5-5-CR26075-26308480 Hazmat Survey.pdf

Limited Pre-Renovation Survey Report and Hazardous Materials Survey

American Fork Armory

251 South 200 East

American Fork, Utah 84003

RMEC PJ25A-5447

February 4, 2026

Prepared For:

State of Utah Division of Facilities Construction and Management

4315 South 2700 West, 3rd Floor

Taylorsville, Utah 84129-218

Utah National Guard UTNG American Fork Armory Latrine Remodel 11 February 2026 American Fork, UT 84003 DFCM # 26308480 | NGB # | AN #25057 90% Review Set

Utah National Guard UTNG American Fork Armory Latrine Remodel 06 March 2026

American Fork, UT 84003 DFCM # 26308480 | NGB # | AN #25057 PERMIT SET

APPENDIX A

Utah National Guard UTNG American Fork Armory Latrine Remodel 11 May 2026 American Fork, UT 84003 DFCM #26308480 | AN #25057 PERMIT SET

Utah DFCM

American Fork Armory (American Fork, Utah)

PJ25A-5447 Page I

DOCUMENT CONTROL

LIMITED PRE-RENOVATION SURVEY REPORT AND HAZARDOUS MATERIALS

SURVEY

AMERICAN FORK ARMORY

PROJECT NUMBER: PJ25A-5447

PREPARED FOR:

State of Utah Division of Facilities

Construction and Management

4315 South 2700 West, 3rd Floor

Taylorsville, Utah 84129-2128

ATT: Mike Mirabella

PREPARED BY:

RMEC Environmental, Inc.

476 W. 325 South

Bountiful, Utah 84010 t: (801) 467-3661 e: general@rmec.net

AUTHOR(S):

Mackenzie Hobbs

Environmental Scientist

RMEC Environmental, Inc.

2/3/2026

Signature Date

REVIEWER(S):

Daniel E. Nye, MSPH, CIH

Senior Industrial Hygienist

RMEC Environmental, Inc.

2/4/2026

Signature Date

REVISION HISTORY:

Revision Number Date Issued Reason/Comments:

00 February 4, 2026 INITIAL ISSUE

PJ25A-5447 Page II

APPENDICES

APPENDIX A – RMEC Inspection Summary Table(s)

APPENDIX B – Analytical Results Report(s)

APPENDIX C – Site Photographs and Sample Location Diagram

APPENDIX D – Copy of Certifications

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Site Information

1.2 Scope of Services

1.3 Limitations and Warranty of Work

1.4 Reliance

2.0 INSPECTION ACTIVITIES

2.1 Credentials

2.2 Field Activities

2.2.1 Visual Assessment

2.2.2 Suspect ACBM Physical Assessment

2.2.3 Suspect ACBM Sample Collection

2.2.4 Coatings Sample Collection to Identify Lead Containing Paint

2.3 Sample Analysis

2.4 Regulatory Overview

3.0 RESULTS/DISCUSSION

3.1 Asbestos Findings

3.1.1 Inaccessible Areas or Unsampled Materials

3.2 LCP Findings

4.0 RECOMMENDATIONS

PJ25A-5447 Page III

EXECUTIVE SUMMARY

RMEC Environmental, Inc. (RMEC) was retained by the State of Utah Division of Facilities Construction and Management (DFCM) to conduct a limited asbestos, lead, and hazardous materials pre-renovation survey for the American Fork Armory, located at 251 South 200 East in American Fork, Utah. This work was requested by DFCM in preparation for a latrine remodel, which was expected to impact portions of the walls, ceilings, flooring, and other building materials near the restrooms.

This Executive Summary only provides a brief overview of the findings from this survey—please read the report in its entirety for a more thorough presentation of all findings.

The site walkthrough and associated on-site sampling was conducted on January 13, 2026, by Mackenzie

Hobbs and Jenna Hubirch, RMEC employees certified by the State of Utah as an Asbestos Inspector (ASB-

7699 and ASB-8981). The purpose of the survey was to identify any regulated asbestos containing materials

(RACM), in accordance with Utah Administrative Code (UAC) R307-801, that would require abatement, removal, and/or other safety precautions prior to the planned renovation activities. RMEC was also tasked with identifying whether lead-containing paint (LCP), as defined by the U.S. Occupational Safety and

Health Administration (OSHA), was present in the structure and would likely be disturbed during renovation activities. Lastly, RMEC was asked to identify other hazardous materials that might be impacted during the planned renovation activities.

Asbestos Findings

As noted in Table A in Appendix A, no asbestos-containing materials (ACM) were identified as part of this survey.

Lead Findings

As noted in Table C in Appendix A, one (1) sampled area was identified as containing detectable levels of LCP. The sample appeared to be limited to one column area in the ladies room.

For surfaces where lead has been detected in any amount, OSHA requirements (see 29 CFR 1926.62) and best management practices (BMPs) should be followed to prevent lead exposures to workers during demolition or salvaging (if applicable) activities.

Hazardous Materials Findings

RMEC searched for other hazardous materials that could potentially be affected by activities within the scope of the project and noted the following (quantities are also noted):

• Fluorescent Light Bulbs (~30 total throughout the project area that may be affected)

• Fluorescent Lamp Ballasts (~14 total throughout the project area that may be affected)

• Refrigerators with freon (2 mini fridges were observed in the recruiter’s office and 2 commercial fridges were observed in the kitchen)

• Drinking fountains with freon (1 drinking fountain was observed in the hallway)

• Air Conditioners (1 air conditioning unit was observed in the recruiter’s office that contained

R401A freon/refrigerant)

• Maintenance/Janitorial Chemicals (~20 containers of hazardous maintenance chemicals and cleaning chemicals in consumer quantities were observed in the janitorial closet and kitchen)

PJ25A-5447 Page IV

As needed, all hazardous materials should be properly handled and disposed of according to local, regional, state, and/or national regulations before demolition or renovation occurs.

PJ25A-5447 Page 1

1.0 INTRODUCTION

RMEC Environmental, Inc. (RMEC), a State of Utah-Certified Asbestos Company (#ASBC-325), was retained by the State of Utah Division of Facilities Construction and Management (DFCM) to conduct a limited pre-renovation and hazardous materials survey of the project area described below.

In accordance with Utah Administrative Code (UAC) R307-801-9, the purpose of this limited survey was to identify and document any regulated asbestos containing materials (RACM) that would require removal or other potential actions prior to the planned renovation activities. Painted/Coated surfaces were also evaluated for lead, and an inventory of other potential hazardous materials was also determined.

1.1 Site Information

This section provides basic information that could be readily obtained about the project site/area and its associated structure(s).

Location/Address 251 South 200 East, American Fork, Utah 84003

Owner State of Utah Division of Facilities & Construction Management

Site Description The American Fork Armory facility is a two-story commercial space of brick, concrete, and steel-frame construction. The building was reportedly constructed in the early 1950s. Per DFCM, the planned renovation work was expected to include the renovation and expansion of the current restroom area. Building materials expected to be impacted included specific walls, ceiling, and flooring in that area.

1.2 Scope of Services

The scope of work for the asbestos survey included a limited on-site inspection for asbestos-containing materials (ACM), specifically with the intent to identify RACM (as defined in Section 2.4 of this report) in planned renovation areas. Accessible suspect asbestos-containing building materials (ACBM) were categorized into homogeneous areas for bulk sample collection and analysis, and then representative bulk samples of each identified homogeneous area throughout the project area were collected in accordance with

40 CFR 763.86. For each suspect ACBM identified during this work, RMEC’s intent was to provide accurate details regarding material type, location, condition, and approximate quantity throughout the project area (including any targeted building exteriors).

The scope of work for an evaluation of lead-containing paint (LCP) included evaluating all suspect painted/coated surfaces in the planned renovation areas. The intent was to identify all paint types, components, substrates, locations, conditions, and approximate quantities, and then note which ones contained any detectable level of lead.

The scope of work for the hazardous materials inventory included identifying other hazardous materials or products in the project area that could be disturbed during renovation activities.

Specific inspection and sampling methodologies are described in Section 2.0 of this report.

1.3 Limitations and Warranty of Work

RMEC warrants that the findings contained in this report have been prepared in general accordance with accepted professional practices at the time of its preparation as applied by similar professionals in the

PJ25A-5447 Page 2 community. The field and laboratory results reported herein (only if bulk samples were collected) are considered sufficient in detail and scope to determine the presence of accessible and/or exposed suspect

ACM, LCP, or hazardous materials at the defined project area. The results, findings, conclusions, and recommendations expressed in this report are based on the conditions observed during the site visit(s).

Changes in the state of the art or in applicable regulations cannot be anticipated and have not been incorporated into this report. RMEC does not warrant the work of regulatory agencies, laboratories, or other third parties, even if they provided information that may have been used in the preparation of this report.

Certain survey and analytical methods have been used to provide the client with information regarding the presence of accessible and/or exposed ACM or LCP present in the project area at the time of the survey.

Test results are valid only for materials tested. There is a distinct possibility that conditions or materials may exist—for suspect ACBM, LCP, and hazardous materials—which could not be reasonably identified within the scope of the survey, or which were not apparent during the site visit. The survey is also limited to the information available from the client at the time the survey was conducted.

Please note that the survey covered only accessible suspect materials and/or surfaces found within the planned renovation area—all relevant inaccessible areas are noted and explained in Section 3.0 of this report.

Estimations regarding total quantity for each suspect ACBM, LCP, or hazardous material are based only on a cursory visual evaluation. Noted hazardous materials were individually tallied. Actual quantities may vary significantly, especially if certain areas were not accessible. RMEC shall not be held liable for differences in actual versus estimated quantities.

1.4 Reliance

This report has been prepared for the sole use of the person(s) or entity(ies) listed below and only represents conditions within the project area that were present at the time this survey was completed.

• Utah Division of Facilities Construction and Management (DFCM)

This report may not be relied upon by any other person(s) or entity(ies) without the express written consent of RMEC Environmental, Inc. and the above-listed parties. Any use of the contents of this report by any other third party is at the sole risk of that party. Further, contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation, as necessary.

PJ25A-5447 Page 3

2.0 INSPECTION ACTIVITIES

2.1 Credentials

This survey was completed by the following qualified RMEC personnel:

Name Credential Information

Mackenzie Hobbs State of Utah Asbestos Certification – Inspector

Certification #: ASB-7699 (expires 04/23/2026)

Jenna Hubrich State of Utah Asbestos Certification – Inspector

Certification #: ASB-8981 (expires 12/10/2026)

In addition to the personal certification listed above, it should be noted that RMEC Environmental, Inc. is a Certified Asbestos Company (ASBC-325) with the Utah Department of Environmental Quality – Division of Air Quality (UDEQ-DAQ).

2.2 Field Activities

The asbestos portion of this limited pre-renovation survey was conducted in general accordance with the sampling and collection protocols established in the Asbestos Hazard Emergency Response Act (AHERA) standard (located at 40 CFR 763.86) for asbestos sampling.

The hazardous materials inventory includes items that, in addition to ACM and lead, would contribute to regulated debris or emissions during the renovation process. Those materials could also be regulated by state-level or federal regulations as hazardous wastes under certain circumstances if removed.

RMEC completed the on-site survey and walkthrough of the project area on the following dates:

• January 13, 2025

Site photographs of suspect ACBM samples or other relevant features are included in Appendix C of this report.

2.2.1 Visual Assessment

RMEC commenced the survey by conducting a visual assessment for suspect ACBM and potential

LCP. Homogeneous areas consisting of similar building materials (including texture and color) with similar histories were identified and recorded for the sampling of suspect ACBM.

All other hazardous materials were visually inventoried only. A summary of those inventoried materials is presented in Table B in Appendix A of this report.

2.2.2 Suspect ACBM Physical Assessment

All homogeneous areas of suspect ACBM were assessed to determine whether they were friable or significantly damaged. “Friable” is defined as being able to be crumbled, pulverized, or reduced to powder by hand pressure when dry. A determination of friability is done by physically touching the suspect material.

PJ25A-5447 Page 4

2.2.3 Suspect ACBM Sample Collection

Based on the visual and physical assessments discussed previously in Sections 2.2.1 and 2.2.2, RMEC collected bulk samples of suspect ACBM. Where possible, sample locations were selected at random and intended to be representative of the entire applicable material.

Once homogeneous areas were identified, bulk samples were collected to confirm the presence or absence of asbestos in suspect materials. During sample collection, RMEC attempted to minimize the potential for the release of asbestos fibers, including using wet methods, where necessary.

Frequency of sampling was based on observations at the site (i.e., friability and total quantity) and assumptions made regarding whether observed materials were homogeneous.

Specific details about each of the collected bulk samples are listed in Table A of Appendix A.

2.2.4 Coatings Sample Collection to Identify Lead Containing Paint

To determine the presence of lead-containing paint (LCP), RMEC identified each painted/coated surface in the project area that were suspected of having differing painting histories.

RMEC utilized a hand-held SciAps Inc. Model X550Pb X-Ray Fluorescence (XRF) device to sample all suspect painted/coated surfaces in the project area. An XRF provides immediate results for each sampled material using non-destructive testing methods and allows for all unique components and substrates to be sampled. Surfaces were measured according to component type, substrate, and the presence of a potential source of LCP.

Specific details and results for each XRF reading are listed in Table C of Appendix A.

2.3 Sample Analysis

Asbestos samples were submitted under chain of custody to Dixon Information Inc. (Dixon) of Salt Lake

City, Utah for laboratory analysis. Dixon is accredited by the American Industrial Hygiene Association

(AIHA) and the National Institute of Standards and Technology (NIST) under the National Voluntary

Laboratory Accreditation Program (NVLAP). Details about Dixon’s accreditations are included in the analytical report attached in Appendix B of this report.

Samples were analyzed by Polarized Light Microscopy (PLM) visual estimation methodology, using the method specified in Appendix E, Subpart E of 40 CFR 763. For samples with a limited detection of asbestos—including those that meet the regulatory definition of a “wall system”—a point count methodology was requested to determine whether that material should be considered ACM (see Section

2.4 of this report). All bulk samples and their associated analytical results are summarized in Table A of

Appendix A.

2.4 Regulatory Overview

The information provided below is a summary and not intended to be inclusive of all potentially pertinent regulatory information. Please note that the standards discussed hereafter should be reviewed and verified separately prior to demolition and renovation activities.

There are separate definitions for the various types of ACM, as classified by the U.S. Environmental

Protection Agency (EPA). Asbestos is included in the National Emission Standards for Hazardous Air

Pollutants (NESHAP) standard—located in 40 CFR Part 61, Subpart M—under the Clean Air Act (CAA).

PJ25A-5447 Page 5

NESHAP regulates asbestos fiber emissions and asbestos waste disposal practices. The NESHAP regulation also requires determinations regarding friability of existing ACM prior to demolition or renovation activities. ACM is defined as any building material containing more than 1% asbestos (as determined by PLM or other approved analytical methods).

As mentioned previously, all ACM is physically evaluated to determine whether it is “friable.” Non-friable

ACM is any material that contains more than 1% asbestos (again, as determined by an approved analytical method) that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. There are two different categories for non-friable ACM:

Category I Non-Friable ACM means asbestos-containing packings, gaskets, resilient floor covering

(commonly known as vinyl asbestos tile [VAT]) and asphalt roofing products, as determined by PLM.

Asbestos-containing mastic is also considered Category I non-friable ACM. These materials rarely become friable and are assumed to remain non-friable if demolition or renovation is performed using

“normal” methods, but will become friable if severely weathered, sanded, or abraded. Category I materials which are not in poor condition and not friable prior to demolition or renovation do not have to be removed, except where demolition will be by intentional burning.

Category II Non-Friable ACM means any other “non-friable” material that does not meet the Category

I non-friable ACM category described above. Category II materials may not need to be removed depending upon the quantity and probability of that material becoming friable during demolition or renovation.

On the other hand, friable ACM is always considered to be a regulated ACM (or RACM). All materials that are deemed to be RACM must be removed prior to demolition or renovation. In addition to friable

ACM, RACM is defined in the NESHAP standard to include:

• Category I non-friable ACM that has become friable.

• Category I non-friable ACM that will be or has been subject to sanding, cutting, or abrading.

• Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation activities.

In Utah, asbestos regulations are defined in Utah Administrative Code (UAC) R307-801, Utah Asbestos

Rule. This rule, as well as the associated state-level NESHAP program, is managed by the Utah Department of Environmental Quality (UDEQ) Division of Air Quality (DAQ). Of note, the federal NESHAP program, found at 40 CFR 61 Subpart M, is adopted by reference in UAC R307-214-1. Per the Asbestos NESHAP regulation, only friable ACM is required to be abated prior to demolition or renovation activities.

It should also be noted that the U.S. Occupational Safety and Health Administration (OSHA) has a construction standard (29 CFR 1926.1101) that regulates workplace exposures to asbestos. That standard requires that employee exposures to airborne asbestos not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time-weighted average (TWA). In addition, worker exposures to airborne asbestos is not to exceed 1.0 f/cc over a 30-minute time period—this is known as an excursion limit (EL). Both the

TWA and EL are considered to be permissible exposure limits (PELs) under the OSHA standard. Other specific work practices and precautions that must be followed during construction and maintenance activities—specifically, those that could disturb ACM—are defined in the OSHA standard relative to each class of regulated work.

PJ25A-5447 Page 6

Additionally, lead is regulated by both U.S. Environmental Protection Agency (EPA) and OSHA, and certain detectable quantities of lead may constitute a hazardous waste by EPA or a lead dust hazard during demolition or renovation (e.g., construction) activities by OSHA.

The EPA has the authority to regulate the waste status of demolition or renovation debris, including lead-containing materials. Specific requirements that must be addressed include potential notification and testing prior to transporting, treatment, storing, or disposal. For example, debris is hazardous if a Toxicity

Characteristic Leachate Procedure (TCLP) analytical result is above 5.0 parts per million (ppm) for lead.

Of note, the aggregate of construction debris, which would include both the paint itself as well as any debris

(such as drywall and other building materials) would typically render the overall lead quantity to fall well below the 5.0-ppm hazardous waste threshold using TCLP. Therefore, LCP is rarely considered for waste disposal when done in bulk. Conversely, LCP separated from its substrate may be considered hazardous waste.

According to OSHA, a lead dust hazard must be evaluated prior to demolition or renovation activities that would disturb LCP of any detectable concentration. Per OSHA regulations (see 29 CFR 1926.62), if lead is detected above the laboratory analytical detection limit in any amount, efforts must be made to minimize employee exposures. The OSHA standards also stipulate how painted components or other building surfaces with detectable lead quantities should be safely handled. Ultimately, employers must ensure that no employee is exposed to lead concentrations above 50 micrograms per cubic meter of air (μg/m3) over an eight-hour period without adequate protection. There is also an action level of 30 μg/m3 that, if exceeded, triggers medical monitoring requirements.

3.0 RESULTS/DISCUSSION

The following sub-sections detail the findings from RMEC’s limited on-site pre-renovation survey.

3.1 Asbestos Findings

Table A in Appendix A provides a summary of all bulk samples collected as part of this limited pre-renovation survey. A summary of the bulk samples collected is provided below in Table 3.1.

Table 3.1 – Summary of RMEC Bulk Samples

Total Number of Suspect ACBM Bulk Samples Collected: 28

Total Number of Homogeneous Areas (HA) Represented: 12

Total Number of Suspect ACBM Confirmed to be ACM: 0

Total Number of ACM Confirmed to be RACM: 0

Please refer to Section 4.0 of this report for any recommendations related to materials containing asbestos.

PJ25A-5447 Page 7

3.1.1 Inaccessible Areas or Unsampled Materials

There were no notable inaccessible rooms encountered during this inspection. Many asbestos containing materials are located in concealed areas such as wall cavities, below ground level and other hidden spaces. Since RMEC has been contracted to conduct a limited asbestos survey, it is understood that RMEC will minimize its impact during the investigation. As such, if there are concerns with locating any of these hidden materials, RMEC and DFCM would need to agree on the level of destruction necessary to correctly identify or rule out the presence of these hidden materials. This survey was performed in an occupied area, therefore minimally destructive methods were used to identify potential asbestos containing materials.

If any other suspect building materials are encountered during demolition or renovation activities and are found to be different than those that were already sampled (see Table A in Appendix A), they should be immediately sampled for asbestos by a qualified inspector.

3.2 LCP Findings

RMEC took a total of sixty-two (62) XRF readings from within the project area. Table C in Appendix A provides a summary of all the collected XRF readings and their results. To summarize, one (1) paint types analyzed as part of this limited survey were determined to have detectable levels of lead and, therefore, meets the OSHA definition of LCP. The highest reading was recorded at 1 mg/cm2.

Of note, 1.0 mg/cm2 (used to define “lead-based paint” under EPA regulations) is presented in Table C in

Appendix A as a benchmark reference point for comparing observed results with a known standard;

however, that threshold does not apply to this property—further, as discussed in Section 2.4, there is no minimum allowable lead content under OSHA.

PJ25A-5447 Page 8

4.0 RECOMMENDATIONS

Asbestos Recommendations

Based on the work completed as part of this limited survey, RMEC has determined that there are no ACM

(including RACM) present in the anticipated project area.

If further demolition or renovation activities are planned for the property—specifically, outside the area inspected as part of this limited pre-renovation asbestos survey—RMEC recommends that a separate asbestos inspection be completed for those applicable areas or structures.

Lead Recommendations

For surfaces where lead has been detected in any amount, OSHA requirements (see 29 CFR 1926.62) and best management practices (BMPs) should be followed to prevent lead exposures to workers during renovation or salvaging (if applicable) activities.

In the event that DFCM employees use manual renovation practices around LCP, RMEC recommends the following additional provisions:

• Utilize dust suppression activities such as wetting surfaces prior to disturbance, or dust collection at the point of generation.

• Certain BMPs should be undertaken and can be found at the EPA’s Lead Renovation, Repair and

Painting Program, found at https://www.epa.gov/lead/renovation-repair-and-painting-program-contractors.

• OSHA requires that employers perform an assessment to determine employee exposures to lead during activities that disturb any amount of lead (see 29 CFR 1926.62).

Hazardous Materials Recommendations

As listed in Table B in Appendix A, multiple types of hazardous materials were noted in the planned renovation area. As needed, all identified hazardous materials should be properly handled (removed) and disposed according to local, regional, state, and/or national regulations before commencing any activities that might disturb them. Also, the local health department with jurisdiction over the property may require proof of proper disposal of hazardous materials prior to demolition activities.

Other Recommendations

Finally, please note that this report is required to be kept on-site during any and all demolition or renovation activities associated with the project area and shall also be made available to all persons who have access to the site during those activities.

RMEC also recommends that this report be kept on file for at least five (5) years after those activities are completed and can be made available to any regulatory agency. For asbestos samples collected as part of this survey, if demolition/renovation work on those associated building materials is not completed in the project area within three (3) years, this report should be updated by a certified asbestos inspector if any subsequent work will need to rely on the results herein.

Utah National Guard UTNG American Fork Armory Latrine Remodel 11 May 2026 American Fork, UT 84003 DFCM #26308480 | AN #25057 PERMIT SET https://www.epa.gov/lead/renovation-repair-and-painting-program-contractors https://www.epa.gov/lead/renovation-repair-and-painting-program-contractors

APPENDIX A

RMEC INSPECTION SUMMARY TABLE(S)

Table A: RMEC Suspect ACBM Bulk Samples Analysis Summary

HA No.

Sample

Number Material Description Sample Location

HA

Estimated

Quantity

(ft2)

Asbestos

Analytical

Result

W01

W01-01 Drywall

With Mud & Tape Women’s Bathroom 2,500

None

Detected

W01-02 Drywall

With Mud & Tape Unisex Bathroom 2,500

None

Detected

W01-03 Drywall

With Mud & Tape

Hallway outside Women’s

Bathroom 2,500

None

Detected

W01-04 Drywall

With Mud & Tape Men’s Bathroom 2,500

None

Detected

W01-05 Drywall

With Mud & Tape Men’s Bathroom 2,500

None

Detected

FT01

FT01-01

Brown 1” x 1” Ceramic Floor

Tile with Cement Men’s Bathroom 550

None

Detected

FT01-02

Brown 1” x 1” Ceramic Floor

Tile with Cement Unisex Bathroom 550

None

Detected

WT01

WT01-01

Brown 4” x 4” Ceramic Wall

Tile with Off-White Mastic Men’s Bathroom 1,000

None

Detected

WT01-02

Brown 4” x 4” Ceramic Wall

Tile with Off-White Mastic Woman’s Bathroom 1,000

None

Detected

IN01

IN01-01

White Paper Wrap over Yellow

Fiberglass Insulation Men’s Bathroom 30 LF

None

Detected

IN01-02

White Paper Wrap over Yellow

Fiberglass Insulation Janitorial Closet 30 LF

None

Detected

CM01

CM01-01

Concrete Block with Grey

Concrete and White Block Fill Men’s Bathroom 20

None

Detected

CM01-02

Concrete Block with Grey

Concrete and White Block Fill Men’s Bathroom 20

None

Detected

CM01-03

Concrete Block with Grey

Concrete and White Block Fill Men’s Bathroom 20

None

Detected

CK01

CK01-01 White Caulk Unisex Bathroom Sink 10 None

Detected

CK01-02 White Caulk Men’s Bathroom Sink 10 None

Detected

CA01 CA01-01

Green 1’ x 1’ Carpet Tile with

Brown Mastic Hallway 250

None

Detected

HA No.

Sample

Number Material Description Sample Location

HA

Estimated

Quantity

(ft2)

Asbestos

Analytical

Result

CA01-02

Green 1’ x 1’ Carpet Tile with

Brown Mastic Hallway 250

None

Detected

CB01

CB01-01

Black Cove Base with Yellow

Mastic Hallway 75

None

Detected

CB01-02

Black Cove Base with Yellow

Mastic Hallway 75

None

Detected

AS01

AS01-01

Plastic Splash Sheet with

Yellow Adhesive Janitorial Closet 150

None

Detected

AS01-02

Plastic Splash Sheet with

Yellow Adhesive Janitorial Closet 150

None

Detected

CT01

CT01-01

White 2” x 4” Pinhole Ceiling

Tile Recruiter’s Office 175

None

Detected

CT01-02

White 2” x 4” Pinhole Ceiling

Tile Recruiter’s Office 175

None

Detected

CT02

CT02-01

White 2” x 4” Ceiling Tile

(without Pinholes) Kitchen 600

None

Detected

CT02-02

White 2” x 4” Ceiling Tile

(without Pinholes) Kitchen 600

None

Detected

FT02

FT02-01

Brown 4” x 4” Ceramic Floor

Tile with Cement Kitchen 600

None

Detected

FT02-02

Brown 4” x 4” Ceramic Floor

Tile with Cement Kitchen 600

None

Detected

HA = Homogeneous Area

LF = Linear Feet a Quantity is presented in relation to the planned project area

Values in Italics contain detectable amounts of asbestos, but are not regulated by the EPA.

Values in bold are considered to be ACM.

Values in red are considered to be RACM based on their composition, classification, and physical conditions.

Table B: Hazardous Materials Inventory

Material Type Quantity Area Approx.

Location Comments

Regulated by EPA as Universal Waste

Fluorescent Light

Tubes & Bulbs ~30

Throughout

Project Area

Ceiling Light

Fixtures

Fluorescent bulbs were noted in various locations. All appeared to be intact and in good shape.

Fluorescent Lamp

Ballasts ~14

Throughout

Project Area

Ceiling Light

Fixtures

NOTE: Lamp Ballasts that were inspected did not contain PCBs.

Batteries None

Mercury Thermostat None

Equipment Containing Chlorofluorocarbons (CFCs)

Refrigerators

(refrigerants)

Throughout

Project Area

Recruiter’s

Office and

Kitchen

Two mini fridges were observed in the Recruiter’s Office and two commercial fridges were observed in the kitchen.

Drinking Fountains

(refrigerants) 1 Hallway Hallway

One drinking fountain was noted near the hallway between the kitchen and the bathrooms.

Air Conditioners

(refrigerants)

Recruiter’s

Office

Recruiters’

Office

One wall mounted air conditioning unit containing

R401A refrigerant was observed in the Recruiter’s Office

Other Potential Hazardous Materials

Maintenance/Cleaning

Chemicals ~20

Throughout

Project Area

Janitorial

Closet and

Kitchen

Several containers of consumer-grade hazardous materials and cleaners were observed in the janitorial and kitchen areas.

These chemicals were observed to be in consumer quantities.

Table C: RMEC Lead Containing Paint XRF Results

Number Substrate And Component

Surface

Paint Color

XRF Result

(mg/cm2) Room/Area Description

01 Drywall Paint White 0 Mop Closet Wall

02 Tile Glaze White 0 Unisex Bathroom Wall

03 Tile Glaze Brown 0 Unisex Bathroom Wall

04 Tile Glaze Cream 0 Unisex Bathroom Wall

05 Locker Paint Gray 0 Unisex Bathroom

06 Wood Finish Wood 0 Unisex Bathroom Door

07 Metal Door Frame Paint Gray 0 Unisex Bathroom Door Frame

08 Drywall Paint White 0 Hallway Wall

09 Wood Finish Wood 0 Janitorial Closet Door

10 Metal Door Frame Paint Gray 0 Janitorial Closet Door

11 Tile Glaze Gray 0 Janitorial Closet Floor

12 Drywall Paint White 0 Janitorial Closet Wall

13 Metal Door Frame Paint Gray 0 Women’s Bathroom Door

14 Tile Glaze Gray 0 Women’s Bathroom Floor

15 Wood Finish Wood 0 Women’s Bathroom Door

16 Wood Finish Wood 0 Women’s Bathroom Bench

17 Metal Bench Stand Gray 0 Women’s Bathroom Bench

18 Tile Glaze White 0 Women’s Bathroom Wall

19 Tile Glaze Brown 0 Women’s Bathroom Wall

20 Tile Glaze Cream 0 Women’s Bathroom Wall

Drywall Paint White

Women’s Bathroom Window

Column

22 Drywall Paint White 0 Women’s Bathroom Wall

23 Drywall Paint White 0 Women’s Bathroom Wall

24 Drywall Paint White 0 Women’s Bathroom Wall

25 Drywall Paint White 0 Women’s Bathroom Wall

Number Substrate And Component

Surface

Paint Color

XRF Result

(mg/cm2) Room/Area Description

Drywall Paint White

Women’s Bathroom Window

Column (Sample #21 Confirmatory

Sample)

27 Drywall Paint White 0 Women’s Bathroom Wall

28 Metal Door Frame Paint Gray 0 Men’s Bathroom Door Frame

29 Wood Finish Wood 0 Men’s Bathroom Door

30 Metal Hot Water Coil Paint Light Gray 0 Women’s Bathroom Hot Water Fan

Coil

31 Drywall Paint White 0 Women’s Bathroom Ceiling

32 Light Fixture Paint White 0 Women’s Bathroom Light Fixture

33 Metal Fan Paint White 0 Women’s Bathroom Fan

34 Metal Ceiling Hatch Paint White 0 Women’s Bathroom

35 Drywall Paint White 0 Hallway Ceiling

36 Drywall Paint White 0 Unisex Bathroom Ceiling

37 Drywall Paint White 0 Unisex Bathroom Wall

38 Metal Vent Paint White 0 Vent in Unisex Bathroom

39 Metal Kick Plate Finish Silver 0 Men’s Bathroom Door

40 Tile Glaze Cream 0 Men’s Bathroom Wall

41 Tile Glaze Brown 0 Men’s Bathroom Wall

42 Tile Glaze Gray 0 Men’s Bathroom Floor

43 Metal Window Frame Paint Black 0 Men’s Bathroom Window

44 Metal Stall Door Paint Gray 0 Men’s Bathroom

45 Metal Urinal Dividers Paint Gray 0 Men’s Bathroom

46 Wood Finish Wood 0 Men’s Bathroom Bench

47 Metal Finish Gray 0 Men’s Bathroom Bench

48 Concrete Paint White 0 Men’s Bathroom Wall

49 Tile Glaze White 0 Men’s Bathroom Wall

50 Drywall Paint White 0 Men’s Bathroom Ceiling

51 Wood Finish Wood 0 Kitchen Door

Number Substrate And Component

Surface

Paint Color

XRF Result

(mg/cm2) Room/Area Description

52 Metal Door Frame Paint Gray 0 Kitchen Door Frame

53 Drywall Paint White 0 Kitchen Wall

54 Tile Glaze Tan 0 Kitchen Floor

55 Metal Kick Plate Finish Silver 0 Kitchen Door

56 Drywall Paint White 0 Kitchen Ceiling

57 Ceiling Panel Paint White 0 Kitchen Ceiling

58 Metal Ceiling Grid Paint White 0 Kitchen Ceiling

59 Drywall Paint White 0 Recruiter’s Office Wall

60 Metal AC Unit Paint White 0 Recruiter’s Office AC Unit

61 Metal AC Unit Switch Paint White 0 Recruiter’s Office AC Unit

62 Metal Ceiling Grid Paint White 0 Recruiter’s Office Ceiling

Values in bold indicate results with a detectable amount of lead.

Values in red indicate results over the EPA limit of 1.0 mg/cm2 (used as a benchmark, not a regulatory threshold).

APPENDIX B

ANALYTICAL RESULTS REPORT(S)

January 23, 2026

RMEC Environmental, Inc.

476 West 325 South

Bountiful, UT 84010

Ref: Batch # 223703, Lab # RMEC9305 - RMEC9332

Received January 13, 2026

Test report, Page 1 of 8

251 S. 200 E. American Fork UT 84003

DFCM American Fork Armory

Job# 25A-5447

Sampled by Mackenzie Hobbs 1/13/26

Dear RMEC Environmental, Inc.:

Samples RMEC9305 through RMEC9332 have been analyzed using the qualitative analysis of bulk samples by polarized light microscopy (PLM), and the quantitation of asbestos content by calibrated visual estimate (CVE) based on EPA -- 40 CFR Appendix E to Subpart E of Part 763

(EPA 600/M4-82-020), Interim Method of the Determination of Asbestos in Bulk Insulation

Samples, and EPA 600/R-93/116: Method for the Determination of Asbestos in Bulk Building

Materials, as well as guidance from the OSHA ID-191 method. Appendix "A" contains statements which an accredited laboratory must make to meet the requirements of accrediting agencies. It also contains additional information about the method of analysis. Appendix "A" must be included as an essential part of this test report. This analysis is accredited under NVLAP Lab Code: 101012-0.

It does not contain data or calibrations for tests performed under AIHA-LAP LLC Lab Code:

101579.

This report may be reproduced but all reproduction must be in full unless written approval is received from the laboratory for partial reproduction. The results of analysis are as follows:

Lab RMEC9305, Field W01-01 White Drywall w/ Mud & Tape

This sample contains four types of material: The first type is off-white paint; the second type is white limestone plaster with perlite and mica; the third type is brown plant fiber paper; and the fourth type is white gypsum plaster with vermiculite and 1% fiberglass. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 1% of the sample. The second type is 5% of the sample. The third type is 4% of the sample. The fourth type is 90% of the sample.

Batch # 223703

Lab # RMEC9305 - RMEC9332

Lab RMEC9306, Field W01-02 White Drywall w/ Mud & Tape

This sample contains four types of material: The first type is off-white paint; the second type is white limestone plaster with perlite, mica, and 1% fiberglass; the third type is brown plant fiber paper; and the fourth type is white gypsum plaster with vermiculite and 1% fiberglass. This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 20% of the sample. The third type is 4% of the sample. The fourth type is 75% of the sample.

Lab RMEC9307, Field W01-03 White Drywall w/ Mud & Tape

This sample contains four types of material: The first type is off-white paint; the second type is white limestone plaster with perlite and mica; the third type is brown and white plant fiber paper;

and the fourth type is white gypsum plaster with vermiculite and 1% fiberglass. This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 10% of the sample. The third type is 4% of the sample. The fourth type is 85% of the sample.

Lab RMEC9308, Field W01-04 White Drywall w/ Mud & Tape

This sample contains four types of material: The first type is off-white paint; the second type is white limestone plaster with perlite and mica; the third type is brown and white plant fiber paper;

and the fourth type is white gypsum plaster with vermiculite and 1% fiberglass. This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 15% of the sample. The third type is 4% of the sample. The fourth type is 80% of the sample.

Lab RMEC9309, Field W01-05 White Drywall w/ Mud & Tape

This sample contains four types of material: The first type is off-white paint; the second type is white limestone plaster with perlite and mica; the third type is brown and white plant fiber paper;

and the fourth type is white gypsum plaster with vermiculite and 1% fiberglass. This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 5% of the sample. The third type is 4% of the sample. The fourth type is 90% of the sample.

Lab RMEC9310, Field FT01-01 Brown 1x1 Tile w/ Grout / Adhesive

This sample contains four types of material: The first type is tan and black ceramic tile; the second type is tan resin mastic with limestone; the third type is grey sandy cement with limestone; the fourth type is brown and grey sandy cement with limestone and mica. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 80% of the sample. The second type is 3% of the sample. The third type is 7% of the sample. The fourth type is 10% of the sample.

Lab RMEC9311, Field FT01-02 Brown 1x1 Tile w/ Grout / Adhesive

This sample contains four types of material: The first type is tan and black ceramic tile; the second type is tan resin mastic with limestone; the third type is grey sandy cement with limestone; the fourth type is brown and grey sandy cement with limestone and mica. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 85% of the sample. The second type is 2% of the sample. The third type is 7% of the sample. The fourth type is 6% of the sample.

Lab RMEC9312, Field WT01-01 Brown 4x4 Tile w/ Off-white Grout / Adhesive

This sample contains five types of material: The first type is off-white ceramic tile; the second type is off-white resin mastic with limestone; the third type is off-white paint; the fourth type is grey sandy cement; the fifth type is grey sandy cement with limestone and mica. This sample is non-homogeneous. Asbestos is none detected.

The first type is 75% of the sample. The second type is 10% of the sample. The third type is 2% of the sample. The fourth type is 3% of the sample. The fifth type is 10% of the sample.

Lab RMEC9313, Field WT01-02 Brown 4x4 Tile w/ Off-white Grout / Adhesive

This sample contains three types of material: The first type is white ceramic tile; the second type is white resin mastic with limestone; the third type is white limestone plaster with perlite, mica, and rust scale debris. This sample is non-homogeneous. Asbestos is none detected.

The first type is 85% of the sample. The second type is 10% of the sample. The third type is 5% of the sample.

Lab RMEC9314, Field IN01-01 Fiberglass Insulation w/ White Paper Wrap

This sample contains four types of material: The first type is metallic foil; the second type is cross-woven fiberglass in clear resin; the third type is brown plant fiber paper; the fourth type is 95% glass wool in yellow resin. This sample is non-homogeneous. Asbestos is none detected.

The first type is 3% of the sample. The second type is 2% of the sample. The third type is 2% of the sample. The fourth type is 93% of the sample.

Lab RMEC9315, Field IN01-02 Fiberglass Insulation w/ White Paper Wrap

This sample contains four types of material: The first type is metallic foil; the second type is cross-woven fiberglass in clear resin; the third type is brown plant fiber paper; the fourth type is 95% glass wool in yellow resin. This sample is non-homogeneous. Asbestos is none detected.

The first type is 3% of the sample. The second type is 2% of the sample. The third type is 2% of the sample. The fourth type is 93% of the sample.

Lab RMEC9316, Field CM01-01 Painted Concrete Block w/ Gray Grout

This sample contains three types of material: The first type is off-white paint; the second type is off-white coating; the third type is grey sandy cement with cinders. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 13% of the sample. The second type is 13% of the sample. The third type is 74% of the sample.

Lab RMEC9317, Field CM01-02 Painted Concrete Block w/ Gray Grout

This sample contains three types of material: The first type is off-white paint; the second type is off-white coating; the third type is grey sandy cement with cinders. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 10% of the sample. The second type is 15% of the sample. The third type is 75% of the sample.

Lab RMEC9318, Field CM01-03 Painted Concrete Block w/ Gray Grout

This sample contains three types of material: The first type is off-white paint; the second type is off-white coating; the third type is grey sandy cement with cinders. This sample is non-homogeneous.

Asbestos is none detected.

The first type is 10% of the sample. The second type is 15% of the sample. The third type is 75% of the sample.

Lab RMEC9319, Field CK01-01 White Caulk

This is white rubber caulking with limestone and mica. Asbestos is none detected.

Lab RMEC9320, Field CK01-02 White Caulk

This is white rubber caulking with limestone and mica. Asbestos is none detected.

Lab RMEC9321, Field CA01-01 Green Carpet Tile w/ Brown Mastic

This sample contains three types of material: The first type is brown and grey synthetic fiber carpet;

the second type is grey and green rubber with limestone and 5% fiberglass; the third type is grey resin mastic with debris. This sample is non-homogeneous. Asbestos is none detected.

The first type is 33% of the sample. The second type is 65% of the sample. The third type is 2% of the sample.

Lab RMEC9322, Field CA01-02 Green Carpet Tile w/ Brown Mastic

This sample contains three types of material: The first type is brown and grey synthetic fiber carpeting; the second type is grey rubber with limestone and 5% fiberglass; the third type is grey resin mastic. This sample is non-homogeneous. Asbestos is none detected.

The first type is 40% of the sample. The second type is 58% of the sample. The third type is 2% of the sample.

Lab RMEC9323, Field CB01-01 Black Cove Base w/ Yellow Mastic

This sample contains five types of material: The first type is black rubber cove base with limestone;

the second type is tan resin mastic; the third type is white paint; the fourth type is white limestone plaster with perlite and mica; the fifth type is brown plant fiber paper. This sample is non-homogeneous. Asbestos is none detected.

The first type is 90% of the sample. The second type is 3% of the sample. The third type is 1% of the sample. The fourth type is 5% of the sample. The fifth type is 1% of the sample.

Lab RMEC9324, Field CB01-02 Black Cove Base w/ Yellow Mastic

This sample contains five types of material: The first type is black rubber cove base with limestone;

the second type is tan resin mastic; the third type is white paint; the fourth type is white limestone plaster with perlite and mica; the fifth type is brown plant fiber paper. This sample is non-homogeneous. Asbestos is none detected.

The first type is 90% of the sample. The second type is 5% of the sample. The third type is 1% of the sample. The fourth type is 3% of the sample. The fifth type is 1% of the sample.

Lab RMEC9325, Field AS01-01 Plastic Splash Sheet w/ Yellow Adhesive

This sample contains two types of material: The first type is 20% fiberglass in white limestone binder; the second type is tan resin mastic. This sample is non-homogeneous. Asbestos is none detected.

The first type is 95% of the sample. The second type is 5% of the sample.

Lab RMEC9326, Field AS01-02 Plastic Splash Sheet w/ Yellow Adhesive

This sample contains three types of material: The first type is 20% fiberglass in white limestone and plastic binder; the second type is tan resin mastic; the third type is brown plant fiber paper. This sample is non-homogeneous. Asbestos is none detected.

The first type is 90% of the sample. The second type is 3% of the sample. The third type is 7% of the sample.

Lab RMEC9327, Field CT01-01 White 2x4 Ceiling Tile w/ Pinholes

This is a light gray sample with perlite, 30% plant fiber, and 30% mineral wool in resin binder with a white coating on one side. This sample is non-homogeneous. Asbestos is none detected.

The white coating is 1% of the sample.

Lab RMEC9328, Field CT01-02 White 2x4 Ceiling Tile w/ Pinholes

This is a light gray sample with perlite, 30% plant fiber, and 30% mineral wool in resin binder with a white coating on one side. This sample is non-homogeneous. Asbestos is none detected.

The white coating is 1% of the sample.

Lab RMEC9329, Field CT02-01 White 2x4 Ceiling Tile w/o Pinholes

This sample contains three types of material: The first type is white paint; the second type is brown plant fiber paper; and the third type is white gypsum plaster with 1% fiberglass and 1% plant fiber.

This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 3% of the sample. The third type is 96% of the sample.

Lab RMEC9330, Field CT02-02 White 2x4 Ceiling Tile w/o Pinholes

This sample contains three types of material: The first type is white paint; the second type is brown plant fiber paper; and the third type is white gypsum plaster with 1% fiberglass and 1% plant fiber.

This sample is non-homogeneous. Asbestos is none detected.

The first type is 1% of the sample. The second type is 3% of the sample. The third type is 96% of the sample.

Lab RMEC9331, Field FT02-01 Brown 4x4 Floor Tile w/ Concrete/

This sample contains two types of material: The first type is brown ceramic tile; the second type is brown sandy cement with limestone. This sample is non-homogeneous. Asbestos is none detected.

The first type is 97% of the sample. The second type is 3% of the sample.

Lab RMEC9332, Field FT02-02 Brown 4x4 Floor Tile w/ Concrete/

This sample contains two types of material: The first type is brown ceramic tile; the second type is brown sandy cement with limestone. This sample is non-homogeneous. Asbestos is none detected.

The first type is 97% of the sample. The second type is 3% of the sample.

In order to be sure reagents and tools used for analysis are not contaminated with asbestos, blanks are tested. Asbestos was none detected in the blanks tested with this bulk sample set.

Very truly yours, Steve H. Dixon, President

Analyzed by Anton N. Snow on January 22, 2026

APPENDIX "A"

This report relates only to the items tested. This report must not be used to claim product certification, approval or endorsement by NVLAP, NIST, AIHA LAP, or any U.S. government agency.

NVLAP and AIHA LAP require laboratories to report the condition of samples received for testing. The condition of these samples is considered acceptable for analysis unless otherwise noted. If a test item is unacceptable for analysis, requires a modification to the standard method, or has limited analysis sensitivity, this will be noted under the laboratory number for that specific test item in the final report. If the samples are non-homogeneous, a statement will be included with the sample result. Each component or sub-sample is analyzed separately. The reported results and percentages of each material type are based on the sample received by the laboratory and may not be representative of the parent material.