At05_ACMSurvey.pdf

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GAOA VALE DISTRICT OFFICE BUILDING RENOVATIONS D-B
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This is an Asbestos-Containing Material (ACM) Survey and Abatement Cost Estimate report for BLM Task Order 164 under BPA L14PB00728 for the Vale District Office in Oregon. The survey was conducted on April 6, 2015, and the report was issued July 1, 2015, by Tetra Tech on behalf of Aarcher, Inc.

The survey identified one asbestos-containing material in the building: brown pebble pattern vinyl sheet flooring with associated mastic located in Rooms 107 and 115, containing 20% chrysotile asbestos in good condition. The material covers approximately 450 square feet. Forty-three bulk asbestos samples were collected and analyzed by Reservoirs Environmental, Inc. laboratory using Polarized Light Microscopy (PLM) according to EPA method 600/R-93/116. Of the 76 individual layers analyzed, only the vinyl sheet flooring and mastic tested positive for asbestos (greater than 1% by volume). All other sampled materials, including roofing, ceramic tile, drywall, ceiling panels, building insulation, and various mastics, tested as non-asbestos. The abatement cost estimate for the identified ACM is $3,600.00, subject to specified assumptions including free access to work areas, one mobilization, availability of power and water, and no special regulatory conditions. The report includes laboratory analytical results, site drawings showing sample collection locations, inspector and laboratory accreditations, and photographs of identified ACM.

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ASBESTOS-CONTAINING MATERIAL (ACM) SURVEY AND

ABATEMENT COST ESTIMATE

BLM Task Order 164, BPA L14PB00728 (NAB060001 Legacy Number)

L1440784 – Vale District Office

43.98692 / -117.23875

Vale District Office, Oregon

Report Date July 1, 2015 Site Survey Date April 6, 2015 ACM Identified in Building?* Yes ACM Abatement Cost Estimate* $3,600.00 *Subject to the assumptions and limitations as described in the following report.

Submitted by:

Aarcher, Inc.

2635 Riva Road, Suite 100 Annapolis, Maryland 21401 410-897-9100 Program Manager: Craig J. Schwartz

Submitted to:

U.S. Department of the Interior Bureau of Land Management (BLM) Building 50, Denver Federal Center Denver, Colorado 80225-0047 Attn: Krista Doebbler

Tetra Tech 618 South 25th Street, Billings, Montana 59101

Tel 406.248.9161 Fax 406.248.9282 www.tetratech.com

July 1, 2015

Aarcher, Inc.

Craig J. Schwartz, CHMM, CPEA President 2635 Riva Road, Suite 100 Annapolis, Maryland 21401

RE: Asbestos-Containing Materials Survey and Asbestos Abatement Cost Estimates L1440784 – Vale District Office Vale District Office, Oregon Tetra Tech Project Number 114-551646, Task 100

Dear Mr. Schwartz:

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

Tetra Tech appreciates the opportunity to perform these services for Aarcher, Inc. (AARCHER) and we look forward to working with you in the future. If you have questions or comments regarding the information in this report or if we can be of further assistance please do not hesitate to contact the Tetra Tech Billings, Montana office at (406) 248-9161.

Sincerely, Tetra Tech

Daniel Lawrence Roger W. Herman, Jr.

AHERA Accredited Building Inspector/ AHERA Accredited Building Inspector/ Management Project Designer/ Contractor Supervisor Planner/ Project Designer/ Contractor Supervisor

Contract Number L14PB00728 – Call 164

L1440784 – Vale District Office Vale District Office, Oregon i

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE OF SERVICES

2.0 GENERAL SITE CONDITIONS

3.0 REGULATORY STANDARDS

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES

4.1 Homogeneous Materials

4.2 Hazard Assessment Factors

4.3 Sampling Strategy

4.4 Suspect Asbestos-Containing Material

4.5 Laboratory Analytical Results

5.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES SUMMARY TABLE

6.0 CONCLUSIONS

7.0 ASSUMPTIONS AND LIMITATIONS

LIST OF APPENDICES

Appendix A: ACM Laboratory Analytical Results Appendix B: Site Drawing Appendix C: Inspector and Laboratory Accreditations Appendix D: ACM Photographs

1.0 PURPOSE AND SCOPE OF SERVICES

The purpose of this project was to conduct an Asbestos-Containing Materials (ACM) survey and provide Asbestos Abatement Cost Estimates for identified ACM located in the L1440784 – Vale District Office located at the Vale District Office, Oregon. Tetra Tech provided services as outlined below:

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

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

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

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

Hazard Emergency Response Act (AHERA) protocols;

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

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

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

2.0 GENERAL SITE CONDITIONS

The building is a one story wood framed structure, building situated on a slab-on-grade foundation and covered by an asphalt roof. The building contains a Forced Air heating system located in the attic and on the building exterior. The building was reportedly constructed in 1962, and is approximately 16,320 gross square feet. Interior finishes include carpet and vinyl sheet flooring.

The exterior finish consists of wood siding.

3.0 REGULATORY STANDARDS

The survey for asbestos-containing materials (ACM) was conducted using the protocol developed for schools under the Asbestos Hazard Emergency Response Act (AHERA), as promulgated in Title 40, Code of Federal Regulations, Part 763 (40 CFR, Part 763).354. Classification of the asbestos-containing material was performed under the guidelines of the National Emission Standards for Hazardous Air Pollutants (NESHAP). The work was also performed in general accordance with the AARCHER Subcontract Number 020004-S-TT, dated October 8, 2014 and Task Order 020004-S-TT-05, dated October 8, 2014. Tetra Tech field personnel were accredited AHERA Asbestos Building Inspectors at the time of the inspection.

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS

ABATEMENT COST ESTIMATES

Tetra Tech representative Mr. Dan Lawrence conducted the asbestos survey of the building on April 6, 2015. Mr. Lawrence is an AHERA accredited Building Inspector, Project Designer and Supervisor. All field work was performed by and/or under the guidance of Mr. Dan Lawrence.

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

Previous ACM survey reports for the building were not made available for review by Tetra Tech prior to completion of the building inspection.

The building was visually inspected for the presence of building materials suspected to contain asbestos. Bulk samples of identified suspect ACMs were collected and placed into individual containers for transport to a National Voluntary Laboratory Accreditation Program (NVLAP)/American Industrial Hygiene Association (AIHA)-accredited laboratory for analysis.

Materials visibly identified as non-asbestos (fibrous glass, foam rubber, wood, metal, and other non-suspect materials) were not sampled. The asbestos survey consisted of three basic procedures: 1) conducting a visual inspection of the structure and identifying functional spaces;

2) identifying homogeneous material areas of suspect surfacing, thermal system insulation, and miscellaneous materials; and 3) sampling accessible, friable and non-friable suspect materials.

4.1 Homogeneous Materials

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

4.2 Hazard Assessment Factors

From the list of suspect homogeneous materials, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, assessing the potential for disturbance, and determining the friability of each material. Friability is a term used to describe the ease in which a building material inherently lends itself to disturbance. By definition, "friable" materials are those that can be crumbled or reduced to powder by hand pressure when dry. Friable material may or may not contain asbestos. Each material on the list was further classified into one of three categories, which have specific sampling requirements for each category.

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

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

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

All suspected ACMs were then assessed by their condition as good (no visible damage or showing only very limited damage or deterioration), damaged (less than 25% localized damage or 10% distributed damage), or significantly damaged (25% or greater localized damage or 10% or greater distributed damage) per Title 40 Code of Federal Regulations Part 63. ACM in good condition, whether friable or not, does not release fibers to the air and does not pose a health hazard.

4.3 Sampling Strategy

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

If the analytical results indicated that all the samples collected per homogenous material did not contain asbestos, then the homogenous material was considered a non-ACM. However, if the analytical results of one or more of the samples collected per homogenous material indicated that asbestos was present in quantities of greater than one percent (1%) asbestos by weight (as defined by EPA), all of the homogenous material was treated as an ACM regardless of any other analytical results. Material which was visually determined to be non-asbestos (i.e., fibrous glass, foam rubber, metal, etc.) by the accredited inspector was not required to be sampled.

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

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

4.4 Suspect Asbestos-Containing Material

Forty-three (43) bulk asbestos samples were collected from the building, with a total of 76 individual layers analyzed by Polarized Light Microscopy (PLM). The number of layers analyzed was based on the number of distinct materials associated with each bulk sample. For example, floor tile and associated mastic are collected as one bulk sample, but are analyzed as two distinct materials by the asbestos laboratory, as required by NVLAP.

4.5 Laboratory Analytical Results

Bulk samples were analyzed by Reservoirs Environmental, Inc. analytical laboratory located in Denver, Colorado, using PLM according to EPA method 600/R-93/116. This laboratory participates in the NVLAP, a quality assurance program for PLM.

Any material that contains greater than 1 percent (>1%) asbestos by PLM is considered an ACM and must be handled according to OSHA, EPA, and applicable state and local regulations.

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

For friable materials, when the amount of asbestos in the sample material is reported as “None- Detected” by PLM analysis, no further verification of the sample results by Point Counting Methodology is recommended.

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

For non-friable materials such as vinyl/asphaltic products (floor tiles/floor sheeting, mastics, shingles, etc.), where small, thin asbestos fibers may have been potentially milled into the nonorganic binder matrix, when the amount of asbestos in the sample material is reported as “None-Detected” by PLM analysis, due to the difficulty in analyzing such small, thin asbestos fibers in resinously bound materials by PLM analysis, EPA recommends but does not require that these types of materials, which were reported as non-ACMs by PLM, be further analyzed using TEM Chatfield Method. Tetra Tech did not conduct such analysis.

The results of the laboratory analysis are summarized in tabular form in Section 5.0. The laboratory analytical report and corresponding chain-of-custody documents are included in Appendix A. Sample concentrations are reported in percent asbestos by volume and indicate the types of asbestos. Other common non-asbestos components may also be noted on the analytical reports. Site drawing(s) depicting approximate bulk sample locations is provided in Appendix B.

Inspector and laboratory accreditations are provided in Appendix C, and Appendix D presents a photographic log of all ACM’s identified in the building (if present).

5.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES SUMMARY TABLE

ACM Bulk Sampling Results

L1440784 – Vale District Office

Vale District Office, Oregon

H o m o g e n e o u s M a te ri a l

L o c a ti o n o f M a te ri a l

A s b e s to s C o n te n t

C o n d iti o n o f M a te ri a l

F ri a b le in

C u rr e n t

C o n d iti o n a

P o te n tia l to

B e c o m e F ri a b le b

H e a lt h

R is k Id e n tif ie d a t ti m e o f S u rv e y c

A p p ro xi m a te

M a te ri a l Q u a n ti ty

M a te ri a l C a te g o ry

R e q u ir e d

N u m b e r o f

S a m p le s to b e

C o lle c te d

N u m b e r o f

S a m p le s

C o lle c te d

S a m p le N u m b e rs

A C

M A b a te m e n t C o s t

E st im a te d

Vinyl Sheet Flooring – Brown Pebble Pattern & Associated Mastic

Room 107,115

20% Chrysotile

G No No No 450 SF M N/A 3 784-F1.2A, B, C $3.600.00

AHERA / NESHAP Guidelines for Determining the Number of Samples to Collect on Federal facility

ND = None Detected N/A = Not Applicable

MATERIAL CATEGORY:

M = Miscellaneous Material

SM = Surfacing Material

TSI = Thermal System Insulation

APPROXIMATE MATERIAL QUANTITIES:

SF = Square Feet

LF = Linear Feet

Ea = Each

CONDITION:

G = Good

D = Damaged

SD = Significantly Damaged

Homogeneous Material Category

Homogeneous Material Quantity

Number of Samples Required

Surfacing Materials

<1000 SF 3

1000 - 5000 SF 5

>5000 SF 7 or more

Thermal System Insulation No Stipulation 3 (Must also sample all repair patches)

Miscellaneous Materials No Stipulation

Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos."

a. Friable” means any material that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Friable material may or may not contain asbestos. Friable ACM does not pose a health risk unless it is damaged or disturbed (either ACM or non-ACM).

b. When non-friable ACM or friable ACM in good condition is subjected to mechanical forces, such as those encountered during demolition, renovation, or building maintenance, it can be crumbled, pulverized, or reduced to powder, and thereby release asbestos fibers. The nature and extent of any special work practices for custodial, maintenance, and construction staff should reflect the likelihood that the ACM will be disturbed and that fibers will be released. Maintenance activities can be divided into three categories with regard to their potential for disturbing ACM: (1) Those which are unlikely to involve any direct disturbance of ACM; for example, cleaning shelves or counter tops with a damp cloth;

(2)Those which may cause accidental disturbance of ACM; for example, working on a fixture near a ceiling with surfacing ACM; and (3) Those which involve intentional small-scale manipulation or disturbance of ACM; for example, removing a small segment of thermal system insulation (TSI) ACM to repair a pipe leak.

c. Health risks associated with ACM in buildings are based on whether the materials are capable of releasing fibers to the air. ACM, whether friable or non-friable, do not pose a health hazard if it is in good condition and not damaged or disturbed. Proper asbestos management practices should be used during the demolition, renovation, or building maintenance of any materials that contains non-friable ACM or friable ACM in good condition.

d. These materials were determined to be less than 1% asbestos as a composite; and therefore would not require to be disposed of as asbestos waste. Specific abatement recommendations and procedures would be dependent upon the scope of the activities anticipated to disturb these materials, and should be determined on a case-by-case basis.

Materials Tested and Determined Not to be ACM

Bulk Sampling Results

L1440784 – Vale District Office

Vale District Office, Oregon H o m o g e n e o u s M a te ri a l

L o c a ti o n o f M a te ri a l

A s b e s to s C o n te n t

C o n d iti o n o f M a te ri a l

A p p ro xi m a te

M a te ri a l Q u a n ti ty

M a te ri a l C a te g o ry

R e q u ir e d

N u m b e r o f

S a m p le s to b e

C o lle c te d

N u m b e r o f

S a m p le s

C o lle c te d

S a m p le N u m b e rs

Roofing Material Roof of structure ND G 16,320 SF M N/A 3 784-M1.1A, B, C

Ceramic Tile – Brown Circle Pattern

Room 101 ND D 75 SF M N/A 3 784-F1.1A, B, C

Mastic Associated with White 4” Cove Base

Room 110 ND G 8 SF M N/A 3 784-M12.1A, B, C

Mastic Associated with Gray 4” Cove Base

Room 107,115 ND G 45 SF M N/A 3 784-M12.2A, B, C

Tan Vinyl Sheet Flooring & Associated Mastic

Room 108,109,118,119

ND G 140 SF M N/A 3 784-F1.3A, B, C

Mastic Associated with Gray 4” Cove Base

Room 101,115 ND G 6 SF M N/A 3 784-M12.3A, B, C

Drywall/ Joint Compound/ Orange Peel Texture

Walls throughout structure

ND G 13,760 SF SM 7 7

784-S3.1A, B, C, D, E, F, G

White Vinyl Sheet Flooring & Associated Mastic

Room 115 ND G 290 SF M N/A 3 784-F1.4A, B, C

White Sink Undercoating Room 115 ND G 2 SF M N/A 3 784-M10.1A, B, C

Drywall/ Joint Compound/ Light Orange Peel Texture

Room 102 ND G 400 SF SM 3 3 784-S3.1A, B, C

Ceiling Panels with Pinholes & Fissures

Ceiling throughout structure

ND G 16,320 SF M N/A 3 784-M5.1A, B, C

Building Insulation Throughout Attic ND G 16,320 SF M N/A 3 784-M15.1A, B, C

Materials Tested and Determined Not to be ACM

Bulk Sampling Results

L1440784 – Vale District Office

Vale District Office, Oregon H o m o g e n e o u s M a te ri a l

L o c a ti o n o f M a te ri a l

A s b e s to s C o n te n t

C o n d iti o n o f M a te ri a l

A p p ro xi m a te

M a te ri a l Q u a n ti ty

M a te ri a l C a te g o ry

R e q u ir e d

N u m b e r o f

S a m p le s to b e

C o lle c te d

N u m b e r o f

S a m p le s

C o lle c te d

S a m p le N u m b e rs

AHERA / NESHAP Guidelines for Determining the Number of Samples to Collect on Federal Facility ND = None Detected

N/A = Not Applicable

MATERIAL CATEGORY:

M = Miscellaneous Material

SM = Surfacing Material

TSI = Thermal System Insulation

APPROXIMATE MATERIAL QUANTITIES:

SF = Square Feet

LF = Linear Feet

Ea = Each

CONDITION:

G = Good

D = Damaged

SD = Significantly Damaged

Homogeneous Material Category Homogeneous

Material Quantity

Number of Samples Required

Surfacing Materials

<1000 SF 3

1000 - 5000

SF

>5000 SF 7 or more

Thermal System Insulation No Stipulation 3 (Must also sample all repair patches)

Miscellaneous Materials No Stipulation

Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos."

6.0 CONCLUSIONS

The results of the asbestos survey conducted at the L1440784 – Vale District Office, Vale District Office, Oregon building indicate that: one (1) of the accessible suspect building materials sampled were found to contain more than 1% asbestos.

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

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

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

7.0 ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during Tetra Tech’s inspection of the L1440784 – Vale District Office structure located at the Vale District Office, Oregon.

The selection of sample locations and frequency of sampling was based on Tetra Tech’s observations and the assumption that like materials in the same area are homogeneous in content. Limited destructive investigation was conducted as needed to facilitate this inspection;

however concealed ACMs may exist in concealed areas not investigated or identified during this inspection.

This report is designed to aid the client in understanding the extent of ACM as they pertain to the “Recognition and Measurement of Asbestos-Related Cleanup Costs,” Technical Bulletin 2006-1, prepared by the Federal Accounting Standards Advisory Board, dated September 28, 2006 and to the renovation/demolition areas of the facility building areas. It should be noted that this report is not a complete Asbestos Abatement Specification or Work Plan.

Our professional services have been performed, our findings obtained, and our conclusions prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied.

This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated during this inspection.

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

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

Assumes one mobilization to complete the abatement of one ACM.

Assumes both power and water at no cost to contractor.

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

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

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

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

Work hours 7:00 AM to 5:00 PM Monday through Friday.

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

No delays interfering with the diligent execution of the work beyond the contractor’s control will be encountered.

APPENDIX A

ACM LABORATORY ANALYTICAL RESULTS

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015

T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

Subcontract Number: NA

Laboratory Report: RES 317514-1

Project # / P.O. # 114-551646.100

Project Description: BLM Vale Bldg L1440784

RES 317514-1

Sincerely, April 22, 2015

Dear Customer, Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and Environmental matrices by the National Voluntary Laboratory Accreditation Program (NVLAP), Lab Code 101896-0 for Transmission Electron Microscopy (TEM) and Polarized Light Microscopy (PLM) analysis and the American Industrial Hygiene Association (AIHA), Lab ID 101533 - Accreditation Certificate #480 for Phase Contrast Microscopy (PCM) analysis. This laboratory is currently proficient in both Proficiency Testing and PAT programs respectively.

Reservoirs Environmental, Inc. has analyzed the following samples for asbestos content as per your request. The analysis has been completed in general accordance with the appropriate methodology as stated in the attached analysis table. The results have been submitted to your office.

Tetra Tech, Inc. (Billings, MT) 618 S. 25th Street Billings MT 59101

Dan Lawrence is the job number assigned to this study. This report is considered highly confidential and the sole property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with personnel other than those of the client. The results described in this report only apply to the samples analyzed.

This report must not be used to claim endorsement of products or analytical results by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without written approval from Reservoirs Environmental, Inc. Samples will be disposed of after sixty days unless longer storage is requested. If you have any questions about this report, please feel free to call 303-964-1986.

Jeanne Spencer

President

P: 303-964-1986

F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

1-866-RESI-ENV

www.reilab.com

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 5A Black tar EM 1386627784-M1.1A 0 100

ND 95B Black/multi-colored shingle 15 85

ND 2A Black tar EM 1386628784-M1.1B 0 100

ND 98B Black/multi-colored shingle 15 85

ND 2A Black tar EM 1386629784-M1.1C 0 100

ND 98B Black/multi-colored shingle 15 85

ND 5A Gray resinous material EM 1386630784-F1.1A 0 100

ND 95B Brown ceramic tile 0 100

ND 10A Gray resinous material EM 1386631784-F1.1B 0 100

ND 90B Brown ceramic tile 0 100

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

5801 Logan Street, Suite 100, Denver, CO 80216

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 5A Gray granular cementitious material EM 1386632784-F1.1C 0 100

ND 10B Gray resinous material 0 100

ND 85C Brown ceramic tile 0 100

ND 100A Off white mastic EM 1386633784-M12.1A 0 100

ND 100A Off white mastic EM 1386634784-M12.1B 0 100

ND 100A Off white mastic EM 1386635784-M12.1C 0 100

ND 100A Tan mastic EM 1386636784-M12.2A 0 100

ND 100A Tan mastic EM 1386637784-M12.2B 0 100

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 100A Tan mastic EM 1386638784-M12.2C 0 100

ND TRA Tan mastic EM 1386639784-F1.2A 0 100

20 Chrysotile100B Brown sheet vinyl w/ gray fibrous backing material 5 75

ND TRA Tan mastic EM 1386640784-F1.2B 0 100

20 Chrysotile100B Brown sheet vinyl w/ gray fibrous backing material 5 75

ND 1A Tan mastic EM 1386641784-F1.2C 0 100

20 Chrysotile99B Brown sheet vinyl w/ gray fibrous backing material 5 75

ND 5A Tan mastic EM 1386642784-F1.3A 0 100

ND 95B Tan sheet vinyl 0 100

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 10A Tan mastic EM 1386643784-F1.3B 0 100

ND 90B Tan sheet vinyl 0 100

ND 5A Tan mastic EM 1386644784-F1.3C 0 100

ND 95B Tan sheet vinyl 0 100

ND 100A Brown mastic EM 1386645784-M12.3A 0 100

ND 100A Brown mastic EM 1386646784-M12.3B 0 100

ND 100A Brown mastic EM 1386647784-M12.3C 0 100

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 5A White texture w/ white paint EM 1386648784-S3.1A 0 100

ND 5B White texture w/ white paint 0 100

ND 90C White/tan drywall 15 85

ND 5A White texture w/ white/multi-layered paint EM 1386649784-S3.1B 0 100

ND 95B White/tan drywall 15 85

ND 5A White texture w/ white paint EM 1386650784-S3.1C 0 100

ND 5B White tape 90 10

ND 5C White joint compound 0 100

ND 85D White/tan drywall 15 85

ND 10A White texture w/ white/multi-layered paint EM 1386651784-S3.1D 0 100

ND 90B White/tan drywall 15 85

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 5A White texture w/ white/multi-colored paint EM 1386652784-S3.1E 0 100

ND 95B White/tan drywall 15 85

ND 20A White texture w/ white multi-layered paint EM 1386653784-S3.1F 0 100

ND 80B White/tan drywall 15 85

ND 10A White texture w/ white paint EM 1386654784-S3.1G 0 100

ND 90B White/tan drywall 15 85

ND 2A Colorless adhesive EM 1386655784-F1.4A 0 100

ND 98B Gray sheet vinyl w/ gray fibrous backing material 20 80

ND 2A Colorless adhesive EM 1386656784-F1.4B 0 100

ND 98B Gray sheet vinyl w/ gray fibrous backing material 20 80

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND TRA Colorless adhesive EM 1386657784-F1.4C 0 100

ND 100B Gray sheet vinyl w/ gray fibrous backing material 20 80

ND 100A White fibrous resinous material EM 1386658784-M10.1A 70 30

ND 100A White fibrous resinous material EM 1386659784-M10.1B 70 30

ND 100A White fibrous resinous material EM 1386660784-M10.1C 70 30

ND 5A White texture w/ white paint EM 1386661784-S3.2A 0 100

ND 5B White tape 90 10

ND 5C White joint compound 0 100

ND 85D White/tan drywall 15 85

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 20A White texture w/ white paint EM 1386662784-S3.2B 0 100

ND 80B White/tan drywall 15 85

ND 5A White texture w/ white paint EM 1386663784-S3.2C 0 100

ND 5B White tape 90 10

ND 5C White joint compound 0 100

ND 85D White/tan drywall 15 85

ND 100A Gray/white ceiling tile EM 1386664784-M5.1A 60 40

ND 100A Gray/white ceiling tile EM 1386665784-M5.1B 60 40

ND 100A Gray/white ceiling tile EM 1386666784-M5.1C 60 40

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 317514-1

Tetra Tech, Inc. (Billings, MT)

114-551646.100

BLM Vale Bldg L1440784

April 15, 2015

3-5 Day

April 22, 2015

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective January 1, 2015 Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client Sample Number

Lab ID Number

L A Y E R

Mineral

Method: EPA 600/R-93/116 - Short Report, Bulk

Physical Description

Sub Part

Visual Estimate (%)

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite

Non Asbestos Fibrous

Components

Non- Fibrous

Components

Asbestos Content

ND 100A Gray insulation EM 1386667784-M15.1A 90 10

ND 100A Gray insulation EM 1386668784-M15.1B 90 10

ND 100A Gray insulation EM 1386669784-M15.1C 90 10

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Analyst / Data QAAnalystAnalystAnalystAnalyst

P: 303-964-1986 F: 303-477-4275

1-866-RESI-ENV

www.reilab.com

APPENDIX B

SITE DRAWING

784-F1.1A

784-F1.1C

784-F1.1B

784-F1.2A

784-F1.2C

784-F1.2B

784-F1.3A

784-F1.3B

784-F1.3C

784-F1.4A

784-F1.4B

784-F1.4C

784-M1.1A

784-M1.1B

784-M1.1C

784-M5.1A

784-M5.1B

784-M5.1C

784-M10.1A, B, C

784-M12.1A, B, C

784-M12.2A

784-M12.2B

784-M12.2C

784-M12.3A

784-M12.3B, C

784-M15.1A

784-M15.1B

784-M15.1C

784-S3.1A

784-S3.1B

784-S3.1C

784-S3.1D

784-S3.1E

784-S3.1F

784-S3.1G

784-S3.2A

784-S3.2B

784-S3.2C

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

06/21/2015 DLL

1" = 25'

1114-551646

RH

Asbestos Survey

Vale District Office - Bldg L1440784

Vale District Office

Vale, Oregon

Sample Collection Locations

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

06/21/2015 DLL

1" = 25'

2114-551646

RH

Asbestos Survey

Vale District Office - Bldg L1440784

Vale District Office

Vale, Oregon

ACM Locations

APPENDIX C

INSPECTOR AND LABORATORY ACCREDITATIONS

AIHA Laboratory Accreditation Programs, LLC acknowledges that

Reservoirs Environmental, Inc.

Laboratory ID: 101533 along with all premises from which key activities are performed, as listed above, has fulfilled the requirements of the AIHA Laboratory Accreditation Programs (AIHA-LAP), LLC accreditation to the ISO/IEC 17025:2005 international standard, General Requirements for the Competence of Testing and Calibration Laboratories in the following:

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE Accreditation Expires: 02/01/2017 ENVIRONMENTAL LEAD Accreditation Expires: 02/01/2017 ENVIRONMENTAL MICROBIOLOGY Accreditation Expires: 02/01/2017 FOOD Accreditation Expires: 02/01/2017 UNIQUE SCOPES Accreditation Expires:

Specific Field(s) of Testing (FoT)/Method(s) within each Accreditation Program for which the above named laboratory maintains accreditation is outlined on the attached Scope of Accreditation. Continued accreditation is contingent upon successful on-going compliance with ISO/IEC 17025:2005 and AIHA-LAP, LLC requirements. This certificate is not valid without the attached Scope of Accreditation. Please review the AIHA- LAP, LLC website (www.aihaaccreditedlabs.org) for the most current Scope.

Gerald Schultz, CIH Chairperson, Analytical Accreditation Board

Cheryl O. Morton Managing Director, AIHA Laboratory Accreditation Programs, LLC

Revision 14: 03/26/2014 Date Issued: 03/31/2015 http://www.aihaaccreditedlabs.org/

APPENDIX D

ACM PHOTOGRAPHS

Site & ACM Photographs L1440784 – Vale District Office

Vale District Office - Oregon

Photograph 1 – ACM Vinyl Sheet Flooring & Associated Mastic

File details come from the government source that posted it. Updated .