A1_FHR_Hazardous Materials Reports.pdf

UNITED STATES ARMY CORPS OF ENGINEERS

REAL PROPERTY SERVICES FIELD OFFICE

RENOVATION OF

BUILDINGS 51450 & 51451

HAZARDOUS MATERIALS

ASSESSMENT

W912DR-18-D-0001-19F0586

IFC Submission March 11, 2021

CONTACT:

John E. Wittmann 703.647.8288 jwittmann@wileywilson.com

Buildings 51450 & 51451 – IFC Submission 11 March 2021 Wiley|Wilson TOC - i

TABLE OF CONTENTS

BUILDINGS 51450 AND 51451 ............................................................................................................Tab 1

Executive Summary

Introduction

Limited Asbestos Inspection

Lead-Containing Materials Survey

Conditions and Limitations

Closure

References/Appendix

BUILDINGS 51449, 51552, 51453 AND 51454 ...........................................................................Tab 2

Executive Summary

Introduction

Limited Asbestos Inspection

Lead-Containing Materials Survey

Conditions and Limitations

Closure

References/Appendix

SUMMARY REPORT

ASBESTOS AND LEAD CONTAINING MATERIALS

INSPECTION AT BUILDINGS 51450 AND 51451

FORT HUACHUCA, ARIZONA

Prepared for:

Wiley|Wilson 2850 Eisenhower Avenue, Suite 200

Alexandria, VA 22314

Prepared by:

2730 East Camelback Road Suite 210

Phoenix, Arizona 85016

April 2020

SUMMARY REPORT FOR ASBESTOS AND LEAD-BASED PAINT INSPECTION

BUILDINGS 51450 AND 51451

FORT HUACHUCA, ARIZONA

STATEMENT OF INDEPENDENT TECHNICAL REVIEW

Vernadero Group Inc., under subcontract to Wiley|Wilson, has completed the summary report for asbestos-containing materials and lead-based paint inspection of Buildings 51450 and 51451 at Fort Huachuca, Arizona.

Notice is hereby given that an independent technical review has been conducted that is appropriate to the level of risk and complexity inherent in the project. During the independent technical review, compliance with established policy principles and procedures, utilizing justified and valid assumptions, was verified. This included review of data quality objectives; technical assumptions; methods, procedures, and materials to be used; the appropriateness of data used, and level of data obtained; and reasonableness of the results, including whether the product meets the customer’s needs consistent with law and existing policy.

Significant concerns and the explanation of the resolution are documented in the project file.

Changes to the report addressing the comments have been verified by the Project Manager. As noted above, all concerns resulting from independent technical review of the project have been considered.

Eric Webb, PhD Project Manager

Date

14 April 2020

ASBESTOS AND LEAD-BASED PAINT SURVEY REPORT

BUILDINGS 51450 AND 51451

Cushing Street

Fort Huachuca, Arizona

Prepared for:

Wiley|Wilson 2850 Eisenhower Avenue, Suite 200

Alexandria, Virginia 22314

Prepared by:

VERNADERO GROUP INC.

2730 East Camelback Road

Suite 210 Phoenix, Arizona 85016

April 2020

Asbestos and Lead Material Survey Report Buildings 51450 and 51451 April 2020 i Vernadero Group Inc.

EXECUTIVE SUMMARY

On 3 through 5 December 2019, Vernadero Group Inc. conducted an asbestos- and lead-containing materials inspection of Buildings 51450 and 54451 located north of Cushing Street and west of Winans Avenue at Fort Huachuca, Arizona (the Site). The Site is currently unoccupied. The U.S. Environmental Protection Agency and the Occupational Safety and Health Administration consider a material to be asbestos-containing if at least one sample collected from the homogeneous material has asbestos present in concentrations greater than 1 percent by weight. A material with a reading greater than or equal to one milligram per square centimeter is considered to be lead containing.

Field activities included surveys for asbestos-containing materials (ACMs) including inspection, sampling, and analysis (if needed and authorized) of suspected ACMs, when accessible, from the interior of each building. Samples were not collected from roofing materials. Surveys for lead-based paint and lead-containing materials were conducted using a portable X-Ray fluorescence (XRF) unit for the interior and exterior spaces in each building.

A total of 36 bulk samples for asbestos were collected in Building 51450 and 79 bulk samples were collected in Building 51451 and submitted for laboratory analysis following standard chain-of-custody procedures. Suspect ACMs not sampled were assumed to contain asbestos. Tables ES-1 (Building 51450) and ES-2 (Building 51451) provide a summary of ACM that was detected or assumed and the regulatory classification of the ACM.

A total of 58 XRF readings were collected in Building 51450, and 73 XRF readings were taken in Building 51451. Tables ES-3 (Building 51450) and ES-4 (Building 51451) summarize materials found to contain lead above regulatory limits.

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Table ES-1. Summary of Asbestos-Containing Materials and Regulatory Classifications – Building 51450

Material Description Material Location HA Quantity Asbestos

Content EPA OSHA

Light Brown 9” x 9” Vinyl Floor Tile

Rooms 1024, 1025, 1026, 1018. 1017, 1016, 1015

1 1,665

sq. ft. 2% chrysotile Category I Class II

Black Mastic Associated with

Asbestos-Containing 9” x 9” Light Brown

Vinyl Floor Tile

Rooms 1024, 1025, 1026, 1018. 1017, 1016, 1015

1,665

sq. ft.

7% chrysotile Category I Class II

White 12” x 12” Vinyl Floor Tile

Rooms 1004, 1005, 1006, 1007, 1009, 1010, 1012, 1019, 1020, 1021

3 4,907 sq.

ft. 2% chrysotile Category I Class II

Brown 9” x 9” Vinyl Floor Tile

Rooms 1015, 1016, 1017, 1018, 1024, 1025, 1026

5 1,665 sq.

ft. 2% chrysotile Category I Class II

Brown 9” x 9” Vinyl Floor Tile

Rooms 1015, 1016, 1017, 1018, 1024, 1025, and 1026

7 457 sq.

ft. 5% chrysotile Category I Class II

Thermal System Insulation – Duct

Wrap

Mechanical Room 1022 9 Est. 36 linear ft. 8% chrysotile Category I Class I

Thermal System Insulation – Duct

Wrap Coating

Mechanical Room 1011 9 Est. 36 linear ft. 8% chrysotile Category I Class I

Thermal System Insulation – Duct

Wrap Coating

Mechanical Room 1022 9 Est. 48 linear ft. 5% chrysotile Category I Class I

HA – homogeneous area; EPA – U.S. Environmental Protection Agency; OSHA – Occupational Safety and Health Administration; “ – inch; sq. ft. – square foot; est. – estimated; ft. – foot iii Vernadero Group Inc.

Table ES-2. Summary of Asbestos-Containing Materials and Regulatory Classifications – Building 51451

Material Description Material Location HA Quantity Asbestos

Content EPA OSHA

Cream 9” x 9” Vinyl Floor Tile with Red

Streaks

Rooms 1001, 1003, 1005, 1006, 1007, 1011, 1012, 1016, 1017, 1018, 1019

1 5,381

sq. ft. 4% chrysotile Category I Class II

Black Mastic Associated with

Asbestos-Containing 9” x 9” Cream Vinyl

Floor Tile

Rooms 1001, 1003, 1005, 1006, 1007, 1011, 1012, 1016, 1017, 1018, 1019

1 5,381

sq. ft. 6% chrysotile Category I Class II

Tan Mastic Associated with

Asbestos-Containing 9” x 9” Cream Vinyl

Floor Tile

Rooms 1001, 1003, 1005, 1006, 1007, 1011, 1012, 1016, 1017, 1018, 1019

1 5,381

sq. ft. 4% chrysotile Category I Class II

Black and Tan Mastics Associated with Non-Asbestos- Containing 9” x 9”

Replacement Cream Vinyl Floor Tile

Rooms 1001, 1005, 1006, 1016, 1017, 1019 2 30 sq. ft. 8% chrysotile Category I Class II

Black and Yellow Mastics Associated with Non-Asbestos- Containing 9” x 9”

White Vinyl Replacement Floor Tile with Tan Flecks

Rooms 1001, 1005, 1006, 1016, 1017, 1019 4 900 sq. ft. 2% chrysotile Category I Class II

Dark Brown 9” x 9” Vinyl Floor Tile Room 1010 5 225 sq. ft. 4% chrysotile Category I Class II iv Vernadero Group Inc.

Material Description Material Location HA Quantity Asbestos

Content EPA OSHA

Black and Yellow Mastics Associated with Asbestos- Containing 9” x 9”

Brown Vinyl Floor Tile

Room 1010 5 225 sq. ft. 2% chrysotile Category I Class II

Dark Brown 9” x 9” Replacement Vinyl

Floor Tile

Rooms 1005, 1019 6 15 sq. ft. 2% chrysotile Category I Class II

Black and Yellow Mastics Associated with Asbestos- Containing 9” x 9”

Brown Replacement Vinyl Floor Tile

Rooms 1005, 1019 6 15 sq. ft. 4% chrysotile Category I Class II

Black and Yellow Mastics Associated with Asbestos- Containing 9” x 9”

Brown Replacement Vinyl Floor Tile

Rooms 1005, 1019 6 15 sq. ft. 5% chrysotile Category I Class II

Black and Yellow Mastics Associated with Non-Asbestos- Containing 9” x 9” Gray Replacement

Floor Tile

Rooms 1005, 1019 8 12 sq. ft. 4% chrysotile Category I Class II

Black and Yellow Mastics Associated with Non-Asbestos- Containing 9” x 9” Pink Replacement

Floor Tile

Rooms 1005, 1017, 1019 9 9 sq. ft. 4% chrysotile Category I Class II

Black and Yellow Mastics Associated with Non-Asbestos- Containing 9” x 9”

White Replacement Vinyl Floor Tile with

Gray Flecks

Rooms 1005, 1017, 1019 10 6 sq. ft. 4% chrysotile Category I Class II

White 9” x 9” Replacement Vinyl Floor Tile with Gray

Streaks

Rooms 1005, 1017, 1019 11 25 sq. ft. 4% chrysotile Category I Class II v Vernadero Group Inc.

Material Description Material Location HA Quantity Asbestos

Content EPA OSHA

Tan and Black Mastics Associated with Non-Asbestos- Containing 9” x 9” Gray Replacement

Vinyl Floor Tile

Rooms 1005, 1017 12 16 sq. ft. 2% - 6% chrysotile Category I Class II

Tan and Black Mastics Associated with Non-Asbestos- Containing 12” x 12” White Replacement

Vinyl Floor Tile

Room 1018 13 26 sq. ft. 2% - 6% chrysotile Category I Class II

Brown and Black Mastics Associated with Non-Asbestos- Containing 9” x 9” Gray Replacement

Vinyl Floor Tile

Room 1016 14 8 sq. ft. 6% chrysotile Category I Class II

Tan and Black Mastics Associated with Non-Asbestos- Containing 9” x 9” Red Replacement

Vinyl Floor Tile

Room 1016 15 24 sq. ft. 6% chrysotile Category I Class II

Tan 9” x 9” Replacement Vinyl

Floor Tile with White Streaks

Rooms 1005, 1019 16 5 sq. ft. 2% chrysotile Category I Class II

Black and Yellow Mastics Associated with Asbestos- Containing 9” x 9” Tan

Replacement Vinyl Floor Tile with White

Streaks

Rooms 1005, 1019 16 5 sq. ft. 4% chrysotile Category I Class II

White Drywall/Skim Coat

Walls throughout building 21 1,977 sq.

ft.

<1% chrysotile Category I Class II

White Drywall/Skim Coat

Ceilings throughout building 23 2,856 sq.

ft.

<1% chrysotile Category I Class II

Thermal System Insulation – Duct

Wrap Coating Mechanical room 24 12 linear

ft. 6% chrysotile Category I Class I

HA – homogeneous area; EPA – U.S. Environmental Protection Agency; OSHA – Occupational Safety and Health Administration; “– inch; sq. ft. – square foot; ft. – foot vi Vernadero Group Inc.

Table ES-3. Summary of Lead-Containing Materials – Building 51450

Building 51450 Interior – Reading Number Component Substrate Room Type Room Number PbC

(mg/cm2)

88 Doorframe Metal Aux 1024 1.8

93 Door Metal Aux 1025 1.2

94 Doorframe Metal Lavatory 1023 1.0

95 Door Metal Lavatory 1023 1.0

97 Wall Ceramic tile Lavatory 1023 1.4

99 Wall Ceramic tile Lavatory 1023 2.5

101 Door Metal Aux 1015 3.4

102 Doorframe Metal Aux 1015 1.2

103 Door Metal Aux 1010 4.4

104 Doorframe Metal Aux 1010 1.0

106 Doorframe Metal Aux 1019 4.2

109 Rolling door Metal Aux 1006 2.6

110 Doorframe Metal Aux 1006 1.2

117 Door Metal Aux 1009 2.4

118 Doorframe Metal Aux 1009 1.2

126 Door Metal Aux 1008 1.9

Building 51450 Exterior – Reading Number Component Substrate Room Type Room Number PbC

(mg/cm2)

73 Handrail Metal Exterior Exterior 5.3

76 Exterior door Metal Exterior Exterior 4.1

77 Doorframe Metal Exterior Exterior 4.9

79 Exterior door Metal Exterior Exterior < LOD

83 Exterior door Metal Exterior Exterior 2.3

84 Doorframe Metal Exterior Exterior 2

86 Handrail Metal Exterior Exterior 1.3

PbC – lead content; mg/cm2 – milligrams per square centimeter; aux – auxiliary; LOD – level of detection vii Vernadero Group Inc.

Table ES-4. Summary of Lead-Containing Materials – Building 51451

Building 51451 Exterior

– Reading Number Component Substrate Room Type Room Number PbC

(mg/cm2)

8 Electrical mount Metal Loading dock Loading dock 2.2

9 Electrical mount Metal Loading dock Loading dock 1.8

10 Electrical mount Metal Loading dock Loading dock 2.4

11 Electrical mount Metal Loading dock Loading dock 2.3

12 Downspout Metal Loading dock Loading dock 1.6

18 Exterior door Metal Exterior Exterior 5.9

21 Exterior door Metal Exterior Exterior 6.7

23 Exterior door Metal Exterior Exterior 5.0

Building 51451 Interior

– Reading Number Component Substrate Room Type Room Number PbC

(mg/cm2)

31 Wall Ceramic tile Janitor's closet 1013 0.7

35 Wall Ceramic tile Lavatory 1015 4.7

36 Wall Ceramic tile Lavatory 1015 0.9

40 Security door Metal Hall 1006 2

42 Doorframe Metal Hall 1006 < LOD

49 Pillar Concrete Store 1001 2.9

51 Pillar Concrete Store 1001 1

54 Pillar Concrete Store 1001 3.4

PbC – lead content; mg/cm2 – milligrams per square centimeter viii Vernadero Group Inc.

FORMAT PAGE

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TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose and Scope of Services Provided

1.2 Authorization

1.3 Site Description

2.0 LIMITED ASBESTOS INSPECTION

2.1 Procedures

2.1.1 Visual Inspection Procedures

2.1.2 Sampling Procedures

2.1.3 Laboratory Analysis

2.2 Suspect ACMs

2.3 Quality Control

2.4 Conclusions and Recommendations

2.4.1 Confirmed ACMs

2.4.2 Assumed ACMs

2.4.3 Recommendations

3.0 LEAD-CONTAINING MATERIALS SURVEY

4.0 CONDITIONS AND LIMITATIONS

5.0 CLOSURE

6.0 REFERENCES

LIST OF TABLES

Table 2-1. Suspect ACMs – Building 51450

Table 2-2. Suspect ACMs – Building 51451

Table 3-1. Lead-Containing Materials – Building 51450

Table 3-2. Lead-Containing Materials – Building 51451 x Vernadero Group Inc.

LIST OF APPENDICES

Appendix A. Site Plan Field Sketches ..................................................................................... A-1

Appendix B. Site Photographs ................................................................................................ B-1

Appendix C. Tables ................................................................................................................. C-1

Appendix D. Laboratory Analytical Results and Chain-of-Custody Documentation .................. D-1

Appendix E. Personnel Certification ........................................................................................ E-1 xi Vernadero Group Inc.

LIST OF ACRONYMS AND ABBREVIATIONS

“ Inch

ACM Asbestos-Containing Material

ADEQ Arizona Department of Environmental Quality cm2 Square Centimeter

EPA United States Environmental Protection Agency

HA Homogeneous Area

ID Identification

LBP Lead-Based Paint

LCM Lead-Containing Material

LOD Level of Detection mg Milligram

NVLAP National Voluntary Laboratory Accreditation Program

OSHA United States Occupational Safety and Health Administration

Pb Lead

PbC Lead Content

Vernadero Vernadero Group Inc.

XRF X-Ray Fluorescence xii Vernadero Group Inc.

1 Vernadero Group Inc.

1.0 INTRODUCTION

This report provides a summary of findings from an asbestos and lead material inspection conducted by Vernadero Group Inc. (Vernadero) at the Buildings 51450 and 54451 located north of Cushing Street and west of Winans Avenue at Fort Huachuca, Arizona (the Site).

1.1 Purpose and Scope of Services Provided

The purpose of this inspection was to identify the presence and location of asbestos-containing materials (ACMs) and lead-containing materials (LCMs) prior to renovation of the Site. The inspection was conducted pursuant to U.S. Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations. The inspection would also estimate the quantities of ACMs and LCMs that must be removed or managed in place for the Site.

The scope of services for this project included conducting a visual survey of the property, collecting suspected ACM bulk material samples, submitting samples for laboratory testing, evaluating potential LCMs with a portable X-ray fluorescence (XRF) analyzer, and preparation this summary report on the findings of the investigation. Field activities included surveys for ACMs and LCMs, including inspection, sampling and analysis (if needed and authorized) of suspected ACMs, when accessible, from the interior of the facility. A detailed description of activities conducted as part of the survey is provided in Section 3.0.

1.2 Authorization

Authorization to conduct this work was given by Wiley|Wilson on 24 October 2018.

1.3 Site Description

Records indicate that the site encompasses two main structures, including an approximately 6,960-square-foot building with offices, storage, and shop space (Building 51451) and an approximately 8,280-square-foot building with multiple office spaces, storage, and shop space (Building 51450). The structures are located near the northwest intersection of Cushing Street and Winans Avenue, within the cantonment area of Fort Huachuca. Both main structures were originally constructed in 1969. The main structures are constructed with concrete masonry unit walls clad in a concrete masonry unit exterior and drywall or concrete masonry unit interior walls and ceramic tile interior cladding, with a flat bituminous roof. The Site is divided into offices, classrooms, mechanical rooms, arms vaults, storage rooms, and latrines. The layout of the Site is shown in field sketches provided in Appendix A. Photographs of the site are provided in Appendix B.

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2.0 LIMITED ASBESTOS INSPECTION

Available reports were reviewed before the inspection (Jacobs 2018, 2019; Blanton and Company 1989). On 3, 4, and 5 December 2019, Vernadero staff conducted an ACM and LCM survey of the Site.

2.1 Procedures

Inspection, sampling, and analytical procedures were conducted in general accordance with the Asbestos Hazard Emergency Response Act protocols and guidance in Chapters 5 and 8 of the Public Works Technical Bulletin 420-70-8, Installation Asbestos Management Abatement Program (Department of the Army 1998).

2.1.1 Visual Inspection Procedures

During the field inspection, an initial interior site walk-through was conducted by Vernadero personnel to determine the presence of suspect ACMs that were accessible and/or exposed.

Site visit photographs are provided in Appendix B. Vernadero personnel evaluated the overall condition of each homogeneous material and determined whether the materials were friable or nonfriable by touching the material, wherever practicable. Each material was further assessed for overall condition and rated as good, damaged, or significantly damaged (Appendix C).

Quantities of accessible and exposed suspect materials were also estimated.

2.1.2 Sampling Procedures

Sampling was conducted in general accordance with standard sampling procedures and regulatory guidance, including the number of samples of each type of homogeneous material observed. Sampling locations were chosen to be representative of the homogeneous areas identified at the Site. An effort was made to collect samples randomly. Homogenous material determination was based on the following criteria:

• Similar physical characteristics (same color and/or texture, etc.)

• Application (sprayed-on, troweled-on, assembled into a system, etc.)

• Material function (thermal insulation, flooring, wall system etc.)

A total of 36 bulk samples were collected in Building 51450, and 79 bulk samples were collected in Building 51451 during 3, 4, and 5 December 2019. Samples were submitted for laboratory analysis following chain-of-custody procedures. Complete results are presented in Appendix C.

Inaccessible Areas

The following areas were inaccessible during the survey and were therefore not included in the scope of the survey:

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• Areas behind drywall walls and above ceilings

• Areas beneath or behind ceramic tile and associated grout, including latrines and showers

• Any mastic or glues attaching bulletin boards, mirrors, and similar items to interior walls

Nonsuspect Materials

The following materials were observed but are considered nonsuspect ACM due to their composition (fiberglass, rubber, etc.) and were not sampled:

• Fiberglass insulation (ceiling areas and duct work)

• Areas behind drywall walls and ceilings

Quantification

Quantification of suspect ACMs was conducted using visual estimation by the inspector. The visual estimation was conducted in accordance with generally accepted practices in the asbestos industry, based on materials that were accessible and exposed. These values are sufficiently accurate to document the presence of asbestos within a space, to identify abatement control conditions, and to comply with general policy considerations. Actual quantities may have differed from visually estimated values.

If a licensed asbestos abatement contractor is engaged to remove ACMs, the abatement contractor will be responsible for verifying reported quantities of ACM.

2.1.3 Laboratory Analysis

Laboratory services were provided by EMSL Labs Inc., located in Phoenix, Arizona. EMSL Labs Inc. is certified by the National Voluntary Laboratory Accreditation Program (NVLAP; code 200811-0). Laboratory analytical results and chain-of-custody documentation are provided in Appendix D. Altogether, 36 bulk samples were collected in Building 51450, and 79 bulk samples were collected in Building 51451. All samples were analyzed by polarized light microscopy.

Summaries of materials tested and accompanying results are provided in Table C-2 of Appendix C.

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2.2 Suspect ACMs

Suspect ACMs identified during the bulk sampling event are summarized in Tables 2-1 and 2-2.

Table 2-1. Suspect ACMs – Building 51450

HA ID Material Location

01 Light Brown 9” x 9” Vinyl Floor Tile with Beige and Tan Mastic – Under Blue Carpeting

Rooms 1015, 1016, 1017, 1018, 1024, 1025, 1026

02 Drywall System with White Paint, Skim Coat, Joint Compound

Throughout the building, excepting Room 1002

03 White 12” x 12” Vinyl Floor Tile with Black Mastic Rooms 1004, 1005, 1006, 1007, 1009, 1010, 1012, 1013, 1014, 1019, 1020

04 Acoustic Ceiling Tiles Throughout building

05 Brown 9” x 9” Replacement Vinyl Floor Tile with Brown Mastic Under Blue Carpet

Rooms 1015, 1016, 1017, 1018, 1024, 1025, 1026

06 Brown 9” x 9” Vinyl Floor Tile with Yellow Mastic Room 1021

07 Brown 9” x 9” Vinyl Floor Tile with Black Mastic Rooms 1001, 1002, 1003

08 Drywall System with White Paint, Skim Coat, Joint Compound – Ceilings Rooms 1023,1024, 1025

09 Thermal System Components Mechanical Room 1022

HA – homogenous area; ID – identification; “ – inch

Table 2-2. Suspect ACMs – Building 51451

HA ID Material Location

01 Cream with Red Streaks 9” x 9” Vinyl Floor Tile with Black and Tan Mastic

Throughout building, excepting Rooms 1002, 1004, 1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016.

02 Cream with Tan Streaks Replacement 9” x 9” Vinyl Floor Tile with Black and Tan Mastic

Throughout building, excepting Rooms 1002, 1004, 1006,1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016.

03 Brown Sheet Flooring with Tan Mastic Room 1009

04 White with Tan Flecks Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic

Throughout building, excepting Rooms 1002, 1004, 1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016.

05 Dark Brown with White Marbling Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic Rooms 1005, 1006, 1010, 1019

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HA ID Material Location

06 Dark Brown Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic Rooms 1005, 1019

08 Light Gray with White Streaks Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic Rooms 1005, 1017, 1019

09 Pink with Gray Flecks Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic Rooms 1005 and 1017

10 White with Gray Flecks Replacement 9” x 9” Vinyl Floor Tile with Black and Yellow Mastic Rooms 1005, 1017, 1019

11 White with Gray Streaks Replacement 9” x 9” Vinyl Floor Tile with Tan Mastic Rooms 1005, 1017, 1019

12 Gray with White Flecks Replacement 9” x 9” Vinyl Floor Tile with Tan and Black Mastic Rooms 1005, 1017, 1019

13 Light Gray 12” x 12” Vinyl Floor Tile with Black Mastic Room 1018

14 Light Gray 9” x 9” Vinyl Floor Tile with Brown and Black Mastic Room 1016

15 Red with White Flecks Replacement 9” x 9” Vinyl Floor Tile with Yellow and Black Mastic Room 1017

16 Tan Replacement 9” x 9” Vinyl Floor Tile with Yellow and Black Mastic Rooms 1005, 1019

17 Insulation, Fire/Security Door Steel door separating Rooms 1001 and 1006

18 Green Cove Base with Beige and Brown Mastic Rooms 1012 and 1013

19 Brown Cove Base with Yellow Mastic Room 1015

20 Carpet and Yellow Mastic Rooms 1002 and 1004

21 Drywall System with White Paint, Skim Coat, Joint Compound – Walls

Throughout building excepting Rooms 1002 and 1004

22 Drywall System with Tan Paint, Skim Coat, Joint Compound – Walls Rooms 1002 and 1004

23 Drywall System with White Paint, Skim Coat, Joint Compound – Ceilings

Throughout building, excepting Rooms 1001, 1002, 1003, 1004, 1010 and 1018

24 Thermal System Components Mechanical Room 1008

25 Acoustic Ceiling Tiles Rooms 1001, 1002, 1003, 1004 and

HA – homogenous area; ID – identification; “ – inch

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2.3 Quality Control

EMSL Labs, Inc. is accredited by NVLAP and has quality control procedures incorporated into its accreditation program.

2.4 Conclusions and Recommendations

2.4.1 Confirmed ACMs

EPA and OSHA consider a material to be asbestos containing if at least one sample collected from the homogeneous material has asbestos present in concentrations greater than 1 percent by weight.

Asbestos was confirmed in the following materials in Building 51450:

• Light brown 9-inch-by-9-inch vinyl floor tile with beige and tan mastic underneath blue carpeting in Rooms 1015, 1016, 1017, 1018, 1024, 1025, and 1026. Approximately 1,665 square feet of tile and mastic was determined to be ACM.

• White 12-inch-by-12-inch vinyl floor tile in Rooms 1004, 1005, 1006, 1007, 1009, 1010, 1012, 1013, 1014, 1019, 1020, and 1021. Approximately 4,907 square feet of tile was determined to be ACM.

• Brown replacement 9-inch-by-9-inch vinyl floor tile in Rooms 1015, 1016, 1017, 1018, 1024, 1025, and 1026 underneath blue carpeting. Unknown total quantity due to carpeting overlay, but estimated to be less than 457 square feet, determined to be ACM.

• Brown 9-inch-by-9-inch vinyl floor tile located in the telecommunications area Room 1021 (approximately 24 square feet) was determined to be ACM.

• Brown 9-inch-by-9-inch vinyl floor tile located in the Rooms 1001, 1002, and 1003 (approximately 457 square feet) was determined to be ACM.

• Tan pipe wrap and associated tan coating located in the Mechanical Room (Room 1022). Approximately 36 linear feet was determined to be ACM.

• White/orange pipe coating located in the Mechanical Room (Room 1022). Approximately 48 linear feet was determined to be ACM.

Asbestos was confirmed in the following materials in Building 51451:

• Cream with red streaks 9-inch-by-9-inch vinyl floor tile with black mastic throughout the building, excepting Rooms 1002, 1004, 1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016. Approximately 5,381 square feet of tile and mastic was determined to be ACM.

• Black and yellow mastic associated with cream replacement 9-inch-by-9-inch vinyl floor tile with tan streaks. Throughout the building, excepting Rooms 1002, 1004, 1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016. Approximately 132 square feet of mastic was determined to be ACM.

• Black and yellow mastic associated with non-asbestos-containing white with tan flecks replacement 9-inch-by-9-inch vinyl floor tile throughout the building, excepting Rooms

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1002, 1004, 1008, 1009, 1010, 1012, 1013, 1014, 1015, and 1016. Approximately 45 square feet of mastic was determined to be ACM.

• Dark brown with white marbling replacement 9-inch-by-9-inch vinyl floor tile with black and yellow mastic located in Rooms 1005, 1010, and 1019. Approximately 24 square feet of floor tile and mastic was determined to be ACM.

• Dark brown replacement 9-inch-by-9-inch vinyl floor tile with black and yellow mastic located in Rooms 1005, 1010, and 1019. Approximately 12 square feet of floor tile and mastic were determined to be ACM.

• Black and yellow mastic associated with non-asbestos-containing light gray with white streaks replacement 9-inch-by-9-inch vinyl floor tile located in Rooms 1005, 1017, and 1019. Approximately 18 square feet of mastic was determined to be ACM.

• Black and yellow mastic associated with non-asbestos-containing pink replacement 9-inch-by-9-inch vinyl floor tile located in Rooms 1005 and 1017. Approximately 14 square feet of mastic was determined to be ACM.

• Black and yellow mastic associated with non-asbestos-containing white with gray flecks replacement 9-inch-by-9-inch vinyl floor tile located in Rooms 1005, 1017 and 1019.

Approximately 12 square feet of mastic was determined to be ACM.

• White with gray streaks replacement 9-inch-by-9-inch vinyl floor tile with tan mastic located in Rooms 1005, 1017, and 1019. Approximately 4 square feet of floor tile was determined to be ACM.

• Tan mastic associated with gray with white flecks replacement 9-inch-by-9-inch vinyl floor tile with tan mastic located in Rooms 1005, 1017, and 1019. Approximately 4 square feet of mastic was determined to be ACM.

• Tan and black mastic associated with gray replacement 12-inch-by-12-inch vinyl floor tile located in Room 1018. Approximately 12 square feet of mastic was determined to be

ACM.

• Black and Yellow mastic associated with non-asbestos-containing light gray 9-inch-by-9-inch vinyl floor tile located in Room 1016. Approximately 150 square feet of mastic was determined to be ACM.

• Black and yellow mastic associated with non-asbestos-containing red replacement 9-inch-by-9-inch vinyl floor tile located in Room 1017. Approximately 24 square feet of mastic was determined to be ACM.

• Tan replacement 9-inch-by-9-inch vinyl floor tile with black and yellow mastic located in Rooms 1005 and 1019. Approximately 13 square feet of floor tile and mastic were determined to be ACM.

• Skim coat from non-asbestos-containing drywall system with white paint and joint compound walls throughout the building except for Rooms 1002 and 1004.

Approximately 2,000 square feet of skim coat was determined to contain less than 1 percent ACM.

• Skim coat from non-asbestos-containing drywall system with white paint and joint compound ceilings throughout the building except for Rooms 1001, 1002, 1003, 1004, 1010, and 1018. Approximately 2,856 square feet of skim coat was determined to contain less than 1 percent ACM.

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• Tan duct coating located in the Mechanical Room (Room 1008). Approximately 44 linear feet was determined to be ACM.

2.4.2 Assumed ACMs

The following suspect ACMs were not sampled at the time of the inspection and are assumed to contain asbestos:

• Gaskets and fittings and associated with the air handling units

• Mastics and/or adhesives used to attach mirrors

2.4.3 Recommendations

The ACMs (confirmed and assumed) should be maintained in good, undamaged condition and periodically inspected through use of an operations and maintenance program. Damaged or significantly damaged ACMs should be repaired, encapsulated, enclosed, or removed.

Asbestos-containing building materials at the Site contain asbestos in concentrations greater than 1 percent. Impacting materials containing greater than 1 percent asbestos either through repair, maintenance, renovation, or demolition activities triggers numerous regulations enforced by such agencies as OSHA and Arizona Department of Environmental Quality (ADEQ).

Impacting materials containing greater than 1 percent asbestos through repair, maintenance, renovation or repair activities triggers regulations enforced by the EPA (i.e., environmental exposure, transportation and disposal).

The following are regulations that apply if the above listed ACMs are removed:

• Any individual who contracts to provide health and safety services related to ACMs must be certified by ADEQ. The activities they are certified to provide include conducting asbestos surveys, writing work plans or specifications for abatement, monitoring the work of abatement contractors, collecting air samples, and determining if the work area is safe for reoccupancy by non-asbestos-trained workers.

• If more than 100 square feet of materials that contain greater than 1 percent asbestos will be abated, they must be abated by an ADEQ-registered asbestos abatement entity.

• The removal of ACMs that are classified by OSHA as other/miscellaneous materials is considered a Class II activity according to OSHA regulations.

• Friable ACMs containing greater than 1 percent asbestos must be manifested, transported, and disposed of as hazardous waste in accordance with the ADEQ. ADEQ regulates disposal of asbestos waste.

Prior to any future maintenance, renovation, or demolition activities, any assumed ACMs should be tested. Any areas that were noted as being inaccessible during this project, or any concealed areas, such as behind walls, where suspect ACMs are discovered, will require a survey for

ACM.

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Prior to the initiation of a project that would involve abatement, a detailed engineering cost estimate and project design will be required prior to initiation and any award action. The engineering cost estimate will incorporate such variables as scheduling and phasing of the project, the size and extent of the project, seasonal factors, operational factors and other restrictions, respiratory protection, and alternate abatement options. An engineering cost estimate would also include professional fees, such as for project design and management, and other expenses, such as on-site air monitoring and construction supervision.

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3.0 LEAD-CONTAINING MATERIALS SURVEY

On 4 and 5 December 2019, a visual inspection and LCM survey of Buildings 51450 and 51451 were conducted. A total of 130 tests (assays) were taken (72 in Building 51450 and 58 in Building 51451) using a portable, hand held XRF analyzer (Niton XLP 303a; serial number 7700). Appendix C contains the complete survey results.

Interior and exterior painted surfaces were tested, including deteriorated paint and areas that were anticipated to be disturbed during planned building renovation. Lead concentrations that meet or exceed the Housing and Urban Development published levels identified as being potentially dangerous (e.g., greater than or equal to 1.0 milligram per square centimeter (mg/cm2) were encountered in several locations on metal components, and as ceramic tile, at levels of 1.0 to 10.0 mg/cm2. By EPA regulation, levels of lead greater than 5.0 mg/cm2 may be considered a hazardous waste, if disturbed. Tables 3-1 and 3-2 list the lead-containing materials in Buildings 51450 and 51451, respectively.

Test locations on metal components exhibited lead-in-paint levels above regulatory levels. It should be noted that lead concentrations (in paint) that are less than the levels that identify a surface coating as lead-based paint (LBP) still have the potential of causing lead poisoning.

Should these or any potential LBP painted components and/or surfaces be disturbed in any manner that generates dust, extreme care must be taken to limit its spread. It should be presumed that any and all painted surfaces, components, or surfaces not tested as part of this investigation are coated with LBP, and that renovation or repair activities in these areas dictate the use of safe work practices that limit dust generation and area contamination.

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Table 3-1. Lead-Containing Materials – Building 51450

Reading Number Component Substrate Side Condition Color Room Number Results PbC

(mg/cm2)

Building 51450 Interior

88 Doorframe Metal South Poor Brown 1024 Positive 1.8

93 Door Metal West Good Brown 1025 Positive 1.2

94 Doorframe Metal West Poor Brown 1023 Positive 1.0

95 Door Metal West Poor Brown 1023 Positive 1.0

97 Wall Ceramic tile North Good Yellow 1023 Positive 1.4

99 Wall Ceramic tile North Good Yellow 1023 Positive 2.5

101 Door Metal North Poor Brown 1015 Positive 3.4

102 Doorframe Metal North Poor Brown 1015 Positive 1.2

103 Door Metal North Poor Brown 1010 Positive 4.4

104 Doorframe Metal North Poor Brown 1010 Positive 1.0

106 Doorframe Metal South Good Brown 1019 Positive 4.2

109 Rolling Door Metal North Deteriorated Brown 1006 Positive 2.6

110 Doorframe Metal North Deteriorated Brown 1006 Positive 1.2

117 Door Metal South Good Brown 1009 Positive 2.4

118 Doorframe Metal South Good Brown 1009 Positive 1.2

126 Door Metal West Deteriorated Brown 1008 Positive 1.9

Building 51450 Exterior

73 Handrail Metal North Deteriorated Yellow Exterior Positive 5.3

76 Exterior Door Metal North Good Dark brown Exterior Positive 4.1

77 Doorframe Metal North Good Dark brown Exterior Positive 4.9

79 Exterior Door Metal North Good Dark brown Exterior Positive < LOD

83 Exterior Door Metal West Good Dark brown Exterior Positive 2.3

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Reading Number Component Substrate Side Condition Color Room Number Results PbC

(mg/cm2)

84 Doorframe Metal West Good Dark brown Exterior Positive 2

86 Handrail Metal West Good Yellow Exterior Positive 1.3

PbC – lead content; mg/cm2 – milligrams per square centimeter

Table 3-2. Lead-Containing Materials – Building 51451

Reading Number Component Substrate Side Condition Color Room Number Results PbC

(mg/cm2)

Building 51451 Exterior

8 Electrical Mount Metal South Poor Brown Loading dock Positive 2.2

9 Electrical Mount Metal South Poor Brown Loading dock Positive 1.8

10 Electrical Mount Metal South Poor Brown Loading dock Positive 2.4

11 Electrical Mount Metal South Poor Brown Loading dock Positive 2.3

12 Downspout Metal South Deteriorated Cream Loading dock Positive 1.6

18 Exterior Door Metal East Poor Dark Brown Exterior Positive 5.9

21 Exterior Door Metal North Deteriorated Dark Brown Exterior Positive 6.7

23 Exterior Door Metal North Deteriorated Dark Brown Exterior Positive 5.0

Building 51451 Interior

31 Wall Ceramic tile North Good Yellow 1013 Positive 0.7

35 Wall Ceramic tile North Good Yellow 1015 Positive 4.7

36 Wall Ceramic tile North Good Yellow 1015 Positive 0.9

40 Security Door Metal West Poor Gray 1006 Positive 2.0

42 Doorframe Metal West Poor Gray 1006 Positive < LOD

49 Pillar Concrete South Good White 1001 Positive 2.9

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Reading Number Component Substrate Side Condition Color Room Number Results PbC

(mg/cm2)

51 Pillar Concrete West Good White 1001 Positive 1.0

54 Pillar Concrete South Good White 1001 Positive 3.4

PbC – lead content; mg/cm2 – milligrams per square centimeter

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4.0 CONDITIONS AND LIMITATIONS

The visual inspection and sampling conducted by Vernadero was limited to areas that were accessible at the time of inspection. Destructive and/or invasive inspections are not generally within the scope of our assessment.

It is the responsibility of the property owner to disclose the relevant history of the Site.

Vernadero cannot assume responsibility for investigation of any unknown issues which were not brought to our attention prior to the commencement of the survey.

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5.0 CLOSURE

The conclusions presented in this report are professional opinions based solely upon observations of our field personnel, points of investigation, and results of services provided by an Arizona-licensed/certified contractor. The scope of services conducted in execution of this investigation may not be appropriate to satisfy the needs of other users, and any use of this document or the findings, conclusions, or recommendations presented herein is at the sole risk of said third party.

Opinions and recommendations presented herein apply to the conditions that existed at the time of our investigation and cannot necessarily apply to site changes of which Vernadero is unaware and has not had the opportunity to evaluate. Site conditions may be affected by natural processes or by the works of man. Changes in applicable standards and regulations may also occur as a result of legislation or the broadening of knowledge. Consequently, the findings of this report may be invalidated, wholly or in part, by changes that are unforeseen and beyond our control.

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6.0 REFERENCES

Blanton and Company. 1989. Modifications to 11th Signal Brigade Motor Pool. Fort Huachuca, Arizona. As-built drawings. 9 August 1989.

Department of the Army. 1998. Installation Asbestos Abatement Management Program. Public Works Technical Bulletin 420-70-8.

Jacobs. 2018. Space Planning and Fit Study for INSCOM at Fort Huachuca. 16 November 2018.

Jacobs. 2019. Space Planning for INSCOM Units, Fort Huachuca, AZ. 21 January 2019.

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A-1 Vernadero Group Inc.

Appendix A. Site Plan Field Sketches

A-2 Vernadero Group Inc.

A-3 Vernadero Group Inc.

Figure A-1. Asbestos Survey Sample Locations at Building 51450

A-4 Vernadero Group Inc.

Figure A-2. Asbestos Survey Sample Locations at Building 51451

A-5 Vernadero Group Inc.

Figure A-3. Lead-Based Paint Survey Locations at Building 51450

A-6 Vernadero Group Inc.

Figure A-4. Lead-Based Paint Survey Locations at Building 51451

B-1 Vernadero Group Inc.

Appendix B. Site Photographs

B-2 Vernadero Group Inc.

B-1 Vernadero Group Inc.

Building 51450

Photograph 1: Exterior, Building 51450, Fort Huachuca, Arizona.

Photograph 2: Exterior, Building 51450, loading dock stairs and railing. Handrail paint contains lead at 5.3 mg/cm2.

Photograph 3: Exterior, Building 51450, typical downspout.

Photograph 4: Exterior, Building 51450, loading dock.

Structural steel, doorways.

Photograph 5: Exterior, Building 51450, loading dock.

Structural steel, rolling doorway, standard doorway.

Photograph 6: Exterior, Building 51450, loading dock.

Structural steel, downspouts, doorways, electrical boxes.

Handrail paint contains lead at

1.3 mg/cm2.

B-2 Vernadero Group Inc.

Photograph 7: Exterior, Building 51450, loading dock.

With electrical boxes.

Photograph 8: Exterior, Building 51450, southwest side.

Exterior door and door frame paint contain lead at 2.3 and 2.0 mg/cm2.

Photograph 9: Exterior, Building 51450, rear of building, north side. Exterior door and door frame paint contain lead at

4.1 and 4.9 mg/cm2.

Photograph 10: Exterior, Building 51450, storage building at rear of building, north side.

Photograph 11: Interior, Building 51450, Mechanical Room 1022, HA-09 thermal system insulation – tan pipe wrap and associated tan coating; and white/orange pipe coating.

Photograph 12: Interior, Building 51450, Mechanical Room 1022, HA-09 thermal system insulation – tan pipe wrap and associated tan coating; and white/orange pipe coating.

B-3 Vernadero Group Inc.

Photograph 13: Interior, Building 51450, Room Aux 1015, HA-01, light brown 9” x 9” vinyl floor tile with beige and tan mastic – under blue carpeting.

Photograph 14: Interior, Building 51450, Room Aux 1010, HA-03 white 12” x 12” vinyl floor tile with black mastic.

Photograph 15: Interior, Building 51450, Room STOC 1013, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

Photograph 16: Interior, Building 51450, Room Aux 1019, looking into Room Hall 1020, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

Photograph 17: Interior, Building 51450, Room Aux 1007, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

Photograph 18: Interior, Building 51450, Room Aux 1007, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

B-4 Vernadero Group Inc.

Photograph 19: Interior, Building 51450, Room Aux 1001, HA-02 drywall system with white paint, skim coat, joint compound, HA-04 acoustic ceiling tiles, HA-07 brown 9” x 9” vinyl floor tile with black mastic.

Photograph 20: Interior, Building 51450, Room Aux 1005, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

Photograph 21: Interior, Building 51450, Room Hall 1004, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic, HA-04 acoustic ceiling tiles.

Photograph 22: Interior, Building 51450, Room Aux 1005, HA-02 drywall system with white paint, skim coat, joint compound, HA-03 white 12” x 12” vinyl floor tile with black mastic; and Room Aux 1001, HA-07 brown 9” x 9” vinyl floor tile with black mastic.

Photograph 23: Interior, Building 51450, Room Aux 1001, HA-02 drywall system with white paint, skim coat, joint compound, HA-04 acoustic ceiling tiles, HA-07 brown 9” x 9” vinyl floor tile with black mastic.

B-5 Vernadero Group Inc.

Building 51451

Photograph 24: Exterior, Building 51451.

Photograph 25: Exterior, Building 51451.

Photograph 26: Exterior, Building 51451.

Photograph 27: Exterior, Building 51451.

Photograph 28: Exterior, Building 51451.

Photograph 29: Exterior, Building 51451.

Photograph 30: Exterior, Building 51451.

Photograph 31: Exterior, Building 51451.

Photograph 32: Exterior, Building 51451.

B-6 Vernadero Group Inc.

Photograph 33: Exterior, Building 51451.

Photograph 34: Interior, Building 51451, Room Hall 1006, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-05 dark brown with white marbling replacement 9” x 9” vinyl floor tile with black and yellow mastic.

Photograph 35: Exterior, Building 51451, Room Hall 1006, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; HA- 02 cream with tan streaks replacement 9” x 9” vinyl floor tile with black and tan mastic;

and HA-17 insulation, fire/security door.

Photograph 36: Interior, Building 51451, Room Inst 1009, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic (foreground); and HA-03 brown sheet flooring with tan mastic (stairs).

Photograph 37: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-09 pink with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic.

Photograph 38: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-02 cream with tan streaks replacement 9” x 9” vinyl floor tile with black and tan mastic.

B-7 Vernadero Group Inc.

Photograph 39: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; HA- 05 dark brown with white marbling replacement 9” x 9” vinyl floor tile with black and yellow mastic; and HA-09 pink with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic.

Photograph 40: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; HA-05 dark brown with white marbling replacement 9” x 9” vinyl floor tile with black and yellow mastic;

HA-09 pink with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic;

and HA-12 gray with white flecks replacement 9” x 9” vinyl floor tile with tan and black mastic.

Photograph 41: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-02 cream with tan streaks replacement 9” x 9” vinyl floor tile with black and tan mastic.

Photograph 42: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-02 cream with tan streaks replacement 9” x 9” vinyl floor tile with black and tan mastic.

Photograph 43: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-09 pink with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic.

Photograph 44: Interior, Building 51451, Room Stor 1016, HA-14 light gray 9” x 9” vinyl floor tile with brown and black mastic.

B-8 Vernadero Group Inc.

Photograph 45: Interior, Building 51451, Room LNG 1017, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; HA- 10 white with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic; HA-12 gray with white flecks replacement 9” x 9” vinyl floor tile with tan and black mastic; HA-15 red with white flecks replacement 9” x 9” vinyl floor tile with yellow and black mastic.

Photograph 46: Interior, Building 51451, Room LNG 1017, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; HA-10 white with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic;

HA-12 gray with white flecks replacement 9” x 9” vinyl floor tile with tan and black mastic;

HA-15 red with white flecks replacement 9” x 9” vinyl floor tile with yellow and black mastic.

Photograph 47: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation.

Photograph 48: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation.

Photograph 49: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation.

Photograph 50: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation, tan duct coating.

B-9 Vernadero Group Inc.

Photograph 51: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation, tan duct coating.

Photograph 52: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation, tan duct coating.

Photograph 53: Interior, Building 51451, Mechanical Room 1008, HA-24 thermal system insulation, tan duct coating.

Photograph 54: Interior, Building 51451, Room TCOM 1007, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic.

Photograph 55: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic.

Photograph 56: Interior, Building 51451, Room Shop 1005, HA-01 cream with red streaks 9” x 9” vinyl floor tile with black and tan mastic; and HA-09 pink with gray flecks replacement 9” x 9” vinyl floor tile with black and yellow mastic; HA-21 drywall system with white paint, skim coat, joint compound – walls.

B-10 Vernadero Group Inc.

Photograph 57: Exterior, Building 51451, loading dock with electrical boxes. Electrical mount paint contains lead at 1.8 to 2.4 mg/cm2.