B08_Att_8_Hazmat_Report_2023-06-06.pdf

National Park Service U.S. Department of the Interior

Denver Service Center

31405867.008

REPLACE OBSOLETE HOUSING AT DEVIIL’S TOWER NATIONAL MONUMENT

Report of Hazardous Materials Survey

June 06, 2023

March 8, 2023

Mr. Adam Lamb, AIA, NCARB Project Manager, Architect Croft & Associates, PC 3380 Blue Springs Road Kennesaw, Georgia 30144

Subject: Report of Hazardous Materials Survey

Replace Obsolete Housing at Devil’s Tower National Monument Project Number 31405867.008

Dear Mr. Lamb:

WSP USA, Inc. (WSP), has prepared this report on behalf of Croft and Associates, LLC (Croft) following a hazardous material survey for demolition at the property addressed as 27 Prairie Dog Lane located in Devils Tower, Wyoming (Site, Figure 1). The survey included a lead-based paint, asbestos, and universal hazardous waste inspection for demolition of a one-story multi-family residential structure (Site Building, Figure 2). Samples of suspect materials were collected on January 24, 2023.

1.0 Sampling Objectives

WSP understands the Site Building is planned for demolition and Croft wants to evaluate the structure for asbestos containing building materials and lead-based paint to divert contaminated building waste from the landfill.

This survey included the following tasks:

An asbestos-containing materials (ACM) Survey;

Lead-based paint (LBP) Survey;

Collection of a Lead Toxicity Characteristic Leaching Procedure (TCLP) composite sample; and A regulated building materials inventory.

The United States Environmental Protection Agency (EPA) 40 Code of Federal Regulations (CFR) Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP rule requires that potentially regulated asbestos-containing material (RACM) be identified, classified, and quantified prior to planned disturbance, renovation, or demolition activities.

WSP USA, Inc.

5613 DTC Parkway Suite 500

Denver, Colorado 80111 T: 303-694-4755 www.wsp.com

Report of Hazardous Materials Survey 31405867.008 Replace Obsolete Housing at Devil’s Tower NM March 8, 2023

2.0 Scope of Work

The asbestos survey included a visual and physical assessment of materials planned for demolition in the Site Building. Suspect ACM was sampled in conformance with the sampling protocols outlined in the EPA regulation 40 CFR 763.86, Asbestos Hazard Emergency Response Act (AHERA). Samples were delivered to an accredited laboratory for analysis of asbestos content by polarized light microscopy (PLM).

Suspect LBP samples were collected in conformance with the sampling protocols outlined in the EPA regulation 40 CFR 745 Lead-Based Paint Poisoning Prevention in Certain Residential Structures, Residential Lead-Based Paint Hazard Reduction Act of 1992 (Title X), and other standards developed by the EPA pursuant to Title IV Section 401 – Lead Exposure Reduction of the Toxic Substances Control Act (TSCA). Samples were delivered to an accredited laboratory for analysis by Atomic Absorption Spectroscopy (AAS)/Atomic Emission Spectroscopy – Inductively Coupled Plasma – Mass Spectroscopy

(AES-ICP-MS).

The asbestos and lead-based paint survey was conducted by Mr. Dylan Helt, a Colorado-certified Asbestos Building Inspector (CABI). Copies of Mr. Helt’s certifications and the WSP Asbestos Consulting Firm Certification are included as Enclosure A.

An inventory of Regulated Building Materials was completed for all structures at the site to identify regulated materials that may require special waste disposal.

Site Description

The Site consists of one single-story wood framed structure used for multi-family housing. The structure is separated into six individual units. Four of the units are studio style living areas, the remaining two are one-bedroom units. The Site Building includes an attic with blown-in insulation and a metal roof.

3.0 Asbestos Containing Material Survey

Visual Assessment

The ACM survey activities began with a visual observation of the Site Building to identify functional spaces and homogeneous materials that would be removed during demolition. Building materials and components observed in the Site Building consisted of linoleum flooring, rubberized cove bases, insulation/pin boards, window glazing, vinyl wall coverings, drywall systems, insulation, pipe insulation, caulking, concrete floor sealant, mastic, and tar paper.

Physical Assessment

A physical assessment of each suspect homogeneous ACM was conducted to assess the condition of the material as friable or non-friable. The EPA defines friable material as one that, when dry, can be crumbled, pulverized, or reduced to a powder by hand pressure. Friability was assessed by physically touching suspect ACM. WSP classified the current condition of the suspect ACM and the potential for damage to the suspect ACM.

Asbestos Sample Collection

Bulk samples of suspect ACM were collected in conformance with AHERA and Wyoming Department of Environmental Quality (WDEQ) protocols. The samples were collected using wet methods, as applicable, to reduce the potential for a friable release. Samples were placed in sealable containers and labeled with unique sample identifications based on the material’s location. Results of the visual and physical assessment, sample descriptions, and laboratory analytical results of the ACM survey are identified in Table 1 and are detailed on Figure 2.

A total of 37 bulk samples of suspect ACM were collected from the following materials:

Miscellaneous

Insulation Caulking Mastic Tar paper Linoleum flooring

Cove base Insulation/pin boards Window glazing Vinyl wall covering Drywall composite

Surfacing:

Concrete floor sealant

Thermal System Insulation (TSI)

Pipe insulation

The suspect ACM samples were submitted to Eurofins Reservoirs Environmental, Inc. (Reservoirs) in Denver, Colorado, an independent laboratory that has successfully participated in the National Voluntary Laboratory Accreditation Program and is accredited by the American Industrial Hygiene Association (AIHA). The bulk samples were submitted under chain-of-custody (COC) procedures to Reservoirs for analysis by PLM per EPA methodology (EPA-600/R-93/116). Visual estimation was used to obtain the percentage of asbestos present within the bulk samples. Additionally, asbestos sample results reported as positive for asbestos content by PLM (≤ 1%) were further analyzed by the point count method and reported as a composite sample when applicable.

4.0 Lead Based Paint Chip Sample Collection

Bulk samples of suspect LBP were collected in conformance with protocols outlined in the EPA regulation 40 CFR 745 Lead-Based Paint Poisoning Prevention in Certain Residential Structures, Residential Lead- Based Paint Hazard Reduction Act of 1992 (Title X), developed by the EPA pursuant to Title IV Section 401

– Lead Exposure Reduction of the Toxic Substances Control Act (TSCA). The samples were collected using wet methods, as applicable, to reduce the potential for a release. Samples were placed in sealable containers and labeled with unique sample identifications. Sample descriptions and laboratory analytical results of the LBP are identified in Table 2 and sample locations are detailed on Figure 3.

A total of 6 paint samples were collected of the following materials and the general locations in the Site Building:

Sage colored paint on drywall White colored paint on drywall Gray colored paint on concrete Cream colored paint on metal Brown colored paint on metal Sand colored paint on wood

The bulk samples were submitted under strict COC procedures to Reservoirs in Denver, Colorado for analysis by AAS/ICP-AES-MS.

5.0 Toxicity Characteristics Leaching Procedure Sample Collection

Based on the results of visual observations to determine the different painted surfaces, one composite sample was collected of materials with associated paints, adhesives, and substrates still in place from the Site Building. The sample was collected using wet methods, as applicable, to reduce the potential for a release. The sample was placed in a sealable container and labeled with a unique sample identification.

The bulk TCLP sample was submitted under strict COC procedures to Reservoirs in Denver, Colorado, for analysis by EPA SW-846 Method 1311.

6.0 Regulated Building Materials

Universal Wastes (i.e., batteries, thermostats, lamps, ballasts, mercury-containing equipment, radioactive sources, CFCs) are regulated pursuant to the USEPA Universal Waste Requirements (40 CFR Part 273).

Similarly, these sampling procedures may also be used to determine disposal/management or clean-up options for Universal Wastes. Typical equipment that might contain universal wastes are emergency light batteries, chlorofluorocarbons (CFC) containing refrigerators, water fountains, mercury containing bulbs, thermostats, and thermometers. Descriptions and quantities of the regulated building materials and the locations of these materials are presented in Table 3.

7.0 Regulatory Overview

Asbestos

The United States Environmental Protection Agency (EPA) 40 Code of Federal Regulations (CFR) Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP rule requires that potentially regulated asbestos-containing material (RACM) be identified, classified, and quantified prior to planned disturbance, renovation, or demolition activities.

The Occupational Safety and Health Administration (OSHA) asbestos standard for the construction industry (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter (0.1 f/cc) of air for an 8-hour day. The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work.

The asbestos NESHAP rule (40 CFR Part 61) regulates asbestos fiber emissions and asbestos waste disposal practices. It requires the identification and classification of existing building materials prior to renovation or demolition activities. Under NESHAP, asbestos-containing building materials are classified as either friable, Category I non-friable, or Category II non-friable ACM. Friable materials are those that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Category I non-friable ACM includes packings, gaskets, resilient flooring covering, and asphalt roofing products. Category II non-friable ACM are any materials other than Category I materials that contain more than 1 percent (%) asbestos.

RACM is defined as friable ACM and Category I and Category II non-friable ACM that is in poor condition and has become friable or will be subjected to sanding, grinding, cutting, or abrading. In addition, RACM includes Category II non-friable ACM that has a high probability of becoming, or has become, crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

RACM must be removed prior to renovation or demolition activities. If the amount of RACM exceeds the trigger levels of 260 linear feet (LF), 160 square feet (SF), or the volume equivalent of one 55-gallon drum, the owner or operator must provide the WDEQ with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities. Removal of RACM must be conducted by a trained and appropriately licensed asbestos abatement contractor. laboratory analysis results indicated that no asbestos was detected in any of the suspect building materials sampled;

therefore, activities may be performed without additional special handling or involvement by licensed asbestos professionals. If additional suspect materials are uncovered that were not sampled during this survey, they should be sampled to determine if asbestos is present before being disturbed.

Lead Paint

Title IV of TSCA, as well as other authorities in the Residential LBP Hazard Reduction Act of 1992, direct EPA to regulate LBP hazards. The EPA definition of LBP is paint or other surface coatings that contain lead at concentrations equal to or exceeding 1 milligram of lead per square centimeter (mg/cm2) of paint or greater or paint that contains lead greater than 0.5% lead by weight or 5,000 parts per million (ppm) by weight. In addition, the OSHA Regulation 29 CFR 1910.1025 outlines health and safety for workers who have the potential to disturb lead-containing paint or LBP. The OSHA standard requires that employee exposure to airborne lead be maintained below 50 micrograms per cubic meter (μg/m3).

8.0 Findings

The asbestos and LBP sample locations are identified on Figures 2 and 3. The laboratory analytical reports are included as Enclosure B and photographs of samples are presented as Enclosure C. Asbestos sample results and LBP sample results are summarized in Tables 1 and 2, respectively.

Regulated Asbestos Containing Materials

Drywall Composite

Material Type Miscellaneous Location of Sampled Material Behind light switch on north wall of Apartment D Identified Homogenous Area Drywall system Approximate Quantity 4,000 SF Friable/Non-Friable Friable Condition Good Potential for Damage Moderate Asbestos Content 1.66% Chrysotile Sample IDs DT-DW01-01

Category II Non-Friable Materials

Window Glazing

Material Type Miscellaneous Location of Sampled Material Bottom west window outside Apartment C Identified Homogenous Area Window glazing Approximate Quantity 40 SF Friable/Non-Friable Non-friable Condition Damaged Potential for Damage Moderate Asbestos Content 2.00% to 2.50% Chrysotile Sample IDs DT-WG01-01 to DT-WG01-02

Lead-Based Paint

Paint chip samples were analyzed by AAS/ICP-AES-MS. Analytical results indicated lead was detected above laboratory reporting limits in five of the six samples taken. Four samples (DT-LBP01 through DT- LBP03 and DT-LBP05) returned detectable concentrations below the EPA defined lead-based paint concentration level of 0.5% by weight. One sample (DT-LBP06), which was taken from the sand-colored wooden exterior trim, returned a concentration of 0.666% lead by weight and has been determined to be

LBP.

Toxicity Characteristic Leaching Potential - Lead

The analytical result of the lead TCLP sample indicated lead was not detected above the reporting limit.

Because the reporting limit is below the Resource Conservation and Recovery Act 40 Code of Federal Regulations 268.40 Table 7-1 Lead maximum contaminant concentration of 5 milligrams per liter, building materials not considered lead-based paint or ACM are considered non-hazardous waste and may be disposed of as regular solid waste.

Regulated Building Materials

WSP identified the following materials as potential regulated building materials:

Refrigerators Thermostats Hot water heaters Lighting ballasts Air conditioning units

Regulated building material locations and quantities are summarized in Table 3.

8.0 Conclusions and Recommendations

Based on the analytical results, WSP has developed the following conclusions:

The drywall system of the Site Building was found to contain greater than 1% asbestos following point count analysis and composite reporting. As the drywall is friable as well, it is considered

RACM.

The window glazing of the Site Building was found to contain greater than 1% asbestos following point count analysis. As the window glazing is non-friable, it is considered Category II Non-Friable

ACM.

DT-LBP01 was found to exceed the EPA defined LBP concentration level and is considered to be

LBP

The lead TCLP sample representative of building materials to be demolished and disposed of at a landfill indicated lead was not detected above the reporting limit.

Based on the analytical results and with regards to the planned demolition, the following recommendations are presented below:

As a project whole, the demolition activities will result in the disturbance of the aggregate quantity of the identified non-friable and friable materials, which are considered either ACM or RACM exceed the regulatory trigger levels of 260 LF, 160 SF, or the volume equivalent of one 55-gallon drum. Abatement must be completed by a General Abatement Contractor (GAC) in accordance with State and Federal regulations for demolition of the Site Buildings and a permit for completing the abatement must be obtained from the WDEQ. RACM must be removed from the Site Buildings prior to demolition. All ACM waste should be disposed of according to State and Federal regulations. RACM must be removed from the Site Buildings prior to demolition, specifically this includes the drywall system.

An abatement scope of work (SOW) should be prepared for obtaining bids for asbestos abatement of the identified RACM and other ACM that warrants removal from waste materials to be recycled or reused.

Upon completing the abatement of ACM from the abatement work area(s) a final visual clearance and air clearance must be completed prior to removing the containment area. The final visual and air clearance must be completed by a certified Air Monitoring Specialist (AMS).

A demolition Notification Application Form must be submitted to the WDEQ along with payment of a notification fee. A notification period of 10 working days is required before the demolition can commence. All demolition should be completed in accordance with NESHAP and no visible emissions should be observed during the demolition process.

The exterior sand colored paint of the doors and wooden trim was found to be lead-based paint and will require abatement before demolition as to divert the lead waste from the landfill.

Identified Universal Hazardous Waste Materials should be removed prior to the demolition of the Site Building.

Once demolition has been completed, WSP recommends the surface surrounding the footprints of the former Site Building be free of construction debris.

Croft should note that they are responsible for notifying renovation or demolition contractors of materials that contain asbestos and lead containing paint. It is the contractor’s responsibility to ensure worker protection from exposure to the asbestos and lead containing paint in these materials. Ultimately it is the owner’s responsibility to ensure that their contractor uses appropriate renovation or demolition methods to prevent releases of asbestos fibers and lead paint and that the materials are disposed of properly.

Limitations

This report is exclusively for the use and benefit of Croft for specific application to their project as discussed and is not for the use or benefit of any other person or entity. No survey can eliminate the uncertainty regarding the presence or absence of ACM. This asbestos survey was completed only on the areas specified in the SOW as identified by Croft. The level of diligence and investigative procedures used are intended to reduce, but not eliminate, potential uncertainty regarding the presence of these materials.

The procedures used for this survey attempted to establish a balance between the competing goals of inspection cost, time, and aesthetic damage. The determinations of this report should not be construed as a guarantee that all such materials present in the subject property have been identified in the report. The inspection was conducted in a manner consistent with the level of care and expertise exercised by members of the asbestos inspection and assessment profession.

Those entities and persons involved with the inspection and generation of this report do not imply or guarantee that all potential ACM on or in the structure have been identified or sampled. Historically, asbestos has been added as a component to over 3,000 materials and products produced in the United

States. The inspection was intended to identify those materials that were reasonably suspect and that were most likely to contain asbestos in quantities subject to regulation, based on existing industry and regulatory standards. A full destructive investigation was conducted to identify materials in inaccessible areas (e.g., pipe behind walls, drywall behind wood paneling, flooring under carpet, electrical panels, etc.).

Drawings and diagrams contained in this report are for informational purposes only and proportion and scales are approximate. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. This report is not to be considered as a bid specification or bid document.

Closing

WSP appreciates the opportunity to provide environmental services to the Croft. If you have any questions, please contact the undersigned at (303) 694-4755.

Sincerely, Dylan Helt Jim Bowie Associate Consultant, Geologist Lead Consultant, Senior Environmental Scientist

CABI# 25832

Attachments:

Figure 1 Site Location Map Figure 2 Asbestos Sample Locations Figure 3 Lead-based Paint Sample Locations Table 1 Asbestos Sample Results Table 2 Lead-Based Paint Sample Results Table 3 Universal Hazardous Waste Enclosure A Certifications and Licenses Enclosure B Results of Laboratory Analysis Enclosure C Photo Log

FIGURES

WSP USA Inc.

4600 WEST 60TH AVENUE

ARVADA, CO 80003

TEL: +1 303.433.9788

REFERENCE:

7.5 MINUTE SERIES TOPOGRAPHIC QUADRANGLE

DEVILS TOWER, WYOMING 2021

DEVIL’S TOWER EMPLOYEE HOUSING -

HAZARDOUS MATERIAL SURVEY

DEVILS TOWER, WYOMING

PREPARED FOR

CROFT AND ASSOCIATES, LLC

KENNESAW, GEORGIA

DH

/2

FIGURE 1

JB

SITE LOCATION

SUBJECT PROPERTY LOCATION

NORTH

ARVADA, CO 80003

TEL: +1 303.433.9788

REFERENCE:

ND NON-DETECTABLE FOR ASBESTOS

% - PERCENT ASBESTOS CONTENT

BURRILL PROPERTY - PHASE I ESA

FORT COLLINS, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

DH

/2

FIGURE 2

430 WEST WILLOX LANE,

FORT COLLINS, COLORADO

WELD COUNTY PARCELS 131302314001 & 131302316001

FIRESTONE, COLORADO

DEL CAMINO - PHASE I ESA

FIRESTONE, COLORADO

PREPARED FOR

THE STAENBERG GROUP

DENVER, COLORADO

GREYHOUND TRACT C-3 - PHASE I ESA

COMMERCE CITY, COLORADO

PREPARED FOR

DELWEST

DENVER, COLORADO

ASBESTOS SAMPLE LOCATIONS

DESERT SAGE LAND 1 - PHASE I ESA

CEDAR CITY, UTAH

PREPARED FOR

AES CLEAN ENERGY

LOUISVILLE, COLORADO

SOARING EAGLE RANCH - PHASE I ESA

MASONVILLE, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

SOARING EAGLE RANCH -

HAZARDOUS MATERIAL SURVEY

LOVELAND, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

DEVIL’S TOWER EMPLOYEE HOUSING -

HAZARDOUS MATERIAL SURVEY

DEVILS TOWER, WYOMING

PREPARED FOR

CROFT AND ASSOCIATES, LLC

KENNESAW, GEORGIA

DT-LF01-01

DT-CB01-01

DT-CLK04-01

DT-VFT01-01

DT-MS01-01

DT-MS01-02

DT-CLK02-02

DT-CLK02-01

DT-DW01-01 = 1.66%

DT-TP01-02

DT-TP01-01

DT-CLK03-02

DT-INS01-01

ACM Sample Non-ACM Sample

DT-INS03-02

DT-INS03-01

DT-INS02-02

DT-INS02-01

DT-WG01-02 = 2.00%

DT-WG01-01 = 2.50%

DT-TSI01-03

DT-TSI01-01

DT-TSI02-02

DT-TSI02-01

DT-DW01-02 = ND

DT-SF01-03

DT-TSI02-03

DT-TSI01-02

DT-CLK01-03

DT-CLK01-02

DT-CLK01-01

DT-SF01-02

DT-SF01-01

DT-CB01-02

DT-INS01-02

DT-VFT01-02

DT-CLK04-02

DT-CLK03-01

NORTH

DT-LF01-02

ARVADA, CO 80003

TEL: +1 303.433.9788

REFERENCE:

ND - NON-DETECTABLE FOR LEAD

% - PERCENT LEAD CONTENT

BURRILL PROPERTY - PHASE I ESA

FORT COLLINS, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

DH

/2

FIGURE 3

430 WEST WILLOX LANE,

FORT COLLINS, COLORADO

WELD COUNTY PARCELS 131302314001 & 131302316001

FIRESTONE, COLORADO

DEL CAMINO - PHASE I ESA

FIRESTONE, COLORADO

PREPARED FOR

THE STAENBERG GROUP

DENVER, COLORADO

GREYHOUND TRACT C-3 - PHASE I ESA

COMMERCE CITY, COLORADO

PREPARED FOR

DELWEST

DENVER, COLORADO

LEAD-BASED PAINT SAMPLE LOCATIONS

DESERT SAGE LAND 1 - PHASE I ESA

CEDAR CITY, UTAH

PREPARED FOR

AES CLEAN ENERGY

LOUISVILLE, COLORADO

SOARING EAGLE RANCH - PHASE I ESA

MASONVILLE, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

SOARING EAGLE RANCH -

HAZARDOUS MATERIAL SURVEY

LOVELAND, COLORADO

PREPARED FOR

CITY OF FORT COLLINS

FORT COLLINS, COLORADO

DEVIL’S TOWER EMPLOYEE HOUSING -

HAZARDOUS MATERIAL SURVEY

DEVILS TOWER, WYOMING

PREPARED FOR

CROFT AND ASSOCIATES, LLC

KENNESAW, GEORGIA

NORTH

DT-LBP01 = 0.0219%

DT-LBP02 = 0.00851%

DT-LBP04 < 0.00292%

DT-LBP06 = 0.666%

DT-LBP05 = 0.457%

DT-LBP03 = 0.165%

LBP Sample Non-LBP Sample

TABLES

SAMPLE IDENTIFICATION SAMPLE LOCATION

ESTIMATED

QUANTITY

SAMPLE DESCRIPTION SAMPLE DATE

MATERIAL TYPE

(SURFACING, TSI,

MISC.)

FRIABLE OR NON-

FRIABLE

ASSESSMENT

(GOOD, DAMAGED,

SIGNIFICANTLY

DAMAGED)

POTENTIAL FOR

DISTURBANCE

(LOW, MODERATE, HIGH)

ASBESTOS

CONTENT

DT-LF01-01

Two feet east from northwest corner of

Apartment A

Gray sheet vinyl A) Off white/gray sheet vinyl with gray fibrous backing material and tan adhesive

1/24/2023 Miscellaneous Non-Friable Good Moderate A) ND

DT-LF01-02

Five feet west from southeast corner of

Apartment D

Gray sheet vinyl A) Off white/gray sheet vinyl with gray fibrous backing material and tan adhesive

1/24/2023 Miscellaneous Non-Friable Good Moderate A) ND

DT-CB01-01

Two feet east from northwest corner of

Apartment A Brown cove base A) Brown cove base with trace tan adhesive

1/24/2023 Miscellaneous Non-Friable Good Moderate A) ND

DT-CB01-02

Four feet north from south end of kitchen counters in Apartment E

Brown cove base A) Brown cove base with trace tan adhesive

1/24/2023 Miscellaneous Non-Friable Good Moderate A) ND

DT-Ins01-01 Four fee north from southeast corner of Apartment B

Wall mounted pin boards A) Gray fibrous perlitic material B) Gray/white fibrous material with green/white paint

1/24/2023 Miscellaneous Friable Good Moderate

A) ND

B) ND

DT-Ins01-02 Three feet north from southwest corner of east bedroom of Apartment E

Wall mounted pin boards A) Gray fibrous perlitic material B) Gray/white fibrous material

1/24/2023 Miscellaneous Friable Good Moderate

A) ND

B) ND

DT-WG01-01

Bottom west window outside

Apartment C Window glazing A) Gray glazing with brown/multi-colored paint

1/24/2023 Miscellaneous Non-Friable Damaged Moderate A) 2.50%

DT-WG01-02

Bottom west window outside

Apartment C Window glazing A) Gray glazing with brown/multi-colored paint

1/24/2023 Miscellaneous Non-Friable Damaged Moderate A) 2.00%

DT-VFT01-01 Tub in Apartment B Shower vinyl wall A) White/brown counter top

1/24/2023 Miscellaneous Non-Friable Damaged Moderate A) ND

DT-VFT01-02 Tub in Apartment F Shower vinyl wall A) White caulk B) White/brown counter top

1/24/2023 Miscellaneous Non-Friable Damaged Moderate

A) ND

B) ND

DT-DW01-01

Under light switch on central wall of

Apartment D

Drywall system A) Green/white paint B) White/tan drywall C) Off white compound

1/24/2023 Miscellaneous Friable Good Moderate Composite:

1.66%

DT-DW01-02

Under light switch on north wall of storage room Drywall system A) White/tan drywall with white paint

1/24/2023 Miscellaneous Friable Good Moderate A) ND

DT-Ins02-01 Chimney patch in Apartment C White ceiling insulation A) White insulation

1/24/2023 Miscellaneous Friable Significantly Damaged Low A) ND

DT-Ins02-02 Chimney patch in Apartment C White ceiling insulation A) White insulation

1/24/2023 Miscellaneous Friable Significantly Damaged Low A) ND

DT-Ins03-01 Chimney patch in Apartment C Yellow chimney hole insulation A) Yellow insulation

1/24/2023 Miscellaneous Friable Significantly Damaged Low A) ND

DT-Ins03-02 Chimney patch in Apartment C Yellow chimney hole insulation A) Yellow insulation

1/24/2023 Miscellaneous Friable Significantly Damaged Low A) ND

DT-TSI01-01

Piping in southwest corner of laundry room

Laundry room TSI A) Silver foil B) Off white insulation

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

DT-TSI01-02

Piping behind washing units in laundry room

Laundry room TSI A) Silver foil B) Orange insulation

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

DT-TSI01-03

Piping in southwest corner of laundry room

Laundry room TSI A) Silver foil B) Black foam C) Orange insulation

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

C) ND

TABLE 1

ASBESTOS SAMPLE RESULTS

130 SF

40 SF

770 SF

380 SF

2,760 SF

4,000 SF

6 SF

4 LF

27 PRARIE DOG LANE

DEVIL'S TOWER, WYOMING

CROFT AND ASSOCIATES, LLC

1,620 SF

SAMPLE IDENTIFICATION SAMPLE LOCATION

ESTIMATED

QUANTITY

SAMPLE DESCRIPTION SAMPLE DATE

MATERIAL TYPE

(SURFACING, TSI,

MISC.)

FRIABLE OR NON-

FRIABLE

ASSESSMENT

(GOOD, DAMAGED,

SIGNIFICANTLY

DAMAGED)

POTENTIAL FOR

DISTURBANCE

(LOW, MODERATE, HIGH)

ASBESTOS

CONTENT

TABLE 1

ASBESTOS SAMPLE RESULTS

27 PRARIE DOG LANE

DEVIL'S TOWER, WYOMING

CROFT AND ASSOCIATES, LLC

DT-TSI02-01

Piping in southwest corner of laundry room

Laundry room TSI elbows A) Yellow insulation B) Silver/multi-colored tape

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

DT-TSI02-02

Piping in southwest corner of laundry room

Laundry room TSI elbows A) Silver foil B) Green/colorless resinous material C) Orange insulation

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

C) ND

DT-TSI02-03

Piping behind washing units in laundry room

Laundry room TSI elbows A) Green/colorless resinous material B) Silver foil C) Orange insulation

1/24/2023 TSI Friable Significantly Damaged Moderate

A) ND

B) ND

C) ND

DT-CLK01-01

Caulking around utility risers in laundry room

Gray caulking on laundry room floor A) Yellow/black foam B) Gray resinous material

1/24/2023 Miscellaneous Non-Friable Good Moderate

A) ND

B) ND

DT-CLK01-02

Caulking around utility risers in laundry room Gray caulking on laundry room floor A) Gray resinous material

1/24/2023 Miscellaneous Non-Friable Good Moderate A) ND

DT-SF01-01

Two feet south from north wall in laundry room Laundry room floor sealant A) Light gray/gray paint

1/24/2023 Surfacing Friable Significantly Damaged High A) ND

DT-SF01-02

Five feet south from north wall in laundry room Laundry room floor sealant A) Light gray/gray paint

1/24/2023 Surfacing Friable Significantly Damaged High A) ND

DT-SF01-03

Seven feet south from north wall in laundry room Laundry room floor sealant A) Light gray/gray paint

1/24/2023 Surfacing Friable Significantly Damaged High A) ND

DT-CLK02-01 Bath tub in Apartment C Bathtub caulk A) White caulk

1/24/2023 Miscellaneous Friable Good Moderate A) ND

DT-CLK02-02 Bath tub in Apartment C Bathtub caulk A) White caulk

1/24/2023 Miscellaneous Friable Good Moderate A) ND

DT-MS01-01

Kitchen counter in Apartment C near stove

Kitchen counter mastic A) Off white adhesive B) Black/multi-colored counter top

1/24/2023 Miscellaneous Friable Good Low

A) ND

B) ND

DT-MS01-02

Kitchen counter in Apartment C near stove

Kitchen counter mastic A) Off white adhesive B) Black/multi-colored counter top

1/24/2023 Miscellaneous Friable Good Low

A) ND

B) ND

DT-TP01-01 Southwest corner of building exterior Black tar paper structural lining A) Black felt

1/24/2023 Miscellaneous Non-Friable Good Low A) ND

DT-TP01-02 Southwest corner of building exterior Black tar paper structural lining A) Black felt

1/24/2023 Miscellaneous Non-Friable Good Low A) ND

DT-CLK03-01 Skylight above Apartment F Skylight caulking A) Colorless caulk

1/24/2023 Miscellaneous Non-Friable Damaged High A) ND

DT-CLK03-02 Skylight above Apartment A Skylight caulking A) Colorless caulk

1/24/2023 Miscellaneous Non-Friable Damaged High A) ND

DT-CLK04-01 Riser above Apartment A Chimney/roof utility caulk A) Black caulk

1/24/2023 Miscellaneous Non-Friable Significantly Damaged High A) ND

DT-CLK04-02 Riser above Apartment E Chimney/roof utility caulk A) Colorless caulk

1/24/2023 Miscellaneous Non-Friable Significantly Damaged High A) ND

Notes:

7 SF

4 SF

4,700 SF

72 SF

15 SF

1 SF

90 SF

2 LF

MISC. - miscellaneous

TSI - thermal system insulation

% - percent Shaded - positive result for asbestos

TR-Trace

ND - none detected for asbestos content SF - square feet

LF - linear feet

Sample Number Room/Space Object Substrate Color Condition Results (%)

DT-LBP01 Apartment D Wall Drywall Sage Good 0.0219

DT-LBP02 Storage Room Wall Drywall White Good 0.00851

DT-LBP03 Laundry Floor Concrete Gray Badly Damaged 0.165

DT-LBP04 Exterior Siding Exterior Wall Metal Cream Good <0.00292

DT-LBP05 Exterior Window Window Trim Metal Brown Damaged 0.457

DT-LBP06 Exterior Siding Exterior Door Wood Sand Good 0.666

Notes:

% - percent

Shaded - Exceeds EPA level

EPA defined Lead-based paint level

TABLE 2

PAINT CHIP SAMPLE RESULTS

27 PRARIE DOG LANE

DEVILS TOWER, WYOMING

>0.5% lead by weight

Identified Materials Material Location Estimated Quantity Potentially Hazardous

Material

Refrigerator Each unit 6 count Chlorofluorocarbons

Light Ballasts Throughout 8 count Polychlorinated Biphenyls

Thermostat Each unit 7 count Mercury

Hot Water Heater Laundry 1 count Mercury

Air Conditioners Each unit 12 count Chlorofluorocarbons

TABLE 3

UNIVERSAL HAZARDOUS WASTE

27 PRARIE DOG LANE

DEVILS TOWER, WYOMING

ENCLOSURE A – WSP CERTIFICATIONS

ENCLOSURE B – LABORATORY ANALYTICAL REPORTS

February 06, 2023

Jeanne Spencer President

Subcontractor Number:

Laboratory Report: RES 549488-4

Project #/P.O. #: None Given

Project Description: Devils Tower

Jim Bowie

WSP USA

5613 DTC Parkway Suite 500 Greenwood Village CO 80111

Dear Jim, Eurofins Reservoirs 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 LAP, LLC), Lab ID 101533 for Phase Contrast Microscopy (PCM) analysis. This laboratory is currently proficient in both Proficiency Testing and PAT programs respectively.

Eurofins Reservoirs 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.

RES 549488-4 is the job number assigned to this study. This report is considered highly confidential and the sole property of the customer. Eurofins Reservoirs 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, as received by the customer. 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 Eurofins Reservoirs 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.

by William Spells

02/06/202302/06/202302/06/202302/06/2023

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

5801 Logan St, Suite 100, Denver, CO 80216

Laboratory Sample IDLaboratory Sample IDLaboratory Sample IDLaboratory Sample ID LLLL Asbestos ContentAsbestos ContentAsbestos ContentAsbestos Content Non-Non-Non-Non- Non-Non-Non-Non- AAAA SubSubSubSub AsbestosAsbestosAsbestosAsbestos FibrousFibrousFibrousFibrous YYYY PhysicalPhysicalPhysicalPhysical PartPartPartPart MineralMineralMineralMineral VisualVisualVisualVisual FibrousFibrousFibrousFibrous ComponentsComponentsComponentsComponents EEEE DescriptionDescriptionDescriptionDescription EstimateEstimateEstimateEstimate ComponentsComponentsComponentsComponents

Client Sample NumberClient Sample NumberClient Sample NumberClient Sample Number RRRR (%) (%) (%) (%) 549488 -549488 -549488 -549488 - DT-LF01-01DT-LF01-01DT-LF01-01DT-LF01-01 A Off white/gray sheet vinyl w/ gray fibrous backing material

& tan adhesive

100 NDNDNDND 20 80

549488 -549488 -549488 -549488 - DT-LF01-02DT-LF01-02DT-LF01-02DT-LF01-02 A Off white/gray sheet vinyl w/ gray fibrous backing material & white adhesive

100 NDNDNDND 20 80

549488 -549488 -549488 -549488 - DT-CB01-01DT-CB01-01DT-CB01-01DT-CB01-01 A Brown cove base w/ a trace of tan adhesive 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CB01-02DT-CB01-02DT-CB01-02DT-CB01-02 A Brown cove base w/ a trace of tan adhesive 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-Ins01-01DT-Ins01-01DT-Ins01-01DT-Ins01-01 A Gray fibrous perlitic material 50 NDNDNDND 65 35 B Gray/white fibrous material w/ green/white paint 50 NDNDNDND 70 30 549488 -549488 -549488 -549488 - DT-Ins01-02DT-Ins01-02DT-Ins01-02DT-Ins01-02 A Gray fibrous perlitic material 50 NDNDNDND 65 35 B Gray/white fibrous material 50 NDNDNDND 70 30 549488 -549488 -549488 -549488 - DT-WG01-01DT-WG01-01DT-WG01-01DT-WG01-01 A Gray glazing w/ brown/multi-colored paint 100 ChrysotileChrysotileChrysotileChrysotile 3333 0 97 Point Count Point Count Point Count Point Count 2.502.502.502.50 549488 -549488 -549488 -549488 - DT-WG01-02DT-WG01-02DT-WG01-02DT-WG01-02 A Gray glazing w/ brown/multi-colored paint 100 ChrysotileChrysotileChrysotileChrysotile 3333 0 97 Point Count Point Count Point Count Point Count 2.002.002.002.00 549488 -549488 -549488 -549488 - DT-VFT01-01DT-VFT01-01DT-VFT01-01DT-VFT01-01 A White/brown counter top 100 NDNDNDND 60 40 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

RES Job Number:

Client:

Client Project/P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

TABLE: I ANALYSIS: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES 549488-4

WSP USA

None Given Devils Tower January 25, 2023 EPA 600/R-93/116 - Point Count, Bulk (400) Standard February 05, 2023

EUROFINS RESERVOIRS ENVIRONMENTAL, INC

NVLAP Lab Code 101896-0

AIHA LAP, LLC. LAB ID 101533

NA = Not Analyzed NR = Not Received ND = None Detected TR = Trace; <1 % Visual Estimate Trem-Act = Tremolite-Actinolite

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

Laboratory Sample IDLaboratory Sample IDLaboratory Sample IDLaboratory Sample ID LLLL Asbestos ContentAsbestos ContentAsbestos ContentAsbestos Content Non-Non-Non-Non- Non-Non-Non-Non-

YYYY PhysicalPhysicalPhysicalPhysical PartPartPartPart MineralMineralMineralMineral VisualVisualVisualVisual FibrousFibrousFibrousFibrous ComponentsComponentsComponentsComponents EEEE DescriptionDescriptionDescriptionDescription EstimateEstimateEstimateEstimate ComponentsComponentsComponentsComponents

Client Sample NumberClient Sample NumberClient Sample NumberClient Sample Number RRRR (%) (%) (%) (%)

549488 -549488 -549488 -549488 - DT-VFT01-02DT-VFT01-02DT-VFT01-02DT-VFT01-02 A White caulk 25 NDNDNDND 0 100 B White/brown counter top 75 NDNDNDND 60 40 549488 -549488 -549488 -549488 - DT-DW01-01DT-DW01-01DT-DW01-01DT-DW01-01 A Green/white paint 5 NDNDNDND 0 100 B White/tan drywall 25 NDNDNDND 50 50 C Off white compound 70 ChrysotileChrysotileChrysotileChrysotile 3333 0 97 Point Count Point Count Point Count Point Count 2.252.252.252.25 Composite Composite Composite Composite 1.661.661.661.66 549488 -549488 -549488 -549488 - DT-DW01-02DT-DW01-02DT-DW01-02DT-DW01-02 A White/tan drywall w/ white paint 100 NDNDNDND 20 80 549488 -549488 -549488 -549488 - DT-Ins02-01DT-Ins02-01DT-Ins02-01DT-Ins02-01 A White insulation 100 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-Ins02-02DT-Ins02-02DT-Ins02-02DT-Ins02-02 A White insulation 100 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-Ins03-01DT-Ins03-01DT-Ins03-01DT-Ins03-01 A Yellow insulation 100 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-Ins03-02DT-Ins03-02DT-Ins03-02DT-Ins03-02 A Yellow insulation 100 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-TSI01-01DT-TSI01-01DT-TSI01-01DT-TSI01-01 A Silver foil 25 NDNDNDND 0 100 B Off white insulation 75 NDNDNDND 90 10 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

RES Job Number:

Client:

Client Project/P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

TABLE: I ANALYSIS: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES 549488-4

WSP USA

None Given Devils Tower January 25, 2023 EPA 600/R-93/116 - Point Count, Bulk (400) Standard February 05, 2023

EUROFINS RESERVOIRS ENVIRONMENTAL, INC

NVLAP Lab Code 101896-0

AIHA LAP, LLC. LAB ID 101533

NA = Not Analyzed NR = Not Received ND = None Detected TR = Trace; <1 % Visual Estimate Trem-Act = Tremolite-Actinolite

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

Laboratory Sample IDLaboratory Sample IDLaboratory Sample IDLaboratory Sample ID LLLL Asbestos ContentAsbestos ContentAsbestos ContentAsbestos Content Non-Non-Non-Non- Non-Non-Non-Non-

YYYY PhysicalPhysicalPhysicalPhysical PartPartPartPart MineralMineralMineralMineral VisualVisualVisualVisual FibrousFibrousFibrousFibrous ComponentsComponentsComponentsComponents EEEE DescriptionDescriptionDescriptionDescription EstimateEstimateEstimateEstimate ComponentsComponentsComponentsComponents

Client Sample NumberClient Sample NumberClient Sample NumberClient Sample Number RRRR (%) (%) (%) (%)

549488 -549488 -549488 -549488 - DT-TSI01-02DT-TSI01-02DT-TSI01-02DT-TSI01-02 A Silver foil 25 NDNDNDND 0 100 B Orange insulation 75 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-TSI01-03DT-TSI01-03DT-TSI01-03DT-TSI01-03 A Silver foil 20 NDNDNDND 0 100 B Black foam 25 NDNDNDND 0 100 C Orange insulation 55 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-TSI02-01DT-TSI02-01DT-TSI02-01DT-TSI02-01 A Yellow insulation 35 NDNDNDND 90 10 B Silver/multi-colored tape 65 NDNDNDND 25 75 549488 -549488 -549488 -549488 - DT-TSI02-02DT-TSI02-02DT-TSI02-02DT-TSI02-02 A Silver foil 15 NDNDNDND 0 100 B Green/colorless resinous material 20 NDNDNDND 0 100 C Silver/multi-colored tape 20 NDNDNDND 20 80 D Orange insulation 45 NDNDNDND 90 10 549488 -549488 -549488 -549488 - DT-TSI02-03DT-TSI02-03DT-TSI02-03DT-TSI02-03 A Green/colorless resinous material 15 NDNDNDND 0 100 B Silver foil 20 NDNDNDND 0 100 C Orange insulation 65 NDNDNDND 90 10 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

RES Job Number:

Client:

Client Project/P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

TABLE: I ANALYSIS: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES 549488-4

WSP USA

None Given Devils Tower January 25, 2023 EPA 600/R-93/116 - Point Count, Bulk (400) Standard February 05, 2023

EUROFINS RESERVOIRS ENVIRONMENTAL, INC

NVLAP Lab Code 101896-0

AIHA LAP, LLC. LAB ID 101533

NA = Not Analyzed NR = Not Received ND = None Detected TR = Trace; <1 % Visual Estimate Trem-Act = Tremolite-Actinolite

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

Laboratory Sample IDLaboratory Sample IDLaboratory Sample IDLaboratory Sample ID LLLL Asbestos ContentAsbestos ContentAsbestos ContentAsbestos Content Non-Non-Non-Non- Non-Non-Non-Non-

YYYY PhysicalPhysicalPhysicalPhysical PartPartPartPart MineralMineralMineralMineral VisualVisualVisualVisual FibrousFibrousFibrousFibrous ComponentsComponentsComponentsComponents EEEE DescriptionDescriptionDescriptionDescription EstimateEstimateEstimateEstimate ComponentsComponentsComponentsComponents

Client Sample NumberClient Sample NumberClient Sample NumberClient Sample Number RRRR (%) (%) (%) (%)

549488 -549488 -549488 -549488 - DT-CLK01-01DT-CLK01-01DT-CLK01-01DT-CLK01-01 A Yellow/black foam 25 NDNDNDND 0 100 B Gray resinous material 75 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CLK01-02DT-CLK01-02DT-CLK01-02DT-CLK01-02 A Gray resinous material 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-SF01-01DT-SF01-01DT-SF01-01DT-SF01-01 A Light gray/gray paint 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-SF01-02DT-SF01-02DT-SF01-02DT-SF01-02 A Light gray/gray paint 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-SF01-03DT-SF01-03DT-SF01-03DT-SF01-03 A Light gray/gray paint 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CLK02-01DT-CLK02-01DT-CLK02-01DT-CLK02-01 A White caulk 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CLK02-02DT-CLK02-02DT-CLK02-02DT-CLK02-02 A White caulk 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-MS01-01DT-MS01-01DT-MS01-01DT-MS01-01 A Off white adhesive 25 NDNDNDND 0 100 B Black/multi-colored counter top 75 NDNDNDND 60 40 549488 -549488 -549488 -549488 - DT-MS01-02DT-MS01-02DT-MS01-02DT-MS01-02 A Off white adhesive 10 NDNDNDND 0 100 B Black/multi-colored counter top 90 NDNDNDND 60 40 549488 -549488 -549488 -549488 - DT-TP01-01DT-TP01-01DT-TP01-01DT-TP01-01 A Black felt 100 NDNDNDND 65 35 549488 -549488 -549488 -549488 - DT-TP01-02DT-TP01-02DT-TP01-02DT-TP01-02 A Black felt 100 NDNDNDND 65 35 549488 -549488 -549488 -549488 - DT-CLK03-01DT-CLK03-01DT-CLK03-01DT-CLK03-01 A Colorless caulk 100 NDNDNDND 0 100 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

RES Job Number:

Client:

Client Project/P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

TABLE: I ANALYSIS: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES 549488-4

WSP USA

None Given Devils Tower January 25, 2023 EPA 600/R-93/116 - Point Count, Bulk (400) Standard February 05, 2023

EUROFINS RESERVOIRS ENVIRONMENTAL, INC

NVLAP Lab Code 101896-0

AIHA LAP, LLC. LAB ID 101533

NA = Not Analyzed NR = Not Received ND = None Detected TR = Trace; <1 % Visual Estimate Trem-Act = Tremolite-Actinolite

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

Laboratory Sample IDLaboratory Sample IDLaboratory Sample IDLaboratory Sample ID LLLL Asbestos ContentAsbestos ContentAsbestos ContentAsbestos Content Non-Non-Non-Non- Non-Non-Non-Non-

YYYY PhysicalPhysicalPhysicalPhysical PartPartPartPart MineralMineralMineralMineral VisualVisualVisualVisual FibrousFibrousFibrousFibrous ComponentsComponentsComponentsComponents EEEE DescriptionDescriptionDescriptionDescription EstimateEstimateEstimateEstimate ComponentsComponentsComponentsComponents

Client Sample NumberClient Sample NumberClient Sample NumberClient Sample Number RRRR (%) (%) (%) (%) 549488 -549488 -549488 -549488 - DT-CLK03-02DT-CLK03-02DT-CLK03-02DT-CLK03-02 A Colorless caulk 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CLK04-01DT-CLK04-01DT-CLK04-01DT-CLK04-01 A Black caulk 100 NDNDNDND 0 100 549488 -549488 -549488 -549488 - DT-CLK04-02DT-CLK04-02DT-CLK04-02DT-CLK04-02 A Colorless caulk 100 NDNDNDND 0 100 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

Analyst

Eurofins Reservoirs Environmental, Inc Eurofins Reservoirs QA Manual

Effective April 28, 2022 Q:\QAQC\Eurofins Reservoirs QA Manual.pdf

RES Job Number:

Client:

Client Project/P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Samples Analyzed:

TABLE: I ANALYSIS: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES 549488-4

WSP USA

None Given Devils Tower January 25, 2023 EPA 600/R-93/116 - Point Count, Bulk (400) Standard February 05, 2023

EUROFINS RESERVOIRS ENVIRONMENTAL, INC

NVLAP Lab Code 101896-0

AIHA LAP, LLC. LAB ID 101533

NA = Not Analyzed NR = Not Received ND = None Detected TR = Trace; <1 % Visual Estimate Trem-Act = Tremolite-Actinolite

(303) 964-1986

(866) RESI-ENV

www.reilab.com https://clients.reilab.com

SUBMITTED BY INVOICE TO

Client Sample ID Number

RES Job #: 549488

CONTACT INFORMATION SERIES

ASBESTOS LABORATORY HOURS: Weekdays: 7am - 7pm & Sat. 8am - 5pm REQUESTED ANALYSIS VALID MATRIX CODES LAB NOTES

CHEMISTRY LABORATORY HOURS: Weekdays: 8am - 5pm

MICROBIOLOGY LABORATORY HOURS: Weekdays: 8am - 5pm

**Turnaround times establish a laboratory priority, subject to laboratory volume and are not guaranteed. Additional fees apply for afterhours, weekends and holidays.**

Laboratory Analysis Instructions

(Sample ID's must be unique)

Company: WSP USA Company: WSP USA

Address: 5613 DTC Parkway Address: 5613 DTC Parkway

Suite 500 Suite 500

Greenwood Village, CO 80111 Greenwood Village, CO 80111

Project Number and/or P.O. #: None Given

Project Description/Location: Devils Tower

Contact: Jim Bowie -1 PLM Standard -2 Chem Standard -3 Chem Standard Phone: (303) 815-0983

Fax:

Cell:

Final Data Deliverable Email Address:

jim.bowie@wsp.com (+ 2 ADDNL. CONTACTS)

PLM / PCM / TEM DTL RUSH PRIORITY STANDARD Air = A Bulk = B

Dust = D Food = F

Paint = P Soil = S

Dust RUSH PRIORITY STANDARD

*PRIOR NOTICE REQUIRED FOR SAME DAY TAT

Surface = SU Swab = SW

Tape = T Wipe = W

Metals RUSH PRIORITY STANDARD Drinking Water = DW

Waste Water = WW

Organics* SAME DAY RUSH PRIORITY STANDARD **ASTM E1792 approved wipe media only**

Viable Analysis** PRIORITY STANDARD

**TAT DEPENDENT ON SPEED OF MICROBIAL GROWTH

Medical Device Analysis RUSH STANDARD

Mold Analysis RUSH PRIORITY STANDARD

Special Instructions:

1 DT-LF01-01 X B 1 01/24/23

2 DT-LF01-02 X B 1 01/24/23

3 DT-CB01-01 X B 1 01/24/23

4 DT-CB01-02 X B 1 01/24/23

5 DT-Ins01-01 X B 1 01/24/23

6 DT-Ins01-02 X B 1 01/24/23

7 DT-WG01-01 X B 1 01/24/23

8 DT-WG01-02 X B 1 01/24/23

9 DT-VFT01-01 X B 1 01/24/23

10 DT-VFT01-02 X B 1 01/24/23

11 DT-DW01-01 X B 1 01/24/23

12 DT-DW01-02 X B 1 01/24/23

13 DT-Ins02-01 X B 1 01/24/23

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