B08_Attachment_7_-_Pre-Renovation_ACM_LBP_HAZ_Survey.pdf

REPORT OF PRE-RENOVATION

ASBESTOS CONTAINING MATERIAL

SURVEY, LEAD BASED PAINT

SURVEY, AND HAZARDOUS

BUILDING MATERIAL INVENTORY

NPS – GASTON MOTEL

Birmingham, Jefferson County, Alabama

PREPARED FOR:

Houser Walker Architecture`

1819 Peachtree Road, NE, Suite 102

Atlanta, Georgia 30309

NOVA Project Number: 10102-3023033.1

July 18, 2023

P R O F E S S I O N A L | P R A C T I C A L | P R O V E N

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July 18, 2023

HOUSER WALKER ARCHITECTURE

1819 Peachtree Road, NE

Suite 102

Atlanta, Georgia 30309

Attention: Mr. Rik Bizot AIA, LEED AP

Project Manager

Subject: Report of Environmental Services

Birmingham, Jefferson County, Alabama

NOVA Project Number 10102-3023033.1

Mr. Bizot:

NOVA Engineering and Environmental, LLC (NOVA) has completed the Environmental Services for the National Park Service (NPS) - Gaston Motel site located at 1510 5th Avenue North in

Birmingham, Jefferson County, Alabama. We appreciate your selection of NOVA and for the opportunity to be of service on this project. Please feel free to contact us if you have any questions or if we may be of further assistance.

Sincerely, NOVA Engineering and Environmental, LLC

Curtis Moses Nickolaus DaSantos

Staff Professional Business Unit Manager

Environmental Services Environmental Services

AHERA No. 19414 AHERA No. 19051

EPA Lead Inspector No. 2076 EPA Lead Inspector No. 2006

Alabama Asbestos Inspector No. AIN0523610139

Alabama Lead Inspector No. LIN0123610139

TABLE OF CONTENTS

1.0 SUMMARY

1.1 ASBESTOS CONTAINING MATERIAL

1.2 LEAD BASED PAINT & LEAD CONTAINING PAINT

1.1 HAZARDOUS BUILDING MATERIAL

2.0 INTRODUCTION

2.1 DESCRIPTION OF SUBJECT PROPERTY

2.2 PURPOSE

2.3 LIMITATIONS

2.4 USER RELIANCE

3.0 ASBESTOS CONTAINING MATERIAL

3.1 FIELD AND LABORATORY SERVICES

3.2 ASBESTOS ABATEMENT

4.0 LEAD BASED PAINT & LEAD CONTAINING PAINT

4.1 DEFINITIONS

4.2 FIELD AND LABORATORY SERVICES

4.3 LEAD ABATEMENT ACTIVITIES

5.0 HAZARDOUS BUILDING MATERIAL INVENTORY

5.1 FIELD SERVICES

5.2 HAZARDOUS BUILDING MATERIAL INVENTORY

5.3 HAZARDOUS BUILDING MATERIAL INVENTORY CONCLUSIONS

LIST OF APPENDICES

APPENDIX A – SAMPLE LOCATION PLANS & SITE PHOTOGRAPHS

APPENDIX B – LABORATORY ANALYTICAL DATA & XRF DATA

APPENDIX C – PERSONNEL QUALIFICATIONS

APPENDIX D – QUALIFICATIONS OF CONCLUSIONS

NPS – Gaston Motel July 18, 2023

Houser Walker Architecture NOVA Project Number 10102-3023033.1

1.0 SUMMARY

NOVA Engineering and Environmental, LLC. (NOVA) has completed the Environmental Services for the National Park Service (NPS) - Gaston Motel site located at 1510 5th Avenue North in

Birmingham, Jefferson County, Alabama (Subject Property).

A brief summary of our findings is presented below. This summary is provided for convenience and should not be substituted for review of the full report, including all attachments as provided herein.

1.1 ASBESTOS CONTAINING MATERIAL

During this study, forty-one (41) samples (containing 61 total layers) of floor tile, mastic, leveler, glue, joint compound, Thermal System Insulation (TSI), cement, ceiling texture, window glazing, caulking material, wallboard, grout, and mortar were analyzed by NOVA using Polarized Light Microscopy (PLM) with sixteen (16) analyzed sample layers indicating Asbestos Containing Material (ACM). A sample location plan is included in

Appendix A of this Report.

Black Mastic

• A total of twelve (12) samples of the black mastic located throughout the Subject

Property indicated >1% asbestos (3% Chrysotile Asbestos). Consequently, we believe all of the black mastic located at the Subject Property should be considered

Asbestos Containing Material (ACM).

Green/Brown Leveler

• A total of two (2) samples of the green/brown leveler located in the front lobby and restroom at the Subject Property indicated >1% asbestos (3% - 5% Chrysotile

Asbestos). Consequently, we believe all of the green/brown leveler located at the

Subject Property should be considered Asbestos Containing Material (ACM).

Black Cement

• A total of five (2) samples of the black cement associated with the top of the wood framing located at the Subject Property indicated >1% asbestos (5% Chrysotile

Asbestos). Consequently, we believe all of the black cement located at the Subject

Property should be considered Asbestos Containing Material (ACM).

A complete list of suspected ACM samples obtained is located in Appendix B of this report.

NPS – Gaston Motel July 18, 2023

1.2 LEAD BASED PAINT & LEAD CONTAINING PAINT

Ninety-one (91) X-ray fluorescence (XRF) analyzer readings were made by NOVA throughout the interior of the Subject Property structure to determine the presence of

Lead Based Paint (LBP).

Lead Based Paint

Lead Based Paint (LBP) is defined as a paint or varnish containing lead at a concentration >0.5% by weight when determined by laboratory analysis. LBP is also defined by HUD as 1.0 mg/cm2 when determined using an XRF analyzer.

The predominant LBP material identified by the NOVA survey include:

• Painted surfaces of metal structural beams and columns located at the Subject

Property; and

• Painted surfaces of metal stairwell riser components located at the Subject Property.

Lead Containing Paint

OSHA does not define Lead Based Paint based on lead content. Any detectable lead in a paint or varnish makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure. Consequently, for purposes of this study, Lead

Containing Paint is considered any detectable level of lead.

The predominant LCP material identified by the NOVA survey include:

• Painted green surfaces of concrete located at the Subject Property.

1.1 HAZARDOUS BUILDING MATERIAL

NOVA surveyed potential Hazardous Building Material (HBM) that was reasonably observed at the Subject Property. Potential HBM observed at the Subject Property include

LED lighting and miscellaneous construction/maintenance chemicals. The Subject Property was gutted down to the wood framing and concrete walls/floors at the time of NOVA's on-site Hazardous Building Material Inventory (HBMI).

The names and locations of all the material identified in the HBMI are included in the table in Section 5.2 of this report.

NPS – Gaston Motel July 18, 2023

2.0 INTRODUCTION

2.1 DESCRIPTION OF SUBJECT PROPERTY

The Subject Property is identified as the National Park Service (NPS) - Gaston Motel site located at 1510 5th Avenue North in Birmingham, Jefferson County, Alabama (Subject

Property). Specifically, for the purposes of this Pre-Renovation Asbestos Containing

Material (ACM) Survey, Lead Based Paint (LBP) Survey, and Hazardous Building Material

Inventory (HBMI), the Subject Property includes one (1) two (2) story approximately

10,000 square foot wood framed former hotel structure.

2.2 PURPOSE

As requested by Houser Walker Architecture (CLIENT), the Pre-Renovation Asbestos

Containing Material Survey, Lead Based Paint Survey, and Hazardous Building Material

Inventory (HBMI) was performed in an effort to identify Asbestos-Containing Material

(ACM), Lead Based Paint (LBP), and Hazardous Building Material at the Subject

Property. This work has been performed in general accordance with applicable state and federal regulations, and routine industry practice.

ACM sampling was performed in general accordance with the Asbestos Hazard

Emergency Response Act (AHERA) guidelines and ASTM E2356-18,”Standard Practice for Comprehensive Building Asbestos Survey” as a Baseline Survey. Deviations from the Baseline Survey protocols include:

• Determination of ACM quantities were excluded from the scope of work

2.3 LIMITATIONS

NOVA has performed the Pre-Renovation Asbestos Containing Material Survey, Lead

Based Paint Survey, and Hazardous Building Material Inventory (HBMI), which is a limited inquiry into a property's environmental status and is not sufficient to discover every potential source of ACM, LBP, or Hazardous Building Material (HBM) of the property to be evaluated. No survey/sampling can wholly eliminate uncertainty regarding the potential ACM, LBP, or HBM in connection with a property. Performance of this practice is intended to reduce, but not eliminate, uncertainty regarding the potential for ACM, LBP, and HBM in connection with a property.

The level of inquiry is variable. Not every property will warrant the same level of assessment for ACM, LBP, and HBM.

NPS – Gaston Motel July 18, 2023

Consistent with good commercial or customary practices, the appropriate level of assessment will be guided by the type of property subject to assessment, the intended use of the property, the expertise and risk tolerance of the CLIENT, and the information developed in the course of the assessment.

NOVA's findings, opinions, conclusions and recommendations are based on information obtained through visual assessment of surficial conditions in readily accessible areas.

It is possible that additional ACM, LBP, or HBM exist or may subsequently become known that may impact or change the assessment after NOVA's services are complete.

NOVA’s assessment represents our professional opinion, only. Therefore, NOVA cannot, under any circumstances, make a statement of warranty or guarantee, expressed or implied, that ACM, LBP, and HBM are limited to those that are discovered while we are performing the Sampling.

2.4 USER RELIANCE

NOVA’s Pre-Renovation Asbestos Containing Material Survey, Lead Based Paint Survey, and Hazardous Building Material Inventory, along with the findings and conclusions contained in the report, either in completed form, summary form, or by extraction, is prepared, and intended, for the sole use of Houser Walker Architecture (CLIENT) and therefore may not contain sufficient information for other purposes or parties. The

CLIENT is the only intended beneficiary of this report. The contents of NOVA's report will continue to be the property of NOVA. NOVA's report may not be disclosed to, used by, or relied upon by, any person or entity other than the CLIENT without the express written consent of NOVA.

Authorization for disclosure to a third party or authorization for third-party reliance on a final report of any report will be considered by NOVA upon the written request of the

CLIENT. NOVA reserves the right to deny authorization to allow disclosure or reliance of

NOVA's report to third parties.

NPS – Gaston Motel July 18, 2023

3.0 ASBESTOS CONTAINING MATERIAL

3.1 FIELD AND LABORATORY SERVICES

Mr. Curtis Moses, a NOVA professional, and federal and state certified asbestos inspector, performed the field work for the Pre-Renovation Asbestos Containing Material

Survey at the Subject Property.

3.1.1 ASBESTOS CONTAINING MATERIAL SAMPLING

The building area was visually assessed by NOVA to identify suspect ACM, which were then grouped into three categories according to their intended use:

• Surfacing Material such as sprayed-on or troweled fireproofing, acoustical and decorative insulation, textured “popcorn” finishes, paint, stucco, etc.

• Thermal System Insulation (TSI), such as pipe, boiler and storage tank insulation, and insulation on ducts, pumps, heat exchangers, and other equipment.

• Miscellaneous Material, such as floor and ceiling tiles, wallboard, asbestos-cement board, siding and other building material that did not fall into one of the previously mentioned categories.

Where applicable, material with similar texture, color and general appearance were considered homogeneous for sampling purposes, including visually similar material on different floors. NOVA’s assessment also included touching representative samples to determine friability, a mechanical classification defined as whether a material can be crumbled, pulverized, or reduced to powder by hand pressure.

Bulk samples were subsequently obtained in general accordance with the AHERA (40

CFR 763.86, Sampling) and ASTM E2356-18 procedures. The samples were placed in appropriate containers, and the containers sealed and labeled with a unique identification number. The samples were subsequently transported (following routine industry practices and chain-of-custody procedures) to EMSL Analytical, LLC (EMSL) for analysis.

The ACM samples were analyzed for asbestos using Polarized Light Microscopy (PLM) methods in accordance with EPA Method 600/R-93/116. Copies of the complete asbestos laboratory report and chain-of custody are included in Appendix B.

Using the results of the laboratory analysis and NOVA’s visual assessment, the asbestos containing building material can be further categorized into three groups:

NPS – Gaston Motel July 18, 2023

• Friable ACM - Material means any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40

CFR part 763 Section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

• Category I Nonfriable ACM - Asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40

CFR part 763, Section 1, Polarized Light Microscopy.

• Category II Nonfriable ACM - Any material, excluding Category I Nonfriable ACM, containing more than one percent (1%) asbestos as determined using the methods specified in Appendix A, Subpart F, 40 CFR part 763, Section 1, Polarized Light

Microscopy that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

During this study, forty-one (41) samples (containing 61 total layers) of floor tile, mastic, leveler, glue, joint compound, Thermal System Insulation (TSI), cement, ceiling texture, window glazing, caulking material, wallboard, grout, and mortar were analyzed by NOVA using Polarized Light Microscopy (PLM) with sixteen (16) analyzed sample layers indicating Asbestos Containing Material (ACM). A sample location plan is included in

Appendix A of this Report.

Black Mastic

• A total of twelve (12) samples of the black mastic located throughout the Subject

Property indicated >1% asbestos (3% Chrysotile Asbestos). Consequently, we believe all of the black mastic located at the Subject Property should be considered

Asbestos Containing Material (ACM).

Green/Brown Leveler

• A total of two (2) samples of the green/brown leveler located in the front lobby and restroom at the Subject Property indicated >1% asbestos (3% - 5% Chrysotile

Asbestos). Consequently, we believe all of the green/brown leveler located at the

Subject Property should be considered Asbestos Containing Material (ACM).

Black Cement

• A total of five (2) samples of the black cement associated with the top of the wood framing located at the Subject Property indicated >1% asbestos (5% Chrysotile

Asbestos). Consequently, we believe all of the black cement located at the Subject

Property should be considered Asbestos Containing Material (ACM).

NPS – Gaston Motel July 18, 2023

A complete list of suspected ACM samples obtained is located in Appendix B of this report.

3.2 ASBESTOS ABATEMENT

Any component, which is similar in appearance to, and is in the general vicinity or similar application of samples identified as containing asbestos, as well as any other materials not shown by proper sampling and analysis to be non-asbestos containing, should be handled as asbestos-containing materials (ACM). As previously noted, determination of the actual quantities of ACM at all locations should be made by the contractor during a site inspection prior to beginning abatement.

ACM should be abated (removed) prior to disturbance by maintenance, renovation and/or demolition by a licensed asbestos abatement contractor and disposed at an approved solid waste disposal facility.

Abatement is highly regulated and consists of several parts. In addition to the demolition/renovation permit, an advance notification to the Alabama Department of

Environmental Management is required.

During abatement, third party monitoring is recommended to review if the asbestos is adequately managed and contained during the abatement process and to document clearance and re-occupancy criteria established for the project.

Most Clients also request an abatement management report. This report compiles pertinent data regarding the personnel, abatement, and asbestos disposal for liability management after the fact should there be concerns later from workers or others. The ten (10) day notice, abatement, third party oversight, and management report are not included with the authorized scope of work for this project, but we can provide these supplemental services, if desired. Please note that the means and methods necessary for ACM abatement, as well as worker protection and monitoring, are the sole responsibility of the abatement contractor.

NPS – Gaston Motel July 18, 2023

4.0 LEAD BASED PAINT & LEAD CONTAINING PAINT

4.1 DEFINITIONS

concentration >0.5% by weight when determined by laboratory analysis, (1972, Lead

Based Paint Poison Prevention Act (LBPPPA)). LBP is also defined by HUD as 1.0 mg/cm2 when determined using x-ray fluorescence (XRF) analyzer. These concentrations are applicable for housing and child-care facilities; however, these concentration levels are also frequently used as targets in commercial projects to allow flexibility in future area usage.

Lead Containing Paint (LCP) was defined as a paint or varnish containing lead at a concentration >0.06% by weight (600 ppm) when determined by laboratory analysis, (1978, LBPPPA). In 2009, LCP was further defined as containing lead at a concentration

>0.009% by weight (90 ppm) for certain consumer products and residential use.

Please note that OSHA does not define Lead Based Paint based on lead content. Any detectable lead in a paint or varnish makes it lead paint for purposes of complying with

OSHA regulations to determine worker exposure. Consequently, for purposes of this study, Lead Containing Paint is considered any detectable lead.

4.2 FIELD AND LABORATORY SERVICES

Mr. Curtis Moses, a NOVA professional and EPA certified lead inspector, performed the field work for the Lead Based Paint Survey at the Subject Property on March 16, 2023.

Ninety-one (91) X-ray fluorescence (XRF) analyzer readings were made by NOVA throughout the interior of the Subject Property structure to determine the presence of

Lead Based Paint (LBP).

4.2.1 LEAD BASED PAINT SAMPLING

Where applicable, material with similar texture, color and general appearance were considered homogeneous for sampling purposes, including visually similar material on different floors and/or different buildings.

NOVA’s XRF readings are presented below:

No. Time Units Component Substrate Side Condition Color Results PbC Error

1 3/16/2023 10:01 cps 2.72 0

2 3/16/2023 10:03 mg / cm ^2 calibration positive 1 0.1

3 3/16/2023 10:03 mg / cm ^2 calibration positive 1.1 0.1

NPS – Gaston Motel July 18, 2023

No. Time Units Component Substrate Side Condition Color Results PbC Error

4 3/16/2023 10:05 mg / cm ^2 calibration positive 1 0.1

5 3/16/2023 10:05 mg / cm ^2 beam metal A intact orange positive 5.6 3.7

6 3/16/2023 10:07 mg / cm ^2 grate metal A intact black negative < LOD 0.03

7 3/16/2023 10:07 mg / cm ^2 grate metal A intact black negative < LOD 0.03

8 3/16/2023 10:08 mg / cm ^2 window wood A intact stain negative < LOD 0.03

9 3/16/2023 10:08 mg / cm ^2 window wood C intact stain negative < LOD 0.03

10 3/16/2023 10:09 mg / cm ^2 door metal C intact orange negative < LOD 0.03

11 3/16/2023 10:09 mg / cm ^2 door metal C intact orange negative < LOD 0.03

12 3/16/2023 10:10 mg / cm ^2 grate metal A intact black negative < LOD 0.03

13 3/16/2023 10:11 mg / cm ^2 grate metal A intact black negative < LOD 0.03

14 3/16/2023 10:13 mg / cm ^2 grate metal A intact black negative < LOD 0.03

15 3/16/2023 10:14 mg / cm ^2 grate metal A intact black negative < LOD 0.03

16 3/16/2023 10:15 mg / cm ^2 column metal A intact orange positive 5.6 2.1

17 3/16/2023 10:15 mg / cm ^2 beam metal A intact orange positive 6.3 2.2

18 3/16/2023 10:16 mg / cm ^2 grate metal A intact black negative < LOD 0.03

19 3/16/2023 10:18 mg / cm ^2 wall concrete C intact white negative < LOD 0.03

20 3/16/2023 10:19 mg / cm ^2 wall concrete D intact white negative < LOD 0.03

22 3/16/2023 10:21 mg / cm ^2 wall concrete D intact green negative < LOD 0.6

23 3/16/2023 10:22 mg / cm ^2 grate metal D intact black negative < LOD 0.03

24 3/16/2023 10:24 mg / cm ^2 wall concrete C intact green negative < LOD 0.03

26 3/16/2023 10:25 mg / cm ^2 grate metal A intact black negative < LOD 0.03

27 3/16/2023 10:35 mg / cm ^2 pipe metal B intact black negative < LOD 0.03

28 3/16/2023 10:35 mg / cm ^2 pipe metal B intact black negative < LOD 0.03

29 3/16/2023 10:36 mg / cm ^2 grate metal A intact black negative < LOD 0.03

30 3/16/2023 10:37 mg / cm ^2 grate metal A intact black negative < LOD 0.03

31 3/16/2023 10:38 mg / cm ^2 floor ceramic A intact tan negative < LOD 0.03

32 3/16/2023 10:39 mg / cm ^2 floor ceramic A intact tan negative < LOD 0.03

33 3/16/2023 10:41 mg / cm ^2 grate metal A intact black negative < LOD 0.03

34 3/16/2023 10:42 mg / cm ^2 door metal A intact orange negative < LOD 0.03

35 3/16/2023 10:43 mg / cm ^2 door wood A intact orange negative < LOD 0.03

36 3/16/2023 10:43 mg / cm ^2 railing metal D intact green negative < LOD 0.03

37 3/16/2023 10:44 mg / cm ^2 railing metal D intact green negative < LOD 0.03

38 3/16/2023 10:44 mg / cm ^2 railing metal D intact green negative < LOD 0.03

39 3/16/2023 10:45 mg / cm ^2 railing metal D intact green negative < LOD 0.03

40 3/16/2023 10:45 mg / cm ^2 railing metal D intact green negative < LOD 0.03

41 3/16/2023 10:47 mg / cm ^2 railing metal D intact green negative < LOD 0.03

42 3/16/2023 10:48 mg / cm ^2 railing metal D intact green negative < LOD 0.03

43 3/16/2023 10:49 mg / cm ^2 ceiling concrete A intact white negative < LOD 0.03

45 3/16/2023 10:50 mg / cm ^2 ceiling concrete A intact white negative < LOD 0.03

46 3/16/2023 10:51 mg / cm ^2 trim wood A intact brown negative < LOD 0.03

47 3/16/2023 10:51 mg / cm ^2 wall wood C intact brown negative < LOD 0.03

48 3/16/2023 10:52 mg / cm ^2 door metal C intact orange negative < LOD 0.03

49 3/16/2023 10:52 mg / cm ^2 door wood C intact orange negative < LOD 0.03

50 3/16/2023 10:52 mg / cm ^2 window metal C intact orange negative < LOD 0.03

NPS – Gaston Motel July 18, 2023

No. Time Units Component Substrate Side Condition Color Results PbC Error

51 3/16/2023 10:53 mg / cm ^2 floor concrete C intact gray negative < LOD 0.03

52 3/16/2023 10:54 mg / cm ^2 floor concrete C intact gray negative < LOD 0.03

53 3/16/2023 10:55 mg / cm ^2 riser metal C intact green negative < LOD 0.03

54 3/16/2023 10:55 mg / cm ^2 riser metal C intact green negative < LOD 0.03

55 3/16/2023 10:56 mg / cm ^2 tread metal C intact green negative < LOD 0.03

56 3/16/2023 10:58 mg / cm ^2 tread metal C intact green negative < LOD 0.03

57 3/16/2023 10:58 mg / cm ^2 rail metal C intact green negative < LOD 0.03

58 3/16/2023 10:59 mg / cm ^2 rail metal C intact green negative < LOD 0.03

59 3/16/2023 11:00 mg / cm ^2 walk beam metal C intact green negative < LOD 0.03

60 3/16/2023 11:01 mg / cm ^2 ceiling concrete C intact white negative < LOD 0.03

61 3/16/2023 11:02 mg / cm ^2 door metal C intact orange negative < LOD 0.03

62 3/16/2023 11:03 mg / cm ^2 door wood C intact orange negative < LOD 0.03

63 3/16/2023 11:03 mg / cm ^2 door wood D intact orange negative < LOD 0.03

64 3/16/2023 11:03 mg / cm ^2 door metal D intact orange negative < LOD 0.03

65 3/16/2023 11:04 mg / cm ^2 door metal D intact orange negative < LOD 0.03

66 3/16/2023 11:04 mg / cm ^2 door wood D intact orange negative < LOD 0.03

67 3/16/2023 11:05 mg / cm ^2 window metal D intact orange negative < LOD 0.03

68 3/16/2023 11:05 mg / cm ^2 window metal D intact orange negative < LOD 0.03

69 3/16/2023 11:06 mg / cm ^2 gate metal D intact green negative < LOD 0.03

70 3/16/2023 11:07 mg / cm ^2 riser metal D intact green negative < LOD 0.03

71 3/16/2023 11:08 mg / cm ^2 grate metal D intact black negative < LOD 0.03

72 3/16/2023 11:09 mg / cm ^2 grate metal D intact black negative < LOD 0.03

73 3/16/2023 11:09 mg / cm ^2 riser metal D intact brown positive 1.9 0.6

74 3/16/2023 11:10 mg / cm ^2 wall concrete D intact brown negative < LOD 0.03

75 3/16/2023 11:11 mg / cm ^2 wall concrete D intact brown negative < LOD 0.03

76 3/16/2023 11:11 mg / cm ^2 riser metal D intact green positive 4.6 1.6

77 3/16/2023 11:11 mg / cm ^2 riser concrete D intact green negative < LOD 0.04

78 3/16/2023 11:12 mg / cm ^2 riser metal D intact green positive 3.1 1.2

79 3/16/2023 11:13 mg / cm ^2 door wood A intact brown negative < LOD 0.03

80 3/16/2023 11:17 mg / cm ^2 window metal A intact orange negative < LOD 0.03

81 3/16/2023 11:22 mg / cm ^2 column metal A intact green negative < LOD 0.03

82 3/16/2023 11:22 mg / cm ^2 window wood A intact stain negative < LOD 0.03

83 3/16/2023 11:23 mg / cm ^2 window wood A intact stain negative < LOD 0.03

84 3/16/2023 11:24 mg / cm ^2 door metal B intact tan negative < LOD 0.03

85 3/16/2023 11:24 mg / cm ^2 door metal B intact tan negative < LOD 0.03

86 3/16/2023 11:26 mg / cm ^2 wall brick A intact tan negative < LOD 0.03

87 3/16/2023 11:26 mg / cm ^2 wall brick A intact green negative < LOD 0.03

88 3/16/2023 11:33 mg / cm ^2 wall brick A intact green negative < LOD 0.03

89 3/16/2023 11:39 mg / cm ^2 calibration positive 1 0.1

90 3/16/2023 11:40 mg / cm ^2 calibration positive 1 0.1

91 3/16/2023 11:42 mg / cm ^2 calibration positive 1 0.1

< LOD = below level of detection

NPS – Gaston Motel July 18, 2023

Lead Based Paint concentration >0.5% by weight when determined by laboratory analysis. LBP is also defined by HUD as 1.0 mg/cm2 when determined using an XRF analyzer.

The predominant LBP material identified by the NOVA survey include:

• Painted surfaces of metal structural beams and columns located at the Subject

Property; and

• Painted surfaces of metal stairwell riser components located at the Subject Property.

Lead Containing Paint

OSHA does not define Lead Based Paint based on lead content. Any detectable lead in a paint or varnish makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure. Consequently, for purposes of this study, Lead

Containing Paint is considered any detectable level of lead.

The predominant LCP material identified by the NOVA survey include:

• Painted green surfaces of concrete located at the Subject Property.

4.3 LEAD ABATEMENT ACTIVITIES

The US EPA has stated that solid architectural components coated with LBP are less likely to be hazardous because of the small ratio of lead paint to total waste mass (US

EPA, 1993, Applicability of RCRA Disposal Requirements to Lead-Based Paint

Abatement Wastes, Final Report, EPA 747-R-93-006 Technical Programs Branch, Office of Pollution Prevention and Toxics, March 1993).

The US Army conducted a study which concluded that whole-building demolition debris is not likely to exceed the toxicity characteristic standard for lead if it is handled as a single, whole waste stream and disposed of all together (US Dept. of the Army, US Army

Environmental Hygiene Agency, Interim Final Report, Lead-Based Paint Contaminated

Debris Waste Characterization Study No. 27-26-JK44-92. May 1993). Consequently, whole-building demolition debris is typically considered a non-hazardous waste with regard to lead under RCRA.

We believe the greatest impact of LBP and/or LCP may be on the contractor’s salvage activities of railing, doorframes, etc.., particularly activities that include cutting, grinding, sanding or scraping.

NPS – Gaston Motel July 18, 2023

As previously noted, OSHA does not define lead paint based on content. Any detectable lead in paint makes it lead paint for purposes of complying with OSHA regulations to determine worker exposure.

• The contractor must conduct an initial exposure assessment of all workplaces and operations where lead or lead-containing material is being used, disturbed or removed to determine whether any employee may be exposed to lead at or above the action level.

• Personnel involved in LBP or LCP must be monitored and directed by a Competent

Person who will determine appropriate compliance controls and procedures.

• The Lead in Construction standard's action level is 30 ug/m3 calculated as an 8-hour time-weighted average.

In addition, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning. Under the rule, beginning April

22, 2010, contractors performing abatement, renovation, repair and painting projects that disturb lead-based paint in homes, child-care facilities, and schools (K-12) built before 1978 must be certified by EPA and must follow specific lead-safe work practices to prevent lead contamination.

Persons performing lead-based paint (LBP) abatement activities must:

• Be certified

• Work for a Certified Lead Firm

Persons performing renovation work must:

• Be a certified Renovator

• Work for a Certified Renovation Firm

The EPA and the also regulate the LBP and LCP waste stream resulting from abatement and renovation activities. A potential lead waste material must be analyzed for toxicity using the Toxicity Characteristic Leachate Procedure (TCLP).

• If TCLP results from waste stream of paint chips, dust (including dust from floor refinishing operations), soil, and/or stripper sludge are less than 5 milligrams per liter (5 parts per million or ppm), the waste may usually go to a municipal solid waste

(MSW) or construction debris (CD) landfill, depending on concentrations and landfill operator requirements.

NPS – Gaston Motel July 18, 2023

• If greater than 5 milligrams per liter (5 ppm) must comply with Georgia State Rules for Hazardous Waste Management.

Please note that the means and methods necessary for LBP and/or LCP abatement or demolition, as well as worker protection and monitoring, are the sole responsibility of the contractor.

NPS – Gaston Motel July 18, 2023

5.0 HAZARDOUS BUILDING MATERIAL INVENTORY

5.1 FIELD SERVICES

Mr. Curtis Moses, a NOVA Professional, performed the field work for the Hazardous

Building Material Inventory (HBMI) for the Subject Property.

5.2 HAZARDOUS BUILDING MATERIAL INVENTORY

observed at the Subject Property. Potential HBM observed at the Subject Property include LED lighting, and miscellaneous facility construction/maintenance chemicals.

The Subject Property was gutted down to only wood framing and concrete walls/floors at the time of NOVA’s on-site Hazardous Building Material Inventory (HBMI).

The materials identified are listed below:

SUMMARY OF HAZARDOUS BUILDING MATERIAL FINDINGS

MATERIAL / EQUIPMENT LOCATION ESTIMATED QUANTITY

LED Lighting Exterior Walkway 10

LED Lighting Pole Mounted 2

LED Lighting Front of Structure 1

M 200 - Sealant Northwest Entry 4 – 1 Gallon

Containers

Paint Thinner Northwest Entry 1 Container

5 Gallon Primer Northwest Entry 3 – 5 Gallon

Containers

Fluorokem Coating Northwest Entry 2 – 32oz Containers

Henry CM100 - Roofing

Cement Northwest Entry

2 – 5 Gallon

Containers

Pecora 890 NST Northwest Entry 4 Box’s

Sustain 1195 - Stain Northwest Entry 1 – 5 Gallon Container

Additionally, a small amount of chemicals associated with cleaning/maintenance were observed throughout the facility.

It should be noted that the above list is an approximation of what was observed by NOVA at the time of the site reconnaissance.

NPS – Gaston Motel June 28, 2023

Houser Walker Architecture NOVA Project Number 10102-3023033

5.3 HAZARDOUS BUILDING MATERIAL INVENTORY CONCLUSIONS

observed at the Subject Property. Potential HBM observed at the Subject Property include

LED lighting, and miscellaneous facility construction/maintenance chemicals. The

Subject Property was gutted down to only wood framing and concrete walls/floors at the time of NOVA’s on-site Hazardous Building Material Inventory (HBMI).

The removal and proper disposal of the HBM identified within this report should be managed in accordance with the following rules:

• Solid Waste Management – Georgia Environmental Rule 391-3-4

• Hazardous Waste Management – Georgia Environmental Rule 391-3-11

Batteries: All batteries should be removed from equipment and transported for recycling in accordance with applicable regulations. Additional batteries likely associated with the security, emergency lighting, and fire warning systems should be disposed properly.

Fluorescent and Incandescent Light Bulbs: Bulbs should be disposed in accordance with Resource Conservation & Recovery Act (RCRA):

• Subtitle C: Hazardous Waste (40 CFR Parts 261, 262), or if found to be non-hazardous;

• Subtitle D: Municipal & Other Non-Hazardous Waste (40 CFR 258).

Chemical Waste: All chemicals, including cleaning/maintenance/construction chemicals, should be removed, transported and disposed in accordance with applicable regulations.

Electronic devices: Computer monitors, computer hard drives, printers, telephones, refrigerators, LED lighting, thermostats, and microwave ovens can contain chemicals such as lead, cadmium, chromium, mercury and copper. Caution should be used during the removal of these devices, and they should be disposed in accordance with applicable regulations.

APPENDIX A

SAMPLE LOCATION PLANS

SITE PHOTOGRAPHS

SAMPLE LOCATION PLAN

First Floor

NPS GASTON MOTEL

HOUSER WALKER ARCHITECTURE

BIRMINGHAM, JEFFERSON COUNTY, ALABAMa aNOVA Project Number 10102-3023033.1

Asbestos Containing Material

Non-Asbestos Containing Material

Lead Based Paint

Lead Containing Paint

No Detect

A-FT-1

A-FT-2

A-M-3

A-M-4

A-G-5

A-G-6

A-G-7

A-G-8

A-JC-9

A-JC-10

A-JC-11

A-JC-14A-TSI-17A-TSI-15 A-TSI-16A-CT-20

A-C-18

A-C-19

A-CT-21

A-CT-22

A-W-23

A-C-25

A-GM-39

12 13

41 42

58 59 60 6162 6364 65

66 67

SAMPLE LOCATION PLAN

Second Floor

NPS GASTON MOTEL

HOUSER WALKER ARCHITECTURE

BIRMINGHAM, JEFFERSON COUNTY, ALABAMA

NOVA Project Number 10102-3023033.1

Asbestos Containing Material

Non-Asbestos Containing Material

Lead Based Paint

Lead Containing Paint

No Detect

A-W-24

A-CT-27

A-CT-28

A-C-26

A-G-37

A-W-30

A-GM-38A-FT-34

A-G-35

A-JC-31

A-GM-40

A-W-29

A-JC-32

A-JC-33

A-G-36

A-GM-41

27 28

29 30

32 33

373839

40 4344 45 464748 49

Birmingham, Jefferson County, Georgia

NOVA Project Number 10102-3023033

Photograph 1: Typical view of the exterior of the Subject Property.

Photograph 2: Typical view of the exterior LED lighting located along the walkway at the Subject Property.

Photograph 3: Additional view of the exterior LED lighting located along the walkway at the Subject Property.

Photograph 4: View of the LED fixture located at the front entry to the Subject Property.

Photograph 5: View of the Pecora 890 NST located in the northwest entry storage at the Subject Property.

Photograph 6: Typical view of the Henry CM100 roofing cement (5 gallon) located in the northwest entry storage at the Subject Property.

Photograph 7: View of the M 200 sealant (1 gallon) and paint thinner located in the northwest entry storage at the Subject Property.

Photograph 8: View of the Sustain 1195 (5 gallon) located in the northwest entry storage at the Subject Property.

Photograph 9: Typical view primer and coating located in the northwest entry storage at the Subject Property.

Photograph 10: Typical view of the pole mounted LED lighting located along the northwest border of the Subject Property.

APPENDIX B

LABORATORY ANALYTICAL DATA

XRF DATA

EMSL Analytical, Inc.

2205 Corporate Plaza Parkway SE, Suite 200 Smyrna, GA 30080

Tel/Fax: (770) 956-9150 / (770) 956-9181 http://www.EMSL.com / atlantalab@emsl.com

072304427EMSL Order:

Customer ID: NOVA30

Customer PO: 3023033

Project ID:

Attention: Phone:Curtis Moses (678) 982-5576

Fax:Nova Engineering & Environmental, Inc. (770) 425-1113

Received Date:3900 Kennesaw 75 Parkway 05/22/2023 2:30 PM

Analysis Date:Suite 100 05/26/2023

Collected Date:Kennesaw, GA 30144

Project: 3023033

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-FT-1-Floor Tile

072304427-0001

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Residual Tile with

Mastic / Tan - Front

Restoom - 2

A-FT-1-Mastic

072304427-0001A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Residual Tile with

Mastic / Tan - Front

Restoom - 2

A-FT-2-Floor Tile

072304427-0002

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Residual Tile with

Mastic / Tan - Corner

Restroom - 1

A-FT-2-Mastic

072304427-0002A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Residual Tile with

Mastic / Tan - Corner

Restroom - 1

A-M-3-Leveler

072304427-0003

5% ChrysotileNon-fibrous (Other)95%Green

Non-Fibrous

Homogeneous

Leveler with Black

Mastic - Front

Restroom

A-M-3-Mastic

072304427-0003A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Leveler with Black

Mastic - Front

Restroom

A-M-4-Leveler

072304427-0004

2% ChrysotileNon-fibrous (Other)98%Brown

Non-Fibrous

Homogeneous

Leveler with Black

Mastic - Front

Lobby/Hall

A-M-4-Mastic 1

072304427-0004A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Leveler with Black

Mastic - Front

Lobby/Hall

A-M-4-Mastic 2

072304427-0004B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Leveler with Black

Mastic - Front

Lobby/Hall

A-G-5-Leveler

072304427-0005

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - Front

Office

A-G-5-Mastic 1

072304427-0005A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - Front

Office

A-G-5-Mastic 2

072304427-0005B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - Front

Office

A-G-6-Leveler

072304427-0006

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - Hall

A-G-6-Mastic 1

072304427-0006A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - Hall

A-G-6-Mastic 2

072304427-0006B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - Hall

A-G-7-Leveler

072304427-0007

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

South

Initial report from: 05/30/2023 11:24:02

Page 1 of 4ASB_PLM_0008_0001 - 1.78 Printed: 5/30/2023 11:24 AM

Tel/Fax: (770) 956-9150 / (770) 956-9181 http://www.EMSL.com / atlantalab@emsl.com

072304427EMSL Order:

Customer ID: NOVA30

Customer PO: 3023033

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-G-7-Mastic 1

072304427-0007A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

South

A-G-7-Mastic 2

072304427-0007B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

South

A-G-8-Leveler

072304427-0008

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

NW

A-G-8-Mastic 1

072304427-0008A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

NW

A-G-8-Mastic 2

072304427-0008B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - Rooms

NW

A-JC-9

072304427-0009

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Entry Office on Wood

Frame

A-JC-10

072304427-0010

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Room on Concrete

Wall - S

A-JC-11

072304427-0011

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Room on Concrete

Wall - N

A-JC-14

072304427-0012

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Room on Wood

Frame - NW

A-TSI-15

072304427-0013

None DetectedNon-fibrous (Other)30%Cellulose70%Various

Fibrous

Homogeneous

TSI - Floor to 2nd

Insulation - Rooms -

South

Result includes a small amount of inseparable attached material

A-TSI-16

072304427-0014

None DetectedNon-fibrous (Other)30%Cellulose70%Various

Fibrous

Homogeneous

TSI - Floor to 2nd

Insulation - Rooms -

Mid

Result includes a small amount of inseparable attached material

A-TSI-17

072304427-0015

None DetectedNon-fibrous (Other)30%Cellulose70%Various

Fibrous

Homogeneous

TSI - Floor to 2nd

Insulation - Rooms -

NW

Result includes a small amount of inseparable attached material

A-C-18

072304427-0016

5% ChrysotileNon-fibrous (Other)95%Black

Non-Fibrous

Homogeneous

Cement On Wood

Framing - at Ceiling

A-C-19

072304427-0017

5% ChrysotileNon-fibrous (Other)95%Black

Non-Fibrous

Homogeneous

Cement On Wood

Framing - at Door

A-CT-20

072304427-0018

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Ceiling Texture -

Residual - Center

Door Framing

A-CT-21

072304427-0019

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Ceiling Texture -

Residual - Center

Door Framing

A-CT-22

072304427-0020

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Ceiling Texture -

Residual - Center

Door Framing

A-W-23

072304427-0021

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Window Glazing -

Corner Unit NW - 1st

Floor

Page 2 of 4ASB_PLM_0008_0001 - 1.78 Printed: 5/30/2023 11:24 AM

Tel/Fax: (770) 956-9150 / (770) 956-9181 http://www.EMSL.com / atlantalab@emsl.com

072304427EMSL Order:

Customer ID: NOVA30

Customer PO: 3023033

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-W-24

072304427-0022

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Window Glazing -

Corner Unit NW - 2nd

Floor

A-C-25

072304427-0023

None DetectedNon-fibrous (Other)100%Red

Non-Fibrous

Homogeneous

Frame Caulking -

Corner Unit NW - 1st

Floor

A-C-26

072304427-0024

None DetectedNon-fibrous (Other)100%Red

Non-Fibrous

Homogeneous

Frame Caulking -

Corner Unit NW - 2nd

Floor

A-CT-27

072304427-0025

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Ceiling Texture -

Residual - Center

Frame

A-CT-28

072304427-0026

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Ceiling Texture -

Residual - NW Frame

A-W-29

072304427-0027

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Wallboard - Residual

- Back Wall - S

A-W-30

072304427-0028

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Wallboard - Residual

- Back Wall - N

A-JC-31

072304427-0029

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Back Wall - S

A-JC-32

072304427-0030

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Back Wall - Center

A-JC-33

072304427-0031

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Joint Compound -

Frame - NW

A-FT-34-Floor Tile

072304427-0032

None DetectedNon-fibrous (Other)100%Tan

Non-Fibrous

Homogeneous

Residual Tile with

Mastic - Retroom -

Center

A-FT-34-Mastic

072304427-0032A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Residual Tile with

Mastic - Retroom -

Center

A-G-35-Leveler

072304427-0033

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue with

Leveler - Room -

South

A-G-35-Mastic 1

072304427-0033A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue with

Leveler - Room -

South

A-G-35-Mastic 2

072304427-0033B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue with

Leveler - Room -

South

A-G-36-Leveler

072304427-0034

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - NW

Room with Leveler

A-G-36-Mastic 1

072304427-0034A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - NW

Room with Leveler

A-G-36-Mastic 2

072304427-0034B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - NW

Room with Leveler

A-G-37-Leveler

072304427-0035

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Carpet Glue - Center

Room with Leveler

Page 3 of 4ASB_PLM_0008_0001 - 1.78 Printed: 5/30/2023 11:24 AM

Tel/Fax: (770) 956-9150 / (770) 956-9181 http://www.EMSL.com / atlantalab@emsl.com

072304427EMSL Order:

Customer ID: NOVA30

Customer PO: 3023033

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

A-G-37-Mastic 1

072304427-0035A

3% ChrysotileNon-fibrous (Other)97%Black

Non-Fibrous

Homogeneous

Carpet Glue - Center

Room with Leveler

A-G-37-Mastic 2

072304427-0035B

None DetectedNon-fibrous (Other)100%Yellow

Non-Fibrous

Homogeneous

Carpet Glue - Center

Room with Leveler

A-GM-38

072304427-0036

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Grout/Mortar - 2nd

Floor Rear Wall

A-GM-39

072304427-0037

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Grout/Mortar - at

Brick

A-GM-40

072304427-0038

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Grout/Mortar -

Flooring

A-GM-41-Ceramic Tile

072304427-0039

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Grout/Mortar -

Flooring

A-GM-41-Grout

072304427-0039A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Grout/Mortar -

Flooring

A-GM-41-Backing

072304427-0039B

None DetectedNon-fibrous (Other)40%Cellulose60%Various

Fibrous

Homogeneous

Grout/Mortar -

Flooring

Analyst(s)

Kyle Rich (61) Violedah Richardson, Laboratory Manager or Other Approved Signatory

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 Smyrna, GA NVLAP Lab Code 101048-1

Page 4 of 4ASB_PLM_0008_0001 - 1.78 Printed: 5/30/2023 11:24 AM

OrderID: 072304427

1 3/16/2023 10:01 cps 2.72 0

2 3/16/2023 10:03 mg / cm ^2 calibration positive 1 0.1

3 3/16/2023 10:03 mg / cm ^2 calibration positive 1.1 0.1

4 3/16/2023 10:05 mg / cm ^2 calibration positive 1 0.1

5 3/16/2023 10:05 mg / cm ^2 beam metal A intact orange positive 5.6 3.7

6 3/16/2023 10:07 mg / cm ^2 grate metal A intact black negative < LOD 0.03

7 3/16/2023 10:07 mg / cm ^2 grate metal A intact black negative < LOD 0.03

8 3/16/2023 10:08 mg / cm ^2 window wood A intact stain negative < LOD 0.03

9 3/16/2023 10:08 mg / cm ^2 window wood C intact stain negative < LOD 0.03

10 3/16/2023 10:09 mg / cm ^2 door metal C intact orange negative < LOD 0.03

11 3/16/2023 10:09 mg / cm ^2 door metal C intact orange negative < LOD 0.03

12 3/16/2023 10:10 mg / cm ^2 grate metal A intact black negative < LOD 0.03

13 3/16/2023 10:11 mg / cm ^2 grate metal A intact black negative < LOD 0.03

14 3/16/2023 10:13 mg / cm ^2 grate metal A intact black negative < LOD 0.03

15 3/16/2023 10:14 mg / cm ^2 grate metal A intact black negative < LOD 0.03

16 3/16/2023 10:15 mg / cm ^2 column metal A intact orange positive 5.6 2.1

17 3/16/2023 10:15 mg / cm ^2 beam metal A intact orange positive 6.3 2.2

18 3/16/2023 10:16 mg / cm ^2 grate metal A intact black negative < LOD 0.03

19 3/16/2023 10:18 mg / cm ^2 wall concrete C intact white negative < LOD 0.03

20 3/16/2023 10:19 mg / cm ^2 wall concrete D intact white negative < LOD 0.03

22 3/16/2023 10:21 mg / cm ^2 wall concrete D intact green negative < LOD 0.6

23 3/16/2023 10:22 mg / cm ^2 grate metal D intact black negative < LOD 0.03

24 3/16/2023 10:24 mg / cm ^2 wall concrete C intact green negative < LOD 0.03

26 3/16/2023 10:25 mg / cm ^2 grate metal A intact black negative < LOD 0.03

27 3/16/2023 10:35 mg / cm ^2 pipe metal B intact black negative < LOD 0.03

28 3/16/2023 10:35 mg / cm ^2 pipe metal B intact black negative < LOD 0.03

29 3/16/2023 10:36 mg / cm ^2 grate metal A intact black negative < LOD 0.03

30 3/16/2023 10:37 mg / cm ^2 grate metal A intact black negative < LOD 0.03

31 3/16/2023 10:38 mg / cm ^2 floor ceramic A intact tan negative < LOD 0.03

32 3/16/2023 10:39 mg / cm ^2 floor ceramic A intact tan negative < LOD 0.03

33 3/16/2023 10:41 mg / cm ^2 grate metal A intact black negative < LOD 0.03

34 3/16/2023 10:42 mg / cm ^2 door metal A intact orange negative < LOD 0.03

35 3/16/2023 10:43 mg / cm ^2 door wood A intact orange negative < LOD 0.03

36 3/16/2023 10:43 mg / cm ^2 railing metal D intact green negative < LOD 0.03

37 3/16/2023 10:44 mg / cm ^2 railing metal D intact green negative < LOD 0.03

38 3/16/2023 10:44 mg / cm ^2 railing metal D intact green negative < LOD 0.03

39 3/16/2023 10:45 mg / cm ^2 railing metal D intact green negative < LOD 0.03

40 3/16/2023 10:45 mg / cm ^2 railing metal D intact green negative < LOD 0.03

41 3/16/2023 10:47 mg / cm ^2 railing metal D intact green negative < LOD 0.03

42 3/16/2023 10:48 mg / cm ^2 railing metal D intact green negative < LOD 0.03

43 3/16/2023 10:49 mg / cm ^2 ceiling concrete A intact white negative < LOD 0.03

45 3/16/2023 10:50 mg / cm ^2 ceiling concrete A intact white negative < LOD 0.03

46 3/16/2023 10:51 mg / cm ^2 trim wood A intact brown negative < LOD 0.03

47 3/16/2023 10:51 mg / cm ^2 wall wood C intact brown negative < LOD 0.03

48 3/16/2023 10:52 mg / cm ^2 door metal C intact orange negative < LOD 0.03

49 3/16/2023 10:52 mg / cm ^2 door wood C intact orange negative < LOD 0.03

50 3/16/2023 10:52 mg / cm ^2…