Key West International Airport Noise Insulation Program

Group 3

Volume 3 of 4 Lead-Based Paint Remediation Specification

Prepared for:

THE MONROE COUNTY BOARD OF COUNTY COMMISSIONERS

Michelle Lincoln, District 2 Mayor David Rice, District 4 Mayor Pro Tem Craig Cates, District 1 Commissioner Jim Scholl, District 3 Commissioner Holly Merrill Raschein, District 5 Commissioner

Prepared by:

Jacobs Project Management Co.

7108 Fairway Drive, Suite 170 Palm Beach Gardens, FL 33418

In Association with:

Deborah Murphy Lagos & Associates, LLC The Sun Group, Inc.

Jones & Conde, LLC

AirQuest Environmental, Inc.

February 2026

TABLE OF CONTENTS

TABLE OF CONTENTS – VOLUME 3 OF 4

LEAD-BASED PAINT REMEDIATION

Section A Summary of Findings Section B Lead Remediation Specifications

Appendix A Asbestos Containing Materials Inspection Reports Appendix B Lead-Based Paint Inspection Reports

LEAD-BASED PAINT REMEDIATION III-1

SECTION A

SUMMARY OF FINDINGS

The asbestos surveys were performed in compliance with the requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for an asbestos survey prior to renovation activities. Analysis was performed using PLM with dispersion staining.

NESHAP defines ACM as containing more than 1% asbestos as determined using PLM (as specified in Appendix E, Subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy).

Based on the results of these ACM inspections, samples containing more than 1% asbestos were recorded as follows:

TABLE 1

ASBESTOS CONTAINING MATERIALS

Address Asbestos Content %

2808 Staples Ave None Detected

2809 Flagler Ave None Detected

2832 Staples Ave None Detected

2908 Flagler Ave None Detected

3031 Flagler Ave None Detected

LEAD-BASED PAINT REMEDIATION III-2

The Lead-Based Paint (LBP) inspections were conducted to determine the presence of LBP that may be impacted by upcoming renovations. The reports were prepared in general accordance with “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing” 2012 revision published by the US Department of Housing and Urban Development (HUD).

The LBP inspections were conducted using an x-ray fluorescence (XRF) instrument. LBP was defined as any paint containing more than 1.0 milligrams per square centimeter (mg/cm2) lead as indicated on the XRF.

XRF results are classified as positive if they are greater than or equal to the current US HUD regulatory limit of 1.0 mg/cm2, and negative if they are less than this threshold.

Based on the results of these LBP inspections, XRF readings equal to or above the current US HUD regulatory limit of 1.0 mg/cm2 were recorded as follows:

TABLE 2

LEAD-BASED PAINT

Address Results Location

2808 Staples Ave Negative

2809 Flagler Ave Negative

2832 Staples Ave Negative

2908 Staples Positive

⮚ Eggshell Bedroom 2 Drywall Wall – Wall “B” (East) ⮚ White Living Room Wood Windowsill – Wall “A” (North) ⮚ White Living Room Wood Window Casing – Wall “A” (North) ⮚ White Bedroom 3 Wood Ceiling ⮚ White Exterior Wood Windowsill – Wall “A” North

3031 Flagler Ave Negative

LEAD REMEDIATION III-3

SECTION B

LEAD REMEDIATION

PART 1 - GENERAL

1.1 SUMMARY

A. Activities impacting lead-based paint (LBP) that are subject to the requirements of this section are detailed in the reports included in Appendix B.

B. All LBP identified will be handled in accordance with this specification, regardless of the quantity that will be disturbed.

C. No lead abatement, as defined in 40 CFR part 745, subpart L will be conducted.

1.2 REFERENCES

A. The following regulations, their appendices, memorandums, guidelines, attachments and other pertinent documents which form a part of these regulations shall apply in their entirety.

1. Title 40 CFR Part 261, Identification and Listing of Hazardous Waste.

2. Title 40 CFR Part 268, Land Disposal Restrictions.

3. Title 40 CFR Part 745, Lead; Renovation, Repair, and Painting Program; Final Rule.

4. Title 29 CFR Part 1910.134, Respiratory Protection Occupational Safety and Health Administration (OSHA) latest edition.

5. Title 29 CFR 1926.62, OSHA Lead Standard.

6. Title 29CFR 1910.1025, General Industry Lead Standard.

7. Title 49 CFR, Part 172, Hazardous Materials Tables and Hazardous Materials Communications Regulations, latest edition.

8. Lead Based Paint: The Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing, US Department of Housing and Urban Development (HUD) Guidelines.

9. The Lead Contractor shall have in his possession, at the jobsite and in view, one copy of this Specification.

10. Where a conflict exists between the requirements of this specification and any of the above-mentioned regulations, the most stringent shall be applicable.

LEAD REMEDIATION III-4

1.3 HEALTH WARNINGS

A. Contractors are warned that unprotected exposure to lead may result in damage to the blood, nervous system, kidneys, bones, heart, and reproductive system and contribute to high blood pressure. Care must be taken to avoid releasing or causing to be released, lead dust into the atmosphere. The Owner assumes no liability for damages, personal injuries, illness, disabilities or death to the Contractor, the Contractor’s employees, and other persons subject to the Contractor's control or to any other person including members of the general public, property owner or tenant, arising from, or incident to the purchase, use, disposition, subsequent operations performed on contact with or contributed to in any manner by the Contractor.

1.4 PROHIBITED ACTIVITIES

A. Prohibited activities include open flame burning/torching, using a heat gun above 1,100 degrees Fahrenheit (°F) and sanding, grinding, planning, needle gunning or blasting without a shroud and HEPA vacuum attachment.

1.5 DEFINITIONS

A. The term "Abatement" signifies any measure or set of measures designed to permanently eliminate lead-based paint hazards from the target housing or child-occupied facility as defined in 40 CFR part 745, subpart L. Abatement includes, but is not limited to:

1. The removal of lead-based paint and lead-contaminated dust, the permanent enclosure or encapsulation of lead-based paint, the replacement of lead-painted surfaces or fixtures, and the removal or covering of lead-contaminated soil.

2. Preparation, cleanup, disposal, and post-abatement clearance testing activities associated with such measures.

B. The term "Action Level" means an airborne concentration of lead of 30 micrograms per cubic meter of air calculated as an 8-hour time-weighted average (TWA).

C. The term “Certified Inspector” means an individual who has been trained and is certified by the Environmental Protection Agency (EPA) to conduct lead-based paint inspections.

D. The term "Child-occupied Facility" means a building, or portion of a building, constructed prior to 1978, visited regularly by the same child, 6 years of age or under, on at least two different days within any week (Sunday through Saturday period), provided that each day’s visit lasts at least 3 hours, and the combined weekly visit lasts at least 6 hours, and the combined annual visits last at least 60 hours. Child-occupied facilities may include, but are not limited to, day-care centers, preschools and kindergarten classrooms.

E. The term “Cleaning Verification Card” means a card developed and distributed, or otherwise approved, by the EPA for the purpose of determining, through comparison of wet and dry disposable cleaning cloths with the card, whether post-renovation cleaning has been properly completed.

LEAD REMEDIATION III-5

F. The term “Common Area” means a portion of a building that is generally accessible to all residents or users. Common areas include (but are not limited to) hallways, stairways, laundry rooms, recreation rooms, playgrounds, community centers and fenced areas whether interior or exterior spaces.

G. The term “Component” means a specific design or structural element, or fixture distinguished by its form, function, and location. A component can be located inside or outside the dwelling. Examples include (but are not limited to) ceilings, walls, floors, shelves, crown molding, trim, fences, handrails window sills and soffits.

H. The term "Containment" means a process to protect workers and the environment by controlling exposures to the lead-contaminated dust and debris created during a renovation, repair or painting project.

I. The term “Critical Barrier” indicates the perimeter of the enclosure within which lead disruption/removal work takes place. Critical Barriers may include existing floor, wall, and ceiling structures, as well as constructed partitions, closures and seals.

J. The term "Encapsulant” means a substance that forms a barrier between lead-based paint and the environment using a liquid- applied coating (with or without reinforcement materials) or an adhesively bonded covering material.

K. The term "Enclosure" means the use of rigid, durable construction materials that are mechanically fastened to the substrate in order to act as a barrier between lead-based paint and the environment.

L. The term "Exposure Assessment" means a determination of employee exposure for a given task measured by air sampling. The Assessment must meet the criteria for objective data as outlined in the OSHA Lead in Construction Standard (29 CFR 1926.62).

M. The term "Hazardous Waste" refers to a listed waste or any solid or liquid waste with one or more of the following characteristics: toxic, corrosive, flammable, explosive, combustible, oxidizer, pyrophoric, unstable (reactive) or water - reactive. This definition includes lead paint that has been removed from the substrate and has failed the TCLP for any reason.

N. The term "Inspection" means a surface-by-surface investigation to determine the presence of lead-based paint and the provision of a report explaining the results of the investigation.

O. The term "Lead-Based Paint" (LBP) is identified as paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams per square centimeter or more than

0.5 percent by weight or lesser value as defined by EPA.

P. The term "Lead-Based Paint Inspector/Certified Renovator" (LBP Inspector/CR) is defined as someone that is certified by the Environmental Protection Agency (EPA) to conduct lead-based paint inspections and/or is an EPA Certified Renovator.

Q. The term "Non-Hazardous Waste" refers to any solid or liquid waste not exhibiting

LEAD REMEDIATION III-6

characteristics of Hazardous Waste. This definition includes lead-based paint not removed from substrate and not failing TCLP for other characteristics. It also includes lead paint chips that do not fail the TCLP for any reason.

R. The term "OSHA PEL" stands for the Permissible Exposure Limit established by the Occupational Safety and Health Administration for lead exposure. The OSHA PEL refers to an airborne concentration of lead of 50 micrograms per cubic meter of air calculated as an 8-hour time-weighted average (TWA).

S. The term “Renovation” refers to a modification of all or part of any existing structure that disturbs a painted surface, including (but not limited to) removal/modification of painted surfaces, components or structures, surface preparation activities and window replacement as defined in 40 CFR part 745, subpart E.

T. The term “Renovator” means a person who either performs or directs workers who perform a renovation. A certified renovator is a renovator who has successfully completed a renovator course accredited by the EPA. Note: because the term renovation is broadly defined by the EPA rule “Lead-Based Paint Renovation, Repair and Painting Program” contractors such as electricians and plumbers may be considered “renovators” under this rule.

U. The term “RRP” stands for Title 40 CFR Part 745, Lead; Renovation, Repair, and Painting Program; Final Rule.

V. The term "TCLP" stands for Toxicity Characteristic Leaching Procedure and refers to one of the tests to determine if waste is to be disposed of as a Hazardous Waste or non-hazardous solid waste.

W. The term “Wet Disposable Cleaning Cloth” refers to a commercially available, pre-moistened, white disposable cloth designed to be used for cleaning hard surfaces such as countertops and uncarpeted floors.

1.6 CONTRACTOR QUALIFICATIONS

A. Contractor: The Contractor must be an EPA Licensed Lead Based Paint Contractor.

B. Training: The Contractor must employ an EPA Certified Renovator. The Contractor must have documented lead safe work practices training for all onsite workers.

C. Previous Experience. The Contractor must demonstrate substantial experience with similar projects and provide references and follow all applicable OSHA safety and health programs.

D. Demonstrated Ability of Workers: The Contractor must demonstrate that remediation workers have successfully completed the required EPA training regarding lead-based paint remediation.

E. Insurance: The Contractor must demonstrate that sufficient coverage is in force to meet Owner’s requirements.

LEAD REMEDIATION III-7

F. Permits: The Contractor shall secure, pay for, and maintain in full force and effect until no longer necessary, all necessary licenses, and permits required by federal and state law, local ordinance, statute or regulations relevant to the work.

G. Project Conditions: The Contractor shall acquaint himself/herself with all conditions that may affect the work as would be evident from a thorough investigation of the project site and the drawings and specifications covering the work.

1. It shall be the responsibility of the Contractor to carefully examine the physical condition of the project and coordinate all requirements and coordination of their work.

H. The Contractor shall be responsible for all tests to be performed with regard to his/her work, as required by Federal, State, and/or local regulation.

1.7 LBP Inspector/CR

A. Lead Based Paint Inspector/Certified Renovator (LBP Inspector/CR): The NIP Program Manager will provide the services of a third-party LBP Inspector/CR certified by the EPA to review and approve the Lead RRP Activities. The LBP Inspector/CR shall verify removal of material that tested positive for lead.

1.8 VERIFICATION OF HAZARDOUS MATERIALS

A. It is the Contractor's responsibility to verify that areas of work that have not been tested in the attached reports are free of lead, if additional materials are discovered during abatement activities. The Contractor is responsible for any verifications of lead testing as required in areas that have not been tested that are anticipated to be disturbed by the Work, at no additional cost to the Owner. The Contractor shall use the services of an EPA Lead Based Paint Inspector for this determination.

1.9 PRE-CONSTRUCTION MEETINGS

A. A pre-construction conference will be held to:

1. Inspect and discuss condition and extent of work to be performed on LBP materials.

2. Review and finalize the schedule.

3. Review requirements of work performed by other trades.

4. Coordinate work with other trades.

1.10 SUBMITTALS

A. Pre-Work Submittals

1. Within ten (10) weeks of the Notice to Proceed -Permits, the Contractor shall submit all required pre-abatement submittals to the NIP Program Manager. After

LEAD REMEDIATION III-8

completion of the submittal review, additional information may be required for clarification of or in support of documents submitted. Work will not commence until the NIP Program Manager has approved all submittals, including owner notifications, employee certifications and physicals. Should any part of the submittal be disapproved, the entire submittal will be returned to the Contractor until corrections are made.

2. Lead Inspection Reports

3. A current (within 1 year), relevant (similar activities and paint concentrations on proposed RRP workers) negative exposure assessment for all RRP activities, or

a. Physician’s Written Opinion (current within 1 year) for all RRP workers in accordance with OSHA’s Lead Standards (29 CFR 1910.1025 and 29 CFR 1926.62) and Respiratory Protection Standard (29 CFR 1910.134).

b. Current (within 6 months) blood lead levels for all RRP workers (29 CFR

1910.1025 and 29 CFR 1926.62)

c. Written Respiratory Protection Program in accordance with OSHA’s Respiratory Protection Standard (29 CFR 1910.134).

d. Fit Tests (current within 6 months) for all RRP workers in accordance with OSHA’s Respiratory Protection Standard (29 CFR 1910.134).

4. Documented RRP training for each RRP worker.

5. Documented RRP training for each RRP Contractor Renovator

6. Work Schedule: Provide starting date, completion date, days to be worked (weekdays/weekends) and hours to be worked.

7. Safety Data Sheets (SDS): Provide an SDS for each cleaning agent selected for use on this Project. Substitution of alternative products is not permitted once Safety Data Sheets are submitted without authorization of the NIP Program Manager and resubmittal of SDS for substituting cleaning agents.

8. Any request for variance from this specification shall be in writing and submitted to the NIP Program Manager at least ten (10) days in advance of the submittal date. Approval shall be at the discretion of the NIP Program Manager.

1.11 QUALITY ASSURANCE

A. Conform to all Federal, State, and Local regulations, guidelines and rules which govern the handling and disposal of lead impacted materials.

LEAD REMEDIATION III-9

B. Record Keeping:

1. The Contractor shall maintain a Daily Project Log consisting of a three (3) ring binder. The daily project log will be utilized each day to document the following information:

a. Date and time of the project

b. Name of Certified Renovator

c. Brief description of daily work activities

PART 2 - PRODUCTS

2.1 PROTECTIVE CLOTHING

A. The Contractor will provide the workers with the required protective disposable clothing as recommended in the referenced guidelines, consisting of full-body coveralls, head covers, gloves and boots.

B. The Contractor will not under any circumstances permit any person to enter the work areas without the appropriate protective clothing and equipment. The Contractor will provide protective clothing for use by the LBP Inspector/CR. The Contractor will furnish as many sets as required for monitoring.

2.2 RESPIRATORY PROTECTION

A. Respirators equipped with HEPA filters will be used, when required, and approved by the NIOSH.

B. Respirators will be individually fit-tested to personnel on a yearly basis.

C. No respirator will be issued to personnel without such personnel participating in a respiratory training program.

1. The Contractor shall provide and make available a sufficient quantity of respirator filters so that filter changes can be made as necessary during the workday.

Filters will be removed and discarded during the decontamination process.

Filters cannot be reused. Filters must be changed if breathing becomes difficult.

PART 3 – EXECUTION

3.1 LEAD RENOVATION, GENERAL

A. Conduct lead renovation, repair and painting activities in accordance with all state and federal regulations and guidelines.

B. Assign a Certified Renovator to the project that will remain on- site during all renovation, repair and painting work.

LEAD REMEDIATION III-10

C. Maintain at each job site and post the following documents:

1. Employee Respiratory Protection Program.

2. Company standard operating procedure.

3. This specification section.

4. Safety Data Sheets for products used on job.

5. EPA Renovator Certificates for each supervisor (initial and the most recent refresher).

6. Proof of lead awareness training and medical approvals for all workers on-site.

7. For renovations in common areas and childcare facilities post a written notification detailing the general nature and locations of the work and anticipated completion date.

8. For renovations in common areas and childcare facilities post a copy of the EPA lead pamphlet “Renovate Right- Important Lead Hazard Information for Families, Child Care Providers and Schools.”

D. Open-flame burning or torching of lead-based paint is prohibited.

E. Machine sanding, grinding, abrasive blasting and sandblasting of lead-based paint is prohibited, unless the sanding, grinding, blasting, or sandblasting is conducted using a shrouded tool with a high-efficiency particulate air (HEPA) exhaust control that removes particles of 0.3 microns or larger from the air at an efficiency of 99.97% or more.

F. Dry scraping of lead-based paint is permitted only in conjunction with heat guns or around electrical outlets. Operating a heat gun on lead-based paint is permitted only if the temperature generated by the heat gun is less than 1,100 oF.

3.2 HEALTH AND SAFETY REQUIREMENTS

A. Exposure Assessment: If the Contractor has made a previous Exposure Assessment that is representative of the task to be performed on-site, the Contractor may rely on this data and determine the need for personal protective equipment and work practice controls based upon this data, if approved by the NIP Program Manager.

B. Personal Air Monitoring: When the Contractor does not have an Exposure Assessment or the Assessment is determined to be insufficient, the Contractor must conduct personal air sampling in accordance with the OSHA’s Lead Standards (29 CFR

1910.1025 and 29 CFR 1926.62).

3.3 PREPARATION

A. General: Prepare Work Areas in a manner that will protect occupants and property and contain the work area so that no dust or debris leaves the work area.

LEAD REMEDIATION III-11

B. Preparing Building Exteriors: Ensure adequate measures are in place to prevent dust and debris from escaping the work area and to limit airborne lead content below the Action Level of 30 µg/m3 (micrograms per cubic meter) adjacent to the Work Area.

1. Erect barricades and install warning tape or signs as necessary to prevent inadvertent exposure of passersby to LBP in all forms, including, but not necessarily limited to dust, particles, and fumes.

2. Completely cover grounds and vegetation extending 10 feet beyond the perimeter or a sufficient distance to collect falling debris with minimum 8-mil thick polyethylene sheets with joints between sheets lapped and taped; with one edge taped to adjacent building surfaces below area of work; and with free ends secured in position with stakes, tie-down lines or weights. Cover sufficient ground area to capture wind-blown chips, dust and particles. Contractor is responsible for any paint debris found at project completion.

C. Preparing Building

1. Remove all objects from the work area or cover with plastic sheeting with all seams and edges sealed.

2. Cover the floor surface a minimum of six feet beyond the perimeter of the surfaces undergoing renovation or a sufficient distance to contain the dust, whichever is greater.

3. Post signs at all entrances to the work area that states the following (or equivalent):

LEAD WORK AREA

WARNING: POISON

NO SMOKING OR EATING

3.4 WORK PRACTICES

A. General: Perform renovation of LBP coated materials in compliance with the following requirements:

1. Restrict access to Work Area to essential personnel.

2. Use moist-removal methods where applicable. Do not over-saturate the Work Area.

3. For Transite shingles, carefully remove nails in each shingle and remove without breakage. If the shingle is broken, pick up all pieces and place in disposal bags.

4. Remove contaminated clothing and personal protective equipment before leaving the Work Area, or Work Area enclosure, as applicable.

5. If dust or debris is escaping the Work Area or if the Action Level is exceeded outside Work Area, discontinue work and modify Critical Barrier, or perform other modifications of methods or materials as required to prevent dust and debris

LEAD REMEDIATION III-12

from escaping.

6. Prohibit eating, drinking, and smoking in the Work Area.

7. Collect and contain all paint chips, debris, personal, protective equipment and protective sheeting, daily. Seal in heavy duty bags or drums to prepare for proper disposal.

8. Use precautions (such as tack mats, shoe covers. HEPA vacuuming and or wet wiping) to ensure that all personnel, tools, waste containers and other items are free of dust and debris when leaving the area.

3.5 POST RENOVATION CLEANING

A. Upon completion of work, mist the plastic sheeting and fold the plastic containment sheeting dirty side inward, after misting and seal edges or dispose of plastic in sealed bags.

B. Brushing, brooming and other dry methods that generate airborne dust are prohibited.

C. Remove and dispose of all solid waste used for protection and clean-up as Non- Hazardous Waste as indicated in Disposal Article (2.6) below.

D. After cleanup is complete a Certified Renovator must perform a visual inspection to determine if dust, debris or residue is present. If dust, debris or residue is present the area must be re-cleaned and the visual inspection repeated.

E. After the Certified Renovator is satisfied, the NIP Program Manager and LBP Inspector/CR will also perform a visual inspection to determine if dust, debris or residue is present. If dust, debris or residue is present the area must be re-cleaned and the visual inspection repeated.

F. After the visual inspection has passed, exterior areas are considered clean.

3.6 DISPOSAL

A. The Contractor will notify the NIP Program Manager in advance of the date and time that lead contaminated waste will be transported.

B. To prevent exceeding available storage capacity on site, sealed and labeled containers of contaminated waste periodically shall be removed and transported to the disposal site.

C. A completed generator label will be placed on each bag, drum, and wrapped component before transporting to the landfill site.

D. Upon the completion of documented analytical testing on all generated waste, all regulated lead contaminated waste shall be disposed of at an authorized site in accordance with regulatory requirements of the EPA, RCRA, National Pollutant Discharge Elimination System (NPDES) and applicable state and local guidelines and

LEAD REMEDIATION III-13

regulations.

E. Wet wipe all containers in Work Area prior to transfer to load-out. Wet wipe containers again in loadout area prior to transfer to disposal vehicle.

F. Temporary storage of lead contaminated waste at an intermediate location is not permitted except under special authorization from the NIP Program Manager.

APPENDIX A

ASBESTOS CONTAINING MATERIALS

INSPECTION REPORTS

Phone (954) 792-4549

Fax: (954) 792-2221 www.AirQuestInc.com

6851 Southwest 45th Street, Fort Lauderdale, FL 33314

AirQuest Project #19814

Limited Pre-Renovation Report of Building Material Survey, Sampling, and Evaluation of Asbestos Containing Materials

For:

Parcel 36 – McLaren, Sandra 2808 Staples Avenue Key West, Florida 33040

Mr. Ryan Forney Project Manager Jacobs Project Management Co.

Palm Beach Garden, Florida 33418

December 19, 2023

Asbestos Consulting Business #ZA-304

Project #19814 ii Limited Pre-Renovation Asbestos Survey

CERTIFICATION PAGE

Limited Pre-Renovation Report of Building Material Survey, Sampling, and

Evaluation of Asbestos Containing Materials

Parcel 36 – McLaren, Sandra 2808 Staples Avenue

Key West, Florida 33040

Prepared For:

Mr. Ryan Forney Project Manager

Jacobs Project Management Co.

Palm Beach Gardens, Florida 33418

Prepared By:

6851 Southwest 45th Street

Fort Lauderdale, Florida 33314

George Raimundo Traci-Anne Boyle, CIH, CSP Industrial Hygienist FL Asbestos Consultant #AX-60

December 19, 2023

Project #19814 iii Limited Pre-Renovation Asbestos Survey

EXECUTIVE SUMMARY

AirQuest Environmental, Inc. (“AirQuest”) performed a limited pre-renovation survey for asbestos containing materials (ACM) within select areas of the interior and exterior of the single-family residence located at 2808 Staples Avenue, Key West, Florida 33040 (“the site”). The survey was performed on November 17, 2023, by AirQuest Industrial Hygienist, Mr. George Raimundo, a trained Asbestos Hazard Emergency Response Act (AHERA) certified asbestos inspector.

The purpose of the survey was to locate and identify ACM within the site prior to renovation activities.

The survey was performed in compliance with the requirements under the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for an asbestos survey prior to renovation activities.

The results of our observation and laboratory analysis did not identify ACM in the samples collected from the site.

The scope of the survey was to locate and identify interior and exterior suspect building materials that may be impacted by upcoming soundproofing renovation activities, which include renovation to select windows, doors and Heating, Ventilation and Air Conditioning (HVAC) system components. Materials included and sampled during the survey generally included wall systems, ceiling systems, caulking, and mastics associated with the air handler system.

The remaining interior building materials and areas, the exterior, and the roof of the building were not included in the scope of the inspection.

Destructive sampling procedures were not used to access the interior of wall cavities, fire doors, or above hard ceilings. If any materials are encountered during renovation activities that were not sampled in this report, the materials should not be disturbed until they have been sampled and identified as non-ACM through laboratory analysis.

Written notice of intent to renovate or demolish is required ten (10) working days prior to the start of any construction activities. Even if no asbestos is present at the site, notification is still required.

Notifications must contain certain specified information including, but not limited to, the scheduled starting and completion dates of the work, the location of the site, the names of operators or asbestos-removal contractors, methods of removal and the amount of asbestos, and whether the operation is a demolition or a renovation. All demolitions and renovations are “subject” to the Asbestos NESHAP insofar as owners and operators must determine if and how much asbestos is present at the site. The Asbestos NESHAP does not apply to residential structures with four or fewer dwellings (i.e., apartments or single-family homes) if they are not part of a larger project.

Project #19814 iv Limited Pre-Renovation Asbestos Survey

PAGE

EXECUTIVE SUMMARY iii

1 INTRODUCTION AND SITE DESCRIPTION 1

2 SURVEY METHODS AND LABORATORY ANALYSIS 1

2.1 SURVEY METHODS 1

2.2 PLM AND PLM POINT COUNT 2

2.3 TRANSMISSION ELECTRON MICROSCOPY (TEM) 2

3 SUSPECT ASBESTOS CONTAINING MATERIALS 3

4 CONCLUSIONS AND RECOMMENDED RESPONSE ACTION 4

5 LIMITATIONS 4

TABLES

Table 1 – Laboratory Analysis and Summary

APPENDICES

Appendix I - Certifications

Appendix II - Laboratory Report and Chain of Custody Record

Appendix III – Photographs

Appendix IV - Sample-Location Diagram file://AQ-FL-S1/AirQuest/AirQuestDocs/Templates/External%20Use/Reports/Asbestos/NEW%20ACM%20Pre-Demo%20Report.docx#_Toc20141316

Project #19814 1 Limited Pre-Renovation Asbestos Survey

1 INTRODUCTION AND SITE DESCRIPTION

AirQuest Environmental, Inc. (“AirQuest”) performed a limited pre-renovation survey for asbestos containing materials (ACM) within select areas of the interior and exterior of the single-family residence located at 2808 Staples Avenue, Key West, Florida 33040 (“the site”). The survey was performed on November 17, 2023, by AirQuest Industrial Hygienist, Mr. George Raimundo, a trained Asbestos Hazard Emergency Response Act (AHERA) certified asbestos inspector (see Appendix I).

The purpose of the survey was to locate and identify ACM within the site prior to renovation activities.

The survey was performed in compliance with the requirements under the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for an asbestos survey prior to renovation activities.

The scope of services for this project consisted of the following five steps:

Building Walk-Through and Observations, Bulk Sampling of Suspect ACM, Polarized Light Microscopy (PLM) Analysis of Bulk Samples, Hazard Assessment and Evaluation, and Final Report Preparation.

The site was a single-family residence. The interior walls were finished with drywall system.

Exterior window white caulk was present around windows. The exterior walls were finished with particle board. The room (cottage) walls were finished with drywall system.

2 SURVEY METHODS AND LABORATORY ANALYSIS

The sampling protocol used generally follows AHERA guidelines. AHERA was promulgated by the United States Environmental Protection Agency (EPA) in 1987 and regulated public schools.

2.1 SURVEY METHODS

Suspect materials are differentiated into three categories: surfacing material, thermal system insulation, or miscellaneous material. Surfacing material is anything that is sprayed or troweled onto a surface. Thermal system insulation is material used to insulate HVAC pipes, tanks, etc., and miscellaneous material is any other type of material.

A homogeneous area is defined as an area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture. A homogeneous area is not limited to only a room and may be found in several rooms. Sample selection in the building was determined by identifying the homogeneous areas and basing sampling locations upon these areas.

Project #19814 2 Limited Pre-Renovation Asbestos Survey

In conducting the building inspection in compliance with local, state, and federal regulations, all suspected ACM which were accessible to the inspector, were either sampled to confirm the actual presence of asbestos or assumed to contain asbestos.

Building areas between walls, under floors, under concrete slabs and above permanent ceilings, all of which could not be accessed, were not visually inspected nor were materials therein sampled as a part of this building inspection.

Due to the fact that over 3,600 different building products are recognized as asbestos containing building materials, it cannot be said that all such products that may be included in the site have been, or could be, identified.

2.2 PLM AND PLM POINT COUNT

Analysis was performed using PLM with dispersion staining. The laboratory is rated proficient through National Institute of Standards and Technology - National Voluntary Laboratory Accreditation Program (NIST-NVLAP) for bulk asbestos analysis.

NESHAP defines ACM as containing more than 1% asbestos as determined using PLM (as specified in Appendix E, Subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy).

NESHAP defines friable ACM as any material containing more than 1 percent (%) asbestos that, when dry, can be crumbled, pulverized, or reduced to a powder by hand pressure. If the asbestos content of a friable material is less than ten (10) % as determined by a method other than point counting by PLM, the Owner may elect to verify the asbestos content by point counting using

PLM.

Estimates of quantities of ACM were based upon the identification of suspect materials. Where suspect ACM were located behind walls, above ceilings, beneath carpeting, or other concealed conditions and the quantities cannot be verified, the estimate is based upon the conditions present during the survey. These estimates are not to be considered absolute and should be verified when the ACM is exposed.

2.3 TRANSMISSION ELECTRON MICROSCOPY (TEM)

The method of bulk sample analysis, PLM, is not 100% absolute in the identification of ACM.

There are many factors which may contribute to false negatives being reported. Some of the more common factors include non-homogeneity of the building material and the optical variations of the microscopist. Because of the inherent limitations of PLM Bulk Sample analysis, the owner may elect to re-analyze the reported negative PLM samples by TEM to determine whether they may be regulated under NESHAPs.

In order to obtain an absolute analysis of a building material, any reported negative sample suspect of being asbestos or any material not sampled should be analyzed by Transmission Electron Microscopy (TEM) with energy dispersive x-ray analysis (EDAX) for bulk-sample confirmation.

Interpretation of TEM results must be viewed with caution as these procedures are not presently recognized by EPA regulations. However, they are useful analytical techniques for confirmation of non-friable materials when PLM results are inconclusive.

Project #19814 3 Limited Pre-Renovation Asbestos Survey

This analytical technique is described in the EPA Guidance Document, EPA/600 R-93/116, July 1993, Test Method – Method for the Determination of Asbestos in Bulk Building Materials. This method, Analytical Electron Microscopy (AEM), also referred to as TEM, can often be a reliable method for the detection and positive identification of asbestos in some bulk building materials, both friable and nonfriable. The method is particularly applicable to bulk materials that contain a large amount of interfering materials that can be removed by ashing and/or dissolution and contain asbestos fibers that are not resolved by PLM techniques. Many floor tiles and plasters would be included in the type of sample. In combination with suitable specimen preparation techniques, the AEM method can also be used to quantify asbestos concentrations.

The TEM analytical methodology is also referred to in an EPA Advisory, Federal Register, Vol.

59, No. 146, August 1, 1994, Advisory Regarding Availability of an Improved Asbestos Bulk Sample Analysis Sample Test Method, Supplementary Information on Bulk Sample Collection and Analysis. The Advisory states that this approach should be considered for the following circumstances: (1) Floor tiles which may contain thin fibers, and which were analyzed under the 1982 PLM method and found not to be asbestos containing; and (2) materials such as hard wall and acoustical plaster, stucco or other similar multi-layered materials or systems which were not analyzed and reported by layers (discrete strata).

3 SUSPECT ASBESTOS CONTAINING MATERIALS

Four (4) homogeneous areas (HA) of suspect material were identified and a total of eleven (11) samples were collected. The laboratory split the samples into layers, resulting in the analysis of thirteen (13) samples. Sample descriptions and laboratory results are summarized in Table 1.

A copy of the laboratory report and chain of custody record is included in Appendix II.

Photographs of each HA are included in Appendix III. A diagram showing sample locations is included in Appendix IV.

Table 1 – Laboratory Analysis and Summary

Samples Collected on November 17, 2023

Sample Number HA Sample Location Description of

Suspect Material Asbestos Content %

PRCL 36-01 1 North Area Drywall System Walls ND

PRCL 36-02 1 Northwest Area Drywall System Walls ND

PRCL 36-03 1 East Area Drywall System Walls ND

PRCL 36-04 2 North Area Exterior White Window Caulking ND

PRCL 36-05 2 Northwest Area Exterior White Window Caulking ND

PRCL 36-06 3 Northeast Area Particle Board ND

Project #19814 4 Limited Pre-Renovation Asbestos Survey

Sample Number HA Sample Location Description of

Suspect Material Asbestos Content %

PRCL 36-07 3 East Area Particle Board ND

PRCL 36-08 3 Northwest Area Particle Board ND

PRCL 36-09 4 Southeast Area Drywall System Walls in Cottage ND

PRCL 36-10 4 Southeast Area Drywall System Walls in Cottage ND

PRCL 36-11 4 Southeast Area Drywall System Walls in Cottage ND

4 CONCLUSIONS AND RECOMMENDED RESPONSE

ACTION

The results of our observation and laboratory analysis did not identify ACM within the samples collected from the site.

Destructive sampling procedures were not used to access the interior of wall cavities, fire doors, or above hard ceilings. If any materials are encountered during renovation activities that were not sampled in this report, the materials should not be disturbed until they have been sampled and identified as non-ACM through laboratory analysis.

Written notice of intent to renovate or demolish is required ten (10) working days prior to the start of any construction activities. Even if no asbestos is present at the site, notification is still required.

Notifications must contain certain specified information, including but not limited to, the scheduled starting and completion dates of the work, the location of the site, the names of operators or asbestos removal contractors, methods of removal and the amount of asbestos, and whether the operation is a demolition or a renovation. All demolitions and renovations are “subject” to the Asbestos NESHAP insofar as owners and operators must determine if and how much asbestos is present at the site. The Asbestos NESHAP does not apply to residential structures with four or fewer dwellings (i.e., apartments or single-family homes) if they are not part of a larger project.

5 LIMITATIONS

The scope of the survey was to locate and identify interior and exterior suspect building materials that may be impacted by upcoming soundproofing renovation activities, which include renovation to select windows, doors and Heating, Ventilation and Air Conditioning (HVAC) system components. Materials included and sampled during the survey generally included wall systems, ceiling systems, caulking, and mastics associated with the air handler system.

This report was prepared in a manner consistent with that level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions. This report

Project #19814 5 Limited Pre-Renovation Asbestos Survey was prepared for the exclusive use of the client and assigned agents and is not intended for any other purposes. Our report is based on the information available to us at the time of our investigation and is limited in scope to the stated purpose and/or the area(s) inspected. Other conditions elsewhere on the site may differ from those in the inspected locations and such conditions are unknown, may change over time, and/or have not been considered. This report does not claim to identify all potential hazards and/or contaminants that may be present, nor does it imply any medical opinion on the relationship of potential health effects with any reported hazards and/or contaminants. Our opinions are based on our findings and professional expertise, with no guaranty or warranty implied herein. The data obtained in this report does not establish the habitability of the site, nor does it determine if a building is safe or unsafe. Should additional information become available, we reserve the right to determine the impact, if any, of the new information on our opinions, conclusions, and recommendations, if necessary, as warranted by the discovery of the additional information. AirQuest accepts no responsibility for interpretation of this report by others. Its contents shall not be used or relied upon by other parties without prior written authorization by AirQuest.

Appendix I Certifications

Melanie S. Griffin, SecretaryRon DeSantis, Governor

STATE OF FLORIDA

DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION

ASBESTOS LICENSING UNIT

THE ASBESTOS CONSULTANT HEREIN IS LICENSED UNDER THE

PROVISIONS OF CHAPTER 469, FLORIDA STATUTES

BOYLE, TRACI-ANNE

Do not alter this document in any form.

AIRQUEST ENVIRONMENTAL INC

LICENSE NUMBER: AX60

EXPIRATION DATE: NOVEMBER 30, 2024

This is your license. It is unlawful for anyone other than the licensee to use this document.

6851 SW 45 ST

DAVIE FL 33314

Always verify licenses online at MyFloridaLicense.com https://www.myfloridalicense.com/LicenseDetail.asp?SID=&id=8c21d1d6249bcaa3338cefa039457259

Appendix II Laboratory Report and Chain of Custody Record

EMSL Analytical, Inc.

19501 NE 10th Ave. Bay A N. Miami Beach, FL 33179

Tel/Fax: (305) 650-0577 / (305) 650-0578 http://www.EMSL.com / miamilab@emsl.com

172306472EMSL Order:

Customer ID: AQE63

Customer PO:

Project ID:

Attention: Phone:Lab Results (954) 792-4549

Fax:AirQuest Environmental, Inc. (954) 792-2221

Received Date:6851 Southwest 45th Street 11/22/2023 9:55 AM

Analysis Date:Fort Lauderdale, FL 33314 11/24/2023

Collected Date: 11/17/2023

Project: 19814 - Jacobs / 2808 Staples Ave. Key West, FL.

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

PRCL 36-01-Drywall

172306472-0001

None DetectedNon-fibrous (Other)100%Brown/White

Non-Fibrous

Heterogeneous

Drywall System

PRCL 36-01-Joint

Compound

172306472-0001A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Drywall System

PRCL 36-02

172306472-0002

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Drywall System

PRCL 36-03

172306472-0003

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Drywall System

PRCL 36-04

172306472-0004

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Caulk

PRCL 36-05

172306472-0005

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Caulk

PRCL 36-06

172306472-0006

None DetectedNon-fibrous (Other)60%Cellulose40%Gray

Fibrous

Homogeneous

Particle Board

PRCL 36-07

172306472-0007

None DetectedNon-fibrous (Other)60%Cellulose40%Gray

Fibrous

Homogeneous

Particle Board

PRCL 36-08

172306472-0008

None DetectedNon-fibrous (Other)100%Gray

Fibrous

Homogeneous

Particle Board

PRCL 36-09

172306472-0009

None DetectedNon-fibrous (Other)90%Cellulose10%Brown/White

Fibrous

Heterogeneous

Drywall System

PRCL 36-10-Drywall

172306472-0010

None DetectedNon-fibrous (Other)90%Cellulose10%Brown/White

Fibrous

Heterogeneous

Drywall System

PRCL 36-10-Joint

Compound

172306472-0010A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Drywall System

PRCL 36-11

172306472-0011

None DetectedNon-fibrous (Other)90%Cellulose10%Brown/White

Fibrous

Heterogeneous

Drywall System

Initial report from: 11/24/2023 15:05:08

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 11/24/2023 3:05 PM

Tel/Fax: (305) 650-0577 / (305) 650-0578 http://www.EMSL.com / miamilab@emsl.com

172306472EMSL Order:

Customer ID: AQE63

Customer PO:

Project ID:

Analyst(s)

Mary Hamel (13) Kimberly Wallace, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. N. Miami Beach, FL NVLAP Lab Code 200204-0

Initial report from: 11/24/2023 15:05:08

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 11/24/2023 3:05 PM

O r d e r I D

P a g e f

Appendix III Photographs

Project #19814 Page 1 of 1

Parcel 36 – McLaren, Sandra 2808 Staples Avenue

Key West, Florida 33040

AirQuest Environmental, Inc.

Project # 19814 November 2023

Exterior of Residence

HA 1 – Drywall System Walls

HA 2 – Exterior White Caulk

HA 3 – Particle Board

HA 4 – Drywall System Walls in Cottage

Appendix IV Sample-Location Diagram

Jacobs Project Management Co.

7108 Fairway Drive, Suite 170 Palm Beach

Garden, Florida 33418

LEGEND

Non-Asbestos Containing Material Sample Locations

DATE: 11/17/23

PROJECT #: 19814

Asbestos Survey Report Sample Location Diagram

NORTH

2808 STAPLES AVENUE,

KEY WEST, FLORIDA 33040

91011

Limited Pre-Renovation Report of Building Material Survey, Sampling, and Evaluation of Asbestos Containing Materials

For:

Ansell Residence 2809 Flagler Avenue Key West, Florida 33040

Prepared For:

Mr. Ryan Forney Project Manager Jacobs Project Management Co.

7108 Fairway Drive, Suite 170 Palm Beach Garden, Florida 33418

November 26, 2025

Limited Pre-Renovation Report of

2809 Flagler Avenue

Project Manager

Jacobs Project Management Co.

6851 Southwest 45th Street

AirQuest Environmental, Inc. (“AirQuest”) performed a limited pre-renovation survey for asbestos containing materials (ACM) within select areas of the interior and exterior of the single-family residence located at 2809 Flagler Avenue, Key West, Florida 33040 (“the site”). The survey was performed on October 29, 2025, by AirQuest Industrial Hygienist, Mr. George Raimundo, a trained Asbestos Hazard Emergency Response Act (AHERA) accredited asbestos inspector.

The survey was performed in compliance with the requirements under the National Emission

Standards for Hazardous Air Pollutants (NESHAPs) for an asbestos survey prior to renovation activities.

The purpose of the survey was to locate and identify ACM within the site prior to renovation activities. The scope of the survey was to locate and identify interior and exterior suspect building materials that may be impacted by upcoming soundproofing renovation activities, which include renovation to select windows, doors, and Heating, Ventilation and Air Conditioning (HVAC) system components. Materials included and sampled during the survey generally included wall systems, ceiling systems, caulking, and mastics associated with the air handler system. The remaining interior building materials and areas, the exterior, and the roof of the building were not included in the scope of the inspection.

The results of our observation and laboratory analysis did not identify ACM in the samples collected from the site.

Destructive sampling procedures were not used to access the interior of wall cavities, fire doors, or above hard ceilings.