8 Asbestos Lead Paint Survey Report.pdf

Limited Asbestos and Lead Paint Survey Repair Base Communications HQ, FAC 1540

Davis-Monthan Air Force Base (DMAFB)

Tucson, Pima County, Arizona

Terracon Project No. 63187104

June 6, 2019

Prepared for:

MOCA Systems, Inc.

San Antonio, TX

Prepared by:

Terracon Consultants, Inc.

Tucson, AZ

TABLE OF CONTENTS

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EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Reliance

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND RECOMMENDATIONS

6.0 LIMITATIONS/GENERAL COMMENTS

APPENDIX A MATERIALS CONTAINING 1% OR LESS ASBESTOS BY HA

APPENDIX B ASBESTOS SURVEY SAMPLE SUMMARY

APPENDIX C IDENTIFIED LEAD CONTAINING AND LEAD BASED PAINTS

APPENDIX D LEAD SURVEY SAMPLE SUMMARY

APPENDIX E SAMPLING LOCATION DIAGRAMS

APPENDIX F ANALYTICAL LABORATORY DATA

APPENDIX G LICENSES AND CERTIFICATIONS

Repair Base Communications HQ, FAC 1540 ■ Tucson, Arizona

June 6, 2019 ■ Terracon Project No. 63187104

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EXECUTIVE SUMMARY

Terracon Consultants Inc. (Terracon) conducted an asbestos and lead paint survey of the building located at the Davis-Monthan Air Force Base (DMAFB) Repair Base Communications HQ, FAC

1540 in Tucson, Pima County, Arizona. The survey was conducted on April 25, 2019 by an

Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos building inspector and a United States Environmental Protection Agency (EPA) certified lead-based paint (LBP) inspector. This survey was conducted in general accordance with Terracon Proposal No.

P63177104, Revision 1, dated July 30, 2018. We understand the purpose of this survey was to identify and locate asbestos-containing materials (ACMs), LBP, and Lead-Containing Paint (LCP) within interior and exterior areas slated for renovation. We understand future renovations include a mechanical system overhaul and will affect building materials along the north and south faces of the building.

The asbestos portion of the survey was performed to satisfy requirements of the EPA Regulation

40 Code of Federal Regulations (CFR) Part 61, Subpart M, National Emission Standards for

Hazardous Air Pollutants (NESHAP). Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA 40 CFR Part 763 Subpart E, known as

AHERA. Bulk asbestos samples were delivered to an accredited laboratory for analysis by

Polarized Light Microscopy (PLM). Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids or in other concealed areas.

The lead paint survey was performed to assist in compliance with United States Occupational

Safety and Health Administration (OSHA) requirements for lead-in-air content during disturbance of painted materials. The lead paint sampling was performed in general accordance with the procedures prescribed in the EPA’s work practice standards for conducting lead paint testing (40

CFR 745.227). The lead paint survey was not designed to meet the requirements of the U.S.

Department of Housing and Urban Development (HUD) for LBP surveys. The lead paint survey was conducted by collecting paint chip samples for laboratory analysis.

Asbestos Findings

Terracon collected a total of 41 bulk asbestos samples from 13 homogeneous of suspect ACM throughout the building. None of the samples were identified as containing greater than 1% asbestos. As such, none of the materials sampled are considered ACM.

The following materials were identified as a result of laboratory analysis as containing ≤1% asbestos:

HA No. Material Description Material Location Estimated Quantity*

1 Window Pane Glazing North and South Face of Building 320 Square Feet

*Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this survey.

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The materials listed in the table above were determined by PLM point counting to contain asbestos at concentrations ranging from 1.2% to 1.3% chrysotile asbestos. Per Appendix E of 40 CFR 763, Subpart E, the EPA interprets these results to be rounded down to the nearest whole number (1).

Thus these materials are considered not to contain asbestos at concentrations greater that 1% and is not regulated by NESHAP. However, compliance with the OSHA standard (29 CFR 1926.1101) is still required. Compliance by building owners with the OSHA asbestos regulations may result in response actions not required by the EPA for certain unregulated materials. Under the OSHA

Construction Standard for Asbestos (29 CFR 1926.1101), materials containing less than or equal to 1% asbestos is still regulated to some degree. The employer who disturbs this asbestos material must, 1) use wet methods, 2) promptly contain any waste in leak-tight containers, and 3) conduct air monitoring or have a negative exposure assessment. The waste is not regulated for transportation or disposal by EPA or OSHA.

A summary of the classification, condition and approximate quantity of identified trace ACM is presented in Appendix A. A summary of suspect ACM samples collected during the survey is included as Appendix B. Diagrams depicting the surveyed areas and sample locations are included in Appendix E.

Terracon can provide the Client with a proposal for developing asbestos abatement specifications

(project design) and for performing abatement oversight, air monitoring, and air clearance testing upon request.

Lead Paint Findings

Terracon collected 8 paint chip samples from the site structure. Of the samples collected, the following sample was identified as LCP (paint containing detectable concentrations of lead less than 5,000 parts per million (ppm):

Sample No. Paint Description Sample Location

L-8 Tan Paint on Metal Window Frame North Exterior

A summary of the identified LCP is provided in Appendix C. A summary of all paint chip samples collected during the lead paint survey is included as Appendix D. Diagrams depicting the surveyed areas and sample locations are included in Appendix E.

Occupational exposure to lead occurring in the course of construction work, including demolition, is subject to the OSHA “Interim” Lead Exposure in Construction standard (29 CFR 1926.62). OSHA considers that surface coatings or materials that contain lead at concentrations exceeding the laboratory detection limit may constitute a health hazard to employees engaged in lead-related construction work. A negative exposure assessment should be conducted to determine if exposure during construction activities are below the required OSHA action levels and permissible exposure limits.

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1.0 INTRODUCTION

Terracon Consultants Inc. (Terracon) conducted an asbestos and lead paint survey at the building located at the Davis-Monthan Air Force Base (DMAFB) Repair Base Communications HQ, FAC

1540 in Tucson, Pima County, Arizona. The survey was conducted on April 25, 2019 by an

Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos building inspector and an United States Environmental Protection Agency (EPA) certified lead paint inspector. This survey was conducted in general accordance with Terracon Proposal No. P63177104, Revision

1, dated July 30, 2018. We understand the purpose of this survey was to identify and locate asbestos-containing materials (ACMs), Lead-Based Paint (LBP), and Lead-Containing Paint

(LCP) within interior and exterior areas slated for renovation of the aforementioned building. We understand future renovations include a mechanical system overhaul and will affect building materials along the north and south faces of the building.

The asbestos portion of the survey was performed to satisfy requirements of the EPA Regulation

40 Code of Federal Regulations (CFR) Part 61, Subpart M, National Emission Standards for

Hazardous Air Pollutants (NESHAP). Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA 40 CFR Part 763 Subpart E, known as

AHERA. Bulk asbestos samples were delivered to an accredited laboratory for analysis by

Polarized Light Microscopy (PLM). Although reasonable effort was made to survey accessible suspect materials, additional suspect but un-sampled materials could be located in walls, in voids or in other concealed areas.

The lead paint survey was performed to assist in compliance with Occupational Safety and Health

Administration (OSHA) requirements for lead-in-air content during disturbance of painted materials. The lead paint sampling was performed in general accordance with the procedures prescribed in the EPA’s work practice standards for conducting lead paint testing (40 CFR

745.227). The lead survey was not designed to meet the requirements of the U.S. Department of

Housing and Urban Development (HUD) for LBP surveys. The lead paint survey was conducted by collecting paint chip samples for laboratory analysis.

1.1 Reliance

This report is for the exclusive use of to MOCA Systems, Inc. (Client), as well as DMAFB and any subsequent contractors that they hire to perform work on the subject facilities for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of

Terracon and MOCA Systems, Inc. Reliance on this report by MOCA Systems, Inc. and all authorized parties will be subject to the terms, conditions, and limitations as defined in the

Agreement between the Client (MOCA Systems, Inc.) and Consultant (Terracon).

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2.0 BUILDING DESCRIPTION

The site is developed with an approximate 50,000 square foot building (Facility 1540) located on the DMAFB in Tucson, Arizona. Facility 1540 is a former metal airplane hangar renovated for office use. The floor system of Facility 1540 consists poured flooring covered by rolled vinyl flooring, vinyl tiling, and carpeting. The weight-bearing wall systems are constructed of metal beams and siding. The interior walls are constructed of textured drywall systems. The ceiling systems are constructed with drop-in acoustic ceiling tiles.

3.0 FIELD ACTIVITIES

The surveys were conducted by Derek R. Sizemore, an AHERA-accredited asbestos inspector and EPA-certified LBP inspector. Copies of inspector certificates are provided in Appendix G. The asbestos survey was conducted in general accordance with the sample collection protocols established in EPA 40 CFR Part 763 Subpart E Section 763.86, AHERA. A summary of survey activities is provided in this section. The lead paint survey was conducted in general accordance with the procedures prescribed in the EPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The sampling was not designed to meet the requirements of HUD.

3.1 Visual Assessment

Asbestos

Survey activities were initiated with visual observation of the interior and exterior of the building to identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application. Assessment was conducted in visually accessible areas of the building proposed for demolition and renovation. Building materials identified as metal, glass, or wood were not considered suspect ACM.

The roofing systems were not sampled as part of this survey. Terracon inspected the interior ceiling, wall, and flooring systems in multiple places throughout the building and did not observe additional coverings/layers except where noted in this report, but there may be additional suspect material present within the building in concealed areas that was not observed.

Lead Paint

Terracon visually assessed the interior and exterior of the existing building to identify construction materials suspect for lead paint. Painted/coated surfaces which appear similar throughout in terms of color, texture, substrate and date of application are treated as a homogeneous material for paint chip collection purposes. Painted/coated surfaces were visually assessed for evidence of distress, flaking, and/or peeling.

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3.2 Physical Assessment

Asbestos

A physical assessment of each homogeneous area (HA) of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized or reduced to powder by hand pressure when dry.

Friability was assessed by physically touching suspect materials.

A physical assessment of each selected painted surface was conducted to assess its condition.

The painted surfaces were assessed as good, fair or poor condition depending on degree of cracking, peeling or chipping.

3.3 Sample Collection

Based on observations, bulk samples of suspect ACM were collected in general accordance with

EPA AHERA sampling protocols. Samples of suspect materials were collected from randomly selected locations in each homogeneous area. Bulk samples were collected using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content.

Terracon collected 41 bulk asbestos samples from 13 homogeneous areas of suspect ACM. A summary of the classification, condition and approximate quantity of identified ACM is presented in

Appendix A. A summary of suspect ACM samples collected during the survey is included as

Appendix B. Diagrams depicting the site buildings, and sample locations are included in Appendix

E.

Lead Based Paint

Terracon collected 8 paint chip samples during the lead paint survey. A summary of the identified lead-based and lead-containing paints is included in Appendix C. A summary of all paint chip samples collected during the lead paint survey is included as Appendix D.

3.4 Sample Analysis

Asbestos

Bulk suspect ACM samples were submitted under chain of custody to International Asbestos

Testing Laboratories of Mt. Laurel, NJ for analysis by PLM with dispersion staining techniques per EPA methodology 600/R-93/116. The percentage of asbestos in a sample, where applicable, was determined by microscopic visual estimation. International Asbestos Testing Laboratories is

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No. 101165-0. A copy of the analytical laboratory report is provided in Appendix F.

The EPA recognizes that PLM analysis of asbestos bulk samples can be inaccurate at low concentrations of asbestos (i.e., less than 10%). In Appendix E of 40 CFR 763, Subpart E (Interim

Method of the Determination of Asbestos in Bulk Insulation Samples), the EPA codifies point counting as part of the asbestos analytical method. For samples reported with <10% asbestos by

PLM visual estimation, the laboratory further analyzed the sampled by the point count method.

Paint chip samples were submitted under chain of custody to International Asbestos Testing

Laboratories of Mt. Laurel, NJ for analysis by Flame Atomic Absorption Spectroscopy (FAAS) per

EPA methodology SW846-(3050B:7000B). International Asbestos Testing Laboratories is accredited under the American Industrial Hygiene Association (AIHA) (Accreditation No. 100188).

A copy of the analytical laboratory report is provided in Appendix F.

4.0 REGULATORY OVERVIEW

Asbestos

The Asbestos NESHAP program in Arizona is enforced by federal, state, and county Asbestos

NESHAP Coordinators. For projects occurring in Pima County, the County has been delegated authority from the EPA to enforce the Asbestos NESHAP within its respective jurisdictional boundaries, excluding tribal lands.

The Asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity.

Friable ACM is a material containing more than 1% asbestos that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. All friable ACM is considered regulated asbestos containing material (RACM).

The asbestos NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I and

Category II non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity.

Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, Cement

Panels (Exterior), glazing, mortar and grouts.

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The OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos must not exceed 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight-hour time weighted average (TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30 minute time period known as an excursion limit (EL). The TWA and EL are known as OSHA’s asbestos permissible exposure limits (PELs). The OSHA standard classifies construction and maintenance activities which could disturb ACM and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

The lead paint sampling activities were conducted in general accordance with the EPA’s work practice standards for conducting lead activities (40 CFR 745.227). Lead is regulated by the EPA and OSHA.

The Resource Conservation and Recovery Act (RCRA) gave the EPA authority to regulate the waste status of demolition or renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead containing wastes are considered hazardous waste under

RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed five milligrams per liter

(mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

The US EPA has established an action level for LBP of 1.0 milligram per square centimeter

(mg/cm2), 0.5% by weight or 5,000 ppm. If a sample analytical result is equal to or greater than

1.0 mg/cm2, 0.5% by weight, or 5,000 ppm, the prepared surface is considered to be LBP.

Detectable lead quantities may constitute a lead dust hazard during renovation and demolition activities. Personnel performing renovation and demolition activities that may disturb painted components and building surfaces with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure. OSHA defines lead paint as a paint, which contains lead, regardless of the concentration.

Currently, any proposed renovation or demolition is subject to the OSHA regulations (29 CFR

1926.62 – Lead Exposure in Construction). The OSHA regulation defines specific training requirements, engineering controls and working practices for construction personnel subject to this standard. Occupational exposure to lead occurring in the course of construction work, including maintenance activities, painting, alteration and repairs is subject to the OSHA “Interim” Lead

Exposure in Construction standard.

Construction work covered by 29 CFR 1926.62 includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m³) averaged over an eight-hour

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The above overview is not intended to be inclusive of all potentially pertinent regulatory information.

The relevant EPA and OSHA standards should be consulted prior to undertaking activities involving the demolition, renovation, or maintenance of surfaces coated with lead paints.

5.0 FINDINGS AND RECOMMENDATIONS

Asbestos Findings

Terracon collected a total of 41 bulk asbestos samples from 13 homogeneous of suspect asbestos-containing materials (ACM) throughout the building. None of the samples were identified as containing greater than 1% asbestos. As such, none of the materials sampled are considered ACM.

The following materials were identified as a result of laboratory analysis as containing ≤1% asbestos:

HA No. Material Description Material Location Estimated Quantity*

1 Window Pane Glazing North and South Face of Building 320 Square Feet

*Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this survey.

The materials listed in the table above were determined by PLM point counting to contain asbestos at concentrations ranging from 1.2% to 1.3% chrysotile asbestos. Per Appendix E of 40 CFR 763, Subpart E, the EPA interprets these results to be rounded down to the nearest whole number (1).

Thus, these materials are considered not to contain asbestos at concentrations greater that 1% and is not regulated by NESHAP. However, compliance with the OSHA standard (29 CFR 1926.1101) is still required. Compliance by building owners with the OSHA asbestos regulations may result in response actions not required by the EPA for certain unregulated materials. Under the OSHA

Construction Standard for Asbestos (29 CFR 1926.1101), materials containing less than or equal to 1% asbestos is still regulated to some degree. The employer who disturbs this asbestos material must, 1) use wet methods, 2) promptly contain any waste in leak-tight containers, and 3) conduct air monitoring or have a negative exposure assessment. The waste is not regulated for transportation or disposal by EPA or OSHA.

A summary of the classification, condition and approximate quantity of identified trace ACM is presented in Appendix A. A summary of suspect ACM samples collected during the survey is included as Appendix B. Diagrams depicting the surveyed areas and sample locations are included in Appendix E.

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Terracon can provide the Client with a proposal for developing asbestos abatement specifications

(project design) and for performing abatement oversight, air monitoring, and air clearance testing upon request.

Lead Paint Findings

Terracon collected 8 paint chip samples from the site structure. Of the samples collected, the following sample was identified as LCP (paint containing detectable concentrations of lead less than 5,000 ppm):

Sample No. Paint Description Sample Location

L-8 Tan Paint on Metal Window Frame North Exterior

A summary of the lead-containing paints identified are included in Appendix C. A summary of all paint chip samples collected during the lead paint survey is included as Appendix D. Diagrams depicting the surveyed areas and sample locations are included in Appendix E.

Occupational exposure to lead occurring in the course of construction work, including demolition, is subject to the OSHA “Interim” Lead Exposure in Construction standard (29 CFR 1926.62). OSHA considers that surface coatings or materials that contain lead at concentrations exceeding the laboratory detection limit may constitute a health hazard to employees engaged in lead-related construction work. A negative exposure assessment should be conducted to determine if exposure during construction activities are below the required OSHA action levels and permissible exposure limits.

6.0 LIMITATIONS/GENERAL COMMENTS

Terracon did not perform sampling which required demolition or destructive activities such as knocking holes in walls, dismantling of equipment or removal of protective coverings. Reasonable efforts to access suspect materials within known areas of restricted access (e.g., crawl spaces) were made; however, confined spaces or areas which may pose a health or safety risk to Terracon personnel were not sampled. Sampling did not include suspect materials which could not be safely reached with available ladders/man-lifts.

This Asbestos-Containing Material (ACM) and LBP Survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the dates on which this survey was performed, and should not be relied upon to represent conditions at a later date.

This report has been prepared on behalf of and exclusively for use by MOCA Systems, Inc. for specific application to their project as discussed. This report is not a bidding document.

Contractors or consultants reviewing this report must draw their own conclusions

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A-1

APPENDIX A

Repair Base Communications HQ, FAC 1540

Davis-Monthan Air Force Base

Tucson, Pima County, Arizona

IDENTIFIED MATERIALS CONTAINING 1% OR LESS ASBESTOS BY HA

HA

No.

Material Description Material Location % and Type Asbestos#^ Condition Estimated Quantity*

1 Window Pane Glazing Network Operations 145, News Photo 189, and Storage 184 PC 1.3% Chrysotile - Grey Glazing Good 320 Sq. Ft.

PC = point count analysis

Sq. Ft. = Square Feet #The material listed in the table above was determined by PLM point counting to contain asbestos at concentrations ranging from 1.2% to 1.3% chrysotile asbestos. Per Appendix E of 40 CFR Part 763 Subpart E, the EPA interprets these results to be rounded down to the nearest whole number (1). Thus, this material is considered not to contain asbestos at concentrations greater than 1% and is not regulated by NESHAP. However, compliance with the

OSHA standard (29 CFR 1926.1101) is still required. Compliance by building owners with the OSHA asbestos regulations may result in response actions not required by the EPA for certain unregulated materials. Under the OSHA Construction Standard for Asbestos (29 CFR 1926.1101), materials containing less than or equal to 1% asbestos is still regulated to some degree. The employer who disturbs this asbestos material must, 1) use wet methods, 2) promptly contain any waste in leak-tight containers, and 3) conduct air monitoring or have a negative exposure assessment. The waste is not regulated for transportation or disposal by EPA or OSHA.

^% & Type Asbestos = this column contains both the analytical result of the sample with the highest concentration of asbestos detected in the samples that make up the HA and the types of asbestos identified.

*Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if materials are present in hidden and/or inaccessible areas not evaluated as part of this survey.

B-1

Samples in bold contain ≤1% asbestos by rounding

PC = Point Count Analysis

APPENDIX B

Repair Base Communications HQ, FAC 1540

Davis-Monthan Air Force Base

Tucson, Pima County, Arizona

ASBESTOS SURVEY SAMPLE SUMMARY

HA

No.

Material Description Sample Number Sample Location Lab Results

1 Window Pane Glazing 1-SC1-1 Storage 184 None Detected - Grey Glazing

1 Window Pane Glazing 1-SC1-2 News Photo 189 PC 1.2% Chrysotile - Tan Glazing

1 Window Pane Glazing 1-SC1-3 Network Operations 145 PC 1.3% Chrysotile - Grey Glazing

2 Orange Peel Textured Drywall System 2-WB4-4 News Photo 189 None Detected - White Drywall

2 Orange Peel Textured Drywall System 2-WB4-4 News Photo 189 None Detected - White Joint Compound

2 Orange Peel Textured Drywall System 2-WB4-4 News Photo 189 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-4 News Photo 189 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-5 Storage 184 None Detected - White Drywall

2 Orange Peel Textured Drywall System 2-WB4-5 Storage 184 None Detected - White Joint Compound

2 Orange Peel Textured Drywall System 2-WB4-5 Storage 184 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-5 Storage 184 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-6 Loading Unloading 174 None Detected - White Drywall

2 Orange Peel Textured Drywall System 2-WB4-6 Loading Unloading 174 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-7 Network Operations 145 None Detected - White Drywall

2 Orange Peel Textured Drywall System 2-WB4-7 Network Operations 145 None Detected - White Texture

2 Orange Peel Textured Drywall System 2-WB4-8 ADPE 165 None Detected - White Drywall

2 Orange Peel Textured Drywall System 2-WB4-8 ADPE 165 None Detected - White Texture

B-2

PC = Point Count Analysis

HA

No.

Material Description Sample Number Sample Location Lab Results

3 2' X 2' Acoustic Ceiling Tile 3-CT2-9 ADPE 165 None Detected - Tan Ceiling Tile

3 2' X 2' Acoustic Ceiling Tile 3-CT2-10 Information Assurance 146 None Detected - Tan Ceiling Tile

3 2' X 2' Acoustic Ceiling Tile 3-CT2-11 Network Operations 145 None Detected - Tan Ceiling Tile

4 Fiberglass Batt Insulation 4-AW1-12 Storage 184 None Detected - Pink Insulation

4 Fiberglass Batt Insulation 4-AW1-13 Information Assurance 146 None Detected - Yellow Insulation

4 Fiberglass Batt Insulation 4-AW1-14 Network Operations 145 None Detected - Yellow Insulation

5 HVAC Grey Sealant 5-SC5-15 HVAC Unit Above Ceiling None Detected - Grey Mastic

5 HVAC Grey Sealant 5-SC5-16 HVAC Unit Above Ceiling None Detected - Grey Mastic

5 HVAC Grey Sealant 5-SC5-17 HVAC Unit Above Ceiling None Detected - Grey Mastic

6 Black Sealant on Equipment 6-SC5-18 NE of Building None Detected - Black Sealant

6 Black Sealant on Equipment 6-SC5-19 NE of Building None Detected - Black Sealant

6 Black Sealant on Equipment 6-SC5-20 NE of Building None Detected - Black Sealant

7 Grey Sealant on Equipment 7-SC5-21 NE of Building None Detected - Grey Sealant

7 Grey Sealant on Equipment 7-SC5-22 NE of Building None Detected - Grey Sealant

7 Grey Sealant on Equipment 7-SC5-23 NE of Building None Detected - Grey Sealant

8 Concrete Equipment Pad 8-FC2-24 NE of Building None Detected - Tan Cementitious

8 Concrete Equipment Pad 8-FC2-25 NE of Building None Detected - Tan Cementitious

8 Concrete Equipment Pad 8-FC2-26 NE of Building None Detected - Tan Cementitious

9 White Floor to Wall Caulk 9-CA4-27 Exterior North None Detected - White Caulk

9 White Floor to Wall Caulk 9-CA4-28 Exterior North None Detected - White Caulk

9 White Floor to Wall Caulk 9-CA4-29 Exterior South None Detected - White Caulk

10 Wood Siding Caulk 10-CA3-30 Exterior South None Detected - White Caulk

10 Wood Siding Caulk 10-CA3-31 Exterior North None Detected - White Caulk

10 Wood Siding Caulk 10-CA3-32 Exterior North None Detected - White Caulk

11 Grey Cove Base & Mastic 11-FC3-33 SE Exit Door None Detected - Grey Cove Base

B-3

PC = Point Count Analysis

HA

No.

Material Description Sample Number Sample Location Lab Results

11 Grey Cove Base & Mastic 11-FC3-33 SE Exit Door None Detected - Off-White Mastic

11 Grey Cove Base & Mastic 11-FC3-33 SE Exit Door None Detected - White Joint Compound

11 Grey Cove Base & Mastic 11-FC3-34 Storage 184 None Detected - Grey Cove Base

11 Grey Cove Base & Mastic 11-FC3-34 Storage 184 None Detected - Off-White Mastic

11 Grey Cove Base & Mastic 11-FC3-34 Storage 184 None Detected - White Joint Compound

11 Grey Cove Base & Mastic 11-FC3-35 ADPE 165 None Detected - Grey Cove Base

11 Grey Cove Base & Mastic 11-FC3-35 ADPE 165 None Detected - Off-White Mastic

11 Grey Cove Base & Mastic 11-FC3-35 ADPE 165 None Detected - White Joint Compound

12 Exterior Duct Sealant 12-SC5-36 Exterior North None Detected - Grey Sealant

12 Exterior Duct Sealant 12-SC5-37 Exterior North None Detected - Grey Sealant

12 Exterior Duct Sealant 12-SC5-38 Exterior North None Detected - Grey Sealant

13 Fire Rated Textured Drywall System 13-WB4-39 Records Storage 179 None Detected - White Drywall

13 Fire Rated Textured Drywall System 13-WB4-39 Records Storage 179 None Detected - White Joint Compound

13 Fire Rated Textured Drywall System 13-WB4-39 Records Storage 179 None Detected - White Texture

13 Fire Rated Textured Drywall System 13-WB4-39 Records Storage 179 None Detected - White Texture

13 Fire Rated Textured Drywall System 13-WB4-40 Records Storage 179 None Detected - White Joint Compound

13 Fire Rated Textured Drywall System 13-WB4-41 Records Storage 179 None Detected - White Joint Compound

13 Fire Rated Textured Drywall System 13-WB4-41 Records Storage 179 None Detected - White Texture

C-1

APPENDIX C

Davis-Monthan Air Force Base

Tucson, Pima County, Arizona

IDENTIFIED LEAD-CONTAINING PAINTS

Sample No. Paint Description Sample Location Condition Lab Results (ppm)

L-8 Tan Paint on Metal Window Frame North Exterior Good 3,900 ppm = parts per million

D-1

APPENDIX D

Davis-Monthan Air Force Base

Tucson, Pima County, Arizona

LEAD PAINT SAMPLE SURVEY SUMMARY

Sample No. Paint Description Sample Location Condition Lab Results (ppm)

L-1 Tan Paint on Wood Panels Exterior Good BRL

L-2 Tan Paint on Metal Door Exterior Good BRL

L-3 Tan Paint on Metal Door Frame Exterior Good BRL

L-4 White Paint on Metal Door News Photo 189 Good BRL

L-5 White Paint on Metal Door Frame News Photo 189 Good BRL

L-6 Brown Paint on Metal Door Frame Southeast Exit Interior Good BRL

L-7 White Paint on Drywall Southwest Exit Interior Good BRL

L-8 Tan Paint on Metal Window Frame North Exterior Good 3,900

Samples in bold are lead-containing paint (LCP) / Paint containing detectable concentrations of lead less than 5,000 ppm ppm = parts per million

APPENDIX E

SAMPLING LOCATION DIAGRAMS

Drawn By:

Checked By:

Approved By:

Project Mngr:

File No.

Date:

Scale:

Project No. EXHIBIT

Consulting Engineers and Scientists

355 SOUTH EUCLID, SUITE 107 TUCSON, ARIZONA 85719

FAX. (520) 792-2539PH. (520) 770-1789

ASBESTOS SAMPLE LOCATIONS & RESULTS

NLEGEND

NOT SHOWN

63187104.dwg

63187104

DAVIS MONTHAN AIR FORCE BASE: REPAIR BASE

COMMUNICATIONS HQ, FAC 1540

DRS

SR

DRS

DDK 06-2019

APPROXIMATE SAMPLE LOCATION (NON-ACM)

APPROXIMATE SAMPLE LOCATION (ACM)

APPROXIMATE SAMPLE LOCATION (≤1% ACM)

TUCSON, ARIZONA

37,38

18-26

TRACE ACM: MATERIALS WITH 1.0% OR LESS ASBESTOS

HA 1: SAMPLES 1-3: WINDOW GLAZING

ddkoller Rectangle

Drawn By:

Checked By:

Approved By:

Project Mngr:

File No.

Date:

Scale:

Project No. EXHIBIT

Consulting Engineers and Scientists

355 SOUTH EUCLID, SUITE 107 TUCSON, ARIZONA 85719

FAX. (520) 792-2539PH. (520) 770-1789

LEAD PAINT SAMPLE LOCATIONS & RESULTS

NLEGEND

NOT SHOWN

63187104.dwg

63187104

DAVIS MONTHAN AIR FORCE BASE: REPAIR BASE

COMMUNICATIONS HQ, FAC 1540

DRS

SR

DRS

DDK 06-2019

APPROXIMATE SAMPLE LOCATION (NON-LEAD)

APPROXIMATE SAMPLE LOCATION (LEAD-BASED PAINT)

APPROXIMATE SAMPLE LOCATION (LEAD-CONTAINING PAINT)

TUCSON, ARIZONA

L-8

L-1

L-4, L-5

L-7

L-2, L-3

L-6

APPENDIX F

ANALYTICAL LABORATORY DATA

Lab No.: 6771786 Client No.: 1-SC1-1

Analyst Observation: Grey Glazing Client Description: Window Glazing

Location: Storage 184 Facility:

Percent Asbestos:

None Detected

Percent Non-Asbestos Fibrous Material:

Percent Non-Fibrous Material:

Lab No.: 6771787 Client No.: 1-SC1-2

Analyst Observation: Tan Glazing

Location: News Photo 189

PC 1.2 Chrysotile

98.8

Lab No.: 6771788 Client No.: 1-SC1-3

Analyst Observation: Grey Glazing

Location: Network Operations 145

PC 1.3 Chrysotile

98.7

Lab No.: 6771789 Client No.: 2-WB4-4

Analyst Observation: White Drywall Client Description: Orange Peel Textured Drywall System

4 Cellulose 1 Fibrous Glass

Lab No.: 6771789(L2)

Analyst Observation: White Joint Compound

Lab No.: 6771789(L3)

Analyst Observation: White Texture

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Client: TER692

Dated : 5/6/2019 3:56:18 Page 1 of 13

Lab No.: 6771790 Client No.: 2-WB4-5

Lab No.: 6771790(L2)

Lab No.: 6771790(L3)

Fibrous Glass

Lab No.: 6771791 Client No.: 2-WB4-6

Location: Loading Unloading 174

Lab No.: 6771791(L2) Client No.: 2-WB4-6

Location: Loading Unloading 174

Lab No.: 6771792 Client No.: 2-WB4-7

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:18 Page 2 of 13

Lab No.: 6771792(L2) Client No.: 2-WB4-7

Lab No.: 6771793 Client No.: 2-WB4-8

Location: ADPE 165

Lab No.: 6771793(L2) Client No.: 2-WB4-8

Lab No.: 6771794 Client No.: 3-CT2-9

Analyst Observation: Tan Ceiling Tile Client Description: 2x2 ACt

85 Cellulose 5 Fibrous Glass

Lab No.: 6771795 Client No.: 3-CT2-10

Location: Information Assurance 146

Lab No.: 6771796 Client No.: 3-CT2-11

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:18 Page 3 of 13

Lab No.: 6771797 Client No.: 4-AW1-12

Analyst Observation: Pink Insulation Client Description: Fiberglass Batt Insulation

99 Fibrous Glass

Lab No.: 6771798 Client No.: 4-AW1-13

Analyst Observation: Yellow Insulation

Location: Information Assurance 146

Lab No.: 6771799 Client No.: 4-AW1-14

Analyst Observation: Yellow Insulation

Lab No.: 6771800 Client No.: 5-SC5-15

Analyst Observation: Grey Mastic Client Description: HVAC Grey Sealant

Location: HVAC Unit Above Ceiling

Lab No.: 6771801 Client No.: 5-SC5-16

Lab No.: 6771802 Client No.: 5-SC5-17

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 4 of 13

Lab No.: 6771803 Client No.: 6-SC5-18

Analyst Observation: Black Sealant Client Description: Black Sealant On Equipment

Location: NE Of Building

Lab No.: 6771804 Client No.: 6-SC5-19

Lab No.: 6771805 Client No.: 6-SC5-20

Lab No.: 6771806 Client No.: 7-SC5-21

Analyst Observation: Grey Sealant Client Description: Grey Sealant On Equipment

Lab No.: 6771807 Client No.: 7-SC5-22

Lab No.: 6771808 Client No.: 7-SC5-23

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 5 of 13

Lab No.: 6771809 Client No.: 8-FC2-24

Analyst Observation: Tan Cementitious Client Description: Concrete Equipment Pad

Lab No.: 6771810 Client No.: 8-FC2-25

Lab No.: 6771811 Client No.: 8-FC2-26

Lab No.: 6771812 Client No.: 9-CA4-27

Analyst Observation: White Caulk Client Description: White Floor To Wall Caulk

Location: Exterior North

Lab No.: 6771813 Client No.: 9-CA4-28

Lab No.: 6771814 Client No.: 9-CA4-29

Location: Exterior South

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 6 of 13

Lab No.: 6771815 Client No.: 10-CA3-30

Client Description: Wood Siding Caulk

Location: Exterior South

Lab No.: 6771816 Client No.: 10-CA3-31

Lab No.: 6771817 Client No.: 10-CA3-32

Lab No.: 6771818 Client No.: 11-FC3-33

Analyst Observation: Grey Cove Base Client Description: Grey Cove Base & Mastic

Location: SE Exit Door

Lab No.: 6771818(L2)

Analyst Observation: Off-White Mastic

Lab No.: 6771818(L3)

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 7 of 13

Lab No.: 6771819 Client No.: 11-FC3-34

Lab No.: 6771819(L2)

Lab No.: 6771819(L3)

Lab No.: 6771820 Client No.: 11-FC3-35

Lab No.: 6771820(L2)

Lab No.: 6771820(L3)

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 8 of 13

Lab No.: 6771821 Client No.: 12-SC5-36

Client Description: Exterior Duct Sealant

Lab No.: 6771822 Client No.: 12-SC5-37

Lab No.: 6771823 Client No.: 12-SC5-38

Lab No.: 6771824 Client No.: 13-WB4-39

Client Description: Fire Rated Textured Drywall System

Location: Records Storage 179

Lab No.: 6771824(L2)

Lab No.: 6771824(L3)

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 9 of 13

Lab No.: 6771825 Client No.: 13-WB4-40

2 Cellulose

Lab No.: 6771826 Client No.: 13-WB4-41

1 Cellulose

Lab No.: 6771826(L2) Client No.: 13-WB4-41

Laboratory Director

Approved By:

Date Analyzed:

4/26/2019Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Zach Schwartz

05/03/2019 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Terracon

355 South Euclid, Suite 107 Tucson AZ 85719

5/3/2019Report Date:

Report No.: 588618 - PLM Project: Building 1540 Project No.: 63187104

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 5/6/2019 3:56:19 Page 10 of 13

Appendix to Analytical Report Customer Contact:

Method:40 CFR Appendix E to Subpart E of Part 763, interim method for the Determination of Asbestos in Bulk Insulation Samples, and USEPA 600, R93-116 as needed.

This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.

Please note the following points of contact for any questions you may have.

iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Cassie Doherty Sample Login Notes: See Batch Sheet Attached Sample Matrix: Bulk Building Materials Exceptions Noted: See Following Pages

General Terms, Warrants, Limits, Qualifiers:

General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.

iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.

This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.

This report shall not be reproduced except in full, without written approval of the laboratory.

Information Pertinent to this Report:

Analysis by US EPA 600 93-116: Determination of Asbestos in Bulk Building Materials by Polarized Light Microscopy (PLM).

Certifications:

NIST-NVLAP No. 101165-0• NYSDOH-ELAP No. 11021• AIHA-LAP, LLC No. 100188•

Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. PC Trace represents a <0.25% amount. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.

Analytical Methodology Alternatives: Your initial request for analysis may not have accounted for recent advances in regulatory requirements or advances in technology that are routinely used in similar situations for other qualified projects. You may have the option to explore additional analysis for further information. Below are a few options, listed as the matrix followed by the appropriate methodology. Also included are links to more information on our website.

Bulk Building Materials that are Non-Friable Organically Bound…