ACM_Survey_Report.pdf

Prepared for:

Minnesota Pollution Control Agency

18 Woodlake Drive Southeast

Rochester, Minnesota 55904-6250

Prepared by:

Terracon Consultants, Incl

955 Wells Street, Suite 100

Saint Paul, Minnesota 55106

Pre-Demolition Asbestos and

Regulated Materials Inspection Winona Superfund Site - Treatment Building

1405 Gilmore Avenue

Winona, Minnesota

August 22, 2024 | Terracon Project No: 41997044

955 Wells Street, Suite 100

Saint Paul, Minnesota 55106-3870

P (651) 770-1500

F (763) 957-5713 Terracon.com

Facilities | Environmental | Geotechnical | Materials

August 22, 2023

Minnesota Pollution Control Agency

Remediation Division, Superfund Section

520 Lafayette Road North

St. Paul, Minnesota, 55155

Attn: Mr. Drew Bahl

P: (651) 757-2187

E: Drew.Bahl@state.mn.us

Re: Pre-Demolition Asbestos and Regulated Materials Inspection

Winona Superfund Site - Treatment Building

1405 Gilmore Avenue

Winona, Minnesota 55987

Terracon Project No. 41997044P

Dear Mr. Bahl, Terracon Consultants, Inc. (Terracon) is pleased to submit the attached report for the above referenced site. The purpose of this report is to present the results of the Pre-Demolition Asbestos and Regulated Materials Inspection, performed on August 2, 2024. This survey was conducted in general accordance with Terracon Proposal No. P41247126 dated June 14, 2024.

Asbestos-containing materials (ACM) were not identified in the samples collected from the subject building. Other potential regulated materials were identified and inventoried as part of this

Inspection. Please refer to the attached report for details.

Terracon appreciates the opportunity to provide this service to the Minnesota Pollution Control

Agency. If you have any questions regarding this report , please contact the undersigned.

Sincerely, Terracon Consultants, Inc.

Eric J. Donner Mike J. Willey Environmental Technician Authorized Project Reviewer D (651) 894-6628 D (763) 489-3126 M (507) 829-4965 M (612) 269-3439 Eric.donner@Terracon.com mike.willey@Terracon.com https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAbHc_CR8tBmZW48Ct-GuZcGScbUFyafS-https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAbHc_CR8tBmZW48Ct-GuZcGScbUFyafS-

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

1.2 Reliance

1.3 Standard of Care

2.0 PROJECT DESCRIPTION

2.1 Building Description

2.2 Existing Documents

3.0 SCOPE OF SERVICES

3.1 Asbestos Inspection

3.1.1 Visual Assessment

3.1.2 Physical Assessment

3.1.3 Sample Collection

3.1.4 Sample Analysis

3.2 Regulated Waste Items and Materials Inventory

4.0 REGULATORY REVIEW

4.1 Asbestos

4.1.1 Federal Asbestos Regulations

4.1.2 State and County Asbestos Regulations

4.2 Regulated Materials

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Inspection Findings

5.1.1 Asbestos Materials Summary Table

5.1.2 Asbestos-Containing Material Classifications

5.1.3 Asbestos Management Recommendations

5.2 Hazardous / Special / Universal Waste Inspection

5.2.1 Polychlorinated Biphenyl (PCB) Containing Oils

5.2.2 Metal-Containing Items

5.2.3 Miscellaneous Regulated Waste Materials

5.3 Beneficial Reuse

5.4 Additional Services

6.0 GENERAL REPORTING LIMITATIONS

APPENDIX A EXHIBIT 1 SITE LOCATION TOPOGRAPHIC MAP

EXHIBIT 2 PROPERTY LAYOUT MAP

EXHIBIT 3 SAMPLE LOCATION MAP

APPENDIX B TABLE I: ASBESTOS ASSESSMENT BY FUNCTIONAL AREA

TABLE II: HAZARDOUS/UNIVERSAL WASTE INVENTORY

APPENDIX C ASBESTOS BULK SAMPLE LABORATORY ANALYTICAL REPORT

APPENDIX D PHOTO LOG

APPENDIX E CERTIFICATIONS

Facilities | Environmental | Geotechnical | Materials 1

PRE-DEMOLITION

ASBESTOS AND REGULATED MATERIALS INSPECTION

WINONA SUPERFUND SITE – TREATMENT BUILDING

1405 GILMORE AVENUE

WINONA, MINNESOTA

Terracon Project No. 41997044

August 22, 2024

1.0 INTRODUCTION

Terracon Consultants, Inc. (Terracon) was retained by the Minnesota Pollution Control Agency

(MPCA) to conduct a Pre-Demolition and Regulated Materials Inspection (Inspection) and to prepare this report (Inspection Report) for the Winona Groundwater Contamination Superfund

Site’s Treatment Building (Building) addressed as 1405 Gilmore Avenue, Winona, Minnesota

(Property). Exhibit 1 in Appendix A shows the location of the Property.

The Inspection was conducted August 2, 2022, by a State of Minnesota certified asbestos inspector, Eric J. Donner in general accordance with proposal number P41247126 dated June 14, 2024. A copy of his inspector certificate is included in Appendix E.

1.1 Project Objective

The objective of the Inspection Report is to identify the presence, quantity and location of asbestos-containing materials (ACM), and providing an inventory of metal containing items, ozone depleting chemical and other universal, special, and potential hazardous wastes (regulated materials) in the building at the time of the field assessment, subject to the stated reporting and sampling limitations.

1.2 Reliance

This report is for the exclusive use of MPCA for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and the MPCA. Reliance on this report by MPCA and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report and Terracon’s Agreement for Services. The limitations of liability defined in Terracon’s Agreement for Services are the aggregate limit of

Terracon’s liability to the MPCA.

1.3 Standard of Care

This Inspection 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 Inspection of the building. The information contained in

Pre-Demolition Asbestos and Regulated Materials Inspection

FY25 Winona GW Contamination Site ■ Winona, MN

August 22, 2024 ■ Terracon Project No. 41997044

Facilities | Environmental | Geotechnical | Materials 2 this report is relevant to the date on which this Inspection 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 MPCA 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 regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

2.0 PROJECT DESCRIPTION

Terracon understands the Inspection was requested in support of the planned demolition activities which require management, documentation, and communication of various building materials, wastes and/or chemicals present within the Building on the Property. The project objective is based upon information required to communicate for compliance with the following summarized requirements:

▪ The Environmental Protection Agency (EPA) regulation 40 CFR 61, Subpart M, National

Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated ACM (RACM) be identified, classified, and quantified prior to planned disturbances or demolition activities.

▪ The Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control

Act (TSCA) impact some construction and demolition projects with respect to hazardous waste (i.e., solvent/thinner, fuel, stains, unused paint, oil/lubricants, compressed gas cylinders, and unpunctured aerosol cans) and universal waste (i.e. fluorescent lights, high intensity discharge lamps, mercury-containing thermostats, batteries, pesticides).

Materials referenced here are generally referred to as “Regulated Materials” th roughout the Inspection Report. Additionally, Minnesota Rules 7035.0805 Subpart 5, regarding renovation and demolition projects, identifies items and materials which will require special handling and removal prior to renovation/demolition activities.

▪ The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1101 Subpart

Z, Asbestos; regulates asbestos exposure during renovation/demolition activities and requires building and facility owners to determine the presence, location and quantity of

Asbestos Containing Materials (ACM) and/or Presumed ACM (PACM) prior to renovation/demolition activities.

2.1 Building Description

Building description and general construction information for the structure assessed on the

Property include:

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Facilities | Environmental | Geotechnical | Materials 3

Winona Superfund Site Treatment Building – 1405 Gilmore Avenue, Winona, Minnesota 55987

Building Use: Storage Shed Occupancy Status: None

Date of

Construction:

1990’s Renovation Dates: Unknown

No. of Floors 1 Building Square

Footage:

Main Structure: Slab-on-grade shed

Exterior Finishes: Wood siding

Interior Finishes: Drywall

Roofing System: Asphalt shingles and paper/felt layers

2.2 Existing Documents

No existing documents were provided to Terracon for the subject Building .

3.0 SCOPE OF SERVICES

3.1 Asbestos Inspection

The Inspection was conducted by State of Minnesota certified asbestos inspector Eric J. Donner in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, the Asbestos Hazard Emergency Response Act (AHERA). A summary of Inspection activities is provided below.

3.1.1 Visual Assessment

Inspection activities were initiated with visual observation of the interior and exterior of the

Building to identify accessible 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.

3.1.2 Physical Assessment

A physical assessment of each homogeneous area 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 that when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, including previously non-friable material when the material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure. Friability was assessed by physically touching suspect materials. The materials were classified into the three following condition categories:

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Facilities | Environmental | Geotechnical | Materials 4

▪ Not Damaged condition (ND); material with less than or equal to one percent damage or deterioration for the subject surface.

▪ Damaged condition (D); materials which greater than one percent although less than ten percent distributed damage or less than twenty five percent localized damage. Damage is determined when deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage;

significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM; or damage to jacketing or coatings; and

▪ Significantly Damaged condition (SD); materials where damage impacts at least ten percent of a localized subject surface area or if the damage is evenly distributed representing an area of at least twenty-five percent of the subject surface area.

3.1.3 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Random samples of suspect materials were collected in each HA. 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 nine (9) bulk samples of suspect ACM from the Property that were separated by the analytical laboratory into fifteen (15) individual layers for analysis.

3.1.4 Sample Analysis

Bulk samples were submitted under chain of custody to an analytical laboratory accredited by the

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

Accreditation Program (NVLAP), for analysis by polarized light microscopy per EPA methodology

EPA/600/R-93/116.

The percentage of asbestos, where applicable, was determined by microscopic visual estimation or point counting. The MDH, OSHA and EPA define ACM as a material which contains greater than one percent asbestos by qualitative or quantitative analysis techniques. The EPA NESHAP requires quantitative analysis, commonly referred to as a “point count”, for all qualitative analysis results when asbestos is detected in concentrations less than one to ten percent. However, under common practice, qualitative results greater than three and less than ten percent are often accepted to be ACM.

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Facilities | Environmental | Geotechnical | Materials 5

3.2 Regulated Waste Items and Materials Inventory

During the Inspection, Terracon generated an inventory of regulated waste items associated with the Building. This inventory was intended to comply with EPA waste management regulations regarding the disposal of regulated waste (listed wastes, characteristic wastes, universal wastes and mixed wastes) including generators, transporters and storage of wastes present on construction/demolition sites.

The inventory documents the presence of items and materials listed under Subpart 5 of Minnesota

Rules 7035.0805 Renovation and Demolition, which is consistent with requirements of the EPA waste management regulations. These items and materials require special handling and may not remain in a building for demolition. They must be removed two days prior to the start of demolition.

Please note: this Inspection Report is not intended to inventory or characterize other construction materials or existing debris, such as, concrete, wood, metal, glass, furniture, and paper or other mixed municipal waste which may influence handling and disposal landfill requirements during renovation and/or demolition work, including potential beneficial reuse considerations.

4.0 REGULATORY REVIEW

4.1 Asbestos

The following are regulations impacting the methods and findings of this Inspection. It is not a comprehensive list of all asbestos regulations.

4.1.1 Federal Asbestos Regulations

The asbestos portion of NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos 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, can 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, 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 ACMs are all non-friable ACMs that are not Category I non-friable ACM.

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Facilities | Environmental | Geotechnical | Materials 6

In their interpretation of layered drywall systems (joint compound, tape, wall board substrates), the EPA has ruled that unless the entire wall system contains more than 1% friable or potentially friable ACM (verified by Point Count analysis), then the total wall system is not considered RACM and is not subject to NESHAP regulations. However, OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities (including demolition) be protected from asbestos fibers more than the permissible exposure limit of 0.1 fibers/cc air, regardless of the source of the asbestos fibers.

4.1.2 State and County Asbestos Regulations

The Minnesota Pollution Control Agency (MPCA) enforces the Asbestos NESHAP rules as adopted by reference by 7011.9920. The owner or operator must provide MPCA with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than or equal to 160 square feet, 260 linear feet or 35 cubic feet. The MPCA Renovation and Demolition rule (Minn. 7035.0805), Subpart 5, also references

7011.9920, and therefore the Asbestos NESHAP rules.

The Minnesota Department of Health (MDH) Asbestos Abatement Rules (AAR) 4620.3000 -3724 regulate the enclosure, removal, or encapsulation of asbestos-containing material in a quantity that meets or exceeds 260 linear feet of friable asbestos-containing material on pipes, 160 square feet of friable asbestos-containing material on other facility components, or, if linear feet or square feet cannot be measured, 35 cubic feet. The AAR requires asbestos -related work is performed by licensed abatement contractors using certified workers. The abatement contractor must submit a notification to MDH at least 5 calendar days prior to the beginning of a project

(may be submitted jointly with notice to MPCA). Work practices, air monitoring requirements, and clearance criteria are specified.

The Minnesota Department of Labor and Industry adopts the OSHA Asbestos standard at 29 CFR

1910.1001 and 1926.1101 by reference at Minnesota Administrative Rule 5205.0660. The OSHA standards 29 CFR 1910.1001 and 29 CFR 1926.1101 regulate employee exposure to asbestos. The

OSHA standards require that employee exposure to airborne asbestos fibers be maintained at or below 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 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. Building owners are required to maintain buildings and equipment in a safe operating condition, including the repair, removal, encapsulation, or enclosure of damaged ACMs.

4.2 Regulated Materials

The Resource Conservation and Recovery Act (RCRA) states that the generator of hazardous waste is required to follow certain procedures when generating, storing, transporting, and/or disposing of the waste generated. Wastes are defined as hazardous by EPA if they are specifically

August 22, 2024 ■ Terracon Project No. 41997044

Facilities | Environmental | Geotechnical | Materials 7 named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four characteristics (characteristic wastes), including ignitability, corrosivity, reactivity, or toxicity.

The EPA has published waste management regulations regarding the disposal of hazardous waste

(listed wastes, characteristic wastes, universal wastes and mixed wastes) including generators, transporters and storage of wastes present on construction/demoliti on sites as follows:

▪ Disposal of batteries, mercury-containing fluorescent light tubes, and other mercury-containing equipment is regulated under EPA 40 CFR Part 273 Standards for Universal

Waste Management.

▪ Disposal of PCB-containing fluorescent light ballasts, caulks, transformers, and oils is regulated under EPA 40 CFR part 761 Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions.

▪ Disposal of mercury from other sources is regulated under EPA hazardous waste regulations 40 CFR 260-262.

The MPCA Renovation and Demolition rule (Minn. 7035.0805), Subpart 5, lists items and materials that must be removed from a building prior to renovation or demolition, including household hazardous waste, industrial solid waste or hazardous waste, waste tires, major appliances, items that contain elemental mercury, items that might contain polychlorinated biphenyls (PCBs), items that contain chlorofluorocarbons (CFCs), oils, lead-containing items, electronic products containing a cathode ray tube, electronic products containing a circuit board, asbestos that would be friable under demolition conditions, material trapped in sumps and traps, and radioactive wastes. These items and materials must be managed or removed from the facility two days prior to the start date of demolition, as submitted on the MPCA notification.

In addition, under Subpart 8, if the owner, person authorizing renovation or demolition, or person conducting the renovation or demolition knows or has reason to know that portions of the structure may be contaminated by hazardous substances or petroleum as defined in Minnesota

Statutes, section 115C.02, subdivision 10, based on past uses of the structure, such as a medical building, laboratory, or manufacturing facility, that person shall, prior to the commencement of renovation or demolition, obtain appropriate samples and receive results from laboratory analysis as necessary to ensure the proper management and disposal of contaminated structural elements and any resulting debris generated.

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Inspection Findings

Suspect homogeneous materials identified and subsequently sampled for asbestos content during the Inspection are listed in the Chain of Custody associated with the laboratory analytical report in

Appendix C. Suspect materials identified within the Inspection Area of the Building are shown on

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Facilities | Environmental | Geotechnical | Materials 8

Table I: Asbestos Assessment by Functional Space in Appendix B. Drawings showing the locations of suspect ACM samples collected are shown in Exhibit 3 in Appendix A

5.1.1 Asbestos Materials Summary Table

The following Asbestos Materials Summary Table lists all materials assumed to be ACM but contained less than one percent asbestos.

Table 1

Asbestos Materials Summary Table

Confirmed Asbestos-Containing Materials

None --

Assumed Asbestos-Containing Materials

None --

Unclassified Asbestos Materials (Containing Less Than One-Percent Asbestos)* and Asbestos Content as Verified by Point Count Analysis

None --

* Materials with asbestos in concentrations of one percent or less, as verified by Point Count analysis, are not Asbestos-Containing Materials by MPCA, MDH, or EPA definition. However, some provisions of OSHA regulations still apply to disturbance of materials containing asbestos in any concentration, including the use of a competent person, wet methods, regulated areas, prompt cleanup, and hazard communication.

Refer to Table I in Appendix B for additional information regarding the locations and quantities of suspect ACMs assessed. Refer to Appendix C for the laboratory analytical report. Refer to

Appendix D for photographs of the sampled materials

5.1.2 Asbestos-Containing Material Classifications

As discussed in Section 4.1 ACMs, if identified during the Inspection, were classified as RACM

(“friable”), Category I non-friable, or Category II non-friable ACM. These categories are shown on

Table I in Appendix B for each applicable material. The classifications indicated are based on the material condition at the time of the Inspection. Material condition can be subject to change due to factors such as mechanical damage (impacts, grinding, sanding, crushing, etc.), moisture damage, weathering (sun) damage, etc., which may affect material classification.

5.1.3 Asbestos Management Recommendations

Asbestos was not detected in samples of suspect materials sampled during the Inspection. Refer to Table I in Appendix B for information regarding the locations and quantities of suspect ACMs assessed.

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Facilities | Environmental | Geotechnical | Materials 9

If previously inaccessible suspected ACM is discovered during renovation/demolition activities, disturbance work should immediately stop, until representative samples can be collected by a licensed asbestos building inspector and laboratory results are ava ilable to render a determination regarding asbestos content within the material discovered. Supplemental inspection may be required by the EPA/MPCA for inaccessible areas or locations outside of the Inspection Area for inspection and sampling, as identified in Section 6.0 in this Inspection Report.

This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. For renovation or demolition projects Terracon recommends an MDH-accredited asbestos Project

Designer be retained to prepare a project specific specification for the management and/or abatement of ACM identified in this Inspection Report, in accordance with applicable regulatory requirements. Additionally, the disposition of non-friable ACMs should be assessed by a Project

Designer based on renovation or demolition plans, including specific considerations of potential for friability during renovation, demolition, and abatement, as well as disposal.

5.2 Hazardous / Special / Universal Waste Inspection

Items and materials listed under Subpart 5 of Minnesota Rules 7035.0805 Renovation and

Demolition require special handling and may not remain in a building for selective or entire building demolition. They must be removed two days prior to the start of demolition. It should be noted that during the hazardous materials survey the building tenant indicated that he intends to properly dispose of all hazardous materials, including built in appliances (heating units, boilers, air compressors, etc.) prior to vacating the building. Terracon inventoried these items and materials to assist in remediation planning and budgeting. Refer to Table II in Appendix B for additional information regarding the location and quantity of these items. The following sections list categories of common regulated materials found in buildings, and general management and disposal considerations.

5.2.1 Polychlorinated Biphenyl (PCB) Containing Oils

Terracon identified light ballasts, potentially containing PCB-containing oils, in fluorescent, neon, or HID light fixtures. Prior to the start of renovation/demolition activities, all light fixtures with ballasts that will require removal will need to be examined and those not marked No PCBs must be placed in a properly labeled metal drum for management as PCB containing waste and will need to be disposed of in accordance with state and federal regulations. The contractor taking possession of any known or suspected PCB containing items for disposal must have a valid EPA

Identification Number for Regulated Waste Activity.

5.2.2 Metal-Containing Items

Terracon identified an HID lamp, control switches, a control panel, and other suspect metal-containing items. These items are inventoried in Table II in Appendix B.

Prior to the start of demolition/renovation activities, HID lamps are required to be removed undamaged and stored in an undamaged condition until they are reused or recycled in accordance

August 22, 2024 ■ Terracon Project No. 41997044

Facilities | Environmental | Geotechnical | Materials 10 with state and federal regulations. Devices that contain mercury switches and circuit boards are required to be removed and disposed of in accordance with state and federal regulations.

5.2.3 Miscellaneous Regulated Waste Materials

Terracon identified multiple electric motors in the building during the Inspection that require special disposal. These items are inventoried in Table II in Appendix B. These materials are not accepted at demolition debris landfills and so require special disposal or recycling. Terracon inventoried items and materials listed under Subpart 5 of Minnesota Rules 7035.0805 Renovation and Demolition. These items and materials must be removed undamaged and stored in an undamaged condition until they are reused or recycled or disposed of in acc ordance with state and federal regulations.

5.3 Beneficial Reuse

This report does not constitute acceptance for beneficial reuse of building materials. Beneficial reuse (recycling) of building materials during demolition may require prior removal of affixed

ACM, lead-based paint, PCB-containing materials (caulks), or stained (contaminated) concrete areas. Contact your Terracon project designers for guidance in regulatory compliance for beneficial reuse applications.

5.4 Additional Services

Terracon personnel accredited in asbestos abatement project design, management planning, inspection, and air monitoring, as well as lead remediation are available to assist with project design and risk assessment. We can help manage projects from start to finish, including development of project concepts, budgets, specifications, contractor bidding, contract management, project oversight and monitoring.

6.0 GENERAL REPORTING LIMITATIONS

The Inspection was conducted utilizing limited destructive sampling techniques. Therefore, efforts were made to determine if multiple layers of materials were present (e.g., flooring), although limited to the extent of allowable access points with hand tools without affecting security, fire and life safety, slips, trips and/or fall hazards including unacceptable aesthetic or functional damage to building surfaces and materials, as per the judgment of the inspector at the time of the

Inspection. Therefore, suspect ACM may be present in concealed spaces, cavities, and plenums of the Building that were not inspected during the Inspection. Additional inspection by an accredited asbestos inspector is required by EPA prior to demolition or renovation that would impact such materials.

The following general areas (not exclusive) could be concealing additional identified ACM or suspect materials.

▪ below grade materials (piping, debris and/or conduit)

APPENDIX A

EXHIBIT 1 SITE LOCATION TOPOGRAPHIC MAP

EXHIBIT 2 SITE LAYOUT

EXHIBIT 3 SAMPLE LOCATIONS

Donner, Eric Highlight

Donner, Eric Highlight

1000090008000

5000 7000

.5

0 2000

.5

KILOMETERS

METERS

MILES

SCALE 1:24 000

NATIONAL GEODETIC VERTICAL DATUM OF 1929

7.5 MINUTE SERIES (TOPOGRAPHIC)

Project Mngr:

Approved By:

Checked By:

Drawn By:

Project No.

Scale:

Date:

EXHIBIT

File No. Consulting Engineers and Scientists

955 WELLS STREET, SUITE. 100 St. Paul, MN 55106

PH. (651) 770-1500 FAX. (651) 770-1657

CONTOUR INTERVAL FEET

WINONA WEST QUADRANGLE

MINNESOTA - WINONA COUNTY

BJS

JLM (41)

BJS

BJS

41997044

AS SHOWN

044sl.dwg

12/21/09

SITE LOCATION TOPOGRAPHIC MAP

WINONA GROUNDWATER CONTAMINATION SUPERFUND SITE

11405 GILMORE AVENUE

WINONA MINNESOTA

APPROXIMATE

SITE LOCATION

Exhibit 2 Property Layout Map

100 ft

N

N

Donner, Eric Rectangle

Donner, Eric Typewriter 1405 Gilmore Avenue

Donner, Eric Callout Inspection Area

Donner, Eric Typewriter Gilmore Avenue

Donner, Eric Typewriter Clarks Avenue

955 Wells St. Ste 100 St. Paul, MN

PH. 651-770-1500 terracon.com

Exhibit

Project No.:

Date:

Drawn By:

Reviewed By:

41997044

August 2021

EJD

MJW

SAMPLE LOCATION MAP

WINONA GROUNDWATER CONTAMINATION SUPERFUND SITE

1405 GILMORE AVENUE

WINONA MINNESOTA

Donner, Eric Stamp

Donner, Eric Typewriter

1405 GILMORE AVENUE

Donner, Eric Typewriter Winona

Donner, Eric Typewriter Minnesota

APPENDIX B

TABLE I: ASBESTOS ASSESSMENT BY FUNCTIONAL AREA

TABLE II: HAZARDOUS/UNIVERSAL WASTE INVENTORY

Table I: Asbestos Assessment by Functional Space

Winona GW Contamination Site | Winona, MN

August 9, 2024 | Project No. 41997044P

Location/Functional Space Suspect Material Description

Sample Number

(HA-Code-

Number)

Asbestos

Content

RACM, Cat. I or Cat. II Non-

Friable

Estimated

Quantity Units Condition

Treatment Building Interior Drywall, tape, and compound 1-WB1-(1,2,3) ND NA 500 SF ND

Treatment Building Interior Interior sealing caulk 2-CA3-(4,5,6) ND NA 4 LF ND

Treatment Building Exterior Roof shingle, tar paper, and felt 3-RF5-(7,8,9) ND NA 340 SF ND

1 Refer to Section 4.1 for regulatory classification

2 Refer to Section 3.1.2 for Condition Information

Facilities | Environmental | Geotechnical | Materials Page 1 of 1

Table II: Asbestos Assessment by Functional Space

Winona GW Contamination Site | Winona, MN

August 9, 2024 | Project No. 41997044P

Quantity Units Quantity Units

1 Each

4 LF

ODC-Containing Items Quantity Units

Quantity Units

1 Each

2 Each Quantity Units

1 Each

8 Each

3 Each

Plumbing Vent Cap Sheet Lead Paint (aerosol)

Drain Plumbing Joint Packing Solvents

Lead-Lined Walls/Doors Cleaning Chemicals

Miscellaneous Electronic Items Pesticides/Poisons

Other (describe) Lawn and Garden Chemicals/Fertilizers

Electric motor

Computers/Servers Storage Tanks (in-building)

Monitors - Cathode Ray Tube (CRT) Automotive Fluids

Monitors - Flat Panel Paint (non-aerosol latex)

Communication Panels Paint (non-aerosol oil)

Mercury Switch Thermostats Halon Fire Suppression Systems

Manometers Other (describe)

Flame Sensors

Control Switches Miscellaneous Hazardous/Universal Wastes

Smoke Detectors Door Closers

Emergency Strobe Lights Flammable Waste Traps

Motion Sensors Hydraulic Vehicle Lifts

Control Panels Hydraulic Elevators

Potential PCB-Containing Items Items Containing Batteries

Air Conditioners/Heat Pumps

Fluorescent Lamps, 4-foot or less Window Air Conditioners

Fluorescent Lamps, greater than 4-foot Walk-in Coolers

Compact Fluorescent Lights (CFLs) Water Fountains/Coolers

Light-Emitting Diode (LED) Fire Extinguishers

High-Intensity Discharge (HID) Refrigerators/Freezers/Vending

Location/Area Inventoried: Treatment Building Interior and Exterior

Light Ballasts Emergency Lighting

Neon Dehumidifiers

Transformers Emergency Exit Signs

Capacitors Backup Power Supplies

Caulks - Interior sealing caulk Automotive Style

Caulks (describe) Other (describe)

Other (describe)

Metal-Containing Items

Facilities | Environmental | Geotechnical | Materials Page 1 of 1

APPENDIX C

ASBESTOS BULK SAMPLE LABORATORY ANALYTICAL REPORTS

EMSL Analytical, Inc.

3410 Winnetka Avenue North New Hope, MN 55427

Tel/Fax: (763) 449-4922 / (763) 449-4924 http://www.EMSL.com / minneapolislab@emsl.com

352407227EMSL Order:

Customer ID: BALI50

Customer PO: 41997044P

Project ID:

Attention: Phone:Eric Donner (651) 770-1500

Fax:Terracon Consultants, Inc. (763) 489-3101

Received Date:13400 15th Avenue North 08/02/2024 3:25 PM

Analysis Date:Minneapolis, MN 55441 08/07/2024

Collected Date:

Project: Winona GW Contamination Site / 41997144P

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

1-WB1-1

352407227-0001

None DetectedNon-fibrous (Other)92%Cellulose8%White

Non-Fibrous

Homogeneous

S Wall - Drywall, Tape, Mud

This is a composite result of wallboard, jt. compound, and tape

1-WB1-2

352407227-0002

None DetectedNon-fibrous (Other)92%Cellulose8%White

Non-Fibrous

Homogeneous

N Wall - Drywall, Tape, Mud

This is a composite result of wallboard, jt. compound, and tape

1-WB1-3

352407227-0003

None DetectedNon-fibrous (Other)92%Cellulose8%White

Non-Fibrous

Homogeneous

E Wall - Drywall, Tape, Mud

This is a composite result of wallboard, jt. compound, and tape

2-CA3-4

352407227-0004

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

W Pipe - Pipe/Wall

Caulk, White

2-CA3-5

352407227-0005

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

W Pipe - Pipe/Wall

Caulk, White

2-CA3-6

352407227-0006

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

E Pipe - Pipe/Wall

Caulk, White

3-RF5-7-Shingle

352407227-0007

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Heterogeneous

N Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-7-Tar Felt

352407227-0007A

None DetectedNon-fibrous (Other)80%Glass20%Black

Fibrous

Heterogeneous

N Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-7-Tar

352407227-0007B

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Heterogeneous

N Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-8-Shingle

352407227-0008

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-8-Tar Felt

352407227-0008A

None DetectedNon-fibrous (Other)80%Glass20%Black

Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-8-Tar

352407227-0008B

None DetectedNon-fibrous (Other)94%Glass6%Black

Non-Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-9-Shingle

352407227-0009

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-9-Tar Felt

352407227-0009A

None DetectedNon-fibrous (Other)80%Glass20%Black

Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

3-RF5-9-Tar

352407227-0009B

None DetectedNon-fibrous (Other)94%Glass6%Black

Non-Fibrous

Heterogeneous

SW Roof Eave -

Asphalt Shingle and paper/felt layers

Initial report from: 08/07/2024 17:17:43

Page 1 of 2ASB_PLM_0008_0002 - 2.31 Printed: 8/7/2024 4:17 PM

EMSL Analytical, Inc.

3410 Winnetka Avenue North New Hope, MN 55427

Tel/Fax: (763) 449-4922 / (763) 449-4924 http://www.EMSL.com / minneapolislab@emsl.com

352407227EMSL Order:

Customer ID: BALI50

Customer PO: 41997044P

Project ID:

Analyst(s)

Bennett Hanson (15) Rachel Travis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. New Hope, MN NVLAP Lab Code 200019-0; Colorado AL-24478

Initial report from: 08/07/2024 17:17:43

Page 2 of 2ASB_PLM_0008_0002 - 2.31 Printed: 8/7/2024 4:17 PM

OrderID: 352407227

APPENDIX D

PHOTO LOG

Site Name: Winona Groundwater Contamination Site

Project No. 41997044

Date of Photographs: August 2, 2024

1. HA 1 drywall, tape, and mud

2. HA 2 interior caulk

3. HA 3 roofing layers

4. Electric motor in shed

5. Interior lighting HID bulb

6. Exterior control panel electronics

7. Exterior electronics and control switches

APPENDIX E

CERTIFICATIONS