B08_Attachment_19_Regulated_Materials_Survey-2022.pdf

Prepared for:

National Park Service

12795 W. Alameda Pkwy, Lakewood, Colorado 80228 January 2022

Regulated Materials Survey Report

Perry’s Victory and International Peace Monument

Put-In Bay, Ohio

NPS Contract No. 140P2021D0002

Task Order No. 140P2022F0013

‘Wood’ is a trading name for John Wood Group PLC and its subsidiaries

Wood Environment & Infrastructure Solutions, Inc

200 American Metro Blvd.

Suite 113

Hamilton, NJ 08619

USA

T: 609-689-2829 www.woodplc.com

January 4, 2022

National Park Service, Denver Service Center – Contracting Services

12795 W. Alameda Pkwy., Lakewood, Colorado 80228

Attn: Nadine Catania, Contracting Officer

Subject: Regulated Material Survey (PMIS 272171)

Perry’s Victory and International Peace Monument

Task Order Number 140P2022F0013, Wood Project Number 6227210305

Dear Ms. Catania:

Wood Environment & Infrastructure Solutions, Inc., (Wood) completed the authorized survey, sampling, and evaluation for regulated materials at the Perry’s Victory and International Peace

Monument (PEVI). The field survey for the regulated materials survey was performed on

December 7, 2021.

This report is intended for the use of the National Park Service. Use of this report is subject to the terms and conditions agreed upon between Wood and the National Park Service. This report presents project information, which includes the assessment procedures and findings, conclusions, and recommendations. Use of this report for purposes beyond those reasonably intended by the National Park Service and Wood will be at the sole risk of the user.

We appreciate the opportunity to provide National Park Service with Wood’s services. If questions arise concerning this report, or if we may be of further service, please contact us at your convenience.

Sincerely, Wood Environment & Infrastructure

Solutions, Inc

Reviewed by:

Andrew G. Shust

Senior Associate

Michael J. Ebel

Vice President / Principal Scientist

Attachments

Regulated Materials Survey Report

NPS Contract No. 140P2021D0002 | January 2022 Page i

Wood project/reference number 6227210305.04.404

Regulated Materials Survey Report

Perry’s Victory and International Peace Monument

Put-In Bay, Ohio

NPS Contract No. 140P2021D0002

Prepared for:

National Park Service

12795 W. Alameda Pkwy, Lakewood, Colorado 80228

Prepared by:

Wood Environment & Infrastructure Solutions, Inc

200 American Metro Blvd.

Suite 113

Hamilton, NJ 08619

USA

T: 609-689-2829

January 2022

Copyright and non-disclosure notice

The contents and layout of this report are subject to copyright owned by Wood (© Wood Environment & Infrastructure Solutions, Inc). save to the extent that copyright has been legally assigned by us to another party or is used by Wood under license. To the extent that we own the copyright in this report, it may not be copied or used without our prior written agreement for any purpose other than the purpose indicated in this report. The methodology (if any) contained in this report is provided to you in confidence and must not be disclosed or copied to third parties without the prior written agreement of Wood. Disclosure of that information may constitute an actionable breach of confidence or may otherwise prejudice our commercial interests. Any third party who obtains access to this report by any means will, in any event, be subject to the Third-Party Disclaimer set out below.

Third-party disclaimer

Any disclosure of this report to a third party is subject to this disclaimer. The report was prepared by Wood at the instruction of, and for use by, our client named on the front of the report. It does not in any way constitute advice to any third party who is able to access it by any means. Wood excludes to the fullest extent lawfully permitted all liability whatsoever for any loss or damage howsoever arising from reliance on the contents of this report. We do not however exclude our liability (if any) for personal injury or death resulting from our negligence, for fraud or any other matter in relation to which we cannot legally exclude liability.

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Table of Contents

1.0 Introduction

1.1 Site Description

1.2 Scope of Work

1.3 Limitations of the Assessment

2.0 Survey Procedures for Asbestos

2.1 Visual Survey

2.2 Bulk Sampling Procedures

2.3 Bulk Sample Results

2.3.1 Suspect ACM Sample Results

2.4 Conclusion and Recommendations

3.0 Survey Procedures For Suspect Lead-Containing Surface Coatings

3.1 Visual Screening Survey

3.2 Lead Guidelines and Procedures

3.3 Paint Chip Screening Results

3.4 Conclusions and Recommendations

4.0 Polychlorinated Biphenyl Equipment

4.1 Visual Screening Survey

4.2 Visual Screening Survey Findings

4.3 Conclusions and Recommendations

5.0 Universal Waste

5.1 Visual Screening Survey

5.2 Visual Screening Survey Findings

5.3 Conclusions and Recommendations

6.0 Refrigerants

6.1 Visual Screening Survey

6.2 Visual Screening Survey Findings

6.3 Conclusions and Recommendations

7.0 Other Regulated Materials

7.1 Visual Screening Survey

7.2 Visual Screening Survey Findings

7.3 Conclusions and Recommendations

Tables

Table 1: Summary of Materials Samples for Asbestos

Table 2: Summary of Paint Chip Samples

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Figures

Figure 1: PEVI ACM & Paint Chip Sample Locations, Basement

Figure 2: PEVI ACM & Paint Chip Sample Locations, Upper and Lower Plaza

Appendices

Appendix A: Wood Certifications

Appendix B: Asbestos Laboratory Reports

Appendix C: Lead Containing Surface Laboratory Reports

Appendix D Photographs

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List of Acronyms and Abbreviations

ACM Asbestos Containing Materials

AHERA Asbestos Hazard Emergency Response Act

ASTM American Society of Testing and Materials

Wood Wood Environment & Infrastructure Solutions, Inc.

CPSC Consumer Product Safety Commission

DOT Department of Transportation

ELLAP Environmental Lead Laboratory Approval Program

HSA Homogeneous Sampling Areas

HUD Housing and Urban Development

LCSC lead-containing surfacing coatings

MM Miscellaneous Materials

N/A Not Applicable

NAD No Asbestos Detected

NESHAP National Emission Standards for Hazardous Air Pollutants

NPS National Park Service

NVLAP National Voluntary Laboratory Approval Program

OAC Ohio Administrative Code

OSHA Occupational Safety and Health Administration

PACM Presumed Asbestos Containing Materials

PEL Permissible Exposure Limit

PEVI Perry’s Victory and International Peace Monument

PCB Polychlorinated Biphenyl

PLM Polarized Light Microscopy

PPE Personal Protective Equipment

RACM Regulated Asbestos-Containing Material

RCRA Resource Conservation and Recovery Act

RMS Regulated Materials Survey

SM Surfacing Material

TEM Transmission Electron Microscopy

TSCA Toxic Substance Control Act

TSI Thermal System Insulation

TWA Time Weighted Average

TCLP Toxic Characteristic Leaching Procedures

TSCA Toxic Substance Control Act

USEPA United States Environmental Protection Agency

XRF X-Ray Fluorescence analysis

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1.0 Introduction

Wood Environment & Infrastructure Solutions, Inc. (Wood) conducted a pre-renovation asbestos and Regulated Materials Survey (RMS) at the Perry’s Victory and International Peace Monument

(PEVI) (PMIS 272171). Wood performed the RMS based on Terms and Conditions outlined in

Task Order Number 140P2022F0013, Contract Number 140P2021D0002 dated November 18, 2021.

1.1 Site Description

The RMS consisted of assessing the basement, Upper and Lower Plaza areas of the Perry’s

Victory and International Peace Monument.

1.2 Scope of Work

Wood completed a RMS. The RMS included identifying, quantifying, and sampling of suspect asbestos-containing materials (ACMs), lead-containing surfacing coatings (LCSC) and other regulated materials.

Wood conducted the asbestos survey portion of the pre-demolition RMS in accordance with

United States Environmental Protection Agency (USEPA) regulation 40 Code of Federal

Regulations (40 CFR), Part 61, Subpart M, National Emissions Standards for Hazardous Air

Pollutants (NESHAP). The purpose of the survey was to identify and quantify suspect ACMs and intended to meet the definition of a “thorough” inspection.

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The survey was performed by visually observing readily accessible and easily observable building materials throughout the basement, Upper and Lower Plaza areas. The primary purpose of the survey was to locate, identify, and assess friable and non-friable ACM within the structure prior to renovation. ACM is defined by the USEPA as any material containing greater than one percent (1%) asbestos. Friable ACM is defined by the USEPA as any material which, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Consideration was also given to non-friable materials that could be rendered friable by the forces expected to act upon them during demolition activity.

The non-asbestos survey portion of the pre-renovation RMS included LCSC survey, a quantification of regulated building materials and components including assumed PCB-containing light ballasts, mercury-containing materials (i.e., fluorescent light tubes, switches, thermostats), and a preliminary inventory of universal wastes, refrigerants, and other regulated materials (i.e., smoke detectors, fire extinguishers, and unknown fluids). The survey was performed in accordance with federal, state, and local regulatory requirements.

1.3 Limitations of the Assessment

This document was prepared for the exclusive use of the National Park Service. The report is based on data and information collected by Wood during the process of preparing this document. The conclusions of the report are professional opinions based solely upon visual Site observations, and interpretations of analyses as described in this report. The opinions presented herein apply to the Site conditions existing at the time of the investigation, and interpretation of current regulations pertaining to ACMs and other regulated materials. Wood accepts no responsibility for any deficiency, misstatement or inaccuracy contained in this report as a result of omissions, misinterpretations or fraudulent acts of persons interviewed or contacted.

Wood makes no other representations whatsoever, including those concerning the legal significance of its findings, or as to other legal matters touched on in this report, including, but not limited to, ownership of any property, or the application of any law to the facts set forth herein.

With respect to regulatory compliance issues, regulatory statutes are subject to interpretation and change. Such interpretations and regulatory changes should be reviewed with legal counsel. This report is not intended to supersede specifications, designs, federal laws, or provincial laws.

The current regulations should always be verified prior to conducting any future Site work involving asbestos or other regulated materials. This survey is not intended to be an abatement design document. ACMs and other regulated materials may be found within wall cavities, above ceilings, in pipe chases, or other areas that were not accessible during this survey. The survey also did not include an investigation of potentially buried piping within or in the vicinity of the structure.

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2.0 Survey Procedures for Asbestos

2.1 Visual Survey

The survey field activities were completed on December 7, 2021. The survey was performed by

Mr. Milo Eldridge an USEPA accredited asbestos inspector certified in the State of Ohio and experienced in conducting pre-renovation surveys. Mr. Andrew Shust also assisted with the survey field work.

This survey determined only general locations of suspect materials based on accessibility and did not determine the exact boundaries. No attempt was made to disassemble equipment or demolish structural elements and architectural finishes to reveal hidden conditions or materials, as this was beyond our scope of authorized services. Due to these limitations, wall voids, building cavities, mechanical equipment, and other similar areas that were not readily and/or easily observable may contain undocumented ACM. Our scope of work also included observing readily accessible and/or easily observable exterior areas. Limited destructive/intrusive investigative techniques were conducted utilizing manual hand tools (e.g., hammer, knife, chisel, etc.). Visual observations were made at convenient locations for the presence of thermal system insulation, finish materials, floor coverings and other suspect materials.

2.2 Bulk Sampling Procedures

A “walk-through” inspection of readily accessible areas was conducted to identify suspect ACM, presumed ACM (PACM), and assumed ACM. The sampling protocol was modeled after USEPA

40 CFR 763.86 and the State of Ohio Environmental Protection Agency Asbestos Program regulations. A Copy of Mr. Eldridge’s asbestos inspector certification is included in Appendix A.

Suspect ACM was identified, quantified, and grouped into homogeneous sampling areas (HSAs) and categorized according to 40 CFR 763.86, as thermal systems insulation (TSI), surfacing material (SM), or miscellaneous material (MM).

Bulk samples of TSI, SM, and MM were collected in a distributive manner. For TSI materials, a minimum of three bulk samples were collected of each HSA. At least one bulk sample was collected from a TSI elbow, joint, or valve material located on each pipe run and from patched/repaired TSI areas that were less than 6 square feet. For SM, a minimum number of samples collected was based on square footage of each HSA as follows: three bulk samples from

1,000 square feet or less; five bulk samples from greater than 1,000 square feet but less than

5,000 square feet; and seven bulk samples from greater than 5,000 square feet. For MM, a minimum of two bulk samples were collected of each HSA.

The individual HAs were then examined and representative bulk samples from each suspect material observed during our site visit were collected in general accordance with EPA and OSHA protocols. Bulk samples were collected and submitted under chain-of-custody to EMSL

Analytical Inc., located in Cinnaminson, New Jersey. EMSL maintains the National Voluntary

Laboratory Accreditation Program (NVLAP) accreditation (Lab Code 101048-0). Each HSA

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Wood project/reference number 6227210305.04.404 sample was analyzed in accordance with USEPA 40 CFR Appendix E to Subpart E of Part 763 and

USEPA Method 600/R-93/116 Polarized Light Microscopy (PLM) analysis with dispersion staining under positive stop guidelines. Positive stop guidelines include analyzing each sample for each

HSA until the presence of asbestos is reported above 1% asbestos or until all the samples for that HSA have been analyzed and reported as not detected for asbestos. If one sample per HSA is reported as greater than 1% asbestos the HSA is considered ACM regardless of the number of samples that are reported as less than 1% or not detected for asbestos.

Non-Suspect Materials - According to 40 CFR 763-86(4), sampling of the following materials is not required where the accredited inspector has deemed the material to be fiberglass, foam glass, rubber, wood, plastic or other recognized non-ACM.

The following table summarizes suspect materials that were observed and sampled during the inspection. Materials containing more than one percent asbestos are considered to be ACM.

TABLE 1

SUMMARY OF MATERIALS SAMPLED FOR ASBESTOS

Sample

Number(s)

HSA

Description Sample Area Type

Friable /

Nonfriable

Approx.

ACM

Quantity

Percent

Asbestos

PEVI-1A

PEVI-1B

PEVI-1C

Pipe

Insulation

Mechanical

Room TSI Friable NA NAD

PEVI-2A

PEVI-2B

PEVI-2C

Fiberglass

Pipe End

Sealant

Throughout

Basement TSI Friable NA NAD

PEVI-3A

PEVI-3B

PEVI-3C

Drywall with

Joint

Compound

Rooms 1, 2, 4

Basement MM Nonfriable NA NAD

PEVI-4A

PEVI-4B

PEVI-4C

Floor

Covering Restrooms MM Nonfriable NA NAD

PEVI-5A

PEVI-5B

PEVI-5C

Fiberglass

Duct

Insulation

Throughout

Basement TSI Friable NA NAD

PEVI-6A

PEVI-6B

PEVI-6C

Caulk Lower Plaza

Area MM Nonfriable NA NAD

PEVI-7A

PEVI-7B

PEVI-7C

Caulk

Stairs to

Upper Plaza

Area

MM Nonfriable NA NAD

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TABLE 1

SUMMARY OF MATERIALS SAMPLED FOR ASBESTOS

Sample

Number(s)

HSA

Description Sample Area Type

Friable /

Nonfriable

Approx.

ACM

Quantity

Percent

Asbestos

PEVI-8A

PEVI-8B

PEVI-8C

Black Mastic

Base of

Tower in

Basement

MM Nonfriable NA NAD

Notes:

MM – Miscellaneous Material

TSI – Thermal Systems Insulation

N/A – Not applicable

NAD – No asbestos detected

BOLD FONT – Indicates a sample layer that is asbestos-containing.

Prepared by AGS

Checked by MJE

2.3 Bulk Sample Results

The asbestos survey results are presented based on bulk sample collection, bulk sample results, and PACM/assumed ACM. Bulk asbestos sample locations collected by Wood are shown on

Figures 1 and 2. A copy of the asbestos sample laboratory report is provided in Appendix B.

Photographs of sampled suspect ACMs are provided in Appendix D.

2.3.1 Suspect ACM Sample Results

Wood identified eight (8) suspect ACMs and collected 24 bulk samples submitted under chain of custody rules for PLM analysis. Based on the PLM results, no suspect ACM was identified throughout the basement, Upper and Lower Plaza areas.

2.4 Conclusion and Recommendations

Wood did not identify building materials throughout the basement, Upper and Lower Plaza areas that are considered ACM. If previously unidentified ACMs are discovered during renovation, then all activities should be stopped and an USEPA accredited asbestos inspector certified in the State of Ohio should inspect the suspect material to determine whether the material is ACM and the friability of the material.

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3.0 Survey Procedures for Suspect Lead-Containing Surface

Coatings

3.1 Visual Screening Survey

Wood’s scope of services included a visual screening for suspect lead-containing surface coatings (LCSC) of predominate paint coatings from accessible surfaces of the basement, Upper and Lower Plaza areas. Paint chip samples were collected from various accessible building components for analysis to evaluate lead content. A total of four (4) paint chip samples were collected from the facility at the time of our survey. The samples were collected from the components by removing a representative sample of the coating from the components until the substrate was visible.

The purpose of the limited screening survey was to provide generalized information regarding the presence of lead-containing building materials and facilitating contractor compliance with

OSHA Standard 29 CFR 1926.62 (Lead in Construction) during the demolition of the structure.

3.2 Lead Guidelines and Procedures

The Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and

Control of Lead-Based Paint Hazards in Housing (June 1995), and the USEPA Requirements for

Lead-Based Paint Activities in Target and Child-Occupied Facilities (40 CFR Part 745) provide regulatory and industry guidelines for conducting lead-based paint sampling. Both HUD and

USEPA have set a threshold of 1.0 milligrams per square centimeter (mg/cm2) by X-Ray

Fluorescence (XRF) analysis, and 5,000 parts per million (ppm), or 0.5% by weight, for defining lead-based paint. Additionally, the Consumer Product Safety Commission (CPSC) defines “lead-free” paint as containing no greater than 0.06% lead by weight. However, OSHA regulates any occupational activities that impact or disturb materials with any detectable concentration of lead or potential exposures to lead.

Paint Chip samples collected during the screening were delivered by courier under chain of custody rules to EMSL Analytical Inc., located in Cinnaminson, New Jersey utilizing chain-of-custody procedures to document the handling of the samples. EMSL Analytical Inc. is an accredited laboratory in the NVLAP (Certification #101048-0). The paint chip samples were submitted to EMSL for analysis utilizing Flame Atomic Absorption Spectroscopy using the U.S.

EPA method SW846 3050B/7000B.

The following table summarizes LCSC that were observed and sampled during the inspection.

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TABLE 2

SUMMARY OF PAINT CHIP SAMPLES

Sample

Number(s) Sample Location

Structure Color Result (% by

Weight)

Evaluated

Result

LBP-1

Mechanical

Room, Basement Ceiling, Concrete White 0.045 Lead Free

LBP-2

Mechanical

Room, Basement Door, Metal Grey <0.0080 Lead Free

LBP-3 Basement Duct, Metal Yellow 0.030 Lead Free

LBP-4

Ladies Restroom, Basement Ceiling, Concrete White <0.0080 Lead Free

Prepared by AGS

Checked by MJE

3.3 Paint Chip Screening Results

Based on visual observations, paint chip sampling of predominate paint coatings, and subsequent analysis, no Lead-based paint and lead containing paint were identified in the basement, Upper and Lower Plaza areas. Copies of the paint chip laboratory analysis sheets are included as Appendix C. Photographs of sampled LCSC are provided in Appendix D.

3.4 Conclusions and Recommendations

Based on paint chip analysis indicate that no building components having lead concentrations that exceed the CPSC definition of LCP (0.06% lead content by weight) and HUD and EPA threshold of 0.5% lead content by weight.

The OSHA Standard 29 CFR 1926.62 (Lead in Construction) does not currently define a specific concentration of lead that must be present within paint for it to be considered “lead-containing.” Therefore, painted and glazed surfaces that contain detectable concentrations of lead must be handled in accordance with the OSHA Standard 29 CFR 1926.62 (Lead in

Construction). Wood recommends contractors performing work that could impact paint films or glazing that have detectable concentrations of lead should take appropriate precautions to comply with the OSHA Standard 29 CFR 1926.62 (Lead in Construction).

Workers performing demolition of LCSC must have, at a minimum, two-hour lead awareness training in accordance with OSHA Standard 29 CFR 1926.62 (Lead in Construction). If LCSC are required to be stripped or removed from the building component substrate, then additional training would be required based upon the measured lead concentration of the surface coating and the airborne lead concentrations measured during the work activity.

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The handling, disposal, and management of waste generated during any restoration, renovation, or demolition operations is regulated by the EPA Resource Conservation and Recovery Act

(RCRA) regulations, 40 CFR Parts 240 - 280. These regulations require that a Toxic Characteristic

Leaching Procedure (TCLP) test be utilized to determine if the waste generated during demolition, renovation, or removal projects is considered hazardous. TCLP sampling may be required based on landfill requirements.

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4.0 Polychlorinated Biphenyl Equipment

4.1 Visual Screening Survey

A visual screening survey of accessible fluorescent lighting fixtures and electrical equipment of the basement, Upper and Lower Plaza areas was conducted to identify polychlorinated biphenyl

(PCB) markings on the light ballasts or equipment. PCBs are commonly found in electrical equipment that require dielectric fluid such as transformers, oil-static cables, and capacitors as well as hydraulic machinery, vacuum pumps, compressors, and heat exchanger fluids. Wood assumed each lighting fixture to contained one ballast. Electrical equipment was visually observed for markings to determine if the electrical equipment may or may not contain PCBs.

USEPA regulations require that ballasts and/or equipment manufactured between July 1, 1979, and July 1, 1998, that do not contain PCBs must be labeled "No PCBs." If the “No PCBs” label was not observed, the ballasts were presumed to contain PCBs. Wood’s scope did not include dismantling or opening any equipment, or collection of samples of suspected PCB-containing fluids.

4.2 Visual Screening Survey Findings

The following is a list of potential PCB items readily observed by Wood in the basement, Upper and Lower Plaza areas:

• Light Ballast – Observed labels that stated No PCBs

• One (1) Transformer – Exterior Southeast side. Wood did not observe any markings on the transformer to identify its PCB content.

No other PCB items or equipment were identified within the basement, Upper and Lower Plaza areas. Photographs of PCB items or equipment are provided in Appendix D.

4.3 Conclusions and Recommendations

Wood recommends that prior to renovation or disturbance activities each fluorescent light fixture be visually inspected for markings indicating that ballasts do not contain PCBs. As mentioned above, ballasts not labeled “No PCBs” should be presumed to contain liquid PCBs, segregated, and managed, and disposed of. Wood recommends prior to renovation or disturbance activities, the transformer identified above be thoroughly inspected for markings indicating that they do not contain PCBs.

Removal, handling, and disposal of PCB containing materials or equipment is regulated under the USEPA’s Toxic Substance Control Act (TSCA) regulations (40 CFR 761) program as well as

USEPA’s regulated waste regulations (40 CFR 261) and are subject to Ohio Administrative Code

(OAC) when sent to a solid waste landfill.

In accordance with current State of Ohio regulations, Wood recommends that any assumed or confirmed PCB containing caulk, equipment and ballasts be removed and transported by a

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Wood project/reference number 6227210305.04.404 qualified hazardous waste contractor/licensed transporter and sent to an approved USEPA and

State of Ohio facility.

If leaking PCB-containing equipment and/or ballasts are identified, they should be segregated from the other non-leaking items and immediately placed in sealed 6-mil thick plastic bags and/or lined 55-gallon metal drums for handling. These materials should be recycled or incinerated in accordance with USEPA Regulation 40 CFR 761 at an approved facility rather than disposed of at a municipal solid waste landfill.

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5.0 Universal Waste

5.1 Visual Screening Survey

Wood conducted a visual survey to observe and document the presence and location of readily accessible Universal Waste sources within the basement, Upper and Lower Plaza areas. State of

Ohio and USEPA 40 CFR Part 273 established requirements for managing universal wastes.

Universal wastes are those wastes that would reasonably be expected to be classified as hazardous wastes but, due to their universal use in industrial and residential properties, regulations were created to ensure that they are managed in a manner that prevents harm to the environment while reducing the regulatory burden on generators of these wastes. Per the

Universal Waste regulations, analytical testing is not required to determine classification as

Universal Waste.

Universal wastes include the following waste types:

• Batteries;

• Mercury-containing devices;

• Pesticides; and,

• Fluorescent Lamps, Fluorescent Bulbs, HID Lamps.

Wood’s scope did not include dismantling or opening any equipment, or collection of samples of suspected mercury-containing.

5.2 Visual Screening Survey Findings

The following is a list of Universal Waste items observed:

• Four (4) exit signs with batteries.

• 31 fluorescent tubes.

• 10 High Pressure Sodium HID bulbs.

• 42 LED tubes.

• Seven (7) LED bulbs.

• Two (2) Fire Strobe Lights.

No other Universal Waste sources were identified within the basement, Upper and Lower Plaza areas. Photographs of Universal Waste sources are provided in Appendix D.

5.3 Conclusions and Recommendations

Wood identified Universal Waste sources within the basement, Upper and Lower Plaza areas.

Wood recommends these Universal Wastes be removed, packaged, transported, and recycled at a State of Ohio and/or USEPA approved facility by a qualified hazardous waste contractor in

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Wood project/reference number 6227210305.04.404 accordance with OAC 3745-52-232 and 3745-52-233 or the USEPA 40 CFR Part 273 Standards for Universal Waste Management.

Additional types of lamps that may be discovered in the facility during renovation activities that do not have the green-painted end caps or green-stamped writing should be assumed to contain concentrations of mercury and other metals such as cadmium and lead higher than the regulatory limits and be considered as universal wastes.

Low-mercury or “green end cap” lamps are not mercury free and must still be recycled or managed by an authorized facility in accordance with the Mercury-Added Consumer Products

Law, which became effective July 12, 2005.

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6.0 Refrigerants

6.1 Visual Screening Survey

Wood conducted a visual survey to observe and document the presence and location of readily accessible equipment which may contain refrigerants such as R-12, R-22, R-32, R-134A, R-290, R410A, and R600A within the basement, Upper and Lower Plaza areas. Examples of such equipment include chillers, refrigerators, air conditioning units, drinking fountains, walk-in coolers, and freezers. Wood visually inspected the equipment for external labels indicating the refrigerant content. Wood’s scope did not include dismantling or opening any equipment.

6.2 Visual Screening Survey Findings

The following is a list of potential refrigerant items observed:

• Two (2) Air Conditioning Units.

We did not observe markings that identified the type of refrigerant used in the equipment identified above. We did not observe any other types of equipment that would potentially contain refrigerants within the basement, Upper and Lower Plaza areas. Photographs of refrigerant equipment are provided in Appendix D.

6.3 Conclusions and Recommendations

The USEPA has regulated Class I and Class II refrigerants and their non-exempt substitutes in

USEPA regulation 40 CFR 82, Subpart F. Class I and Class II refrigerants and their non-exempt substitutes are regulated materials by the USEPA and must be handled and recycled or disposed of in accordance with EPA Federal Regulations 40 CFR 82 by an USEPA qualified, trained, and certified specialist.

Refrigerant containing equipment was assumed to contain refrigerants that are classified as ozone depleting compounds. Effective July 1, 1992, Section 608 of the Clean Air Act prohibits individuals from knowingly venting ozone-depleting compounds (Class I and Class II refrigerants) used as refrigerants into the atmosphere while maintaining, servicing, repairing, or disposing of air-conditioning or refrigeration equipment/appliances. Effective January 1, 2018, this requirement also applies to appliances containing most substitute refrigerants. Examples of substitute refrigerants include, but are not limited to hydrofluorocarbons, perfluorocarbons, hydrofluorolefins, hydrofluoroethers, hydrocarbons, ammonia, carbon dioxide, and blends thereof.

The USEPA requires all Class I and Class II refrigerants and their non-exempt substitutes be properly evacuated from equipment prior to dismantling and/or demolition. If it becomes known that refrigerants are present within equipment expected to be impacted by the project, Wood recommends that the equipment be inspected and, if necessary, the refrigerant be appropriately evacuated and recovered by properly trained and certified heating, ventilation, and air conditioning technicians in accordance with the USEPA approved program.

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7.0 Other Regulated Materials

7.1 Visual Screening Survey

Wood conducted a visual screening within the readily accessible basement, Upper and Lower

Plaza areas to identify smoke detectors suspected of containing a radioactive source material, electronic devices, fire suppression sprinkler heads, fire extinguishers and miscellaneous containers of unknown and regulated substances.

Smoke detectors were visually inspected for the presence of a radioactive source. Smoke detectors typically use either photoelectric sensors or a radioactive source to detect smoke and/or heat sources. A majority of smoke detectors that contain radioactive material use

Americium-241 which is a decay byproduct of Plutonium-241 and are known as ionizing chambers. According to the USEPA, typical radiation exposures to these devices are negligible as long as they are not damaged and used as directed. Wood’s scope did not include dismantling or opening any equipment.

Wood documented observed containers of potentially regulated substances or containers of unknown substances. If a legible label was observed, Wood documented that information as well as the approximate quantity. Wood did not sample or open any containers as part of this scope of work.

7.2 Visual Screening Survey Findings

The following is a list of potential regulated materials items observed:

• One (1) 250-Gallon Tank, Diesel Fuel.

• One (1) Backup Generator

• 17 – Fire Extinguishers.

No other regulated materials were identified within the basement, Upper and Lower Plaza areas.

Photographs of other regulated materials are provided in Appendix D.

7.3 Conclusions and Recommendations

Wood recommends the 250-gallon tank and contents be recycled or disposed of in accordance with federal, state, and local regulations if it’s no longer going to be in service. Except for the diesel fuel tank, Wood did not observe any other known or unknown fluids. Wood recommends that if any unknown fluids are identified that they be sampled for waste characterizations purposes. Based on the laboratory analysis, Wood recommends that the contents be recycled or disposed in accordance with federal, state, and local regulations.

Wood recommends the fire extinguishers be recycled or disposed in accordance with federal, state, and local regulations if they are no longer going to be in service.

NPS Contract No. 140P2021D0002 | January 2022 Page 15

Wood project/reference number 6227210305.04.404

Wood did not observe any smoke detectors suspected of containing a radioactive source material within the basement, Upper and Lower Plaza areas. However, if smoke detectors are identified Wood recommends that each smoke detector be checked for radioactive material before they are disposed of.

Figures

I R

I R

SCALE: 3/4" = 1'-0"

BASEMENT PLAN1

PEVI-3B

PEVI-3A

PEVI-3C

PEVI-2C

PEVI-2B

LBP-4

PEVI-4A

PEVI-4B

PEVI-4C

PEVI-5A,

PEVI-5B,

PEVI-5C

LBP-2

PEVI-1A

PEVI-1B

PEVI-1C

LBP-1

PEVI-2A

PEVI-2A

PEVI-8A

PEVI-8B

PEVI-8C

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

DESIGNED:

AutoCAD SHX Text

TECH. REVIEW:

AutoCAD SHX Text

SUB SHEET NO.

AutoCAD SHX Text

PMIS/PKG NO.

AutoCAD SHX Text

DRAWING NO.

AutoCAD SHX Text

SHEET

AutoCAD SHX Text

OF

AutoCAD SHX Text

TITLE OF SHEET

AutoCAD SHX Text

PERRY'S VICTORY AND INTERNATIONAL PEACE MEMORIAL

AutoCAD SHX Text

DECEMBER 2021

AutoCAD SHX Text

CADD

AutoCAD SHX Text 0"

AutoCAD SHX Text 1"

AutoCAD SHX Text FULL SIZE DRAWINGS = 22"x34" BAR MEASURES 1" LONG

AutoCAD SHX Text

NOT FOR CONSTRUCTION

AutoCAD SHX Text

AutoCAD SHX Text 177252

AutoCAD SHX Text

STATE

AutoCAD SHX Text

REGION

AutoCAD SHX Text

COUNTY

AutoCAD SHX Text

REGION 3

AutoCAD SHX Text

OTTAWA

AutoCAD SHX Text

OHIO

AutoCAD SHX Text

LOCATION OF PARK

AutoCAD SHX Text

PERRY'S VICTORY AND INTERNATIONAL PEACE MEMORIAL

AutoCAD SHX Text

NAME OF PARK

AutoCAD SHX Text 272171

AutoCAD SHX Text

AutoCAD SHX Text

SCALE IN FEET

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text C-101

AutoCAD SHX Text

BASEMENT PLAN

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text

A. SHUST

AutoCAD SHX Text

A. PATEL

AutoCAD SHX Text

NPS CURATORIAL SPACE

AutoCAD SHX Text

UTILITY

AutoCAD SHX Text

COM

AutoCAD SHX Text

RESTROOMS

AutoCAD SHX Text

MECH

AutoCAD SHX Text

DRAIN SUMP

AutoCAD SHX Text

STAIRS (TYP.)

AutoCAD SHX Text

CONCRETE SLAB BASEMENT ACCESS

AutoCAD SHX Text

ASBESTOS PEVI SAMPLE LOCATION

AutoCAD SHX Text

LEGEND

AutoCAD SHX Text

LEAD PAINT CHIP SAMPLE LOCATION

I R

I R

OH

OH

OH

OH

OH

OH

OH

OH

OH

OH

OH

OH

OH

C

O

M

F

O

WAT

SCALE: 3/4" = 1'-0"

UPPER LEVEL PLAN1

PEVI-7A

PEVI-7B

PEVI-7C

PEVI-6C

PEVI-6A

PEVI-6B

AutoCAD SHX Text

DATE:

AutoCAD SHX Text

DESIGNED:

AutoCAD SHX Text

TECH. REVIEW:

AutoCAD SHX Text

SUB SHEET NO.

AutoCAD SHX Text

PMIS/PKG NO.

AutoCAD SHX Text

DRAWING NO.

AutoCAD SHX Text

SHEET

AutoCAD SHX Text

OF

AutoCAD SHX Text

TITLE OF SHEET

AutoCAD SHX Text

PERRY'S VICTORY AND INTERNATIONAL PEACE MEMORIAL

AutoCAD SHX Text

DECEMBER 2021

AutoCAD SHX Text

CADD

AutoCAD SHX Text 0"

AutoCAD SHX Text 1"

AutoCAD SHX Text FULL SIZE DRAWINGS = 22"x34" BAR MEASURES 1" LONG

AutoCAD SHX Text

NOT FOR CONSTRUCTION

AutoCAD SHX Text

AutoCAD SHX Text 177252

AutoCAD SHX Text

STATE

AutoCAD SHX Text

REGION

AutoCAD SHX Text

COUNTY

AutoCAD SHX Text

REGION 3

AutoCAD SHX Text

OTTAWA

AutoCAD SHX Text

OHIO

AutoCAD SHX Text

LOCATION OF PARK

AutoCAD SHX Text

PERRY'S VICTORY AND INTERNATIONAL PEACE MEMORIAL

AutoCAD SHX Text

NAME OF PARK

AutoCAD SHX Text 272171

AutoCAD SHX Text

AutoCAD SHX Text

SCALE IN FEET

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text C-102

AutoCAD SHX Text

UPPER LEVEL PLAN

AutoCAD SHX Text

AutoCAD SHX Text

AutoCAD SHX Text

A. SHUST

AutoCAD SHX Text

A. PATEL

AutoCAD SHX Text

PERRY MEMORIAL

AutoCAD SHX Text

STAIRS (TYP.)

AutoCAD SHX Text

ASBESTOS PEVI SAMPLE LOCATION

AutoCAD SHX Text

LEGEND

Appendix A

Wood Certifications

Appendix B

Asbestos Laboratory Report

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042130402EMSL Order:

AMECEE25Customer ID:

Customer PO:

Project ID:

Attention: Phone:Andrew Shust (609) 689-2829

Fax:Wood Env. & Infrastructure Solutions (609) 689-2838

Received Date:200 American Metro Blvd. 12/11/2021 12:52 PM

Analysis Date:Suite 113 12/16/2021

Collected Date:Hamilton, NJ 08619 12/07/2021

Project: NPS / 6227210305.04.405.573000.6227

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

PEVI-1A

042130402-0001

Mechanical Room -

Pipe Insulation

White

Fibrous

Homogeneous

None DetectedCellulose

Glass

20%

10%

70.0% Non-fibrous (Other)

1HA:

PEVI-1B

042130402-0002

Mechanical Room -

Pipe Insulation

White

Fibrous

Homogeneous

None DetectedCellulose

Glass

20%

10%

70.0% Non-fibrous (Other)

1HA:

PEVI-1C

042130402-0003

Mechanical Room -

Pipe Insulation

Gray/White

Fibrous

Homogeneous

None DetectedCellulose

MinWool

Glass

10%

20%

10%

60.0% Non-fibrous (Other)

1HA:

PEVI-2A-Insulation

042130402-0004

Lower Plaza Basement

- Pipe Insulation

Yellow

Fibrous

Homogeneous

None DetectedGlass98% 2.0% Non-fibrous (Other)

2HA:

PEVI-2A-Sealant

042130402-0004A

Lower Plaza Basement

- End Sealant

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

2HA:

PEV-2B-Insulation

042130402-0005

Lower Plaza Basement

- Pipe Insulation

Yellow

Fibrous

Homogeneous

None DetectedGlass98% 2.0% Non-fibrous (Other)

2HA:

PEVI-2B-Sealant

042130402-0005A

Lower Plaza Basement

- End Sealant

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

2HA:

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received. Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA

600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample.

Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NJ DEP 03036, PA ID# 68-00367, LA #04127

Initial report from: 12/16/2021 10:41:00

ASB_PLMwSigs_0007_0001 Printed:12/16/2021 11:09:12AM Page 1 of 6

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042130402EMSL Order:

AMECEE25Customer ID:

Customer PO:

Project ID:

Attention: Phone:Andrew Shust (609) 689-2829

Fax:Wood Env. & Infrastructure Solutions (609) 689-2838

Received Date:200 American Metro Blvd. 12/11/2021 12:52 PM

Analysis Date:Suite 113 12/16/2021

Collected Date:Hamilton, NJ 08619 12/07/2021

Project: NPS / 6227210305.04.405.573000.6227

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

PEVI-2C-Insulation

042130402-0006

Lower Plaza Basement

- Pipe Insulation

Yellow

Fibrous

Homogeneous

None DetectedGlass90% 10.0% Non-fibrous (Other)

2HA:

PEVI-2C-Sealant

042130402-0006A

Lower Plaza Basement

- End Sealant

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

2HA:

PEVI-3A- Drywall

042130402-0007

Basement Room -1 -

Drywall

Brown/White

Fibrous

Homogeneous

None DetectedCellulose15% 85.0% Non-fibrous (Other)

3HA:

PEVI-3A- Joint

Compound

042130402-0007A

Basement Room -1 -

Joint Compound

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

3HA:

PEVI-3B- Drywall

042130402-0008

Basement Room -2 -

Drywall

Brown/White

Fibrous

Homogeneous

None DetectedCellulose15% 85.0% Non-fibrous (Other)

3HA:

PEVI-3B- Joint

Compound

042130402-0008A

Basement Room -2 -

Joint Compound

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

3HA:

PEVI-3C- Drywall

042130402-0009

Basement Room -4 -

Drywall

Brown/White

Fibrous

Homogeneous

None DetectedCellulose

Glass

15%

3%

82.0% Non-fibrous (Other)

3HA:

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received. Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA

600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample.

Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NJ DEP 03036, PA ID# 68-00367, LA #04127

ASB_PLMwSigs_0007_0001 Printed:12/16/2021 11:09:12AM Page 2 of 6

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042130402EMSL Order:

AMECEE25Customer ID:

Customer PO:

Project ID:

Attention: Phone:Andrew Shust (609) 689-2829

Fax:Wood Env. & Infrastructure Solutions (609) 689-2838

Received Date:200 American Metro Blvd. 12/11/2021 12:52 PM

Analysis Date:Suite 113 12/16/2021

Collected Date:Hamilton, NJ 08619 12/07/2021

Project: NPS / 6227210305.04.405.573000.6227

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

PEVI-3C- Joint

Compound

042130402-0009A

Basement Room -4 -

Joint Compound

White

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

3HA:

PEVI-4A

042130402-0010

Ladies Resroom -

Yellow Floor Covering

Yellow

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

4HA:

PEVI-4B

042130402-0011

Men's Resroom -

Yellow Floor Covering

Yellow

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

4HA:

PEVI-4C

042130402-0012

Men's Resroom -

Yellow Floor Covering

Yellow

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

4HA:

PEVI-5A

042130402-0013

Basement - Fiberglass

Duct Insulation

Black

Fibrous

Homogeneous

None DetectedCellulose

Glass

10%

75%

15.0% Non-fibrous (Other)

5HA:

PEVI-5B

042130402-0014

Basement - Fiberglass

Duct Insulation

Black

Fibrous

Homogeneous

None DetectedCellulose

Glass

10%

75%

15.0% Non-fibrous (Other)

5HA:

PEVI-5C

042130402-0015

Basement - Fiberglass

Duct Insulation

Black

Fibrous

Homogeneous

None DetectedCellulose

Glass

65%

30%

5.0% Non-fibrous (Other)

5HA:

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received. Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA

600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample.

Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NJ DEP 03036, PA ID# 68-00367, LA #04127

ASB_PLMwSigs_0007_0001 Printed:12/16/2021 11:09:12AM Page 3 of 6

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042130402EMSL Order:

AMECEE25Customer ID:

Customer PO:

Project ID:

Attention: Phone:Andrew Shust (609) 689-2829

Fax:Wood Env. & Infrastructure Solutions (609) 689-2838

Received Date:200 American Metro Blvd. 12/11/2021 12:52 PM

Analysis Date:Suite 113 12/16/2021

Collected Date:Hamilton, NJ 08619 12/07/2021

Project: NPS / 6227210305.04.405.573000.6227

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using

Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous % Type

Non-Asbestos Asbestos

PEVI-6A

042130402-0016

Lower Plaza - Caulk Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

6HA:

PEVI-6B

042130402-0017

Lower Plaza - Caulk Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

6HA:

PEVI-6C

042130402-0018

Lower Plaza - Caulk Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

6HA:

PEVI-7A

042130402-0019

Stairs to Upper Plaza -

Caulk

Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

7HA:

PEVI-7B

042130402-0020

Stairs to Upper Plaza -

Caulk

Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

7HA:

PEVI-7C

042130402-0021

Stairs to Upper Plaza -

Caulk

Gray

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

7HA:

PEVI-8A

042130402-0022

Basement on Column -

Black Mastic

Gray/Black

Non-Fibrous

Homogeneous

None Detected100.0% Non-fibrous (Other)

8HA:

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. The report reflects the samples as received. Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA

600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Unless requested by the client, building materials manufactured with multiple layers (i.