596A4-22-700 Asbestos Inspection Report.pdf

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Y1DA--EHRM Infrastructure Upgrades Construction Lexington-Cooper, KY 596A4-22-700
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This hazardous building materials inspection report details the findings of an asbestos and lead-based paint survey conducted at the Lexington VAHS - Bowling Campus in Lexington, Kentucky. The inspection identified several homogenous materials in the facility containing asbestos, including floor tiles, mastic, ceiling tiles, and pipe insulation. Additionally, multiple paint applications throughout the building tested positive for lead-based paint. The report recommends general abatement of all asbestos-containing materials and lead-based paint identified prior to renovation work. Regulatory requirements for notification, removal, and OSHA standards are also outlined.

The related federal contract opportunity is a solicitation for construction services at the same Lexington VAHS location to complete EHRM infrastructure upgrades. The solicitation number is 36C77623B0069 and is being issued by the Department of Veterans Affairs Technology Acquisition Center in Austin, Texas. Pricing and response due dates are not provided in the available information.

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Hazardous Building Materials Inspection Report

EHRM Infrastructure Upgrades Lexington VAHS – Bowling Campus Lexington, KY

VA Project No: 596A4-22-700

Prepared for HFS Company by:

DESERT CONCEPTS E & E, INC and AMI Environmental Team 8000 IH 10 W, Suite 600 San Antonio, TX 78230

November 28, 2022

TABLE OF CONTENTS

1. SURVEY OVERVIEW

1.1. Purpose and Scope

1.1.1. Inspection Area

1.1.2. Limitations

1.2. Regulatory Reference

2. BUILDING INFORMATION

2.1. General Construction

2.2. Pre-Existing Information

3. INSPECTION METHODOLOGIES

3.1. Asbestos Inspection

3.1.1. Key Definitions

3.1.2. Homogenous Material Numbering Convention

3.1.3. Bulk Sampling

3.2. Lead-Based Paint Inspection

3.2.1. Key Definitions

3.2.2. Homogenous Paint Applications Numbering Convention

3.2.3. Paint Chip Sampling

4. SUMMARY OF INSPECTION FINDINGS

4.1. Asbestos Inspection Findings

4.2. Lead Paint Inspection Findings

5. RISKS AND HAZARDS

5.1. Asbestos

5.2. Lead-Based Paint

6. RECOMMENDATIONS

6.1. General Recommendations

6.1.1. Asbestos

6.1.2. Lead-Based Paint

6.2. Hazardous Conditions Recommendations

6.3. Point Count Analysis / TEM Chatfield Analysis Recommendations

7. REGULATORY REQUIREMENTS

7.1. Asbestos-Containing Materials

7.1.1. Notification Requirements

7.1.2. Asbestos Removal Requirements

7.1.3. OSHA Regulation of <1 Percent Asbestos

7.1.4. Asbestos Removal Regulations

7.2. Lead-Based Paint

7.2.1. Disposal Requirements

7.2.2. Construction Requirements

APPENDIX A: Tables

APPENDIX B: Photo Logs

APPENDIX C: Analytical Results

APPENDIX D: Schematics

APPENDIX E: Inspectors Credentials

HAZARDOUS MATERIALS INSPECTION REPORT

EHRM Infrastructure Upgrades

Lexington VAHCS Bowling Campus 1101 Veterans Drive Lexington, KY 40502

1. SURVEY OVERVIEW

On October 18, 2022, Buildings 1 and 1A at the Veterans Affairs Health Care System, 1101 Veterans Dr, Lexington, KY, were inspected for asbestos-containing material (ACM) and lead-based paint (LBP) by representatives of Desert Concepts E&E and AMI Environmental (AMIE). The hazardous building materials inspection was conducted in preparation for EHRM infrastructure upgrades. The AMIE representatives were escorted to determine the impacted areas by Tyler Messner, General Engineer with the Lexington VAHCS.

The renovation project is hereinafter referred to as The Project. The inspection was initiated at the request of Mr. Nick Andrews, PE, SE of HFS Company, on behalf of the VA Medical Center. The inspection and was performed by Mr. Michael Cossette of Environmental Testing and Consulting of Kentucky LLC, in accordance with regulatory requirements and generally accepted industry methods. Copies of applicable requisite training certificates are provided in Appendix E.

1.1. Purpose and Scope

The purpose and scope of the inspection was to identify and sample suspect ACMs, LBPs or other lead containing building materials present in the project area that may be impacted by The Project.

1.1.1. Inspection Area

The hazardous building materials inspection of the project included all accessible interior and areas of rooms: D007D, C121, CU222, CU333, CU411, A002C, A104, A243, A345, A450, AU547, A627, A073, and A022 which will be renovated as part of the EHRM infrastructure upgrades in Buildings 1 and 1A. The above-described areas are hereinafter referred to collectively as the Inspection Area.

1.1.2. Limitations

Asbestos containing materials may exist in wall cavities or interstitial spaces between floors. It is recommended that any new materials discovered in the renovation process prior to or during construction be tested or abated.

Sampling of these materials may not be necessary if, in the case of suspect ACM, the materials are assumed to be ACM or if they are determined by a licensed asbestos inspector to be homogenous to other materials that were sampled. Materials assumed asbestos containing in the inspection area included fire doors.

Hazardous Building Materials Inspection Report AMI Project No. 22-172 EHRM Infrastructure Upgrades November 28, 2022 Lexington-Cooper Lexington, KY Page of 9

1.2. Regulatory Reference

The asbestos inspection was conducted in accordance with USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (ref.: 40 CFR, Part 61), following criteria established for identifying asbestos-containing building materials that may be impacted by planned renovation activities; applicable protocols established by the Asbestos Hazard Emergency Response Act (AHERA) (ref.: 40 CFR 763). There is also no licensing requirement for lead paint sampling in non- HUD facilities.

The State of Kentucky does have State licensing for asbestos inspectors.

2. BUILDING INFORMATION

2.1. General Construction

This project involves the renovation of IT and Telecommunication Rooms.

2.2. Pre-Existing Information

Information on previous surveys or sampling for asbestos was provided. An “Asbestos Re-inspection” dated February 28, 2018 indicated the presence of asbestos containing flooring materials in Building 1, including Vinyl Floor Tiles (VFT) and associated flooring mastic.

3. INSPECTION METHODOLOGIES

3.1. Asbestos Inspection

The inspection and sampling were conducted in accordance with the USEPA National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations (ref.: 40 CFR, Part 61), following criteria established for identifying asbestos-containing. building materials that may be impacted by planned demolition. Additional aspects of the inspection methodology are discussed below.

3.1.1. Key Definitions

3.1.1.1. Homogenous Material

Homogenous materials are unique applications of building materials uniform in color and texture. The homogeneity of a material can be further defined by area(s) of application. Bulk sampling is conducted to determine the asbestos content of a homogenous material.

3.1.1.2. Asbestos-Containing Material (ACM)

The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) define ACMs as any material that contains greater than one percent asbestos, as determined by visual area estimation (microscopic analysis). The State of Kentucky follows the EPA standard. Some materials contain one percent or less asbestos. While these materials are not ACMs by definition, they are still regulated by OSHA, for worker exposure.

3.1.1.3. Friable/Non-Friable ACM

Friable ACMs are materials that contain more than one percent asbestos and, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure, thereby releasing fibers into the air more readily. In contrast, non-friable ACMs are ACMs that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACMs are grouped into two categories: Category I and Category

II.

3.1.1.4. Regulated Asbestos-Containing Materials (RACM)

Regulated Asbestos-Containing Materials (RACM) include friable ACMs and non-friable ACMs that, depending on their category, have become friable, have been subjected to specific forms of impact damage, have a high probability of becoming friable, and/or may become friable during removal.

3.1.2. Homogenous Material Numbering Convention

All suspect asbestos materials are assigned a unique homogeneous material number. AHERA identifies three basic material types: Surfacing Materials (SM), which include spray and trowel applied materials, such as fireproofing, ceiling texture, plaster, etc.; Thermal System Insulation (TSI), which includes insulating materials applied to mechanical and plumbing components for temperature preservation and condensation prevention purposes; and Miscellaneous Materials (MM), which includes all other materials, such as floor coverings and mastics, roofing materials, asbestos cement products, and many others. When a homogenous material has multiple layers, individual layers are identified and analyzed separately by laboratory analysis.

3.1.3. Bulk Sampling

Bulk sampling must be performed to determine whether suspect building material contains asbestos. Asbestos bulk sampling for the inspection was conducted in accordance with protocols established by the Asbestos Hazard Emergency Response Act (AHERA) (ref.: 40 CFR 763). Friability of the suspect asbestos-containing materials was determined by touching and/or sampling of the material.

3.1.3.1. Bulk Sample Numbering Convention

Bulk samples are given a sequence sample number when collected.

3.1.3.2. Polarized Light Microscopy Analysis (PLM)

Bulk samples collected during the inspection were submitted to an EPA accredited laboratory, EMSL Analytical, Inc. (EMSL), located at 6340 CastlePlace Dr.

Indianapolis, IN 46250. EMSL was instructed to perform Polarized Light Microscopy (PLM) analysis, utilizing dispersion staining techniques (ref: EPA Method 600/M4- 82-020). PLM analysis is the least expensive and most commonly used visual estimate method. While PLM analysis is acceptable to EPA, OSHA, and most states for determining asbestos content, some states now require more sophisticated methods when analyzing certain types of materials.

A total of 36 asbestos bulk samples were collected and submitted for laboratory analysis. PLM Analysis was performed on the samples collected, including all heterogeneous layers. Heterogeneous applications are individual layers of different materials contained within a single bulk sample, each of which must be analyzed individually to determine its asbestos content (e.g. vinyl floor tiles and mastic; cove base and mastic; etc.). Table 1 lists all samples collected and analyzed in the current survey.

Some samples and/or heterogeneous applications may not have been analyzed by the lab if a positive result was obtained from a sample that is among a group of samples representing a suspect material. This process, known as stop on first positive, is followed because if a single sample is found to be positive, that material is determined to be ACM, thus making it unnecessary to analyze any additional samples in the sampling group.

Please refer to the Table 1– Asbestos Material Sampling Table in Appendix A for a complete listing of all materials sampled. The laboratory analytical reports may be found in Appendix C for the current inspection.

3.1.3.3. Quantification Method Analysis

EPA regulations allow materials determined to contain less than 10 percent asbestos utilizing a visual estimate quantification method, such as PLM analysis, to be treated as non-asbestos containing if the material is re-analyzed using one of two quantification methods and determined to contain one percent or less of asbestos. The two acceptable quantification methods are point count analysis and TEM Chatfield analysis.

Quantification methods are more time-consuming and more expensive analytical procedures that are occasionally used to more accurately determine the amount of asbestos in certain samples. Because of their higher cost and the acceptable accuracy of the less expensive visual estimation method, laboratories do not typically perform quantification analyses unless specifically requested.

The quantification method known as point count analysis is used for most ACM types, except floor tile. The organic matrix composition of floor tile precludes the use of point count analysis to more accurately determine asbestos amounts within a sample.

Therefore, TEM Chatfield analysis—which effectively removes all organic materials, leaving only asbestos behind—is necessary to provide a more precise percentage of asbestos content in floor tile.

Please refer to section 6.0 Recommendations, for recommendations concerning supplemental analysis.

3.2. Lead-Based Paint Inspection

The LBP inspection included visual identification of homogenous paint applications sampling of the paint(s). While the U. S. Department of Housing and Urban Development (HUD) promulgates guidelines for LBP inspections in child occupied facilities, there are no formal guidelines for non-HUD regulated inspections. Thus, the LBP inspection was conducted in accordance with generally accepted industry standards and practices. Additional aspects of the inspection methodology are discussed below.

3.2.1. Key Definitions

3.2.1.1. Homogenous Paint Applications

Homogenous paint applications are significant paint applications that are visually distinct by their color and uniformity. Significant paint applications do not include incidental occurrences of paint such as isolated occurrences of accent trim, artistic paints, etc.

3.2.1.2. Lead-Based Paint (LBP)

Pursuant to Federal Register, Vol. 61, No. 169, LBP is defined as paint or other surface coatings equal to or greater than 0.5 percent lead by weight or equal to or greater than 1 mg/cm2.

3.2.2. Homogenous Paint Applications Numbering Convention

Homogenous paints and coatings are assigned a unique homogeneous material number (HM#).

The HM# is referenced throughout the report to uniquely identify each paint application.

3.2.3. Lead-based Paint Sampling

Sampling of suspected lead-based paint was conducted. Samples of Lead-based Paint were collected from homogeneous paint applications for laboratory analysis. A total of 9 lead-based paint samples were collected.

4. SUMMARY OF INSPECTION FINDINGS

Key findings of the hazardous building materials inspection are summarized below. Please refer to the Appendices for complete details of the inspection findings and supporting documentation.

4.1. Asbestos Inspection Findings

Below is a summary of the findings of the asbestos inspection:

• MM-07: Floor Mastic 2% Chrysotile A243, A345 200 SF

• MM-10: 12”x12” VFT 2% Chrysotile A002C 80 SF

• MM-10A: Floor Mastic 2% Chrysotile A002C 80 SF

• MM-11A: Floor Mastic 2% Chrysotile A002C 10 SF

• MM-16A: Floor Mastic 2% Chrysotile A450 50 SF

• MM-17A: Floor Mastic 2% Chrysotile A627 70 SF

• MM-19: 9”x9” VFT 2% Chrysotile A022 450 SF

• MM-19A: Floor Mastic 2% Chrysotile A022 450 SF

• Fire Doors Assumed ACM D007D, A104, A022 3 Doors

Please refer to Table 1 – Asbestos Sampling Table in Appendix A for a complete listing of all asbestos sampling.

4.2. Lead Paint Inspection Findings

Below is a summary of the findings of the lead-based paint inspection:

• All suspect lead-based paints and ceramic tiles sampled were analyzed and reported as less than 0.5% lead by weight.

Please refer to Table 2 – Lead Paint Sampling Table in Appendix A for a complete listing of all lead-based paint and material sampling.

NOTE: See Section 7.2.2 Lead in Construction. Paint containing lead (PCL) at levels not considered Lead-based paint was found in samples in Lead Paint Sampling Table.

5. RISKS AND HAZARDS

5.1. Asbestos

To be a significant health concern, asbestos fibers must be inhaled. When asbestos fibers are inhaled, they become lodged in the lung tissue or alveoli. Here they clog and scar the tissues, causing the walls of the alveoli to lose their elasticity and useful function in respiration. Asbestosis (scarring of the lung), lung cancer, and Mesothelioma (cancer of the lining of the chest or lining of the abdominal wall) are diseases associated with asbestos exposure. Risks and hazards increase with increased exposure. ACM condition, proximity to building occupants, building use, and other factors can influence the potential for asbestos fibers to become airborne, and therefore increase exposure risks.

5.2. Lead-Based Paint

Inhalation and ingestion are the major routes of lead exposure. Once in the body, lead is distributed via the bloodstream to red blood cells, soft-tissue and bone. The kidneys and gastrointestinal (GI) tract eliminate lead in the body very slowly, while minute amounts are lost through perspiration.

Lead in the body can cause serious damage to the central and peripheral nervous system, the cardiovascular system, and the kidneys. Exposure to high concentrations of lead can cause retardation, convulsions, coma, and sometimes death. Children are especially vulnerable and susceptible to lead poisoning. Even low levels of exposure persisting during childhood are known to slow a child’s normal development and cause learning and behavioral problems. Exposure to lead can result from deteriorating surfaces and activities mechanically impacting lead surfaces. Preventing exposure requires proper work practices, monitoring, disposal and personal protective equipment during demolition, alteration and friction producing activities.

6. RECOMMENDATIONS

The purpose of this section is to interpret survey findings and provide preliminary recommendations that may be relevant and appropriate at this time. Because this document is a presentation of investigative findings, recommendations related to future construction activities are inherently general in nature. More specific determinations concerning hazardous building materials to be impacted by construction should be made during the abatement project design process.

6.1. General Recommendations

6.1.1. Asbestos

State and/or federal regulations require that ACMs be removed prior to demolition or renovation activities that will impact the ACMs. Depending on the specific renovation work to be performed, certain ACMs may not require removal if they will not be disturbed and do not pose a risk to building occupants or construction trade workers. However, to ensure worker safety and to eliminate future asbestos-related maintenance and management costs and risks, AMIE recommends removal of all identified ACMs in the areas to be renovated. While partial abatement may be technically possible, it is often impractical and not cost-effective.

ACMs not impacted by renovation or demolition activities should be inspected annually and maintained in good condition. ACMs deemed to be in less than good condition (damaged or significantly damaged) should be repaired or removed and replaced. Such repairs should be performed by qualified persons and in accordance with regulatory guidelines.

6.1.2. Lead-Based Paint and Lead Containing Materials

Facility owners are ultimately liable for their lead-containing hazardous waste from cradle to grave. EPA regulations provide two ways to determine whether a waste stream, such as demolition debris containing LBP, must be classified as hazardous waste. Waste generators can either test the waste using an approved testing method (Toxicity Characteristic Leaching Procedure [TCLP]), or they can apply knowledge of the hazardous characteristic of the waste.

Any lead-based painted building components not removed during renovation should be considered for inclusion in a facility management plan that maintains potential exposure below OSHA action levels and ensures the material will be handled properly and in accordance with applicable regulations.

6.2. Hazardous Conditions Recommendations

Hazardous conditions noted in the inspection area included the visual observation of mold in buildings 7, 8, 9, and 10. Miscellaneous hazardous materials including PCB light ballasts and fluorescent light tubes were noted in the basements of Buildings 6, 7, 8, 9, and 10. These items should be recycled or disposed of properly prior to construction.

6.3. Point Count Analysis / TEM Chatfield Analysis Recommendations AMIE does not recommend Point Count or TEM Chatfield analysis of any of the ACMs identified.

7. REGULATORY REQUIREMENTS

7.1. Asbestos-Containing Materials

The removal and disposal of ACMs is regulated at the federal, state, and, sometimes, local level. While some states have developed their own regulatory standards for the various asbestos disciplines, many states have adopted the federal standards but have established licensing requirements and enforcement authority at the state level.

7.1.1. Notification Requirements

EPA’s NESHAP regulation, 40 CFR, Subpart M, 61.145, Standard for Demolition and Renovation, stipulates that an owner of a facility submit proper notification with either the EPA’s regional office and/or the state and local regulatory agency of intention to demolish or renovate. Notifications must be received by the appropriate regulatory agencies 10 working days prior to commencement of asbestos stripping or removal, or other site work. If the demolition or renovation date changes, or the scope of work is increased, another notification is required.

7.1.2. Asbestos Removal Requirements

Asbestos removal must be performed by an abatement contractor following all work practices, worker protection, and disposal requirements set forth in the contract specifications and by the Occupational Safety and Health Administration (OSHA) and the EPA. Key federal regulations concerning asbestos include 29 CFR 1910.1001, 29 CFR 1926.1101, 40 CFR Part 61, Subpart M, and 40 CFR 763.

7.1.3. OSHA Regulation of ≤ 1 Percent Asbestos

While EPA and many states do not regulate materials containing one percent or less asbestos, OSHA regulates materials containing any amount of asbestos. (Ref. OSHA Construction Industry Standard, 29 CFR 1926.1101(a)(3))

7.1.4. Asbestos Removal Regulations

Asbestos Containing Building Material (ACBM) should only be removed by companies with trained workers, and following all applicable regulatory and industry standards.

7.2. Lead Waste

7.2.1. Disposal Requirements

The Resource Conservation and Recovery Act (RCRA) classifies lead-containing waste streams as hazardous materials if TCLP levels exceed five parts per million. If TCLP leachable lead levels exceed that threshold, EPA regulations (40 CFR 261) require the waste stream to be handled and disposed of as a hazardous waste. Waste streams containing less the five parts per million of leachable lead are classified as non-hazardous waste and can be disposed of in a construction and demolition landfill.

7.2.2. Lead in Construction Requirements

OSHA’s 29 CFR 1926.62 regulates worker exposure to lead during construction activities that include demolition or salvage of structures where lead or materials containing lead are present, as well as removal or encapsulation of lead-containing materials. The standard establishes maximum limits of exposure to lead, including a permissible exposure limit and action level, and should be adhered to during construction and demolition activities.

Desert Concepts E&E and AMI Environmental 8000 IH 10 West, Ste. 600

San Antonio, TX 78230 661-203-8172

APPENDIX A

Asbestos and Lead-Based Paint Tables

Table 1 – Asbestos Materials Sampling Table

Table 2 – Lead-Based Paint Sampling Table

Table I

Table 1: Asbestos-Containing Material Sampling Table & Test Results VA Project No: 596A4-22-700 Lexington VAHCS – Bowling Campus November 28, 2022

Material #/ Description Sample # Color Location Sample Result Condition Friable

(Y/N) Estimated Quantity

Photo No.

MM-01: Floor Mastic 01 Black C121 None Detected

MM-01: Floor Mastic 02 Black C121 None Detected

MM-02: Cove Base 03 Tan C121 None Detected

MM-02A: Mastic 03 Cream C121 None Detected

MM-02: Cove Base 04 Tan C121 None Detected

MM-02A: Mastic 04 Cream C121 None Detected

MM-03: Drywall 05 White/ Brown C121 None

Detected

MM-04: Joint Compound 06 White C121 None

Detected 3

MM-05: Fire Stop Caulk 07 Red All TRs None

Detected

MM-06: Cove Base 08 Black A243 None Detected

MM-06A: Mastic 08 Clear A243 None Detected 5

MM-06: Cove Base 09 Black A243 None Detected 5

MM-06A: Mastic 09 Clear A243 None Detected 5

MM-07: Floor Mastic 10 Black A243 2% Chrysotile Good N 120 SF 6

MM-07: Floor Mastic 11 Black A243 2% Chrysotile Good N “ 6

VA Project No: 596A4-22-700 Lexington VAHCS – Bowling Campus November 28, 2022

Material #/ Description Sample # Color Location Sample Result Condition Friable

(Y/N) Estimated Quantity

Photo No.

MM-03: Drywall 12 White/ Brown A243 None

Detected

MM-04: Joint Compound 13 White A243 <1% Chrysotile 7

MM-08: Ceramic Tile Mastic 14 Brown A243 None

Detected

MM-07: Floor Mastic 15 Black A345 2% Chrysotile Good N 80 SF 9

MM-06: Cove Base 16 Black A345 None Detected

MM-06A: Mastic 16 Clear A345 None Detected 10

MM-03: Drywall 17 White/ Brown A345 None

Detected

MM-04: Joint Compound 18 White A345 <1% Chrysotile 11

MM-09: Ceramic Tile Mortar 19 Gray A345, AU547, A627 None

Detected

SM-01: Fire Proofing 20 Gray D007D None Detected 13

SM-01: Fire Proofing 21 Gray D007D None

Detected

SM-01: Fire Proofing 22 Gray D007D None

Detected

MM-03: Drywall 23 White/ Brown

A002C, A627, C-222, CU411, AU547, C333

None Detected

MM-04: Joint Compound 24 White A002C, A627, C-222, CU411, AU547, C333

None

Detected

VA Project No: 596A4-22-700 Lexington VAHCS – Bowling Campus November 28, 2022

Material #/ Description Sample # Color Location Sample Result Condition Friable

(Y/N) Estimated Quantity

Photo No.

MM-10: 12"x12" Vinyl Floor Tile (VFT) 25 Light Tan A002C 2% Chrysotile Good N 80 SF 15

MM-10A: Mastic 25 Black A002C 2% Chrysotile Good N “ 15

MM-11: 12"x12" VFT 26 Dark Tan A002C None Detected

MM-11A: Mastic 26 Black A002C 2% Chrysotile Good N 10 SF 16

MM-12: Cove Base 27 Black A002C None Detected

MM-12A: Mastic 27 Tan A002C None Detected

MM-13: 12”x5” VFT (Cut) 28 Black A104 None

Detected 18

MM-13A: Mastic 28 Yellow A104 None Detected

MM-14: 12"x12" VFT 29 Beige with Tan Specks A104 None

Detected 19

MM-14A: Mastic 29 Yellow A104 None Detected

MM-15: 12"x12" VFT 30 Dark Tan with Light

Tan Streaks A450 None

Detected 20

MM-15A: Mastic 30 Black A450 None Detected

MM-16: 12"x12" VFT 31 White with Gray Streaks A450 None

Detected

MM-16A: Mastic 31 Black A450 2% Chrysotile Good N 50 SF 21

MM-17: 12"x12" VFT 32 Beige with Gray Specks A627 None

Detected

VA Project No: 596A4-22-700 Lexington VAHCS – Bowling Campus November 28, 2022

Material #/ Description Sample # Color Location Sample Result Condition Friable

(Y/N) Estimated Quantity

Photo No.

MM-17A: Mastic 32 Black A627 2% Chrysotile Good N 70 SF 22

MM-18: 2'x4' Ceiling Tile 33 Gray/ White A073 Server Room None

Detected

MM-18: 2'x4' Ceiling Tile 34 Gray/ White A073 Server Room None

Detected

MM-19: 9”x9” VFT 35 Beige with Tan Streaks A022 Telecom Room 2% Chrysotile Good N 450 SF 24

MM-19A: Mastic 35 Black A022 Telecom Room 2% Chrysotile Good N “ 24

MM-19: 9”x9” VFT 36 Beige with Tan Streaks A022 Telecom Room 2% Chrysotile Good N “ 24

MM-19A: Mastic 36 Black A022 Telecom Room 2% Chrysotile Good N “ 24

Fire Doors Not Sampled

Various Colors D007D, A104, A022

Assumed ACM (Not

Analyzed) Good Y 3 Doors 25

Table 2

Table 2: Lead Based Paint Sampling Table & Test Results VA Project No: 596A4‐22‐700 Lexington VAHCS – Bowling Campus November 28, 2022

Sample Location Description Substrate Color Paint Condition

Lab Result (% by

Weight) Estimated Quantity

Photo No.

L-1 C121 Wall Paint Drywall Off-White Good <0.0080 % wt 1

L-2 C121 Door Frame Paint Metal Tan Good <0.017 % wt 2

L-3 A243, A627 Wall Paint Drywall White Good <0.0080 % wt 3

L-4 A243, A627, AU547 Ceramic Wall Tile Ceramic Yellow Good 0.016 % wt 4

L-5 A243, AU547, C-222 Door Frame Paint Metal Beige Good <0.020 % wt 5

L-6 A345, A450, C-222 Wall Paint Drywall White Good <0.0080 % wt 6

L-7 A345 Ceramic Wall Tile Ceramic Yellow Good 0.007 % wt 7

L-8 A345, D007D, A002C Door Frame Paint Metal Beige Good <0.041 % wt 8

L-9 A002C, CU-411 Wall Paint Drywall White Good 0.11 % wt 9

L-10 (Ceramic) A002C Ceramic Floor Tile Ceramic Gray Good <0.005 % wt 10

L-10 (Paint) A104, A627 Door & Door Frame

Paint Metal White Good <0.030 % wt 11

Table 2

Table 2: Lead Based Paint Sampling Table & Test Results VA Project No: 596A4‐22‐700 Lexington VAHCS – Bowling Campus November 28, 2022

Sample Location Description Substrate Color Paint Condition

Lab Result (% by

Weight) Estimated Quantity

Photo No.

L-11 A450, CU-411, C333 Door & Door Frame Paint Metal Beige &

Red Good <0.019 % wt 12

APPENDIX B

Photologs

Asbestos Sampling

Lead-based Paint Sampling

Asbestos-Containing Material Photo Log

Lexington VAHCS – Bowling Campus

PHOTO 1

MM-01: Floor Mastic PHOTO 2

MM-02: Cove Base & MM-02A: Mastic

PHOTO 3

MM-03: Drywall & MM-04: Joint Compound PHOTO 4

MM-05: Fire Stop Caulk

PHOTO 5

MM-06: Cove Base & MM-06A: Mastic PHOTO 6

MM-07: Floor Mastic (2% Chrysotile)

PHOTO 7

MM-03: Drywall & MM-04: Joint Compound PHOTO 8

MM-08: Ceramic Tile Mastic

PHOTO 9

MM-07: Floor Mastic (2% Chrysotile) PHOTO 10

MM-06: Cove Base & MM-06A: Mastic

PHOTO 11 MM-03: Drywall & MM-04: Joint Compound PHOTO 12

MM-09: Ceramic Tile Mortar

PHOTO 13

SM-01: Fire Proofing PHOTO 14

MM-03: Drywall & MM-04: Joint Compound

PHOTO 15 MM-10: 12"x12" Vinyl Floor Tile (2%

Chrysotile) & MM-10A: Mastic (2% Chrysotile)

PHOTO 16

MM-11: 12"x12" VFT & MM-11A: Mastic (2% Chrysotile)

PHOTO 17

MM-12: Cove Base & MM-12A: Mastic PHOTO 18

MM-13: 12”x5” VFT (Cut) & MM-13A: Mastic

PHOTO 19 MM-14: 12"x12" VFT & MM-14A: Mastic PHOTO 20

MM-15: 12"x12" VFT & MM-15A: Mastic

PHOTO 21

MM-16: 12"x12" VFT & MM-16A: Mastic (2%

PHOTO 22

MM-17: 12"x12" VFT & MM-17A: Mastic (2%

PHOTO 23 MM-18: 2'x4' Ceiling Tile PHOTO 24 MM-19: 9”x9” VFT (2% Chrysotile)

& MM-19A: Mastic (2% Chrysotile)

PHOTO 25

Fire Doors (Assumed ACM)

Lead-Based Paint Photo Log

PHOTO 1

L-1 Off-White Drywall Paint- PHOTO 2

L-2 Tan Door Frame Paint

PHOTO 3

L-3 White Drywall Paint PHOTO 4

L-4 Yellow Ceramic Wall Tile

PHOTO 5

L-5 Beige Door Frame Paint PHOTO 6

L-6 White Drywall Paint

Lead-Based Paint Photo Log

PHOTO 7

L-7 Yellow Ceramic Wall Tile PHOTO 8

L-8 Beige Door Frame Paint

PHOTO 9

L-9 White Drywall Paint PHOTO 10

L-10 Gray Ceramic Floor Tile

PHOTO 11 L-10 White Door Frame Paint PHOTO 12

L-11 Beige & Red Door/Door Frame Paint

APPENDIX C

Analytical Results

Asbestos Lab Report

Lead-Based Paint Lab Report

EMSL Analytical, Inc.

6340 CastlePlace Dr. Indianapolis, IN 46250

Tel/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com / indianapolislab@emsl.com

162224799EMSL Order:

Customer ID: AMI50

Customer PO: 22-172

Project ID:

Attention: Phone:Colin Lauenroth (402) 397-5001

Fax:AMI Group, Inc. (402) 397-3313

Received Date:8802 South 135th Street 10/21/2022 10:15 AM

Analysis Date:Suite 100 10/25/2022

Collected Date:Omaha, NE 68138-6511 10/18/2022

Project: 22-172 / Lexington VA ACM

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

162224799-0001

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

C121 - Black Mastic

162224799-0002

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

C121 - Black Mastic

03-Cove Base

162224799-0003

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

Fibrous

Heterogeneous

C121 - Cove Base, Tan w/Cream Mastic

03-Mastic

162224799-0003A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

C121 - Cove Base, Tan w/Cream Mastic

04-Cove Base

162224799-0004

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

Non-Fibrous

Homogeneous

C121 - Cove Base, Tan w/Cream Mastic

04-Mastic

162224799-0004A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

C121 - Cove Base, Tan w/Cream Mastic

162224799-0005

None DetectedGypsum

Non-fibrous (Other)

60%

10%

Cellulose30%Brown/White

Fibrous

Heterogeneous

C121 - Drywall

(White/Brown)

162224799-0006

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

C121 - Joint

Compound (White)

162224799-0007

None DetectedNon-fibrous (Other)98%Glass2%Red

Non-Fibrous

Homogeneous

C121 A243 - Fire

Stop Caulk (Red)

08-Cove Base

162224799-0008

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A243 - Cove Base

(Black) w/Clear

Mastic

08-Mastic

162224799-0008A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A243 - Cove Base

(Black) w/Clear

Mastic

09-Cove Base

162224799-0009

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A243 - Cove Base

(Black) w/Clear

Mastic

09-Mastic

162224799-0009A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A243 - Cove Base

(Black) w/Clear

Mastic

162224799-0010

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A243 - Black Floor

Mastic

162224799-0011

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A243 - Black Floor

Mastic

162224799-0012

None DetectedGypsum

Non-fibrous (Other)

60%

10%

Cellulose30%Brown/White

Fibrous

Heterogeneous

A243 Throughout 15'

Ceiling - Drywall, White/Brown

Initial report from: 10/25/2022 10:22:01

Page 1 of 4ASB_PLM_0008_0001 - 1.78 Printed: 10/25/2022 10:22 AM

Tel/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com / indianapolislab@emsl.com

162224799EMSL Order:

Customer ID: AMI50

Customer PO: 22-172

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

162224799-0013

<1% ChrysotileNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A243 - Joint

Compound, White

162224799-0014

None DetectedNon-fibrous (Other)100%Brown

Non-Fibrous

Homogeneous

A243 Walls - Ceramic

Tile Mastic (Brown)

162224799-0015

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A345 - Black Flooring

Mastic

16-Cove Base

162224799-0016

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A345 - Cove Base

(Black) w/Clear

Mastic

16-Mastic

162224799-0016A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A345 - Cove Base

(Black) w/Clear

Mastic

162224799-0017

None DetectedGypsum

Non-fibrous (Other)

60%

10%

Cellulose30%Brown/White

Fibrous

Heterogeneous

A345 - Drywall

(White/Brown)

162224799-0018

<1% ChrysotileNon-fibrous (Other)100%Tan/White

Non-Fibrous

Homogeneous

A345 - Joint

Compound (White)

162224799-0019

None DetectedQuartz

Non-fibrous (Other)

20%

80%

Gray

Non-Fibrous

Homogeneous

A345, on the Back of

Ceramic Tile -

Ceramic Mortar

(Gray)

162224799-0020

None DetectedNon-fibrous (Other)10%Min. Wool90%Gray

Fibrous

Homogeneous

D007D - Fireproofing, Gray

162224799-0021

None DetectedNon-fibrous (Other)10%Min. Wool90%Gray

Fibrous

Homogeneous

D007D - Fireproofing, Gray

162224799-0022

None DetectedNon-fibrous (Other)10%Min. Wool90%Gray

Fibrous

Homogeneous

D007D - Fireproofing, Gray

162224799-0023

None DetectedGypsum

Non-fibrous (Other)

60%

10%

Cellulose30%Brown/White

Fibrous

Heterogeneous

A002C A627 C-222

CU411 - Drywall, White/Brown

162224799-0024

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

A002C A627 C-222

CU-411 - Joint

Compound, White

25-Vinyl Floor Tile

162224799-0025

2% ChrysotileNon-fibrous (Other)98%Tan

Non-Fibrous

Homogeneous

A002C - 12"x12" VFT

Light Tan Black

Mastic

25-Mastic

162224799-0025A

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A002C - 12"x12" VFT

Light Tan Black

Mastic

26-Vinyl Floor Tile

162224799-0026

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A002C - 12"x12" VFT

Dark Tan Black

Mastic

26-Mastic

162224799-0026A

2% ChrysotileNon-fibrous (Other)98%Tan/Black

Non-Fibrous

Homogeneous

A002C - 12"x12" VFT

Dark Tan Black

Mastic

27-Cove Base

162224799-0027

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A002C - Cove Base

6" (Black)

Page 2 of 4ASB_PLM_0008_0001 - 1.78 Printed: 10/25/2022 10:22 AM

Tel/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com / indianapolislab@emsl.com

162224799EMSL Order:

Customer ID: AMI50

Customer PO: 22-172

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

27-Mastic

162224799-0027A

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A002C - Cove Base

6" (Black)

28-Vinyl Floor Tile

162224799-0028

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A104 Perimeter -

12"x5" VFT Black w/Yellow Mastic

28-Mastic

162224799-0028A

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

A104 Perimeter -

12"x5" VFT Black w/Yellow Mastic

29-Vinyl Floor Tile

162224799-0029

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

A104 - 12"x12" VFT

Beige w/Tan Specks

Yellow Mastic

29-Mastic

162224799-0029A

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

A104 - 12"x12" VFT

Beige w/Tan Specks

Yellow Mastic

30-Vinyl Floor Tile

162224799-0030

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

A450 - 12"x12" VFT

Dark Tan w/Light Tan

Streaks (Black

Mastic)

30-Mastic

162224799-0030A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

A450 - 12"x12" VFT

Dark Tan w/Light Tan

Streaks (Black

Mastic)

31-Vinyl Floor Tile

162224799-0031

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

Non-Fibrous

Homogeneous

A450 - 12"x12" VFT

White with Gray

Specks (Black Mastic)

31-Mastic

162224799-0031A

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A450 - 12"x12" VFT

White with Gray

Specks (Black Mastic)

32-Vinyl Floor Tile

162224799-0032

None DetectedNon-fibrous (Other)100%Beige

Non-Fibrous

Homogeneous

A627 - 12"x12" VFT

Beige w/Gray Specks

Yellow and Black

Mastic

32-Mastic

162224799-0032A

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A627 - 12"x12" VFT

Beige w/Gray Specks

Yellow and Black

Mastic

162224799-0033

None DetectedPerlite

Non-fibrous (Other)

15%

5%

Cellulose

Min. Wool

60%

20%

Gray/White

Fibrous

Homogeneous

A073 Server Room

(Data Center)

Throughout - 2'x4'

Ceiling Tile (White)

162224799-0034

None DetectedPerlite

Non-fibrous (Other)

15%

5%

Cellulose

Min. Wool

60%

20%

Gray/White

Fibrous

Homogeneous

A073 Server Room

(Data Center)

Throughout - 2'x4'

Ceiling Tile (White)

35-Vinyl Floor Tile

162224799-0035

2% ChrysotileNon-fibrous (Other)98%Beige

Non-Fibrous

Homogeneous

A022 Telecom Room

- 9"x9" VFT Beige w/Tan Streaks

35-Mastic

162224799-0035A

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A022 Telecom Room

- 9"x9" VFT Beige w/Tan Streaks

36-Vinyl Floor Tile

162224799-0036

2% ChrysotileNon-fibrous (Other)98%Beige

Non-Fibrous

Homogeneous

A022 Telecom Room

- 9"x9" VFT Beige w/Tan Streaks

36-Mastic

162224799-0036A

2% ChrysotileNon-fibrous (Other)98%Black

Non-Fibrous

Homogeneous

A022 Telecom Room

- 9"x9" VFT Beige w/Tan Streaks

Page 3 of 4ASB_PLM_0008_0001 - 1.78 Printed: 10/25/2022 10:22 AM

Tel/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com / indianapolislab@emsl.com

162224799EMSL Order:

Customer ID: AMI50

Customer PO: 22-172

Project ID:

Analyst(s)

Maggie Hayden (41)

Ross Matlock (10)

Asbestos 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. Indianapolis, IN NVLAP Lab Code 200188-0, AZ0939, CA 2575, CO AL-15132, TX 300262

Page 4 of 4ASB_PLM_0008_0001 - 1.78 Printed: 10/25/2022 10:22 AM

ConcentrationAnalyzed Weight RDL LeadClient SampleDescription Collected

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

EMSL Analytical, Inc.

6340 CastlePlace Dr., Indianapolis, IN 46250 Phone/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com indianapolislab@emsl.com

Attn: Colin Lauenroth AMI Group, Inc.

8802 South 135th Street Suite 100 Omaha, NE 68138-6511

Received: 10/21/2022 10:15 AM

22-172/LEXINGTON VA LBP

Fax: (402) 397-3313 Phone: (402) 397-5001

Project:

10/18/2022Collected:

162224786 CustomerID: AMI50 CustomerPO: 22-172 ProjectID:

EMSL Order:

Site: RM C121 OFF WHITE, DRYWALL PAINT <0.0080 % wt10/24/2022 0.255 g

162224786-0001 0.008010/18/2022L-1 % wt

Site: C121, DOOR FRAME PAINT METAL, TAN <0.017 % wt10/24/2022 0.1151 g

162224786-0002 0.01710/18/2022L-2 % wt

Site: A243 THROUGHOUT, DRYWALL PAINT, WHITE <0.0080 % wt10/24/2022 0.2498 g

162224786-0003 0.008010/18/2022L-3 % wt

Site: A243, AU547,C-222, DOOR FRAME PAINT METAL, BEIGE <0.020 % wt10/24/2022 0.098 g

162224786-0004 0.02010/18/2022L-5 % wt

Site: A345, A450, C-222, DRYWALL PAINT, WHITE <0.0080 % wt10/24/2022 0.2527 g

162224786-0005 0.008010/18/2022L-6 % wt

Site: A345,D007D,A002C, DOOR FRAME PAINT METAL, BEIGE Not enough sample provided; unable to perform analysis

% wtn/a 162224786-0006

#NoPrepAmt10/18/2022L-8 % wt

Site: A002C,C4-4111, DRYWALL PAINT, WHITE

0.11 % wt10/24/2022 0.2597 g

162224786-0007 0.008010/18/2022L-9 % wt

Site: A104,A627, DOOR/DOOR FRAME METAL, WHITE Not enough sample provided; unable to perform analysis

% wtn/a 162224786-0008

#NoPrepAmt10/18/2022L-10 % wt

Site: A450,C4-411,DOOR/DOOR FRAME METAL, BEIGE AND RED Not enough sample provided; unable to perform analysis

% wtn/a 162224786-0009

#NoPrepAmt10/18/2022L-11 % wt

Page 1 of 1Test Report PB w/RDL-2.0.0.0 Printed: 10/25/2022 9:23:28 AM

Aleksandrea Kuchenbrod, Inorganic Chemistry Lab 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.

* Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008% wt based on the minimum sample weight per our SOP. "<" (less than) result signifies the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Indianapolis, IN AIHA-LAP, LLC-ELLAP 157245, OH E10040

Initial report from 10/25/2022 09:23:28 http://www.EMSL.com mailto:indianapolislab@emsl.com

ConcentrationAnalyzed Weight RDL LeadClient SampleDescription Collected

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

EMSL Analytical, Inc.

6340 CastlePlace Dr., Indianapolis, IN 46250 Phone/Fax: (317) 803-2997 / (317) 803-3047 http://www.EMSL.com indianapolislab@emsl.com

Attn: Colin Lauenroth AMI Group, Inc.

8802 South 135th Street Suite 100 Omaha, NE 68138-6511

Received: 11/8/2022 10:14 AM

22-172/LEXINGTON VA-EHRM LBP3

Fax: (402) 397-3313 Phone: (402) 397-5001

Project:

11/2/2022Collected:

162226090 CustomerID: AMI50 CustomerPO: 22-172 ProjectID:

EMSL Order:

<0.041 % wt11/8/2022 0.0492 g 162226090-0001

0.04111/2/2022L-8 (A345) % wt

<0.030 % wt11/8/2022 0.0658 g 162226090-0002

0.03011/2/2022L-10 (A104) % wt

<0.019 % wt11/8/2022 0.1049 g 162226090-0003

0.01911/2/2022L-11 (A450) % wt

Page 1 of 1Test Report PB w/RDL-2.0.0.0 Printed: 11/9/2022 7:38:33 AM

Aleksandrea Kuchenbrod, Inorganic Chemistry Lab 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.

* Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008% wt based on the minimum sample weight per our SOP. "<" (less than) result signifies the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Indianapolis, IN AIHA LAP, LLC-ELLAP Accredited #157245, OH E10040

Initial report from 11/09/2022 07:38:33 http://www.EMSL.com mailto:indianapolislab@emsl.com

Attn.: Colin Lauenroth EMSL Order No.: 362203335 AMI Group, Inc. Sample(s) Received: 10/24/2022 8802 South 135th Street Date Reported: 10/26/2022 Omaha, NE 68138-6511 Date Printed: 10/26/2022 claurenroth@amienvironmental.com Reported By: J. Hu Phone: 402-981-1003

AMI Group, Inc. – 362203335- Page 1 of 4 -

EMSL Analytical, Inc. 200North, Route 130, Cinnaminson, NJ. 08077 Phone: (800) 220-3675

- Laboratory Report -

Elemental Analysis/Lead

Project: 22-172 – Lexington VA LBP

Procurement of Samples and Analytical Overview:

The samples (three, bulk) arrived at EMSL Analytical (Cinnaminson, NJ) on October 24, 2022. The package arrived in satisfactory condition with no evidence of damage to the contents. The data reported herein has been obtained using the following equipment and methodologies.

Methods & Equipment: Hand-Held X-Ray Fluorescence Spectroscopy (XRF)

16 CFR 1303/CPSC-CH-E1003-09.1

Total Lead in Paint and Surface Coatings

Analyzed by:

October 26, 2022

Jian Hu, Ph.D.

Senior Laboratory Scientist

Date

Reviewed/Approved by :

October 26, 2022 Eugenia Mirica, Ph.D.

Laboratory Director Date mailto:claurenroth@amienvironmental.com

8802 South 135th Street Date Reported: 10/26/2022 Omaha, NE 68138-6511 Date Printed: 10/26/2022

AMI Group, Inc. – 362203335- Page 2 of 4 -

Procurement of Samples:

Figure 1. Image of the as-received samples.

Table 1: Identification of the samples submitted for analysis:

Customer Sample ID EMSL Sample ID Sample Description Date Sampled L-4 362203335-0001 Ceramic Tile, Yellow, A243 A627 AU547 October 18, 2022 L-7 362203335-0002 Ceramic Tile, Yellow, A345 October 18, 2022

L-10 362203335-0003 Ceramic Floor Tile, Gray, A002C October 18, 2022

The purpose of the analysis is to quantify the lead content present in the materials. The glazed surfaces were analyzed.

8802 South 135th Street Date Reported: 10/26/2022 Omaha, NE 68138-6511 Date Printed: 10/26/2022

AMI Group, Inc. – 362203335- Page 3 of 4 -

Results:

EMSL ID: 362203335-0001

Sample ID: L-4

Sample Description: Ceramic Tile, Yellow, A243 A627 AU547

Analyte Measured Value Reporting Limit wt% mg/kg (ppm) wt% mg/kg (ppm)

Lead (Pb)

0.016 160 0.005 50 ppm = parts per million

EMSL ID: 362203335-0002

Sample ID: L-7

Sample Description: Ceramic Tile, Yellow, A345

Analyte

0.007 70 0.005 50

EMSL ID: 362203335-0003

Sample ID: L-10

Sample Description: Ceramic Floor Tile, Gray, A002C

Analyte

<0.005 <50 0.005 50

8802 South 135th Street Date Reported: 10/26/2022 Omaha, NE 68138-6511 Date Printed: 10/26/2022

AMI Group, Inc. – 362203335- Page 4 of 4 -

Descriptions & Definitions:

None Detected (ND) denotes the absence of analyte in the subsample analyzed. Trace levels of the analyte may be present in the sample below the limit of detection (LOD).

Limit of Detection (LOD): The minimum concentration that can be theoretically achieved for a given analytical procedure in the absence of matrix or sample processing effects. Particle analysis is limited to a single occurrence of an analyte particle in the sub-sample analyzed.

Limit of Quantitation (LOQ): The minimum concentration of an analyte that can be measured within specified limits of precision and accuracy during routine laboratory operating conditions

Important Terms, Conditions, and Limitations:

Sample Retention: Samples analyzed by EMSL will be retained for 60 days after analysis date. Storage beyond this period is available for a fee with written request prior to the initial 30 day period. Samples containing hazardous/toxic substances which require special handling may be returned to the client immediately. EMSL reserves the right to charge a sample disposal or return shipping fee.

Change Orders and Cancellation: All changes in the scope of work or turnaround time requested by the client after sample acceptance must be made in writing and confirmed in writing by EMSL. If requested changes result in a change in cost the client must accept payment responsibility. In the event work is cancelled by a client, EMSL will complete work in progress and invoice for work completed to the point of cancellation notice. EMSL is not responsible for holding times that are exceeded due to such changes.

Warranty: EMSL warrants to its clients that all services provided hereunder shall be performed in accordance with established and recognized analytical testing procedures, when available. The foregoing express warranty is exclusive and is given in lieu of all other warranties, expressed or implied. EMSL disclaims any other warranties, express or implied, including a warranty of fitness for particular purpose and warranty of merchantability.

Limits of Liability: In no event shall EMSL be liable for indirect, special, consequential, or incidental damages, including, but not limited to, damages for loss of profit or goodwill regardless of the negligence (either sole or concurrent) of EMSL and whether EMSL has been informed of the possibility of such damages, arising out of or in connection with EMSL’s services thereunder or the delivery, use, reliance upon or interpretation of test results by client or any third party. We accept no legal responsibility for the purposes for which the client uses the test results. EMSL will not be held responsible for the improper selection of sampling devices even if we supply the device to the user. The user of the sampling device has the sole responsibility to select the proper sampler and sampling conditions to ensure that a valid sample is taken for analysis. Any resampling performed will be at the sole discretion of EMSL, the cost of which shall be limited to the reasonable value of the original sample delivery group (SDG) samples.

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