Attachment 14 - Asbestos Report.pdf

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521-23-121 | Renovate SPS Phase 2 Federal contract opportunity
Solicitation number
36C24726R0011
Issued by
Department of Veterans Affairs Veterans Health Administration Veterans Integrated Service Network 7

About this file

This document is a NESHAP (National Emission Standards for Hazardous Air Pollutants) Pre-Renovation Asbestos Survey report prepared by AEI Consultants for Davenergy Solutions regarding the Bermingham VA Health Care System in Birmingham, Alabama. The survey, conducted on October 8, 2024, comprehensively examined two mechanical rooms, associated crawl spaces, and roof areas for potential asbestos-containing materials. The investigation involved collecting and analyzing 41 bulk samples across various building materials, including vinyl floor tiles, wall grout, ceramic floor tiles, pipe insulation, concrete, drywall, and roofing materials.

The laboratory analysis, performed by Eurofins EPK Built Environment Testing, found no asbestos-containing materials in any of the samples. The report provides detailed recommendations, including the need to survey any additional areas not covered in this initial inspection, sample any newly discovered suspect materials during renovation, and conduct further investigations under carpeting or floor coverings. The survey was performed by Charles Yoon, an Alabama-certified asbestos inspector, following EPA and NESHAP guidelines, with the goal of identifying potential asbestos hazards prior to planned renovation activities at the medical facility.

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AEI Consultants

1.800.801.3224 www.aeiconsultants.com

NESHAP Pre-Renovation Asbestos Survey REPORT DATE: October 11, 2024

PROPERTY INFORMATION

Bermingham VA Health Care System (Mechanical Rooms) 700 South 19th Street Birmingham, Jefferson County, Alabama 35233

PROJECT INFORMATION

AEI Project No. 500172 Site Assessment Date: October 8, 2024

PREPARED FOR

Davenergy Solutions 4801 Glenwood Avenue, Suite 200 Raleigh, North Carolina 27612

PREPARED BY

AEI Consultants – Atlanta Office 4255 Wade Green Road, Suite 510 Kennesaw, GA 30144

October 11, 2024

Mr. Alexander Boucher Vice President of Operations 4801 Glenwood Avenue, Suite 200 Raleigh, North Carolina 27612

Subject: NESHAP Pre-Renovation Asbestos Survey

Dear Mr. Boucher, AEI Consultants (AEI) is pleased to provide the NESHAP Pre-Renovation Asbestos Survey of the above referenced property. This assessment was authorized and performed in accordance with the scope of services engaged.

We appreciate the opportunity to provide services to you. If you have any questions concerning this report, or if we can assist you in any other matter, please contact me at (424) 421-7237 or mwasson@aeiconsultants.com.

Sincerely, Matthew E. Wasson Vice President, Building Assessment Email: mwasson@aeiconsultants.com mailto:mwasson@aeiconsultants.com mailto:cyoon@aeiconsultants.com

Project No. 500172 Report Date October 11, 2024 Page iii

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Scope of Work

1.2 Site Specific Survey Limitations

1.3 NESHAP Regulations and Guidelines

2.0 SITE DESCRIPTION

3.0 METHODOLOGY

3.1 Material Sampling or Investigation

3.1.1 Asbestos Sampling Procedures

3.2 Analytical Methods

3.2.1 Asbestos Analysis

4.0 4.0 SAMPLING AND ANALYSIS

5.0 SUMMARY AND RECOMMENDATIONS

5.1 Summary of Findings

5.2 Recommendations

6.0 REPORT RELIANCE

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

TABLES

Table 1 Homogeneous Application Summary

APPENDICES

Appendix A Inspector Certifications Appendix B Photographic Log Appendix C Laboratory Certifications Appendix D Laboratory Analytical Reports

1.0 INTRODUCTION

This report documents the methods and findings of the NESHAP Pre-Renovation Asbestos Survey for the Bermingham VA Health Care System (Mechanical Rooms), located at 700 South 19th Street in Birmingham, Alabama.

1.1 Scope of Work

The purpose of the survey was to locate, identify, sample, and assess the condition of building materials suspected of containing greater than one percent (>1%) asbestos.

The survey was performed on October 8, 2024 by Charles Yoon, of AEI, an Alabama certified asbestos inspector (Certificate No. AIN1222B1CE4008, Expiration Date: November 14, 2025).

Inspector Certifications are provided as Appendix A to this report. The asbestos inspection was performed in conformance with modified protocols set forth by the Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA), and the National Emission Standards for Hazardous Air Pollutants (NESHAP) and in accordance with state regulations.

1.2 Site Specific Survey Limitations

The data presented and the opinions expressed in this report are qualified as follows:

• The sole purpose of the investigation and of this report was to assess the Site with respect to asbestos materials as defined in AEI’s Scope of Work and the applicable State, Federal and local environmental laws and regulations.

• The Scope of Services was defined by the requests of the Client, the time and budgetary constraints imposed by the Client, and the availability of access to the Site.

• The collection of bulk building material samples for analysis is a destructive procedure and may cause damage to the integrity of building systems. AEI took normal precautions to minimize damage, however, AEI will not be held responsible for damage to the building systems as a result of sample collection.

1.3 NESHAP Regulations and Guidelines

The Code of Federal Regulations (CFR), 40 CFR 61, Subpart M, NESHAP, classifies asbestos-containing material (ACM) as any material or product that contains greater than one percent (>1%) asbestos. As ACM is identified, it is classified as either friable or non-friable.

Friable materials are more hazardous than non-friable materials since they are more likely to release fibers into the air. Friable is defined as any ACM that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACM is classified as either Category 1 or Category 2 material as follows:

• Category 1 – Asbestos containing packings, gaskets, resilient floor coverings (including associated floor mastic) and asphalt roofing products; and

• Category 2 – All remaining types of non-friable asbestos containing material not included in Category 1 that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated asbestos containing materials (RACM), a hazardous waste when friable, is classified as any manufactured material that contains greater than one percent (>1%) asbestos and is:

1. Friable – The material can be crumbled, pulverized, or reduced to powder by hand pressure.

2. Category 1 that are subjected to sanding, grinding, cutting, or abrading.

3. Category 1 material that has become friable during renovation activities: or

4. Category 2 material that has become friable during renovation activities.

Materials containing greater than 1% asbestos are subject to the NESHAP regulations (40 CFR Part 61, Subpart M). RACM (friable ACM and non-friable ACM that will become friable during renovation/demolition operations) must be removed from structures prior to renovations or demolitions. Certain non-friable ACM and materials containing one percent or less (≤1%) asbestos may remain in structures during renovations/demolitions.

2.0 SITE DESCRIPTION

The site consisted of two mechanical rooms and associated crawl space and roof within a twelve-story medical building, reportedly constructed in 1949. The interior finishing comprised suspected gypsum board wall with joint compound, vinyl floor tile with associated mastic, ceramic floor tile with associated grout, pipe insulations, gypsum wallboard cavity insulation, cove base with associated mastic, concrete masonry unit (CMU) and brick perimeter walls, and bare concrete floor. Thermal system insulation (TSI) which appeared to be fiberglass material was present on pipe runs. The roof finishing comprised of asphalt rolled roofing and associated mastic.

Select Photographs of the Site and identified suspect building materials are included as Appendix B to this report.

3.0 METHODOLOGY

3.1 Material Sampling or Investigation

3.1.1 Asbestos Sampling Procedures

During the survey, AEI visually inspected all readily accessible areas of the subject property and identified homogeneous areas of suspect material (materials that share the same texture, color, use, and appear to have been applied at approximately the same time) and collected representative samples of suspect material for laboratory analysis. The samples collected were placed in plastic bags, sealed, labeled, and transported under chain of custody documentation to an accredited laboratory.

A representative number of samples were collected for each Homogeneous Area in accordance with the following:

The following are the Homogeneous Application symbols which were used for identification during the survey:

T = Thermal System Insulation

M = Miscellaneous Materials

S = Surfacing Materials (Troweled or Spray-Applied)

The minimum number of samples collected and analyzed for each homogeneous material was as specified in the following table. This table was developed based on the AHERA Sampling Protocol (40 CFR 763.86).

Homogeneous Material Type Number of Samples

Surfacing Materials Up to 1,000 sq. ft. – 3 Samples 1,001 – 5,000 sq. ft. – 5 Samples 5,001 – 10,000 sq. ft. – 7 Samples Over 10,000 sq. ft. – Minimum 9 Samples

Thermal Systems Insulation Minimum 3 Samples/Material Type

Miscellaneous Materials Minimum 3 Samples/Material Type

Patch Materials Minimum 2 Samples

Previously Sampled Materials Accepted Positive Sample without Further Collection (Inspector Discretion)

Note: Exceptions to numbers of samples may be made at the discretion of the Inspector (typically for materials with limited quantities).

Bulk material samples were collected in 4-mil plastic bags, or through the use of sample coring devices in sealed plastic tubes and sealed for transport to the laboratory. Each sample collected was assigned its own unique coded number. Samples were collected, analyzed, and stored under strict chain-of-custody protocol.

AEI’s approach included a visual assessment of the spaces to locate, as far as practicable, suspect ACM in interior and exterior building or structure locations. Suspect materials were divided into "Homogeneous Areas", building materials which were determined by the inspector to be similar based on their color, texture, and age. In addition, Homogeneous Areas were identified in some cases by function or use, by size, or area/location of the material as well as color, texture, and age or type of material.

AEI collected a total of forty-one (41) bulk suspect asbestos-containing building material samples from the Site which layered out to eighty-four (84) samples during laboratory analysis.

Mechanical and electrical equipment including, but not limited to, boilers, HVAC units, refrigeration units, etc. may have internal parts that are asbestos containing. In some cases, these materials where applicable were assumed to contain asbestos where no prior information related to sampling of these materials was provided or due to the inaccessible nature of the materials for sampling. Prior to renovation or demolition, internal components should be inspected or assumed to contain asbestos.

3.2 Analytical Methods

All samples collected were transported under Chain of Custody documentation to EMLab P&K, LLC in Norcross, Georgia for analysis. EMLab P&K is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP #201060-0). Laboratory certifications are provided as Appendix C of this report.

3.2.1 Asbestos Analysis

All bulk suspect asbestos samples were analyzed using polarized light microscopy (PLM) in accordance with the EPA “Method of Determination of Asbestos in Bulk Samples” (EPA 600/R- 93/116, July 1993). This method is referred to as the “Improved Method” and is recommended by EPA as a preferred substitute to the Interim Method EPA 600/M4-82-020, 1982. The laboratory analytical report is included as Appendix D to this report. It should be noted that some materials are multi-layered and are inseparable during the bulk sample collection process.

Each layer requires specific analysis and reporting by layer (each layer = 1 sample analysis).

In accordance with U.S. EPA guidelines, samples are categorized into “homogeneous groups” by material type. The number of samples to be taken for each group is dictated by the type and quantity of the material. All samples within the homogeneous group must be one percent or less (≤1%) asbestos in order to classify the material as “non-asbestos”. Conversely, the positive result of any single (1) sample dictates that the Homogeneous Group be classified as ACM. Limitations and Service Constraints

• AEI was granted full access within the subject property. Discrete sampling procedures were utilized on request of the client. Access to the two mechanical rooms and associated crawl space and roof was granted by the property management.

• Due to the hidden nature of some building materials, AEI attempted to access suspect materials for sampling through limited destructive inspection methods.

• The inspection of every space or void (inside walls, ceilings, chases, etc.) within a building structure is not feasible or cost effective. Therefore, reasonable attempts were made to investigate a representative number of locations, which allowed for assumptions to be made regarding typical construction of the investigated building/areas.

• Where concrete substrates were encountered below floor finishes or behind wall finishes, they were considered to be the lowest flooring substrate or outer wall substrate. No coring through identified concrete substrates was performed as part of this survey.

• Where carpeting or other floor coverings exist, AEI attempts to determine substrates or other suspect asbestos-containing flooring materials which may have been covered.

However, without removing all carpeting or other flooring materials from a facility, it cannot be guaranteed that other layers of flooring materials do not exist. Should materials be identified under carpets or other flooring materials during a renovation or demolition activity they should be sampled and analyzed to determine asbestos content prior to disturbance or removal.

• Mechanical and electrical equipment including, but not limited to, boilers, HVAC units, refrigeration units, etc. may have internal parts that are asbestos-containing. No investigation inside equipment was performed.

• An inspection below grade on the building foundation or other Site areas was not performed as part of AEI’s scope of work.

• AEI derived the data in this report primarily from visual inspections, interviews with individuals with information about the Site and a limited number of environmental samples. The passage of time, manifestation of latent conditions, or occurrence of future events may require further exploration at the Site, analysis of the data, and re-evaluation of the findings, observations, conclusions, and recommendations expressed in the report.

• In preparing this report, AEI has relied upon and presumed accurate certain information (or absence thereof) about the Site provided by the Client, and others identified herein.

Except as otherwise stated in the report, AEI has not attempted to verify the accuracy or completeness of such information.

• The data reported and the findings, observations, conclusions, and recommendations expressed in the report are limited by the Scope of Services, including the extent of environmental sampling and other tests.

• Asbestos surveys are considered destructive in that the collection of multiple bulk building material samples must be performed for subsequent laboratory analysis and may cause damage to the integrity of building systems. Multiple samples of each suspect building material are collected utilizing hand tools via chipping, cutting, gouging, coring, or scraping. Samples may vary in size depending upon the type of material(s) being collected and the location of the material. Larger samples are sometimes required to access layered materials (i.e., multiple layers of flooring or roofing). Repairs via patching will only be performed for friable thermal insulation materials. AEI took normal precautions to minimize damage, however, AEI will not be responsible for the minor damage caused by sampling of suspect building materials.

4.0 4.0 SAMPLING AND ANALYSIS

4.1 NESHAP Pre-Renovation Survey

AEI collected a total of forty-one (41) bulk, suspected asbestos-containing building material samples from the Site which layered out to eighty-four (84) during laboratory analysis.

The Homogeneous Application Designations, Material descriptions and locations, approximate quantities of any positive results, and sample location descriptions and results are listed in Table 1 below (Confirmed Positive results or Assumed Positive Materials are Highlighted):

Table 1 Homogeneous Application Summary

700 South 19th Street Birmingham, Alabama

HA

ID

Type of Material

Material Location

Approximate Quantity

Sample

ID#

Sample Collection Location

Sample Result

01 Tan 18”x18” Vinyl Floor Tile

South Mechanical

Room, Southeast

Office Area

N/A

South Mechanical

Room, Southeast

Office Hallway

None Detected

South Mechanical

Room, Southeast

Office Hallway

None Detected

South Mechanical

Room, Southeast

Office Hallway

None Detected

02 CMU Wall Grout

Perimeter Walls N/A

South Mechanical

Room, Northwest

None Detected

South

Mechanical Room, West

None Detected

South Mechanical

Room, Southwest

None Detected

Tan 12”x12”

Ceramic Floor Tile Grout

South Mechanical

Room, Southeast Restrooms

N/A 07

South Mechanical

Room, Southeast Restrooms

None Detected

Table 1 Homogeneous Application Summary

700 South 19th Street Birmingham, Alabama

HA

ID

Type of Material

Material Location

Approximate Quantity

Sample

ID#

Sample Collection Location

Sample Result

South Mechanical

Room, Southeast Restrooms

None Detected

South Mechanical

Room, Southeast Restrooms

None Detected

Tan Residual

Mastic on Columns

South Mechanical

Room, Columns

N/A

South Mechanical

Room, North Center

None Detected

South

Mechanical Room, West

None Detected

South

Mechanical Room, Center

None Detected

05 Brick Mortar

South Mechanical

Room, Perimeter

Walls

N/A

South Mechanical

Room, Northeast

None Detected

South Mechanical

Room, Southeast

None Detected

South Mechanical

Room, Northeast

None Detected

Black 6” Covebase

Mastic

South Mechanical

Room, Throughout

N/A

South

Mechanical Room, West

None Detected

South

Mechanical Room, South

None Detected

South Mechanical Room, East

Hallway

None Detected

07 Drywall/Joint Compound Throughout N/A 19

North Mechanical Room, West

Table 1 Homogeneous Application Summary

700 South 19th Street Birmingham, Alabama

HA

ID

Type of Material

Material Location

Approximate Quantity

Sample

ID#

Sample Collection Location

Sample Result

South Mechanical

Room, Northwest

None Detected

South

Mechanical Room, West

None Detected

Insulation Between Drywall

Throughout

N/A

South Mechanical

Room, Northwest

None Detected

South

Mechanical Room, North

None Detected

South Mechanical

Room, Northeast

None

09 Concrete Throughout

Mechanical

Room, Southeast

None Detected

South

Mechanical Room, Center

None Detected

South Mechanical

Room, Southwest

None Detected

10 4” Pipe Insulation Crawl Space

28 Crawl Space, North

None Detected

29 Crawl Space, South

None Detected

11 10” Pipe Insulation Crawl Space

30 Crawl Space, East

None Detected

31 Crawl Space, West

None Detected

12 6” Pipe Insulation

South Mechanical

Room

Mechanical Room, Center

None Detected

South

Mechanical Room, North

Table 1 Homogeneous Application Summary

700 South 19th Street Birmingham, Alabama

HA

ID

Type of Material

Material Location

Approximate Quantity

Sample

ID#

Sample Collection Location

Sample Result

13 10” Pipe Insulation

North

Room

34 North

Room, North

None Detected

35 North Mechanical

Room, North

None Detected

14 Roofing Membrane

Roof

36 Roof, South None

37 Roof, North None Detected

38 Roof, Center None

15 Roofing Mastic Roof

39 Roof, Southeast

None Detected

40 Roof, South None Detected

41 Roof, West None

N/A – not applicable

5.0 SUMMARY AND RECOMMENDATIONS

This report documents the methods and findings of the NESHAP Pre-Renovation Asbestos Survey for the Bermingham VA Health Care System (Mechanical Rooms), located at 700 South 19th Street in Birmingham, Alabama.

5.1 Summary of Findings

Based upon the laboratory analytical results, the sampled materials did not identify the presence of asbestos in any of the building materials sampled.

5.2 Recommendations

Based on the results of the Pre-Renovation Asbestos Survey Report, AEI makes the following recommendations:

1. Should the scope of the renovation be altered from the original plans, AEI recommends that the areas and/or materials not investigated as part of this inspection including the roofs and any remaining hotel rooms be surveyed by an EPA certified asbestos inspector.

2. If suspect materials that are not referenced in this report are identified during renovation/demolition activities, regulations require, and AEI recommends that the materials be sampled and analyzed to confirm or deny the presence of asbestos prior to disturbance of the materials.

3. Where carpeting or other floor coverings exist, AEI attempts to determine substrates or other suspect asbestos-containing flooring materials which may have been covered.

However, without removing all carpeting or other flooring materials from a facility, it cannot be guaranteed that other layers of flooring materials do not exist. Should materials be identified under carpets or other flooring materials during a renovation or demolition activity they should be sampled and analyzed to determine asbestos content prior to disturbance or removal.

4. An inspection below grade on the building foundation was not performed as part of our scope of work. Prior to disturbance, all building foundations should be inspected for suspect waterproofing materials or other suspect materials.

6.0 REPORT RELIANCE

Because of the limitations stated above, the findings, observations, conclusions, and recommendations expressed by AEI in this report are limited to the information obtained and the surface and subsurface investigation undertaken and should not be considered an opinion concerning the compliance of any past or current owner(s) or operator(s) of the Site with any Federal, State, or local laws or regulations. No warranty or guarantee, whether express or implied, is made with respect to the data reported or findings, observations, conclusions, or recommendations expressed in this report. Furthermore, such data, findings, observations, conclusions, and recommendations are based solely upon Site conditions in existence at the time of investigation.

This assessment was performed at the request of the Client, its successors, and assigns ("Client") utilizing methods and procedures consistent with good commercial or customary practices designed to conform with acceptable industry standards. This report may be distributed to and relied upon by Client and its current and future wholly and partially owned subsidiaries, affiliates, successors, and assigns. The independent conclusions represent AEI Consultants’ best professional judgment based on the conditions that existed and the information and data available to us during the course of this assignment. Information regarding operations, conditions, and test data provided to Client, Reliant Party, or their representative has been assumed to be correct and complete.

This report has been prepared on behalf of and for the exclusive use of the Client and is subject to and issued in connection with the Agreement and the provisions thereof.

7.0 SIGNATURE OF ENVIRONMENTAL PROFESSIONALS

AEI Consultants has performed the NESHAP Pre-Renovation Asbestos Survey for Bermingham VA Health Care System (Mechanical Rooms), located at 700 South 19th Street in Birmingham, Alabama in conformance with applicable Asbestos regulations. Any exceptions to, or deletions from, this practice are described in Sections 1.2 and 3.3 of this report. The survey was limited to the portions of the facility identified in the Introduction to this report.

Prepared By:

Charles Yoon Senior Project Manager AEI Consultants 4255 Wade Green Road, Suite 510 Kennesaw, Georgia 30144

Reviewed by:

Samuel Lardizabal, MPH, CSST, CDPH Project Manager AEI Consultants 701 Campus Square W, Suite 723A El Segundo, California 90245

APPENDIX A

INSPECTOR

CERTIFICATIONS

has examined the documentation of asbestos training and qualifications of the person named below and confers this

Certificate of Accreditation Asbestos Inspector Renewal

Charles Yoon

Alabama Accreditation Number

AIN1123B1CE4008

Certificate Expiration Date

November 14, 2025

This certificate has been issued pursuant to the authority granted to The University of Alabama SafeState Program by the Alabama Asbestos Contractor Accreditation Act, Alabama Act No. 89-517, May, 1989 and Alabama Act No. 97-626, May, 1997.

Environmental Services Manager Associate Director for Environmental Programs

APPENDIX B

PHOTOGRAPHIC

LOG

700 South 19th Street October 8, 2024 Birmingham, Alabama Photographic Log

Exterior View of the Subject Building (Mechanical Room) (Photograph 01)

Interior View of the South Mechanical Room (Photograph 02)

Interior View of the North Mechanical Room (Photograph 03)

View of insulation between Drywall (Non-ACM) (Photograph 04)

View of Tan 18”x18” Vinyl Floor Tile in the Southeast Office Area (Non-ACM) (Photograph 05) View of the Tan 6” Residual Cove base Mastic, throughout (Non-ACM) (Photograph 06)

View of the Brick Mortar in the Perimeter Walls (Non- ACM) (Photograph 07)

View of the CMU Wall Grout in the Perimeter Walls (Non- ACM) (Photograph 08)

View of the Tan Residual Mastic on Drywall Columns (Non-ACM) (Photograph 09)

View of the Concrete Foundation (Non-ACM) (Photograph 10)

View of Tan 12”x12” Ceramic Floor Tile Grout (Non-ACM) (Photograph 11)

View of the Drywall/Joint Compound (Non-ACM) (Photograph 12)

View of the 10” Pipe Insulation in North Mechanical Room (Non-ACM) (Photograph 13)

View of the 6” Pipe Insulation, South Mechanical Room (Non-ACM) (Photograph 14)

View of the 4” Pipe Insulation in Crawl Space (Non-ACM) (Photograph 15)

View of the 10” Pipe Insulation in Crawl Space (Non-ACM) (Photograph 16)

View of the Roofing Membrane, Mechanical Room Roof (Non-ACM) (Photograph 17)

View of the Roofing Mastic, Mechanical Room Roof (Non- ACM) (Photograph 18)

APPENDIX C

LABORATORY

CERTIFICATIONS

United States Department of Commerce National Institute of Standards and Technology

Certificate of Accreditation to ISO/IEC 17025:2017

NVLAP LAB CODE: 201060-0

Eurofins EPK Built Environment Testing - Norcross Norcross, GA is accredited by the National Voluntary Laboratory Accreditation Program for specific services, listed on the Scope of Accreditation, for:

Asbestos Fiber Analysis

2024-04-01 through 2025-03-31

Effective Dates For the National Voluntary Laboratory Accreditation Program

This laboratory is accredited in accordance with the recognized International Standard ISO/IEC 17025:2017.

This accreditation demonstrates technical competence for a defined scope and the operation of a laboratory quality management system (refer to joint ISO-ILAC-IAF Communique dated January 2009).

APPENDIX D

LABORATORY

ANALYTICAL

RESULTS

Approved by:

Approved Signatory Alexis Starrett

Report for:

Charles Yoon AEI Consultants 2207 W 190th St Torrance, CA 90504

Regarding:

Eurofins EPK Built Environment Testing, LLC Project: 500172; Davenergy Solutions/ Birmingham, AL

EML ID: 3809945

All samples were received in acceptable condition unless noted in the Report Comments portion in the body of the report. The results relate only to the samples as received and tested. The results include an inherent uncertainty of measurement associated with estimating percentages by polarized light microscopy. Measurement uncertainty data for sample results with >1% asbestos concentration can be provided when requested.

Eurofins EPK Built Environment Testing, LLC ("the Company"), a member of the Eurofins Built Environment Testing group of companies, shall have no liability to the client or the client's customer with respect to decisions or recommendations made, actions taken or courses of conduct implemented by either the client or the client's customer as a result of or based upon the Test Results. In no event shall the Company be liable to the client with respect to the Test Results except for the Company's own willful misconduct or gross negligence nor shall the Company be liable for incidental or consequential damages or lost profits or revenues to the fullest extent such liability may be disclaimed by law, even if the Company has been advised of the possibility of such damages, lost profits or lost revenues. In no event shall the Company's liability with respect to the Test Results exceed the amount paid to the Company by the client therefor.

Dates of Analysis:

Asbestos PLM: 10-10-2024

Service SOPs: Asbestos PLM (EPA 40CFR App E to Sub E of Part 763 & EPA METHOD 600/R-93-116, SOP EM-AS-S-1267) NVLAP Lab Code 201060-0

EMLab ID: 3809945, Page 1 of 15Eurofins EPK Built Environment Testing, LLC

Eurofins EPK Built Environment Testing, LLC 6215 Regency Parkway, Suite 900, Norcross, GA 30071

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

Summary of Samples with Asbestos Detected

Total Samples Submitted: 41 Total Samples Analyzed: 41 Total Layers Analyzed: 84

Total Samples with Layer Asbestos Content > 1%: 0

Total Samples with Layer Asbestos Content < 1%: 0

EMLab ID: 3809945, Page 2 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-01, Tan 18x18 Vinyl floor tile S.Room, SE of the Hallway Lab ID-Version‡: 18810123-1

Sample Layers Asbestos Content White Mastic ND

Tan Sheet Flooring ND Sample Composite Homogeneity: Good

Location: 700-02, Tan 18x18 Vinyl floor tile S.Room, SE of the Hallway Lab ID-Version‡: 18810124-1

Sample Layers Asbestos Content White Mastic ND

Tan Sheet Flooring ND Sample Composite Homogeneity: Good

Location: 700-03, Tan 18x18 Vinyl floor tile S.Room, SE of the Hallway Lab ID-Version‡: 18810125-1

Sample Layers Asbestos Content White Mastic ND

Tan Sheet Flooring ND Sample Composite Homogeneity: Good

Location: 700-04, CMU Wall grout S. Mech, Room NW Lab ID-Version‡: 18810126-1

Sample Layers Asbestos Content White Grout ND

Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 3 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is reflected by the value of "x".

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-05, CMU Wall grout S. Mech, Room W Lab ID-Version‡: 18810127-1

Sample Layers Asbestos Content White Grout ND

Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 4 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-06, CMU Wall grout S. Mech, Room SW Lab ID-Version‡: 18810128-1

Sample Layers Asbestos Content White Grout ND

Sample Composite Homogeneity: Good

Location: 700-07, Tan 12x12 ceramic floor tile grout S. Mech, Room, Restroom Lab ID-Version‡: 18810129-1

Sample Layers Asbestos Content Tan Grout ND

Sample Composite Homogeneity: Good

Location: 700-08, Tan 12x12 ceramic floor tile grout S. Mech, Room, Restroom Lab ID-Version‡: 18810130-1

Sample Layers Asbestos Content Tan Grout ND

Sample Composite Homogeneity: Good

Location: 700-09, Tan 12x12 ceramic floor tile grout S. Mech, Room, Restroom Lab ID-Version‡: 18810131-1

Sample Layers Asbestos Content Tan Grout ND

Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 5 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-10, Tan Residual Mastic on column S. Mech Room NC Lab ID-Version‡: 18810132-1

Sample Layers Asbestos Content Yellow Mastic ND Brown Paper ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 700-11, Tan Residual Mastic on column S. Mech Room W Lab ID-Version‡: 18810133-1

Sample Layers Asbestos Content Yellow Mastic ND

Brown Paper with Paint ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 700-12, Tan Residual Mastic on column S. Mech Room C Lab ID-Version‡: 18810134-1

Sample Layers Asbestos Content Yellow Mastic ND Brown Paper ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 700-13, Brick mortar S.Mech Room NE Lab ID-Version‡: 18810135-1

Sample Layers Asbestos Content White Mortar ND

Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 6 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-14, Brick mortar S.Mech Room SE Lab ID-Version‡: 18810136-1

Sample Layers Asbestos Content White Mortar ND

Sample Composite Homogeneity: Good

Location: 700-15, Brick mortar S.Mech Room NE Lab ID-Version‡: 18810137-1

Sample Layers Asbestos Content White Mortar ND

Sample Composite Homogeneity: Good

Location: 700-16, Tan 6" Residual covebase mastic S mechanical RM, W Lab ID-Version‡: 18810138-1

Sample Layers Asbestos Content Yellow Mastic ND Brown Paper ND White Mastic ND

Black/White Cove Base ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Moderate

Location: 700-17, Tan 6" Residual covebase mastic S mechanical RM, S Lab ID-Version‡: 18810139-1

Sample Layers Asbestos Content Yellow Mastic ND Brown Paper ND White Mastic ND

Black/White Cove Base ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Moderate

EMLab ID: 3809945, Page 7 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-18, Tan 6" Residual covebase mastic S mechanical RM, E. Hallway Lab ID-Version‡: 18810140-1

Sample Layers Asbestos Content Yellow Mastic ND Brown Paper ND White Mastic ND

Black/White Cove Base ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Moderate

Location: 700-19, Drywall Joint compound N. Mech Room, W Lab ID-Version‡: 18810141-1

Sample Layers Asbestos Content White Drywall with Brown Paper ND

White Joint Compound ND Beige Tape ND

White Compound with Paint ND Composite Non-Asbestos Content: 15% Cellulose Sample Composite Homogeneity: Moderate

Location: 700-20, Drywall Joint compound S. Mech Room, NW Lab ID-Version‡: 18810142-1

Sample Layers Asbestos Content White Drywall with Brown Paper ND

White Joint Compound ND Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Good

Location: 700-21, Drywall Joint compound S. Mech Room, W Lab ID-Version‡: 18810143-1

Sample Layers Asbestos Content Off-White Drywall with Brown Paper ND

White Joint Compound ND Yellow Mastic ND

Composite Non-Asbestos Content: 10% Cellulose Sample Composite Homogeneity: Moderate

EMLab ID: 3809945, Page 8 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-22, Insulation between Drywall S Mech RM NW Lab ID-Version‡: 18810144-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-23, Insulation between Drywall S Mech RM N Lab ID-Version‡: 18810145-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-24, Insulation between Drywall S Mech RM NE Lab ID-Version‡: 18810146-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-25, Concrete S Mech RM SE Lab ID-Version‡: 18810147-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 9 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-26, Concrete S Mech RM C Lab ID-Version‡: 18810148-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Good

Location: 700-27, Concrete S Mech RM SW Lab ID-Version‡: 18810149-1

Sample Layers Asbestos Content Gray Concrete ND

Sample Composite Homogeneity: Good

Location: 700-28, 4" Pipe Insulation, Fiberglass Crawl space, N Lab ID-Version‡: 18810150-1

Sample Layers Asbestos Content Yellow Insulation ND

Silver Foil with Paint ND Composite Non-Asbestos Content: 85% Mineral Wool

5% Synthetic Fibers Sample Composite Homogeneity: Good

Location: 700-29, 4" Pipe Insulation, Fiberglass Crawl space, S Lab ID-Version‡: 18810151-1

Sample Layers Asbestos Content Yellow Insulation ND

Silver Foil with Paint ND Composite Non-Asbestos Content: 85% Mineral Wool

5% Synthetic Fibers Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 10 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. ND means no fibers were detected. When detected, the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.

‡ A "Version" indicated by -"x" after the Lab ID# with a value greater than 1 indicates a sample with amended data. The revision number is

(866) 871-1984 www.eurofinsus.com/Built Client: AEI Consultants C/O: Charles Yoon Re: 500172; Davenergy Solutions/ Birmingham, AL

Date of Sampling: 10-08-2024 Date of Receipt: 10-09-2024 Date of Report: 10-10-2024

ASBESTOS PLM REPORT

Location: 700-30, 10" Pipe Insulation Fiberglass, Crawl space, E Lab ID-Version‡: 18810152-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-31, 10" Pipe Insulation Fiberglass, Crawl space, W Lab ID-Version‡: 18810153-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-32, 6" Pipe Insulation Fiberglass, S Mech RM C Lab ID-Version‡: 18810154-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

Location: 700-33, 6" Pipe Insulation Fiberglass, S Mech RM N Lab ID-Version‡: 18810155-1

Sample Layers Asbestos Content Yellow Insulation ND

Composite Non-Asbestos Content: 95% Mineral Wool Sample Composite Homogeneity: Good

EMLab ID: 3809945, Page 11 of 15Eurofins EPK Built Environment Testing, LLC

The test report shall not be reproduced except in full, without written approval of the laboratory. The 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. The Company reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified.

All components not quantified as asbestos content and non-asbestos content are considered to be non-fibrous matrix components. Matrix components may include, but are not limited to, gypsum, paint, silicate minerals, vinyl, binder, calcium carbonate, tar, and foam.

Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually.

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