardous Materials Survey Report.pdf

Asbestos, Lead-Containing Paint, and Visual Microbial Assessment Report

Little Rock National Cemetery

Administrative and Maintenance Buildings 2523 Springer Blvd

Little Rock, Arkansas August 12, 2021

Terracon Project No. 35217176

Prepared for:

Cox Design and Associates

Austin, Texas

Prepared by:

Terracon Consultants, Inc.

Bryant, Arkansas

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TABLE OF CONTENTS

Page No.

1.0 INTRODUCTION

1.1 Project Objective

1.2 Reliance

2.0 BUILDING DESCRIPTION

3.0 ASBESTOS SURVEY FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Asbestos Regulatory Overview

4.0 LEAD-CONTAINING PAINT FIELD Activities

4.1 Site Limitations

4.2 Methodology and Analysis

4.3 Lead-Containing Paint Regulatory Overview

5.0 VISUAL MICROBIAL ASSESSMENT

6.0 FINDINGS AND RECOMMENDATIONS

7.0 GENERAL COMMENTS

LIST OF APPENDICES

Appendix A Asbestos Survey Sample Summary Appendix B Confirmed Asbestos Containing Material Appendix C Asbestos Analytical Laboratory Data Appendix D Lead Paint Sample Summary Appendix E Lead Paint Analytical Laboratory Data Appendix F Diagram Appendix G Photo Log Appendix H Certifications

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ASBESTOS & LEAD-CONTAINING PAINT SURVEY

AND VISUAL MICROBIAL ASSESSMENT REPORT

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

EXECUTIVE SUMMARY

Terracon Consultants, Inc. (Terracon) conducted an asbestos survey and lead-containing paint survey and visual microbial assessment of the administrative and maintenance buildings at the Little Rock National Cemetery in Little Rock, Arkansas. The purpose of this survey was to identify and sample suspect asbestos-containing materials (ACM) and lead-containing paints (LCP) and to provide information regarding the identity, locations, condition and approximate quantities of ACM and LCP that may require special handling and waste disposal as part of planned building renovation. In addition, a visual microbial assessment was conducted to determine the presence of suspect microbial growth within the subject buildings.

A State of Arkansas certified asbestos inspector conducted the asbestos survey on July 27, 2021 in general accordance with the sampling protocols established in Environmental Protection Agency (EPA) 40 Code of Federal Regulations (CFR) 763, the Asbestos Hazard Emergency Response Act (AHERA), and Terracon Proposal No. P35217176 dated July 26, 2021.

Terracon collected 21 bulk samples from seven homogenous areas of suspect ACM observed from the maintenance building. Asbestos was identified in the samples collected from the maintenance building. Terracon collected 14 bulk samples from four homogeneous areas of suspect ACM observed in the administrative building. Asbestos was not identified in the samples collected from the administrative building.

Confirmed regulated ACM (RACM), including ACM that will be rendered friable, must be removed prior to any renovation operations which could disturb the identified RACM. Removal of RACM from the maintenance building must be conducted by trained and State of Arkansas-licensed asbestos abatement contractor working under the requirements of the Arkansas Department of Environmental Quality (ADEQ). In addition, third party clearance air monitoring must be performed following the abatement.

The owner or operator must provide the ADEQ with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities.

Terracon collected two samples of suspect LCP from various painted surfaces observed throughout the administrative building and six samples of suspect LCP from various painted surfaces observed throughout the maintenance building. Lead in concentrations above the analytical limit of detection

Asbestos, Lead Paint, and Visual Microbial Assessment Little Rock National Cemetery ■ Little Rock, Arkansas August 12, 2021 ■ Terracon Project No. 35217176

Responsive ■ Resourceful ■ Reliable ii was identified in paint samples from the maintenance building. Lead in concentrations above the analytical limit of detections was not identified in the samples from the administration building.

Occupational Safety and Health Administration (OSHA) regulations govern exposure of workers to lead, regardless of the concentration of lead identified. OSHA 29 CFR 1926.62 and 1910.1025, which have been established for general and construction industries, cover any type of workplace activity that could expose an employee to potential lead contamination. Any contractor and/or workers conducting any renovation, repair or demolition activities should be notified of these findings and the contractor should be tasked with determining whether lead-safe work practices are to be employed and/or whether personnel should be provided personal protective equipment (PPE). All occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to OSHA 29 CFR 1926.62.

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 averaged over an eight-hour period without adequate protection. Utilizing lead-safe work practices is recommended to reduce employee exposure during activities that disturb or generate lead dust.

Terracon conducted visual observations of the interior of the administrative and maintenance buildings for obvious indications of visible mold growth. The observations included visibly accessible surfaces but did not include observations of hidden conditions such as inaccessible areas, interiors of wall cavities, interiors of heating, ventilation and air conditioning (HVAC) systems, or behind intact wall coverings. The scope of this limited visual observation for mold should not be construed as a comprehensive mold assessment.

Terracon observed suspect mold growth throughout the administrative building. Site personnel indicated that a water pipe had broken approximately six months prior to the survey and caused damage to the ceiling, walls, and flooring. Portions of the ceiling had collapsed and floor tile had been removed from portions of the building. Significant suspect microbial growth was observed throughout the building on walls, floors, ceilings, HVAC systems, furniture, and cabinets.

Additional microbial growth is likely present inside wall cavities and areas not accessible during the survey.

Terracon observed suspect water damaged plaster ceiling indication possible microbial growth within unaccusable areas above the water heater closet in the maintenance building.

Please refer to the main report for details.

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ASBESTOS, LEAD-CONTAINING PAINT

AND VISUAL MICROBIAL ASSESSMENT REPORT

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted an asbestos-containing material (ACM) and lead-containing paint (LCP) survey and visual microbial assessment of administrative and maintenance buildings located at the Little Rock National Cemetery in Little Rock, Arkansas. We understand the survey and assessment were conducted to facilitate renovation of the structures. This survey was conducted in general accordance with Terracon Proposal No. P35217176 dated July 26, 2021.

Interior and exterior building components were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented. Although reasonable effort was made to survey accessible suspect materials, additional suspect but unsampled materials could be in walls, in voids or in other concealed areas. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA). Samples were delivered to an accredited laboratory for analysis by Polarized Light Microscopy (PLM). The roofs were included in the survey.

1.1 Project Objective

The purpose of this survey was to identify and sample suspect ACM and LCP. This survey provides information regarding the identity, locations, condition, and approximate quantities of ACM and LBP that may require special handling and waste disposal as part of the renovation of the structures.

We understand this asbestos survey was requested due to the planned renovation of the subject buildings. 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 ACM (RACM) be identified, classified and quantified prior to planned disturbances or renovation activities.

The OSHA Lead Standard for Construction (29 CFR 1926.62) requires employers to identify lead hazards prior to any work related to construction, alteration, or repair (including painting and decorating). OSHA considers paint containing any level of lead above the analytical method detection limit a potential hazard which should be communicated to any employees or contractors who may disturb the materials in the course of their assigned work.

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In addition to the ACM and LCP survey, Terracon conducted visual observations of the interior of the administrative and maintenance buildings for obvious indications of visible mold growth.

1.2 Reliance

This report is for the exclusive use of Cox Design and Associates (Cox) for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and Cox. Reliance on this report by Cox and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report and our agreement for services with Cox.

2.0 BUILDING DESCRIPTION

Administrative Building The building is a one-story vacant administrative building measuring approximately 1,700 square feet. The building is comprised of a wood frame on a slab foundation. Exterior walls consist of brick and stucco. Floors consist of resilient floor tile and unfinished concrete. The interior walls and ceilings are composed of drywall. Heating, ventilation, and air conditioning (HVAC) units were observed in the HVAC closet. The roof consist of metal.

It should be noted that the administrative building was significantly damaged by a water event related to broken water pipes. Site personnel indicated that a water pipe had broken approximately six months prior to the survey and caused damage to the ceiling, walls, and flooring. Portions of the ceiling had collapsed and floor tile had been removed from portions of the building. Significant suspect microbial growth was observed throughout the building on walls, floors, ceilings, HVAC systems, furniture, and cabinets.

Maintenance Building The building is a one-story occupied maintenance building measuring approximately 3,000 square feet. The building is comprised of a wood, brick, and concrete masonry unit (CMU) block frame on a concrete foundation. Exterior walls consist of brick. Floors consist of unfinished concrete, ceramic floor tile, and resilient floor tile. The interior walls are composed of drywall and CMU block. Ceilings consist of plaster, and wood. HVAC window units and gas heating units were located within the building. The roof was composed of asphalt shingles.

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3.0 ASBESTOS SURVEY FIELD ACTIVITIES

Mr. Jody Adams, a State of Arkansas certified asbestos inspector, conducted the survey on July 27, 2021 in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, the AHERA; a copy of Mr. Adams’ asbestos inspector training certificate is attached in Appendix H. A summary of survey activities is provided below.

3.1 Visual Assessment

Our survey activities began with visual observation of accessible areas on the interior, exterior of the buildings to identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color, texture and date of application;

Building materials identified as concrete, glass, wood, masonry, metal or rubber were not considered suspect ACM. The roofs and restrooms in the maintenance building were not included in the survey.

Terracon lifted floor coverings in several areas, where possible, but did not observe additional floor coverings/layers except where noted; however, as Terracon could not assess beneath all floor coverings in all areas, there may be isolated areas of additional suspect material present beneath existing flooring.

3.2 Physical Assessment

Terracon conducted a physical assessment of each HA of suspect ACM observed to assess the friability and condition of the materials. EPA defines a friable material as a material which, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Terracon assessed friability by physically touching suspect materials.

3.3 Sample Collection

Based on results of the visual observation, Terracon collected random bulk samples from each HA of suspect ACM in general accordance with EPA sampling protocols 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.

Terracon collected 14 bulk samples from four homogenous areas of suspect ACM observed from the administrative building and 21 bulk samples from seven homogeneous areas of suspect ACM observed in the maintenance building. A summary of suspect ACM samples collected is included as Appendix A.

Suspect ACM samples were delivered under proper chain of custody to Moody Labs of Farmers Branch, Texas for analysis by PLM with dispersion staining techniques per EPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93-116). The percentage of asbestos, where applicable, was determined by microscopic visual estimation. Moody Labs is accredited

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3.4 Asbestos Regulatory Overview

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under NESHAP, asbestos-containing building materials are classified as either friable, Category I nonfriable or Category II nonfriable ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Category I nonfriable ACM includes packings, gaskets, resilient floor coverings and asphalt roofing products containing more than 1% asbestos. Category II nonfriable ACM are any materials other than Category I materials that contain more than 1% asbestos.

Friable ACM, Category I and Category II nonfriable ACM which is in poor condition and has become friable or which will be subjected to drilling, sanding, grinding, cutting or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM). A memo issued by the Arkansas Department of Environmental Quality (ADEQ) on December 19, 2006, clarifies that Category I nonfriable ACM becomes RACM if it has become friable or it will be or has been subjected to sanding, grading, cutting, or abrading, whether by manual or mechanical means.

RACM must be removed prior to renovation or demolition activities which will disturb the materials.

In the state of Arkansas, asbestos activities are regulated by the ADEQ. The ADEQ requires that asbestos-related activities conducted in a public building be performed by personnel licensed by the ADEQ. The owner or operator must provide the ADEQ with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities. Asbestos abatement must be performed by ADEQ-licensed asbestos abatement contractors in accordance with a Project Design prepared by an ADEQ-licensed Asbestos Consultant. Clearance air monitoring must be conducted following the abatement activities; a third-party air monitor is recommended.

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

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4.0 LEAD-CONTAINING PAINT FIELD ACTIVITIES

Terracon performed the lead-containing paint survey to identify lead hazards and lead-containing paint that may be present in the buildings prior to renovation and/or demolition activities. This information is necessary for contractors to comply with OSHA regulation 29 CFR 1926.62 Safety and Health Regulations for Construction – Lead.

Terracon performed the on-site survey and sampling on July 27, 2021. Terracon collected two samples from the administrative building and six samples from the maintenance building from various paint surfaces observed by removing the paint over a small sampling area. Samples were generally obtained from heights less than five feet (5’) above the floor.

The bulk samples were submitted to IATL of Mt. Laurel, New Jersey for analysis using appropriate chain-of-custody procedures. The samples were analyzed utilizing Atomic Absorption (SW 846 3050/7000B) and the analytical results reported in percentage by weight.

4.1 Site Limitations

Suspect LCP other than those identified during the sampling may be present in the buildings. This LCP testing is not considered to be comprehensive in nature and the results are not intended to identify all lead hazards present in the building or to be used to prepare detailed cost estimates for abatement. Based on information provided by the client, the building is proposed for renovation. Suspect LCP which have not been specifically evaluated should be tested prior to disturbance of the material. If additional suspect LCP is identified during the renovation process, those materials should be assumed LCP pending sampling and analysis to rebut the presence of lead.

4.2 Methodology and Analysis

The lead paint testing was conducted by scraping approximately 2 square inches of paint from the supporting substrate. Sample results reported below the limit of detection may contain lead at a concentration below the analytically defined limit. A summary of the lead paint samples and analysis is included in Appendix D.

As a point of reference, Housing and Urban Development (HUD) have defined lead-based paint (LBP) as a paint or other surface coating that contain >5,000 ppm of lead or more than 0.5% of lead by weight for buildings that meet the definition of target housing or child occupied facilities.

OSHA, however, defines LBP as a paint which contains lead, regardless of the concentration.

Due to the nature of the site the OSHA regulations will apply to the renovation activities which impact paint or coatings containing detectable concentrations of lead.

No materials were assumed to be LCP or LBP. Any inaccessible areas that contain painted surfaces should be tested when access permits or should be assumed to contain lead.

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4.3 Lead-Containing Paint Regulatory Overview

Occupational Safety and Health Administration (OSHA) regulations govern exposure of workers to lead, regardless of the concentration of lead identified. OSHA 29 CFR 1926.62 and 1910.1025, which have been established for general and construction industries, cover any type of workplace activity that could expose an employee to potential lead contamination. Any contractor and/or workers conducting any renovation, repair or demolition activities should be notified of these findings and the contractor should be tasked with determining whether lead-safe work practices are to be employed and/or whether personnel should be provided personal protective equipment (PPE). All occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to OSHA 29 CFR 1926.62.

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 averaged over an eight-hour period without adequate protection. Utilizing lead-safe work practices is recommended to reduce employee exposure during activities that disturb or generate lead dust.

5.0 VISUAL MICROBIAL ASSESSMENT

The visual assessment was conducted to identify the presence of visible suspect fungal growth.

The inspection focused primarily on collecting observational data (e.g., information obtained by inspection of the building, interviews with the building management, owners, and occupants). The assessment consisted of a walkthrough of the buildings.

The observations included visibly accessible surfaces in the building areas visited and did not include observations of hidden conditions such as inaccessible areas, interior of wall cavities, interior of heating, ventilation and air conditioning (HVAC) systems, or behind intact wall coverings. Terracon did not attempt to identify sources of moisture intrusion that may have been the source of suspect fungal growth.

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6.0 FINDINGS AND RECOMMENDATIONS

ASBESTOS

Asbestos was identified in the following materials in the maintenance building:

Blue and white 12”x12” floor tile and associated black mastic (two layers) Tan exterior caulking Cement pipe

The 12”x12” floor tile (blue and white, two layers) and associated black mastic is located in the office and break room and is classified as Category I nonfriable ACM in good condition.

The tan gray caulk is located on the exterior of the building around garage bay doors and is classified as Category II nonfriable ACM in good condition.

The cement pipe is located in the entry way of the storage room and is classified as Category II nonfriable RACM in good condition.

Asbestos was not identified in the samples collected from the administrative building.

A summary of the classification, condition and approximate quantity of identified and assumed ACM are presented in Appendix B. Laboratory analytical reports are included in Appendix C.

Confirmed regulated ACM (RACM), including ACM that will be rendered friable or subjected to sanding, grinding, cutting, or abrading, must be removed prior to any renovation operations which could disturb the identified RACM. Any removal of RACM associated with the structure is required to be conducted by trained and licensed asbestos abatement personnel working under the requirements of the Arkansas Department of Environmental Quality (ADEQ).

The OSHA standard classifies construction and maintenance activities which could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

It should be noted that suspect ACM other than those identified during the July 27, 2021 survey may exist within the buildings. Should additional suspect ACM be uncovered prior to or during the abatement and/or renovation process, those materials should be assumed ACM until sampling and analysis can confirm or rebut their asbestos content.

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LEAD-CONTAINING PAINT

The following materials were determined to contain concentrations of lead above the limit of detection for the analytical method performed and are subject to the OSHA Lead Standard for Construction for LCP:

Maintenance Building Blue on interior wood trim White on interior wood walls and plaster ceiling Gray on brick in garage bays Yellow on metal beam in garage bay Yellow and black on metal guard post on exterior of garage bays

The following materials were determined to contain concentrations of lead below the limit of detection for the analytical method performed and are exempt from regulation under the OSHA Lead Standard for Construction:

Administrative Building Tan on interior drywall walls Brown on exterior metal doors

Maintenance Building Tan on metal exterior garage bay doors and frames

The lead paint sample summary is provided in Appendix D; the laboratory analytical reports are presented in Appendix E.

Any contractor and/or workers conducting any renovation, repair or demolition activities should be notified of these findings and the contractor should be tasked with determining whether lead-safe work practices are to be employed and/or whether personnel should be provided personal protective equipment (PPE).

It should be understood, however, that OSHA regulations govern exposure of workers to lead, regardless of the concentration of lead identified. The OSHA regulations, which have been established for general and construction industries, cover any type of workplace activity that could expose an employee to potential lead contamination (OSHA Standards 29 CFR 1926.62 and 1910.1025).

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MICROBIAL OBSERVATIONS

Terracon observed suspect mold growth throughout the administrative building. Site personnel indicated that a water pipe had broken approximately six months prior to the survey and caused damage to the ceiling, walls, and flooring. Portions of the ceiling had collapsed and floor tile had been removed from portions of the building. Significant suspect microbial growth was observed throughout the building on walls, floors, ceilings, HVAC systems, furniture, and cabinets.

Additional microbial growth is likely present inside wall cavities and areas not accessible during the survey.

Terracon observed suspect water damaged plaster ceiling indication possible microbial growth within unaccusable areas above the water heater closet in the maintenance building.

Terracon’s observations were limited to visibly accessible surfaces and did not include observations of hidden conditions such as inaccessible areas, interiors of wall cavities, interiors of heating, ventilation and air conditioning (HVAC) systems, or behind intact wall coverings. The scope of this limited visual observation for mold should not be construed as a comprehensive mold assessment.

7.0 GENERAL COMMENTS

This asbestos lead-containing paint survey and microbial assessment 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 survey and assessment of the subject buildings. The information contained in this report is relevant to the date on which this survey was performed and should not be relied upon to represent conditions later.

This report has been prepared on behalf of and exclusively for use by Cox Design and Associates 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

ASBESTOS SURVEY SAMPLE SUMMARY

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

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SAMPLE

NO. DESCRIPTION MATERIAL LOCATION

Administrative Building A1-1 Drywall with texture Entrance A1-2 Drywall with texture Meeting room A1-3 Drywall with texture Kitchen A1-4 Drywall with texture Restroom A1-5 Drywall with texture Restroom A2-1 12”x12” Floor tile (cream with mastic) Kitchen A2-2 12”x12” Floor tile (cream with mastic) Kitchen A2-3 12”x12” Floor tile (cream with mastic) Kitchen A3-1 Cove base (brown) with mastic Meeting room A3-2 Cove base (brown) with mastic Entrance A3-3 Cove base (brown) with mastic Restroom A4-1 Stucco Exterior A4-2 Stucco Exterior A4-3 Stucco Exterior

Maintenance Building

1-1 12”X12” Floor tile (blue) with mastic (two layers) Office

1-2 12”X12” Floor tile (blue) with mastic (two layers) Break room

1-3 12”X12” Floor tile (blue) with mastic (two layers) Break room

2-1 12”X12” Floor tile (white) with mastic (two layers) Break room

2-2 12”X12” Floor tile (white) with mastic (two layers) Break room

2-3 12”X12” Floor tile (white) with mastic (two layers) Office

3-1 Plaster Break room ceiling 3-2 Plaster Break room ceiling 3-3 Plaster Break room ceiling 4-1 Shingles (gray) with felt Roof 4-2 Shingles (gray) with felt Roof 4-3 Shingles (gray) with felt Roof 5-1 Caulk (tan) Exterior garage doors 5-2 Caulk (tan) Exterior garage doors 5-3 Caulk (tan) Exterior garage doors 6-1 Mortar and grout (gray) Storage room

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

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SAMPLE

NO. DESCRIPTION MATERIAL LOCATION

6-2 Mortar and grout (gray) Storage room 6-3 Mortar and grout (gray) Storage room 7-1 Cement pipe Storage room 7-2 Cement pipe Storage room 7-3 Cement pipe Storage room

APPENDIX B

CONFIRMED ASBESTOS CONTAINING MATERIALS

APPENDIX B

CONFIRMED ASBESTOS CONTAINING MATERIALS

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

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HA No. Description Material Location

Percent/Type Asbestos

NESHAP

Classification Condition Estimated

Quantity*

1 and 2 12”x12” Floor tile (blue and white/two layers) and associated black mastic

Break room and office of maintenance building

ND – Top tile ND – Yellow mastic ND – Black mastic 3% C – Bottom tile

5% C – Black mastic

Category I Nonfriable ACM Good 260 sf

5 Caulking (tan)

Exterior garage doors of maintenance building

5% C – Caulking Category II Nonfriable ACM Good 120 lf

7 Cement pipe Storage room in maintenance building

15% C – Cement asbestos pipe

2% C – Cement asbestos pipe

RACM Good 12 lf

HA = homogeneous area RACM = Regulated asbestos containing material

* Quantities are estimates only.

sf = square feet lf = linear feet ND = None detected C = Chrysotile asbestos NA = Not applicable

APPENDIX C

ASBESTOS ANALYTICAL LABORATORY DATA

PLM Summary Report

Client :

Project :

Project # :

Identification :

Test Method :

Terracon - Bryant

National Cemetery, Little Rock, Maintenance

35217176

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 7/30/2021, twenty one (21) bulk material samples were submitted by Jody Adams of Terracon - Bryant for asbestos analysis by PLM/DS. The PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

21B-09927

07/27/2021

08/04/2021

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116

2051 Valley View Lane Farmers Branch, TX 75234 Phone: (972) 241-8460

1-1 12" x 12" Floor Tile (Blue) with Mastic, 2nd Layer, Break Room

None Detected - Floor Tile None Detected - Yellow Mastic

1-2 12" x 12" Floor Tile (Blue) with Mastic, 2nd Layer, Break Room

None Detected - Top Tile None Detected - Yellow Mastic None Detected - Black Mastic 3% Chrysotile - Bottom Tile 5% Chrysotile - Black Mastic

1-3 12" x 12" Floor Tile (Blue) with Mastic, 2nd Layer, Office None Detected - Floor Tile None Detected - Black Mastic

2-1 12" x 12" Floor Tile (White) with Mastic, 2nd Layer, Break Room

None Detected - Top Tile None Detected - Yellow Mastic None Detected - Black Mastic 3% Chrysotile - Bottom Tile 5% Chrysotile - Black Mastic

2-2 12" x 12" Floor Tile (White) with Mastic, 2nd Layer, Break Room

None Detected - Top Tile None Detected - Yellow Mastic None Detected - Black Mastic 3% Chrysotile - Bottom Tile 5% Chrysotile - Black Mastic

2-3 12" x 12" Floor Tile (White) with Mastic, 2nd Layer, Office None Detected - Top Tile None Detected - Black Mastic None Detected - Bottom Tile None Detected - Black Mastic

3-1 Plaster Ceiling, Break Room None Detected - Plaster

3-2 Plaster Ceiling, Break Room None Detected - Plaster

3-3 Plaster Ceiling, Break Room None Detected - Plaster

4-1 Shingles (Gray) with Felt, Roof None Detected - Roofing Shingle None Detected - Roofing Felt

4-2 Shingles (Gray) with Felt, Roof None Detected - Roofing Shingle None Detected - Roofing Felt

Project :

Project # :

Identification :

Test Method :

Terracon - Bryant

National Cemetery, Little Rock, Maintenance

35217176

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 7/30/2021, twenty one (21) bulk material samples were submitted by Jody Adams of Terracon - Bryant for asbestos analysis by PLM/DS. The PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

21B-09927

07/27/2021

08/04/2021

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116

2051 Valley View Lane Farmers Branch, TX 75234 Phone: (972) 241-8460

4-3 Shingles (Gray) with Felt, Roof None Detected - Roofing Shingle None Detected - Roofing Felt

5-1 Caulk (Tan), Exterior Garage Doors 5% Chrysotile - Caulking

5-2 Caulk (Tan), Exterior Garage Doors 5% Chrysotile - Caulking

5-3 Caulk (Tan), Exterior Garage Doors 5% Chrysotile - Caulking

6-1 Mortar and Grout (Gray), Storage Room None Detected - Ceramic Tile None Detected - Grout None Detected - Mortar

6-2 Mortar and Grout (Gray), Storage Room None Detected - Ceramic Tile None Detected - Grout None Detected - Mortar

6-3 Mortar and Grout (Gray), Storage Room None Detected - Ceramic Tile None Detected - Grout None Detected - Mortar

7-1 Cement Pipe, Storage Room 15% Chrysotile - Cement Asbestos Pipe

7-2 Cement Pipe, Storage Room 15% Chrysotile - Cement Asbestos Pipe 2% Crocidolite - Cement Asbestos Pipe

7-3 Cement Pipe, Storage Room 15% Chrysotile - Cement Asbestos Pipe 2% Crocidolite - Cement Asbestos Pipe

Daniel FarleyAnalyst(s):

Lab Director : Bruce Crabb Approved Signatory :

Thank you for choosing Moody Labs

Lab Manager : Heather Lopez Approved Signatory :

These samples were analyzed by layers. Quantification, unless otherwise noted, is performed by calibrated visual estimate. The test report shall not be reproduced except in full without written approval of the laboratory. The results relate only to the items tested. These test results do not imply endorsement by NVLAP or any agency of the U.S.

Government. Accredited by the National Voluntary Laboratory Accreditation Program for Bulk Asbestos Fiber Analysis under Lab Code 102056-0.

PLM Detail Report

Project # : 35217176

Sample Number Layer Components % Of

Sample Analysis

Date % of Layer

Analyst

Supplement to PLM Summary Report

Client :

Project :

Terracon - Bryant

National Cemetery, Little Rock, Maintenance

Lab Job No. :

Report Date :

21B-09927

08/04/2021

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

Moody Labs NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Calcite / Vinyl Binders1-1 Floor Tile (Grey) 100% 08/04100% DF

Glue Binders1-1 Yellow Mastic (Yellow) <1% 08/04100% DF

Calcite / Vinyl Binders1-2 Top Tile (Grey) 48% 08/04100% DF

Glue Binders1-2 Yellow Mastic (Yellow) 1% 08/04100% DF

Tar Binders1-2 Black Mastic (Black) 3% 08/04100% DF

Chrysotile1-2 Bottom Tile (Light Grey) 46% 08/043% DF

Calcite / Vinyl Binders1-2 Bottom Tile (Light Grey) 46% 08/0497% DF

Chrysotile1-2 Black Mastic (Black) 2% 08/045% DF

Tar Binders1-2 Black Mastic (Black) 2% 08/0495% DF

Calcite / Vinyl Binders1-3 Floor Tile (Light Grey) 98% 08/04100% DF

Tar Binders1-3 Black Mastic (Black) 2% 08/04100% DF

Calcite / Vinyl Binders2-1 Top Tile (Grey) 62% 08/04100% DF

Glue Binders2-1 Yellow Mastic (Yellow) 3% 08/04100% DF

Tar Binders2-1 Black Mastic (Black) 2% 08/04100% DF

Chrysotile2-1 Bottom Tile (Light Grey) 30% 08/043% DF

Calcite / Vinyl Binders2-1 Bottom Tile (Light Grey) 30% 08/0497% DF

Chrysotile2-1 Black Mastic (Black) 3% 08/045% DF

Tar Binders2-1 Black Mastic (Black) 3% 08/0495% DF

Calcite / Vinyl Binders2-2 Top Tile (Grey) 70% 08/04100% DF

Glue Binders2-2 Yellow Mastic (Yellow) 4% 08/04100% DF

Tar Binders2-2 Black Mastic (Black) <1% 08/04100% DF

Chrysotile2-2 Bottom Tile (Light Grey) 25% 08/043% DF

Calcite / Vinyl Binders2-2 Bottom Tile (Light Grey) 25% 08/0497% DF

Chrysotile2-2 Black Mastic (Black) 1% 08/045% DF

Tar Binders2-2 Black Mastic (Black) 1% 08/0495% DF

Calcite / Vinyl Binders2-3 Top Tile (Light Grey) 58% 08/04100% DF

Tar Binders2-3 Black Mastic (Black) 2% 08/04100% DF

Calcite / Vinyl Binders2-3 Bottom Tile (Grey) 38% 08/04100% DF

Tar Binders2-3 Black Mastic (Black) 2% 08/04100% DF

Calcite / Binders3-1 Plaster (White) 100% 08/04100% DF

Sample Number Layer Components % Of

Sample Analysis

Date % of Layer

Analyst

Supplement to PLM Summary Report

Client :

Project :

Terracon - Bryant

National Cemetery, Little Rock, Maintenance

Lab Job No. :

Report Date :

21B-09927

08/04/2021

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

Moody Labs NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Calcite / Binders3-2 Plaster (White) 100% 08/04100% DF

Calcite / Binders3-3 Plaster (White) 100% 08/04100% DF

Sand4-1 Sand (Black) 10% 08/04100% DF

Glass Wool Fibers4-1 Roofing Shingle (Black) 50% 08/0425% DF

Calcite / Tar Binders4-1 Roofing Shingle (Black) 50% 08/0475% DF

Cellulose Fibers4-1 Roofing Felt (Black) 40% 08/0485% DF

Tar Binders4-1 Roofing Felt (Black) 40% 08/0415% DF

Sand4-2 Sand (Black) 10% 08/04100% DF

Glass Wool Fibers4-2 Roofing Shingle (Black) 55% 08/0425% DF

Calcite / Tar Binders4-2 Roofing Shingle (Black) 55% 08/0475% DF

Cellulose Fibers4-2 Roofing Felt (Black) 35% 08/0485% DF

Tar Binders4-2 Roofing Felt (Black) 35% 08/0415% DF

Sand4-3 Sand (Black) 10% 08/04100% DF

Glass Wool Fibers4-3 Roofing Shingle (Black) 75% 08/0425% DF

Calcite / Tar Binders4-3 Roofing Shingle (Black) 75% 08/0475% DF

Cellulose Fibers4-3 Roofing Felt (Black) 15% 08/0485% DF

Tar Binders4-3 Roofing Felt (Black) 15% 08/0415% DF

Chrysotile5-1 Caulking (White) 100% 08/045% DF

Calcite5-1 Caulking (White) 100% 08/0420% DF

Binders / Fillers5-1 Caulking (White) 100% 08/0475% DF

Chrysotile5-2 Caulking (White) 100% 08/045% DF

Calcite5-2 Caulking (White) 100% 08/0420% DF

Binders / Fillers5-2 Caulking (White) 100% 08/0475% DF

Chrysotile5-3 Caulking (White) 100% 08/045% DF

Calcite5-3 Caulking (White) 100% 08/0420% DF

Binders / Fillers5-3 Caulking (White) 100% 08/0475% DF

Sample Number Layer Components % Of

Sample Analysis

Date % of Layer

Analyst

Supplement to PLM Summary Report

Client :

Project :

Terracon - Bryant

National Cemetery, Little Rock, Maintenance

Lab Job No. :

Report Date :

21B-09927

08/04/2021

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

Moody Labs NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Sintered Clays6-1 Ceramic Tile (Orange) 75% 08/04100% DF

Aggregate6-1 Grout (Gray) 3% 08/0465% DF

Cement Binders6-1 Grout (Gray) 3% 08/0435% DF

Aggregate6-1 Mortar (Gray) 22% 08/0465% DF

Cement Binders6-1 Mortar (Gray) 22% 08/0435% DF

Sintered Clays6-2 Ceramic Tile (Orange) 5% 08/04100% DF

Aggregate6-2 Grout (Gray) 50% 08/0465% DF

Cement Binders6-2 Grout (Gray) 50% 08/0435% DF

Aggregate6-2 Mortar (Gray) 45% 08/0465% DF

Cement Binders6-2 Mortar (Gray) 45% 08/0435% DF

Sintered Clays6-3 Ceramic Tile (Orange) <1% 08/04100% DF

Aggregate6-3 Grout (Gray) 90% 08/0465% DF

Cement Binders6-3 Grout (Gray) 90% 08/0435% DF

Aggregate6-3 Mortar (Gray) 10% 08/0465% DF

Cement Binders6-3 Mortar (Gray) 10% 08/0435% DF

Chrysotile7-1 Cement Asbestos Pipe (Grey) 100% 08/0415% DF

Cement Binders7-1 Cement Asbestos Pipe (Grey) 100% 08/0485% DF

Chrysotile7-2 Cement Asbestos Pipe (Grey) 100% 08/0415% DF

Crocidolite7-2 Cement Asbestos Pipe (Grey) 100% 08/042% DF

Cement Binders7-2 Cement Asbestos Pipe (Grey) 100% 08/0483% DF

Chrysotile7-3 Cement Asbestos Pipe (Grey) 100% 08/0415% DF

Crocidolite7-3 Cement Asbestos Pipe (Grey) 100% 08/042% DF

Cement Binders7-3 Cement Asbestos Pipe (Grey) 100% 08/0483% DF

Project :

Project # :

Identification :

Test Method :

Terracon - Bryant

National Cemetery, Little Rock, Admin Building

35217176

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 7/30/2021, fourteen (14) bulk material samples were submitted by Jody Adams of Terracon - Bryant for asbestos analysis by PLM/DS. The PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

21B-09925

07/27/2021

08/04/2021

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116

2051 Valley View Lane Farmers Branch, TX 75234 Phone: (972) 241-8460

A1-1 Drywall with Texture, Entrance None Detected - Drywall Material None Detected - Texture

A1-2 Drywall with Texture, Meeting None Detected - Drywall Material None Detected - Texture

A1-3 Drywall with Texture, Kitchen None Detected - Drywall Material None Detected - Texture

A1-4 Drywall with Texture, Restroom None Detected - Drywall Material None Detected - Texture

A1-5 Drywall with Texture, Restroom None Detected - Drywall Material None Detected - Texture

A2-1 12" x 12" Floor Tile (Cream) with Mastic, Kitchen None Detected - Floor Tile None Detected - Yellow Mastic

A2-2 12" x 12" Floor Tile (Cream) with Mastic, Kitchen None Detected - Floor Tile None Detected - Yellow Mastic

A2-3 12" x 12" Floor Tile (Cream) with Mastic, Kitchen None Detected - Floor Tile None Detected - Yellow Mastic

A3-1 Cove Base (Brown) with Mastic, Meeting Room None Detected - Cove Base None Detected - Tan Mastic

A3-2 Cove Base (Brown) with Mastic, Entrance None Detected - Cove Base None Detected - Tan Mastic

A3-2 Cove Base (Brown) with Mastic, Restroom None Detected - Cove Base None Detected - Tan Mastic

A4-1 Stucco, Exterior None Detected - Stucco

A4-2 Stucco, Exterior None Detected - Stucco

A4-3 Stucco, Exterior None Detected - Stucco

Project :

Project # :

Identification :

Test Method :

Terracon - Bryant

National Cemetery, Little Rock, Admin Building

35217176

Asbestos, Bulk Sample Analysis

Sample Number Client Sample Description / Location Asbestos Content

Sample Date :

On 7/30/2021, fourteen (14) bulk material samples were submitted by Jody Adams of Terracon - Bryant for asbestos analysis by PLM/DS. The PLM Detail Report is attached; additional information may be found therein. The results are summarized below:

Lab Job No. :

Report Date :

21B-09925

07/27/2021

08/04/2021

NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Polarized Light Microscopy / Dispersion Staining (PLM/DS) EPA Method 600 / R-93 / 116

2051 Valley View Lane Farmers Branch, TX 75234 Phone: (972) 241-8460

Willie PruittAnalyst(s):

Lab Director : Bruce Crabb Approved Signatory :

Thank you for choosing Moody Labs

Lab Manager : Heather Lopez Approved Signatory :

These samples were analyzed by layers. Quantification, unless otherwise noted, is performed by calibrated visual estimate. The test report shall not be reproduced except in full without written approval of the laboratory. The results relate only to the items tested. These test results do not imply endorsement by NVLAP or any agency of the U.S.

Government. Accredited by the National Voluntary Laboratory Accreditation Program for Bulk Asbestos Fiber Analysis under Lab Code 102056-0.

Sample Number Layer Components % Of

Sample Analysis

Date % of Layer

Analyst

Supplement to PLM Summary Report

Client :

Project :

Terracon - Bryant

National Cemetery, Little Rock, Admin Building

Lab Job No. :

Report Date :

21B-09925

08/04/2021

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

Moody Labs NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Glass Wool FibersA1-1 Drywall Material (White) 65% 08/042% WP

Cellulose FibersA1-1 Drywall Material (White) 65% 08/041% WP

Gypsum / BindersA1-1 Drywall Material (White) 65% 08/0497% WP

Cellulose FibersA1-1 DW Paper Facing (Tan) 10% 08/04100% WP

Calcite / Talc / BindersA1-1 Texture (White) 25% 08/04100% WP

Glass Wool FibersA1-2 Drywall Material (White) 65% 08/042% WP

Cellulose FibersA1-2 Drywall Material (White) 65% 08/041% WP

Gypsum / BindersA1-2 Drywall Material (White) 65% 08/0497% WP

Cellulose FibersA1-2 DW Paper Facing (Tan) 10% 08/04100% WP

Calcite / Talc / BindersA1-2 Texture (White) 25% 08/04100% WP

Glass Wool FibersA1-3 Drywall Material (White) 65% 08/042% WP

Cellulose FibersA1-3 Drywall Material (White) 65% 08/041% WP

Gypsum / BindersA1-3 Drywall Material (White) 65% 08/0497% WP

Cellulose FibersA1-3 DW Paper Facing (Tan) 10% 08/04100% WP

Calcite / Talc / BindersA1-3 Texture (White) 25% 08/04100% WP

Glass Wool FibersA1-4 Drywall Material (White) 85% 08/042% WP

Cellulose FibersA1-4 Drywall Material (White) 85% 08/041% WP

Gypsum / BindersA1-4 Drywall Material (White) 85% 08/0497% WP

Cellulose FibersA1-4 DW Paper Facing (Tan) 10% 08/04100% WP

Calcite / Talc / BindersA1-4 Texture (White) 5% 08/04100% WP

Glass Wool FibersA1-5 Drywall Material (White) 35% 08/042% WP

Cellulose FibersA1-5 Drywall Material (White) 35% 08/041% WP

MicaA1-5 Drywall Material (White) 35% 08/04<1% WP

Gypsum / BindersA1-5 Drywall Material (White) 35% 08/0497% WP

Cellulose FibersA1-5 DW Paper Facing (Tan) 10% 08/04100% WP

Calcite / Talc / BindersA1-5 Texture (White) 55% 08/04100% WP

Calcite / Vinyl BindersA2-1 Floor Tile (Cream) 98% 08/04100% WP

Glue BindersA2-1 Yellow Mastic (Yellow) 2% 08/04100% WP

Calcite / Vinyl BindersA2-2 Floor Tile (Cream) 98% 08/04100% WP

Glue BindersA2-2 Yellow Mastic (Yellow) 2% 08/04100% WP

Sample Number Layer Components % Of

Sample Analysis

Date % of Layer

Analyst

Supplement to PLM Summary Report

Client :

Project :

Terracon - Bryant

National Cemetery, Little Rock, Admin Building

Lab Job No. :

Report Date :

21B-09925

08/04/2021

2051 Valley View Lane

Farmers Branch, TX 75234 Phone: (972) 241-8460

Moody Labs NVLAP Lab Code 102056-0

TDSHS License No. 30-0084

Calcite / Vinyl BindersA2-3 Floor Tile (Cream) 97% 08/04100% WP

Glue BindersA2-3 Yellow Mastic (Yellow) 3% 08/04100% WP

Calcite / Vinyl BindersA3-1 Cove Base (Brown) 90% 08/04100% WP

Glue BindersA3-1 Tan Mastic (Tan) 10% 08/04100% WP

Calcite / Vinyl BindersA3-2 Cove Base (Brown) 98% 08/04100% WP

Glue BindersA3-2 Tan Mastic (Tan) 2% 08/04100% WP

Calcite / Vinyl BindersA3-2 Cove Base (Brown) 98% 08/04100% WP

Glue BindersA3-2 Tan Mastic (Tan) 2% 08/04100% WP

AggregateA4-1 Stucco (Grey) 100% 08/0465% WP

Binders / FillersA4-1 Stucco (Grey) 100% 08/0435% WP

AggregateA4-2 Stucco (Grey) 100% 08/0465% WP

Binders / FillersA4-2 Stucco (Grey) 100% 08/0435% WP

AggregateA4-3 Stucco (Grey) 100% 08/0465% WP

Binders / FillersA4-3 Stucco (Grey) 100% 08/0435% WP

APPENDIX D

LEAD-CONTAINING PAINT SAMPLE SUMMARY

APPENDIX D

LEAD-CONTAINING PAINT SURVEY SAMPLE SUMMARY

Little Rock National Cemetery Administrative and Maintenance Buildings

2523 Springer Blvd Little Rock, Arkansas

Terracon Project No. 35217176

Responsive ■ Resourceful ■ Reliable

Sample No. Paint Color Paint Substrate Material Location Analytical Result (% by weight)

Administrative Building

L-7 Tan Gypsum board Interior <0.0067

L-8 Brown Metal Doors <0.0085

Maintenance Building

L-1 Blue Wood trim Office and break room 0.0076

L-2 White Wood walls and plaster ceiling

Office and break room 0.0061

L-3 Gray Brick Garage bays 0.012

L-4 Yellow Metal Beam 0.35

L-5 Tan Metal Exterior <0.011

L-6 Yellow and black Metal Guard post 0.92

APPENDIX E

LEAD PAINT ANALYTICAL LABORATORY DATA

Lab No.: 7264817 Client No.: L-1

Description: Blue Location:

Result (% by Weight): 0.0076 Result (ppm): 76 Comments:

Lab No.: 7264818 Client No.: L-2

Description: White Location:

Result (% by Weight): 0.0061 Result (ppm): 61 Comments:

Lab No.: 7264819 Client No.: L-3

Description: Grey Location:

Result (% by Weight): 0.012 Result (ppm): 120 Comments:

Lab No.: 7264820 Client No.: L-4

Description: Yellow Location:

Result (% by Weight): 0.35 Result (ppm): 3500 Comments:

Lab No.: 7264821 Client No.: L-5

Description: Tan Location:

Result (% by Weight): <0.011 Result (ppm): <110 Comments: *

Lab No.: 7264822 Client No.: L-6

Description: Yellow And Black Location:

Result (% by Weight): 0.92 Result (ppm): 9200 Comments: ***

Lab No.: 7264823 Client No.: L-7

Description: Tan Location:

Result (% by Weight): <0.0067 Result (ppm): <67 Comments:

Lab No.: 7264824 Client No.: L-8

Description: Brown Location:

Result (% by Weight): <0.0085 Result (ppm): <85 Comments:

Laboratory Director

Approved By:

Date Analyzed:

7/30/2021Date…