A06_ASBESTOS_REPORT_MLPC_WAREHOUSE.pdf

Submitted by:

Aarcher, Inc.

910 Commerce Road Annapolis, Maryland 21401 410-897-9100 Program Manager: Mark R. Serio, PG

Submitted to:

U.S. Department of the Interior Bureau of Land Management Attn: Suzanne Buntrock, Engineer Building 50, Denver Federal Center Denver, Colorado 80225-0047

ASBESTOS-CONTAINING MATERIAL (ACM) SURVEY AND

ABATEMENT COST ESTIMATE

BLM Task Order 135, BPA L09PA00228 (NAB060001 Legacy Number)

L3543 MONTROSE WAREHOUSE (WEST)

38.45965 / -107.86798

UNCOMPAHGRE FIELD OFFICE COLORADO

Report Date February 18, 2010 Site Survey Date September 29, 2009 ACM Identified in Building?* Yes ACM Abatement Cost Estimate* $9,500

* Subject to the assumptions and limitations as described in the following report.

i

February 18, 2010

Aarcher, Inc.

Mr. Mark Serio Vice President 910 Commerce Road Annapolis, Maryland 21401

Re: Asbestos-Containing Materials Survey and Asbestos Abatement Cost Estimates

L3543 - Montrose Warehouse (West) Uncompahgre Field Office, Colorado

ATC Project Number 35.21320.0001, Task 00025

Dear Mr. Serio:

ATC Associates Inc. (ATC) is pleased to submit the attached Asbestos-Containing Materials Survey and Asbestos Abatement Cost Estimates report for the above-referenced site. This report includes the scope of work, procedures and methodologies, tables, figures, analytical laboratory results, and abatement cost for each asbestos-containing material identified during this survey.

ATC appreciates the opportunity to perform these services for Aarcher, Inc. (AARCHER) and we look forward to working with you in the future. In the meantime if you have questions or comments regarding the information in this report or if we can be of further assistance please do not hesitate to contact the ATC Centennial, Colorado office at (303) 799-6100.

Sincerely, ATC Associates Inc.

Name: Jen Tomas Name: Fritz Leonard Title: Technical Writer Title: Building Sciences Division Manager AHERA Inspector/Management Planner/Project Designer #15149

8985 E. Nichols Avenue, Suite 350 Centennial, CO 80112-3410 www.atcassociates.com

TEL: 303.799.6100

FAX: 303.799.3441

L3543 - Montrose Warehouse (West) ii

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE OF SERVICES

2.0 GENERAL SITE CONDITIONS

3.0 REGULATORY STANDARDS

3.1 Asbestos Regulations

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT

COST ESTIMATES

4.1 Homogeneous Materials

4.2 Hazard Assessment Factors

4.3 Sampling Strategy

4.4 Suspect Asbestos-Containing Material

4.5 Laboratory Analytical Results

5.0 ASBESTOS-CONTAINING MATERIAL SURVEY AND ASBESTOS ABATEMENT

COST ESTIMATES SUMMARY TABLE

6.0 CONCLUSIONS

7.0 ASSUMPTIONS AND LIMITATIONS

APPENDICES

APPENDIX A: ACM LABORATORY ANALYTICAL RESULTS

APPENDIX B: SITE DRAWING

APPENDIX C: INSPECTOR AND LABORATORY ACCREDITATIONS

APPENDIX D: BLM FACILITY SPREADSHEET

APPENDIX E: ACM PHOTOGRAPHS

CAUTION

These photos may not represent all the asbestos-containing materials (ACM) found at this facility. For a complete list of identified ACMs at this facility see Section 5.

1.0 PURPOSE AND SCOPE OF SERVICES

The purpose of this project was to conduct an Asbestos-Containing Materials (ACM) survey and provide Asbestos Abatement Cost Estimates for identified ACM located in the L3543 - Montrose

Warehouse (West) located at Uncompahgre Field Office, Colorado. ATC Associates Inc. (ATC) provided the services as outlined below:

Conduct a representative asbestos survey of the identified building, which includes the following:

1. Review existing asbestos reports for the building areas, if provided;

2. Survey all of the interior and exterior areas of the building, including building roofs;

3. Identify accessible suspect ACMs using Environmental Protection Agency (EPA)

Asbestos Hazard Emergency Response Act (AHERA) protocols;

4. Collect and analyze bulk samples of suspect friable and non-friable materials to eliminate suspect materials as asbestos containing;

5. Quantify ACMs, including material condition and location; and

6. Provide ACM abatement cost estimates for ACM identified during the survey of the building.

2.0 GENERAL SITE CONDITIONS

The building is a single story, metal/structural steel structure, situated on a concrete foundation, covered by a metal roof. Reportedly, the building was constructed in 1984 and is approximately

5,500 gross square feet. Interior finishes include floor tile, baseboard and mastic, drywall/joint compound, wall texture, putty and frame caulk. The exterior finish is steel.

3.0 REGULATORY STANDARDS

3.1 Asbestos Regulations

The survey was performed in accordance with Federal, State and local rules for conducting asbestos surveys to meet Occupational Safety and Health Administration (OSHA) and United

States Environmental Protection Agency (EPA) / National Emission Standards for Hazardous

Air Pollutants (NESHAP) requirements. The work was also performed in general accordance with AARCHER Subcontract Number 522-S003, dated August 12, 2009 and Task Order 522-

S003-001 (Rev. 9/14/09), dated September 14, 2009.

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT

COST ESTIMATES

ATC representative, Mr. Todd Anderson, Senior Field Manager, an Asbestos Hazard Emergency

Response Act (AHERA) Accredited Asbestos Building Inspector/Management Planner/Project

Designer, State of Colorado Department of Public Health and Environment (CDPHE)

Certification #2157, assisted by Mr. Les Puvathingal, AHERA Accredited Asbestos Building

Inspector CDPHE Certification #15037 conducted the asbestos survey of the building on

September 29, 2009. All fieldwork was performed under the guidance of Mr. Fritz Leonard, an

AHERA Accredited Building Inspector/Management Planner/Project Designer CDPHE

Certification #15149.

The scope of the Asbestos-Containing Materials Survey included all of the accessible suspect building materials and finishes of the interior and exterior areas of the building, including building roofs. If ACM was identified in the building, Asbestos Abatement Cost Estimates were provided for each identified material.

Previous ACM survey reports for the building were not made available for review.

The building areas were visually inspected for the presence of building materials that are suspected to contain asbestos. Bulk samples of identified suspect ACMs were collected and placed into individual containers for transport to a National Voluntary Laboratory Accreditation Program

(NVLAP)/American Industrial Hygiene Association (AIHA)-accredited laboratory for analysis.

Materials visibly identified as non-asbestos (fibrous glass, foam rubber, wood, metal, etc.) were not sampled. The asbestos survey consisted of three basic procedures: 1) conducting a visual inspection of the structure and identifying functional spaces; 2) identifying homogeneous material areas of suspect surfacing, thermal system insulation, and miscellaneous materials; and 3) sampling accessible, friable and non-friable suspect materials.

4.1 Homogeneous Materials

Prior to collecting any samples, homogenous materials were identified and listed to develop a sampling strategy. A homogeneous material sampling area can be described as one or more areas of material that are similar in appearance and texture and that have the same installation date and function. The actual number of samples collected from each homogeneous sampling area was based upon criteria detailed in the following sections.

4.2 Hazard Assessment Factors

From the list of suspect homogeneous materials, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, assessing the potential for disturbance, and determining the friability of each material. Friability is a term used to describe the ease in which a building material inherently lends itself to disturbance. By definition, "friable" materials are those that can be crumbled or reduced to powder by hand pressure when dry. Each material on the list was further classified into one of three categories, which have specific sampling requirements for each category.

Surfacing Materials: Refers to spray-applied or troweled surfaces such as plaster ceilings and walls, fireproofing, textured paints, textured plasters, and spray-applied acoustical surfaces.

Thermal System Insulation: Refers to insulation used to inhibit heat gain or loss on pipes, boilers, tanks, ducts, and various other building components.

Miscellaneous Materials: Refers to friable and non-friable products and materials that do not fit in any of the above two categories such as resilient floor covering, baseboards, mastics, adhesives, roofing material, caulking, glazing, and siding. This category also contains wallboard and joint compound wall systems and acoustical ceiling tile.

All confirmed ACMs were then assessed by their condition as good (no visible damage or showing only very limited damage or deterioration), damaged (less than 25% localized damage or 10% distributed damage), significantly damaged (25% or greater localized damage or 10% or greater distributed damage) per Title 40 Code of Federal Regulations Part 63.

4.3 Sampling Strategy

The asbestos inspection was conducted in general accordance with the AHERA requirements using a minimum number of samples collected for each homogenous material, which also meets the sampling requirement found in 29 CFR 1926.1101.

If the analytical results indicated that all the samples collected per homogenous material did not contain asbestos, then the homogenous material would be considered a non-ACM. However, if the analytical results of one or more of the samples collected per homogenous material indicate that asbestos is present in quantities of greater than 1 percent asbestos by weight (as defined by EPA), all of the homogenous material would be treated as an ACM regardless of any other analytical results.

Material which can visually be determined to be non-asbestos (i.e., fibrous glass, foam rubber, metal, etc.) by the accredited inspector are not required to be sampled.

Miscellaneous materials require adequately representative sampling, which is typically done by collecting from one to three samples per material. Inspectors typically rely on other survey observations such as the condition, friability, and quantity of material to determine what would be a sufficient amount of samples to accurately evaluate the presence or absence of asbestos content. For this survey, three samples per each homogenous miscellaneous material were collected.

Actual collection of a bulk asbestos sample involves physically removing a small piece of material and placing it in a marked, airtight container. Sample containers are marked with a unique identification number, which is also noted in the field notes.

4.4 Suspect Asbestos-Containing Material

Twenty-eight bulk asbestos samples were collected from the building and 33 sample layers were analyzed by Polarized Light Microscopy (PLM) based on the number of distinct layers (materials) associated with each bulk sample. For example, floor tile and associated mastic are collected as one bulk sample but are analyzed as two distinct materials by the asbestos laboratory, as required by

NVLAP.

4.5 Laboratory Analytical Results

Bulk samples were analyzed by ATC Associates Inc. Analytical Laboratory located in Centennial, Colorado, using PLM according to EPA method 600/R-93/116. This laboratory participates in the

NVLAP, a quality assurance program for PLM, and is accredited by the National Institute of

Standards and Technology (NIST).

Any material that contains greater than 1 percent (>1%) asbestos by PLM is considered an ACM and must be handled according to OSHA, EPA, and applicable state and local regulations. In addition, the U.S. Occupational Safety and Health Administration (OSHA) define asbestos as building materials containing between one tenth of one percent and one percent (0.1%-1%).

For friable materials, when the amount of asbestos in the sample material is reported as “None-

Detected” by PLM analysis, no further verification of the sample results by Point Counting

Methodology is recommended.

For friable materials, when the amount of asbestos in the sample material is reported as “Trace

Asbestos Detected” or less than 10% asbestos by PLM analysis, the client may either assume the amount to be greater than 1% and treat the material as ACM or require further verification of the amount by Point Counting Methods. If the result obtained by Point Counting is different from the result obtained by PLM analysis, the Point Count Method result should be used.

For non-friable materials, when the amount of asbestos in the sample material is reported as greater than 1% asbestos by PLM analysis, no further verification of the sample results by alternative methods of identification such as Transmission Electron Microscopy (TEM) Chatfield Method is recommended.

For non-friable materials such as vinyl/asphaltic products (floor tiles/ floor sheeting, mastics, shingles etc), where small, thin asbestos fibers may have been potentially milled into the non-organic binder matrix, when the amount of asbestos in the sample material is reported as “Non-

Detected” by PLM analysis, due to the difficulty in analyzing such small, thin asbestos fibers in resinously bound materials by PLM analysis, EPA recommends but does not require that these types of materials, which were reported as non-ACMs by PLM, be further analyzed using TEM

Chatfield Method. ATC did not conduct such analysis.

The results of the laboratory analysis are summarized in tabular form in Section 5.0. The laboratory analytical report and corresponding chain-of-custody documents are included in

Appendix A. Results are reported in percent asbestos by volume and indicate the types of asbestos. Other common non-asbestos components may also be noted on the analytical reports.

A drawing(s) showing bulk sample locations is provided in Appendix B. Inspector and laboratory accreditations are provided in Appendix C. The Bureau of Land Management Facility

Spreadsheet is provided in Appendix D and lists whether or not asbestos was identified at the building as well as the presence or absence of asbestos in each of the building materials sampled during for the survey of the building. Appendix E presents photographs of up to two ACM’s identified in the building (if present). Appendix E is not intended to show all ACM’s identified in the building.

5.0 ASBESTOS-CONTAINING MATERIAL SURVEY AND ASBESTOS ABATEMENT COST ESTIMATES SUMMARY TABLE

ACM BULK SAMPLING RESULTS

Uncompahgre Field Office, Colorado

Homogeneous Material

Material Category

Required Number of Samples to be Collected

Number of

Samples Collected

Sample Number Location of Material Condition Friable Yes/No

Approximate Material Quantity

Asbestos Content ACM Abatement Cost Estimate

12” x 12” Floor tile and mastic M 3 3 MWW – 14, 15, Eye wash station, Office, Hallway, Women’s shower and locker, Men’s shower and locker G No 880 SF 15% $6,000.00

Drywall/joint compound M 3 3 MWW – 1, 2, 3

Eye wash station, Herbarium, Office, Hallway, Entrance, Women’s shower and locker, Men’s shower and locker, Flammable storage, Warehouse

G No 4,685 SF ND $0.00

Wall texture SM 5 7 MWW – 4, 5, 6, 7, 8, 9, 10

Eye wash station, Herbarium, Office, Hallway, Entrance, Women’s shower and locker, Men’s shower and locker, Flammable storage G No 4,285 SF ND $0.00

Black baseboard and mastic M 3 3 MWW – 11, 12, Eye wash station, Office, Hallway, Entrance, Women’s shower and locker, Men’s shower and locker G No 270 LF ND $0.00

Red putty M 3 3 MWW -17, 18, 19 Flammable storage G No 1 SF ND $0.00

Frame caulk M 3 3 MWW – 20, 21, 22 Exterior G No 60 LF ND $0.00

Roof seam sealant M 3 3 MWW – 23, 24, 25 Roof G No 440 LF 10% $3,500.00

Roof penetration sealant M 3 3 MWW – 26, 27, 28 Roof G No 8 SF ND $0.00

AHERA GUIDELINES FOR DETERMINING THE NUMBER OF SAMPLES TO TAKE

HOMOGENOUS MATERIAL CATEGORY HOMOGENOUS MATERIAL AREA SIZE NUMBER OF SAMPLES REQUIRED

Surfacing Materials <1,000 SF 3

1,000-5,000 SF 5

>5,000 SF 7 or more

Thermal System Insulation No Stipulation 3 (Must also sample all repair patches) Miscellaneous Materials No Stipulation Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos." To satisfy National Emission

Standards for Hazardous Air Pollutants (NESHAP) requirements, a minimum of 3 samples were collected.

ND = None Detected N/A = Not Applicable

MATERIAL CATEGORY

M = Miscellaneous Material SM = Surfacing Material TSI = Thermal System Insulation

APPROXIMATE MATERIAL QUANTITIES

SF = Square Feet LF = Linear Feet Ea. = Each

CONDITION

G = Good D = Damaged SD = Significantly Damaged

6.0 CONCLUSIONS

The results of the asbestos survey conducted at the L3543 - Montrose Warehouse (West), Uncompahgre Field Office, Colorado facility building indicate that: two of the accessible suspect building materials sampled were found to contain more than 1% asbestos.

Contractors and employees working in this building should be made aware of the possibility that concealed ACMs may be found during demolition/renovation. They should be advised not to disturb known or suspect ACMs without owner approval.

Any concealed building materials discovered during maintenance or renovation activities, which are suspected to contain asbestos, should be sampled and analyzed to confirm the presence of asbestos prior to disturbing.

The EPA has not prohibited the manufacture and import of miscellaneous materials, such as vinyl floorings, mastics, roofing materials, etc. As a result, any future replacement materials should be checked for the presence of asbestos prior to installation.

7.0 ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during ATC’s inspection of the L3543 - Montrose Warehouse

(West) building located at the Uncompahgre Field Office, Colorado.

The selection of sample locations and frequency of sampling was based on ATC’s observations and the assumption that like materials in the same area are homogeneous in content. Limited destructive investigation was conducted as needed. Concealed ACMs may exist in concealed areas not investigated or identified.

The report is designed to aid the client in understanding the extent of ACM issues as they pertain to the “Recognition and Measurement of Asbestos-Related Cleanup Costs,” Technical Bulletin

2006-1, prepared by the Federal Accounting Standards Advisory Board, dated September 28, 2006 and to the renovation/demolition areas of the facility building areas. It should be noted that this report is not a complete Asbestos Abatement Specification or Work Plan.

Our professional services have been performed, our findings obtained, and our conclusions prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.

Asbestos abatement cost estimates were obtained from asbestos abatement contractors who have not visited the site and have not seen the ACM to be abated. The costs provided herein, are magnitude estimates of costs with the following assumptions made:

• Assumes free and clear access to the work area during working hours.

• Assumes one mobilization to complete the abatement of one ACM.

• Assumes both power and water at no cost to contractor.

• Assumes protect in place all above ceiling electrical wiring, fire alarm, and wifi cables.

• Does not include the demolition of any building components other than the ACM.

• Pricing assumes that any required inspections and air testing is provided by the building owner or owners representative.

• Assumes that no special conditions are added by any state, or local regulatory agency.

• Work hours 7:00 am to 5:00 pm Monday through Friday.

• Not be held responsible for packaging, moving or damage to items being moved, nor for providing storage and or inventory of these items. If storage or inventory is needed the owner will provide what is necessary. Responsibility of any personal items is the owners.

• No delays interfering with the diligent execution of the work beyond contractors control will be encountered.

APPENDIX A

ACM LABORATORY ANALYTICAL RESULTS

ANALYTICAL REPORT

Prepared for:

910 Commerce Road Annapolis, MD 21401

AARCHER

10/10/2009

0010419 Order#:

Report Date:

Project: L3543/Montrose Warehouse (West)

8985 E. Nichols Avenue, Suite 350, Centennial, CO 80112 Ph: 303-799-6100ATC ASSOCIATES, INC.

PLM REPORT SUMMARY

EPA Method 600/M4-82-020; 600/R-93/116

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

Lab No. Sample Description / LocationClient No. Asbestos Content

None DetectedMWW-1 0010419-001 LAYER 1 Joint Compound, White Warehouse

None DetectedMWW-1 0010419-001 LAYER 2 Drywall, White/ Brown Warehouse

None DetectedMWW-2 0010419-002 LAYER 1 Joint Compound, White Women's Shower Locker

None DetectedMWW-2 0010419-002 LAYER 2 Drywall, White/ Brown Women's Shower Locker

None DetectedMWW-3 0010419-003 LAYER 1 Joint Compound, White Office

None DetectedMWW-3 0010419-003 LAYER 2 Drywall, White/ Brown Office

None DetectedMWW-4 0010419-004 Wall Texture, White Eye Wash Station

None DetectedMWW-5 0010419-005 Wall Texture, White Herbarium

These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested.

The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

http://www.atc-enviro.com

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

Lab No. Sample Description / LocationClient No. Asbestos Content

None DetectedMWW-6 0010419-006 Wall Texture, White Office

None DetectedMWW-7 0010419-007 Wall Texture, White Hallway

None DetectedMWW-8 0010419-008 Wall Texture, White Entrance

None DetectedMWW-9 0010419-009 Wall Texture, White Women's Shower & Locker

None DetectedMWW-10 0010419-010 Wall Texture, White Men's Shower & Locker

None DetectedMWW-11 0010419-011 LAYER 1 Baseboard, Black Hallway

None DetectedMWW-11 0010419-011 LAYER 2 Baseboard Mastic, Yellow Hallway

None DetectedMWW-12 0010419-012 LAYER 1 Baseboard, Black Men's Shower & Locker

These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested.

The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

Lab No. Sample Description / LocationClient No. Asbestos Content

None DetectedMWW-12 0010419-012 LAYER 2 Baseboard Mastic, Yellow Men's Shower & Locker

None DetectedMWW-13 0010419-013 LAYER 1 Baseboard, Black Office

None DetectedMWW-13 0010419-013 LAYER 2 Baseboard Mastic, Yellow Office

None DetectedMWW-14 0010419-014 LAYER 1 12"x12" Floor Tile, Beige Men's Shower & Locker

ChrysotileMWW-14 15%0010419-014 LAYER 2 12"x12" Floor Tile Mastic, Black Men's Shower & Locker

None DetectedMWW-15 0010419-015 12"x12" Floor Tile, Beige Note: Floor Tile Only Eye Wash Station

None DetectedMWW-16 0010419-016 12"x12" Floor Tile, Beige Note: Floor Tile Only Women's Shower & Locker

These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested.

The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

Lab No. Sample Description / LocationClient No. Asbestos Content

None DetectedMWW-17 0010419-017 Putty, Red Flammable Storage

None DetectedMWW-18 0010419-018 Putty, Red Flammable Storage

None DetectedMWW-19 0010419-019 Putty, Red Flammable Storage

None DetectedMWW-20 0010419-020 Caulking-Frame, Gray Exterior

None DetectedMWW-21 0010419-021 Caulking-Frame, Gray Exterior

None DetectedMWW-22 0010419-022 Caulking-Frame, Gray Exterior

ChrysotileMWW-23 10%0010419-023 Roof Seam Sealant, Gray Roof

MWW-24 0010419-024 Roof Seam Sealant, Gray Note: Sample Not Analyzed Roof

These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested.

The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

Lab No. Sample Description / LocationClient No. Asbestos Content

MWW-25 0010419-025 Roof Seam Sealant, Gray Note: Sample Not Analyzed Roof

None DetectedMWW-26 0010419-026 Roof Penetration Sealant, Gray Roof

None DetectedMWW-27 0010419-027 Roof Penetration Sealant, Gray Roof

None DetectedMWW-28 0010419-028 Roof Penetration Sealant, Gray Roof

These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested.

The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

8985 E. Nichols Avenue, Suite 350

303.799.6100

35.213200.0001 Task 0025

Date Analyzed:

910 Commerce Road Annapolis MD 21401

AARCHER

Sample Date: 09/29/2009

0010419

ATC Job No.:

L3543/Montrose Warehouse (West)Project:

Mark Serio

10/10/2009Report Date:

NVLAP Lab Code 102031 AIHA Lab Code 101536

Customer Project No.:

Identification:

Test Method:

N/A

Batch No.:

10/10/2009

Centennial, CO 80112 www.atc-enviro.com

Fax 303.799.3441

Customer:

PLM samples were analyzed utilizing the Environmental Protection Agency's Test Method: Method for the Determination of Asbestos in Building Materials (EPA 600/R-93/116. July, 1993). Reporting Limit <1% Asbestos. Additional treatment and tests may be required to accurately define composition (i.e. ashing, extractions, acetone treatment, andTEM). Unused portions of samples are archived for one year unless client requests special handling.

Asbestos content of mastic/adhesive is separated from total percent asbestos and other materials.

Laboratory analysis was accomplished utilizing an Olympus BH-2 polarized light microscope. The microscope is equipped with dispersion staining lenses.

ATC Associates, Inc. is accredited by NVLAP Bulk Asbestos Sample Quality Assurance Program (Lab Code 102031).

ATC participates in the NVLAP Bulk Asbestos Sample Quality Assurance Program and maintains an in-house QC/QA program for bulk samples whereby 10% of all submitted samples are reanalyzed and documented in a Quality Control Manual. ATC also participates in a quarterly round robin QC/QA program for bulk samples with several accredited laboratories throughout the United States. Current and past QC/QA program results are available in the laboratory for inspection.

Samples were analyzed by Jeff Lomme, Laboratory Director. Mr. Lomme is a professional geologist who has successfully completed the McCrone Institutes's "Advanced Asbestos Identification" Course.

Approved Signatory :

The non-detection of asbestos fibers in floor tile by PLM is of itself inconclusive. Confirmation by Transmission Electron Microscope (TEM) is recommended for negative floor tile samples.

This report must not be used by the client to claim product endorsements by NVLAP or an agency of the U.S. government.

This test reports only to the items stated.

PLM Analysis Methodology

Laboratory Equipment

Quality Control

Laboratory Personnel

NVLAP LAB CODE 102031-0Jeff Lomme

APPENDIX B

SITE DRAWING

8985 E. Nichols Avenue Suite 350 Centennial, Colorado 80112

BULK SAMPLE LOCATION DRAWING

PROJECT NO: 035.21320.0001 – Task 25

DESIGNED BY: ATC SCALE: NTS

DRAWN BY: LJP DATE: 10/05/09 FIGURE 1

REVIEWED BY: FL

L3543 MONTROSE WAREHOUSE (WEST)

UNCOMPAHGRE FIELD OFFICE

COLORADO

LEGEND

Positive ACM Sample Positive Roof Sample

Negative ACM Sample Negative Roof Sample

* 38 Sample not analyzed due to at least one sample for homogeneous material with asbestos detected in It.

** ALL LOCATIONS ARE APPROXIMATE

Office

Herbarium

Eye Wash Station

Women’s Shower and Locker

Men’s Shower and Locker

Cage

CageWarehouse

Flammable Storage

Heater

Heater

N

* 24

* 25

APPENDIX C

INSPECTOR AND LABORATORY ACCREDITATIONS

APPENDIX D

BLM FACILITY SPREADSHEET

State Description Installation Name

Gross Square

Feet Construction

Year BEGIN_LAT BEGIN_LONG Colorado Uncompahgre Field Office Montrose Warehouse (West) 5,500.000 1984 38.45965 -107.86798

Continued

Asbestos was found in the building 12" x 12" floor tile and mastic Dryall/joint compound

Wall texture

Black baseboard and mastic Red putty Frame caulk Yes Yes No No No No No

Continued Roof seam sealant Roof penetration sealant Yes No

APPENDIX E

ACM PHOTOGRAPHS

1: Asbestos-containing 12” x 12” floor tile and mastic.

2: Location of asbestos-containing roof seam sealant (top of photograph).