Addendum_4-Asbestos_and_Lead-Based_Paint_Report.pdf

Asbestos Inspection and XRF Lead-Based Paint Screening

Los Reales Landfill Barn

7161 South Craycroft Road

Tucson, Pima County, Arizona

January 27, 2023

Terracon Project No. 63237003

Prepared for:

City of Tucson

Tucson, Arizona

Prepared by:

Terracon Consultants, Inc.

Tucson, Arizona

Terracon Consultants, Inc. 355 S. Eucl id , Suite 107 Tucson, AZ 85719 P 520-770-1789 F 520-792-2539 ter racon.com

January 27, 2023

Mr. Frank Bonillas City of Tucson Environmental and General Services 4004 South Park Avenue, Building 1 Tucson, AZ 85726

Telephone: (520) 837-3742 E-mail: Frank.Bonillas@tucsonaz.gov

Re: Asbestos Inspection and Lead-Based Paint Screening Los Reales Landfill Barn 7161 South Craycroft Road Tucson, Pima County, Arizona Terracon Project No. 63237003

Dear Mr. Bonillas:

Terracon Consultants, Inc. (Terracon) is pleased to submit the attached report for the above referenced site to City of Tucson (Client). The purpose of this report is to present the results of an Asbestos Inspection and X-ray fluorescence (XRF) Lead-Based Paint (LBP) Screening performed on Inspection January 19, 2023. This inspection was conducted in general accordance with Terracon Proposal No. P63237003 dated January 18, 2023 and the email authorization dated January 18, 2023. We understand that this Asbestos Inspection and XRF LBP Screening was requested to assist with future demolition activities.

Terracon appreciates the opportunity to provide this service to City of Tucson. If you have any questions regarding this report, please call the undersigned at (520) 798-4847 (Derek K.).

Sincerely, Terracon Consultants, Inc.

Prepared By: Reviewed By:

Derek Sizemore, CHMM Derek D. Koller, CIH, CHMM Environmental Group Manager Office Manager / Principal

TABLE OF CONTENTS

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EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 Reliance

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

4.0 REGULATORY OVERVIEW

5.0 FINDINGS AND RECOMMENDATIONS

6.0 LIMITATIONS/GENERAL COMMENTS

APPENDICES

APPENDIX A IDENTIFIED ASBESTOS CONTAINING MATERIALS BY HOMOGENEOUS AREA (HA)

APPENDIX B ASBESTOS INSPECTION SAMPLE SUMMARY

APPENDIX C XRF LBP SCREENING SUMMARY

APPENDIX D ASBESTOS SAMPLING DIAGRAMS

APPENDIX E ASBESTOS LABORATORY REPORT AND CHAIN-OF CUSTODY

APPENDIX F LICENSES AND CERTIFICATIONS

Asbestos Inspection and Lead-Based Paint Screening Los Reales Landfill Barn ■ Tucson, Arizona January 27, 2023 ■ Terracon Project No. 63237003

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EXECUTIVE SUMMARY

Terracon Consultants Inc. (Terracon) conducted an Asbestos Inspection and X-ray fluorescence (XRF) Lead-Based Paint (LBP) Screening at the Los Reales Landfill addressed 7161 South Craycroft Road, Tucson, Arizona. Specifically, the structure known as “The Barn” is slated for demolition. The inspection was conducted on January 19, 2023 by Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos building inspectors and an EPA certified lead paint inspector. This inspection was conducted in general accordance with Terracon Proposal No.

P63237003 dated January 18, 2023. We understand that this Asbestos Inspection and XRF LBP Screening was requested to assist with future demolition activities.

The asbestos portion of the inspection was performed to satisfy requirements of the EPA Regulation 40 Code of Federal Regulations (CFR) Part 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP). Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA 40 CFR Part 763 Subpart E, known as AHERA. Bulk asbestos samples were delivered to an accredited laboratory for analysis by Polarized Light Microscopy (PLM).

The XRF LBP Screening was performed in general accordance with the procedures prescribed in the EPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The LBP Screening was not designed to meet the requirements of the U.S. Department of Housing and Urban Development (HUD) for LBP inspections. The lead paint inspection was conducted using a handheld XRF unit.

Asbestos Findings Terracon collected 9 bulk samples from 3 homogeneous areas of suspect asbestos-containing materials (ACMs) throughout the building. The following ACMs were identified as a result of laboratory analysis or assumed to be asbestos containing:

HA No. Material Description Material Location NESHAP Classification1

Estimated Quantity*

3 Roof Penetrations Roof CAT I Non-Friable 50 Sq. Ft.

1Category I (CAT I) non-friable ACM *Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this inspection.

The listed Category I non-friable ACM that is damaged or could be damaged to the extent that it could be crumbled, pulverized or reduced to powder when dry, making it friable, must be removed prior to any activities (renovation and/or demolition) that may disturb this material in accordance with applicable federal, state and local regulations.

A summary of the classification, condition and approximate quantity of identified ACM is presented in Appendix A. The summary of sample locations is presented in Appendix B. Sample location diagrams are provided in Appendix D. Laboratory analytical reports are included in Appendix E.

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Terracon can provide the Client with a proposal for developing asbestos abatement specifications (project design) and for performing abatement oversight, air monitoring, and air clearance testing upon request.

XRF Lead-Based Paint Screening Based on site observations, 12 XRF readings were taken from painted surfaces throughout the interior and exterior of the building on site. A summary of XRF readings is provided below:

n Building materials coated with LBP were not identified.

n The XRF LBP Screening results are included in Appendix C.

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1.0 INTRODUCTION

Terracon Consultants Inc. (Terracon) conducted an Asbestos Inspection and X-ray fluorescence (XRF) Lead-Based Paint (LBP) Screening at the Los Reales Landfill addressed 7161 South Craycroft Road, Tucson, Arizona. Specifically, the structure known as “The Barn” is slated for demolition. The inspection was conducted on January 19, 2023 by Asbestos Hazard Emergency Response Act (AHERA)-accredited asbestos building inspectors and an EPA certified lead paint inspector. This inspection was conducted in general accordance with Terracon Proposal No.

P63237003 dated January 18, 2023. We understand that this Asbestos Inspection and XRF LBP Screening was requested to assist with future demolition activities.

The asbestos portion of the inspection was performed to satisfy requirements of the EPA Regulation 40 CFR Part 61, Subpart M, NESHAP. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA 40 CFR Part 763 Subpart E, known as AHERA. Bulk asbestos samples were delivered to an accredited laboratory for analysis by PLM.

The XRF LBP Screening was performed to assist in compliance with OSHA requirements for lead-in-air content during disturbance of painted materials. The screening was performed in general accordance with the procedures prescribed in the EPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The LBP Screening was not designed to meet the requirements of HUD for LBP inspections. The lead paint inspection was conducted using a handheld XRF unit.

1.1 Reliance

This report is for the exclusive use City of Tucson (Client) for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and City of Tucson. Reliance on this report by City of Tucson and all authorized parties will be subject to the terms, conditions, and limitations as defined in the Agreement between the Client (City of Tucson) and Consultant (Terracon).

2.0 BUILDING DESCRIPTION

The site is developed with one approximate 28-foot by 80-foot metal structure known as “The Barn” within the Los Reales Landfill facility. The floor system of the building consists of poured concrete. The weight-bearing wall systems and roof are constructed of metal.

3.0 FIELD ACTIVITIES

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The asbestos inspection was conducted by Derek Sizemore, an AHERA-accredited asbestos building inspector. The XRF LBP Screening was conducted by Derek Sizemore, an EPA-certified LBP inspector. Copies of Mr. Sizemore’s certificate is provided in Appendix F. The inspection was conducted in general accordance with the sample collection protocols established in USEPA 40 CFR Part 763 Subpart E Section 763.86, AHERA. A summary of inspection activities is provided in this section.

3.1 Visual Assessment

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

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

3.2 Physical Assessment

Asbestos A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

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

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

3.3 Sample Collection

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

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

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

Terracon collected 9 bulk samples from 3 homogeneous areas of suspect ACM. A summary of the classification, condition and approximate quantity of identified ACM is presented in Appendix A.

The summary of sample locations is presented in Appendix B. Sample location diagrams are provided in Appendix D. Laboratory analytical reports for asbestos are included in Appendix E.

XRF LBP Screening An XRF portable lead paint analyzer was used to obtain direct readouts of lead content in coated surfaces in the proposed work areas.

The Heuresis Pb200i XRF utilizes a radioactive source, isotope Cobalt 57 (57Co), to assess the lead content of surface coatings. 57Co emits gamma rays that optically excite the K-shell electrons (causes the electrons to jump to a higher orbital) of atoms. An electron from a different orbital (e.g., L-shell or M-shell) relaxes (falls) to the inner K-shell, filling the vacancy and transforming its potential energy into electro-magnetic radiation of the x-ray spectrum. This quantum mechanical process is called induced x-ray fluorescence. The XRF’s internal instrumentation detects the x-rays that collide with its sensor and compares the x-ray’s energy to lead’s characteristic L-shell to K-shell transition energy.

3.4 Sample Analysis

Asbestos Bulk suspect ACM samples were submitted under chain of custody to Cates Laboratories of Dallas, Texas for analysis by polarized light microscopy with dispersion staining techniques per USEPA methodology 600/R-93/116. The percentage of asbestos in a sample, where applicable, was determined by microscopic visual estimation.

The EPA recognizes that PLM analysis of asbestos bulk samples can be inaccurate at low concentrations of asbestos (i.e., less than 10%). In Appendix E of 40 CFR 763, Subpart E (Interim Method of the Determination of Asbestos in Bulk Insulation Samples), the EPA codifies point counting as part of the asbestos analytical method. For samples reported with <2% asbestos by PLM visual estimation, the laboratory further analyzed the sampled by the point count method.

Lead Paint Based on observations, 12 XRF readings were taken from painted surfaces throughout the interior and exterior of the building on site. As Terracon did not identify paints considered LBP by EPA

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4.0 REGULATORY OVERVIEW

Asbestos The Asbestos NESHAP program in Arizona is enforced by federal, state, and county Asbestos NESHAP Coordinators. For projects occurring in Pima County, the County has been delegated authority from the EPA to enforce the Asbestos NESHAP within its respective jurisdictional boundaries, excluding tribal lands.

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

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

The NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos. Category II non-friable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels (exterior), glazing, mortar, and grouts.

The OSHA Asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained 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. States which administer their own federally approved state OSHA programs may require additional precautions.

Lead Paint

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

The Resource Conservation and Recovery Act (RCRA) gave the EPA authority to regulate the waste status of demolition or renovation debris, including Lead-Containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-Containing wastes are considered hazardous waste under RCRA if TCLP results exceed five milligrams per liter (mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

The US EPA has established an action level for LBP of 1.0 milligram per square centimeter (mg/cm2), 0.5% by weight or 5,000 parts per million (ppm). If a sample analytical result is equal to or greater than 1.0 mg/cm2, 0.5% by weight, or 5,000 ppm, the prepared surface is considered to be LBP.

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

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

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

Construction work covered by 29 CFR 1926.62 includes any repair or renovation activities or other activities that disturb in-place lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (mg/m³) averaged over an eight-hour period without adequate protection. The OSHA Standard also establishes an action level of 30 mg/m³ which, if exceeded, triggers the requirement for medical monitoring.

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

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

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5.0 FINDINGS AND RECOMMENDATIONS

Asbestos Findings Terracon collected 9 bulk samples from 3 homogeneous areas of suspect ACM throughout the building. The following asbestos containing materials were identified as a result of laboratory analysis or assumed to be asbestos containing:

HA No. Material Description Material Location NESHAP Classification1

Estimated Quantity*

3 Roof Penetrations Roof CAT I Non-Friable 50 Sq. Ft.

1Category I (CAT I) non-friable ACM *Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this inspection.

The listed Category I non-friable ACM that is damaged or could be damaged to the extent that it could be crumbled, pulverized or reduced to powder when dry, making it friable, must be removed prior to any activities (renovation and/or demolition) that may disturb this material in accordance with applicable federal, state and local regulations.

A summary of the classification, condition and approximate quantity of identified ACM is presented in Appendix A. The summary of sample locations is presented in Appendix B. Sample location diagrams are provided in Appendix D. Laboratory analytical reports are included in Appendix E.

Terracon can provide the Client with a proposal for developing asbestos abatement specifications (project design) and for performing abatement oversight, air monitoring, and air clearance testing upon request.

XRF Lead-Based Paint Screening Based on site observations, 12 XRF readings were taken from painted surfaces throughout the interior and exterior of the building on site. A summary of XRF readings is provided below:

n Building materials coated with LBP were not identified.

n The XRF LBP Screening results are included in Appendix C.

6.0 LIMITATIONS/GENERAL COMMENTS

Terracon did not perform sampling which required excessive demolition or destructive activities such as knocking holes in walls, dismantling of equipment or removal of protective coverings.

Reasonable efforts to access suspect materials within known areas of restricted access (e.g., crawl spaces) were made; however, confined spaces or areas which may pose a health or safety risk to Terracon personnel were not sampled. Sampling did not include suspect materials which could not be safely reached with available ladders/man-lifts.

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This Asbestos Inspection and XRF LBP Screening 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 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 City of Tucson 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.

A-1

APPENDIX A

7161 South Craycroft Road

Tucson, Pima County, Arizona Terracon Project No. 63237003

IDENTIFIED ASBESTOS CONTAINING MATERIALS BY HOMOGENEOUS AREA (HA)

HA No. Material Description Material Location % and Type Asbestos^ NESHAP Classification Condition Estimated

Quantity*

3 Roof Penetrations Roof 3% Chrysotile – Silver Paint 5% Chrysotile – Roofing Mastic CAT I Non-Friable Good 50 Sq. Ft.

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

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

The materials listed in this table have been sampled and determined to contain asbestos in concentrations greater than 1%. When disturbed, various federal, state and local regulations may apply. These materials should be monitored for damage over time and repaired as necessary by appropriately trained personnel. Removal may be necessary before renovations and in most cases before a demolition. See Appendix B for a summary of samples collected. See Appendix E for detailed analytical results.

B-1

Samples in shaded bold contain >1% asbestos

APPENDIX B

7161 South Craycroft Road

Tucson, Pima County, Arizona Terracon Project No. 63237003

ASBESTOS INSPECTION SAMPLE SUMMARY

HA

No. Material Description Sample

Number Sample Location Lab Results

1 Concrete Foundation 1-FC2-1 Interior None Detected - Concrete 1 Concrete Foundation 1-FC2-2 Interior None Detected - Concrete 1 Concrete Foundation 1-FC2-3 Interior None Detected - Concrete 2 Vent Sealant 2-SC5-4 Exterior None Detected - Black Sealant 2 Vent Sealant 2-SC5-5 Exterior None Detected - Black Sealant 2 Vent Sealant 2-SC5-6 Exterior None Detected - Black Sealant 3 Roof Penetrations 3-SC5-7 Roof None Detected - White Sealant 3 Roof Penetrations 3-SC5-7 Roof 3% Chrysotile - Silver Paint 3 Roof Penetrations 3-SC5-7 Roof 5% Chrysotile - Roofing Mastic 3 Roof Penetrations 3-SC5-8 Roof None Detected - White Sealant 3 Roof Penetrations 3-SC5-8 Roof 3% Chrysotile - Silver Paint 3 Roof Penetrations 3-SC5-8 Roof 5% Chrysotile - Roofing Mastic 3 Roof Penetrations 3-SC5-9 Roof None Detected - White Sealant 3 Roof Penetrations 3-SC5-9 Roof 3% Chrysotile - Silver Paint 3 Roof Penetrations 3-SC5-9 Roof 5% Chrysotile - Roofing Mastic

<LOD = Limit of Detection mg/cm2 = milligrams per square centimeter

C-1

APPENDIX C

7161 South Craycroft Road

Tucson, Pima County, Arizona Terracon Project No. 63237003

XRF LBP SCREENING SUMMARY

XRF

Reading No. Paint Description Location Condition Results (mg/cm2)

CAL 1 Pre-Calibration 1.0 CAL 2 Pre-Calibration 1.0 CAL 3 Pre-Calibration 1.0

1 Beige on Metal Vent Frame Exterior Intact 0.1 2 Beige on Metal Vent Exterior Intact 0.2 3 Beige on Metal Siding Exterior Intact <LOD 4 Beige on Metal Door Frame Exterior Intact 0.1 5 Beige on Metal Door Exterior Intact <LOD 6 Black on Metal Door Frame Interior Intact 0.1 7 Red on Metal Trusses Interior Intact 0.1 8 Red on Metal I-Breams Exterior Intact 0.2 9 Red on Metal Downspout Exterior Intact 0.1

10 Beige on I-beams Exterior Intact <LOD 11 Red on Metal Gutters Roof Intact 0.1 12 Beige on Metal Roof Roof Intact <LOD

CAL 4 Post- Calibration 1.0 CAL 5 Post- Calibration 0.9 CAL 6 Post- Calibration 1.0

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drsizemore Text Box

APPENDIX D

SAMPLING DIAGRAMS

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APPENDIX E

LABORATORY REPORTS AND CHAIN-OF CUSTODY

PLM REPORT SUMMARY

Cates Laboratories NVLAP Lab No. 200569-0

1339 Motor Circle TDSHS License No. 30-0287

Dallas, Texas 75207 (214) 920-5006

Client: Terracon Lab Job No.: PLM-32310

Project (Line 1): Los Reales Landfill Barn Set No.: 46523

Project (Line 2): 181 W. Broadway Boulevard Report Date: 1/25/2023

Project No: 63237003 Sample Date: 1/19/2023

Identification: Asbestos, Bulk Sample Analysis

Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 1 of 2

On 1/20/2023, nine (9) bulk samples were submitted by Mr. Derek Sizemore of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein. The results are summarized below:

Lab

Sample No.

Client

Field I.D.

Sample Description/Location Asbestos Content

These samples were analyzed by layers. The overall percent asbestos for the sample is reported when relevant. The EPA considers a material to be asbestos containing only if it contains greater than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing

Materials (RACM) – materials that are friable or may become friable – be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. CatesLab utilizes CVAE on a routine basis and does not include point counting unless specifically requested by the client. The results may not be reproduced except in full.

CL1115198

1-FC2-1

Concrete - Interior

None Detected

CL1115199

1-FC2-2

CL1115200

1-FC2-3

CL1115201

2-SC5-4

Vent Sealant - Exterior

CL1115202

2-SC5-5

CL1115203

2-SC5-6

CL1115204

3-SC5-7

Roof Penetrations - Roof

None Detected - White Sealant

3% Chrysotile - Silver Paint

5% Chrysotile - Roofing Mastic

CL1115205

3-SC5-8

CL1115206

3-SC5-9

PLM REPORT SUMMARY

Cates Laboratories NVLAP Lab No. 200569-0

Client: Terracon Lab Job No.: PLM-32310

Project (Line 1): Los Reales Landfill Barn Set No.: 46523

Project (Line 2): 181 W. Broadway Boulevard Report Date: 1/25/2023

Project No: 63237003 Sample Date: 1/19/2023

Identification: Asbestos, Bulk Sample Analysis

Test Method: Polarized Light Microscopy/Dispersion Staining (PLM/DS)

EPA Method 600/R-93/116 Page 2 of 2

On 1/20/2023, nine (9) bulk samples were submitted by Mr. Derek Sizemore of Terracon for asbestos analysis by PLM/DS.

Copies of the lab data sheets are attached; additional information may be found therein.

STATEMENT OF LABORATORY ACCREDITATION

The samples were analyzed in general accordance with the procedures outlined in the U.S. EPA Interim Method for the Determination of Asbestos in Bulk Insulation Samples as found in 40 CFR, Part 763, Subpart E, Appendix E (formerly Subpart F, Appendix A), or the current U.S. EPA method (EPA Method 600/R-93/116) for the analysis of asbestos in building materials, by polarized light microscopy. The results of each bulk sample relate only to the material tested and the results shall not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government.

Specific questions concerning bulk sample results shall be directed to the Laboratory Director.

Analyst:

Curtis Grigg

Laboratory Director: John R. Cates, P.G.

Approved Signatory:

TESTING

NVLAP LAB CODE 200569-0

Bulk Asbestos Analysis Sheet

Cates Laboratories EPA Method 600/R-93/116 NVLAP Lab No. 200569-0

Client: Terracon Lab Proj #: PLM-32310

Project (Line 1): Los Reales Landfill Barn Set #: 46523

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115198

Field ID #: 1-FC2-1 Page 1 of 1

Sample Description: Concrete - Interior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115198 kkkx Layer 1 Concrete Stereoscopic Examination 1 1115198 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Grey Cementitious Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Aggregate 60 Non-fibrous 1 1 Cement Binders 40 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected zzz

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115199

Field ID #: 1-FC2-2 Page 1 of 1

Sample Description: Concrete - Interior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115199 kx Layer 1 Concrete Stereoscopic Examination 1 1115199 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Grey Cementitious Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Aggregate 60 Non-fibrous 1 1 Cement Binders 40 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115200

Field ID #: 1-FC2-3 Page 1 of 1

Sample Description: Concrete - Interior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115200 kx Layer 1 Concrete Stereoscopic Examination 1 1115200 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Grey Cementitious Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Aggregate 60 Non-fibrous 1 1 Cement Binders 40 Non-fibrous 1 1

Prep/treatment: mechanical separation Asbestos Content: None Detected

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115201

Field ID #: 2-SC5-4 Page 1 of 1

Sample Description: Vent Sealant - Exterior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115201 kx Layer 1 Black Sealant Stereoscopic Examination 1 1115201 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Rubbery Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Paint 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115202

Field ID #: 2-SC5-5 Page 1 of 1

Sample Description: Vent Sealant - Exterior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115202 kx Layer 1 Black Sealant Stereoscopic Examination 1 1115202 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Rubbery Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Paint 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115203

Field ID #: 2-SC5-6 Page 1 of 1

Sample Description: Vent Sealant - Exterior

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115203 kx Layer 1 Black Sealant Stereoscopic Examination 1 1115203 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Rubbery Yes ND ND 100 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Paint 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115204

Field ID #: 3-SC5-7 Page 1 of 1

Sample Description: Roof Penetrations - Roof

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115204 kx Layer 1 White Sealant Stereoscopic Examination 1 1115204 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 10 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Silver Paint Stereoscopic Examination 2 1115204 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Silver Asphaltic Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 3 Silky / Wavy None 1.556 1.549 low Parallel + 2 1 Binders / Paint 97 Non-fibrous 2 1

Prep/treatment: heat / melt Asbestos Content: 3% Chrysotile

Layer 3 Roofing Mastic Stereoscopic Examination 3 1115204 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Asphaltic Yes ND ND 85 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 5 4 Silky / Wavy None 1.556 1.549 low Parallel + 3 1 Aggregate/Tar Binders 95 Non-fibrous 3 1

Prep/treatment: heat / melt Asbestos Content: 5% Chrysotile

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115205

Field ID #: 3-SC5-8 Page 1 of 1

Sample Description: Roof Penetrations - Roof

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115205 kx Layer 1 White Sealant Stereoscopic Examination 1 1115205 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 10 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Silver Paint Stereoscopic Examination 2 1115205 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Silver Asphaltic Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 3 Silky / Wavy None 1.556 1.549 low Parallel + 2 1 Binders / Paint 97 Non-fibrous 2 1

Prep/treatment: heat / melt Asbestos Content: 3% Chrysotile

Layer 3 Roofing Mastic Stereoscopic Examination 3 1115205 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Asphaltic Yes ND ND 85 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 5 4 Silky / Wavy None 1.556 1.549 low Parallel + 3 1 Aggregate/Tar Binders 95 Non-fibrous 3 1

Prep/treatment: heat / melt Asbestos Content: 5% Chrysotile

Project (Line 2): 181 W. Broadway Boulevard

Project #: 63237003 Sample #: CL1115206

Field ID #: 3-SC5-9 Page 1 of 1

Sample Description: Roof Penetrations - Roof

Comments: Analyst: Curtis Grigg Date Analyzed: 1/25/2023

Lab Job #: PLM-32310 Sample #: CL1115206 kx Layer 1 White Sealant Stereoscopic Examination 1 1115206 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 White Rubbery Yes ND ND 10 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Binders / Fillers 100 Non-fibrous 1 1

Prep/treatment: heat / melt Asbestos Content: None Detected

Layer 2 Silver Paint Stereoscopic Examination 2 1115206 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Silver Asphaltic Yes ND ND 5 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 3 Silky / Wavy None 1.556 1.549 low Parallel + 2 1 Binders / Paint 97 Non-fibrous 2 1

Prep/treatment: heat / melt Asbestos Content: 3% Chrysotile

Layer 3 Roofing Mastic Stereoscopic Examination 3 1115206 Color Texture Homogeneous? % Fibrous % Asbestos % of Sample -1 Black Asphaltic Yes ND ND 85 PLM Examination:

Color/ Parallel Perpendicular Extinction Sign of Components % +/- Morphology Pleochroism Ref. Index Ref. Index Biref Angle Elongation Chrysotile 5 4 Silky / Wavy None 1.556 1.549 low Parallel + 3 1 Aggregate/Tar Binders 95 Non-fibrous 3 1

Prep/treatment: heat / melt Asbestos Content: 5% Chrysotile

APPENDIX F

LICENSES AND CERTIFICATIONS

Derek Sizemore

July 05, 2022

ON-4644-14173-070522

5-Jul-2022

05-Jul-2023

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