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This is a Lead-Containing Materials Paint Chip Analysis Report prepared by Titan Environmental Solutions, Inc. for the Denver CO ASDE Tower facility located at 8500 Pena Blvd, Denver, CO 80249 (Project Number 125602-LS). The report was issued on October 1, 2024, to Jonathan Moore, Project Management Specialist with S&K Engineering & Research at the FAA.

TES analyzed three paint chip samples collected from homogenous areas of suspected lead-based paints and lead-containing materials. The samples were tested by SGS Forensic Laboratories in Carson, California, an AIHA-accredited facility (AIHA-LAP #101629), using EPA Methods 3050B and 7000B with flame atomic absorption spectrophotometry (FAAS). All samples were submitted under proper Chain-of-Custody procedures. The analytical results identified all three samples as Lead-Containing Materials (LCM): Sample 01 from the base of tower leg (galvanized steel, orange) contained 480 ppm lead; Sample 02 from shelter level beam (galvanized steel, white) contained 900 ppm lead; and Sample 03 from under top platform beam (galvanized steel, orange) contained 3,700 ppm lead. TES recommends that any disturbance of these materials be performed by lead hazard communication trained workers using lead-safe work practices in accordance with 29 CFR 1926.62, ensuring exposures do not exceed the Action Level of 30 µg/m³ or the Permissible Exposure Limit of 50 µg/m³. All lead activities must comply with applicable federal, state, and local regulations.

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October 1st, 2024

Jonathan Moore Project Management Specialist AJW-L532 NAS Program Support Subteam S&K Engineering & Research jonathan.ctr.moore@faa.gov

RE: Lead Results

Denver CO ASDE Tower 8500 Pena Blvd, Denver, CO 80249 Project Number 125602-LS

Dear Jonathan Moore, Titan Environmental Solutions, Inc. (TES) received three (3) paint chip samples collected by the Client from homogenous areas of suspected lead-based paints and/or lead-containing materials (LBPs/LCMs) at the referenced property (Subject Property).

TES submitted the lead samples to an American Industrial Hygiene Association (AIHA) accredited laboratory under the Environmental Lead Laboratory Accreditation Program (ELLAP). The laboratory is also a participant in the AIHA Environmental Lead Proficiency Analytical Testing (ELPAT) Program and/or accredited by the California Water Resources Board (CWRB) under the Environmental Laboratory Accreditation Program (ELAP). All samples were submitted under proper Chain-of-Custody (COC) procedures.

The lead samples were analyzed by SGS Forensic Laboratories, located in Carson, California, which is accredited by AIHA under ELLAP (AIHA-LAP #101629). Paint chip sample extraction and analysis were performed in accordance with EPA Methods 3050B and 7000B, and total lead content was measured using flame atomic absorption spectrophotometry (FAAS).

Table 1-1 below provides a summary of the analytical results for the paint chip samples from the suspect LCM/LBP areas.

Lead-Containing Materials Paint Chip Analysis

8500 Pena Blvd, Denver, CO 80249 Project Number 125602-LS

October 1, 2024

Table 1-1: Lead Paint Chip Sampling FAAS Analytical Results

Sample No.

Sample Locations Component / Substrate Color Lead

Concentration

(PPM)

Category

01 Base of Tower Leg / Galvanized Steel Orange 480 LCM

02 Shelter Level Beam / Galvanized Steel White 900 LCM

03 Under Top Platform Beam / Galvanized Steel Orange 3,700 LCM

Legend:

N = North, E = East, W = West, S = South Classification:

- BRL = Below Reporting Limit (RL) of 60 and 6,000 ppm total lead

- LCP = Lead-Containing Paint (LCPs) are defined as those with lead concentrations ≥ the Reporting Limit (RL) and ≥ 90 ppm (parts per million).

- LCM = Lead-Containing Materials (LCMs) are defined as those with lead concentrations ranging from the Reporting Limit (RL) to <5,000 ppm (parts per million).

- LBP = Lead-Based Paints (LBPs) are defined as those containing a lead concentration of ≥5,000 ppm (parts per million).

**The locations provided are estimates based on accessible materials found within the survey area. Additional locations of lead-containing materials may exist at the Subject Property.

TES has the following recommendations based on the findings of this sampling:

• For the purpose of this lead survey, any material containing any detectable level of lead is subject to OSHA’s Lead in Construction Standard codified in Title 29, Code of Federal Regulations, Section 1926.62 (29 CFR Part 1926.62).

• In accordance with 29 CFR 1926.62, any disturbance of LCM and/or LBP should be performed by lead hazard communication trained workers using lead safe work practices that do not result in exposures above the Action Level (AL) of 30 micrograms per cubic meter of air (µg/m3) and/or Permissible Exposure Limit

(PEL) of 50 µg/m3.

• All lead activities must be performed in accordance with all applicable federal, state and local regulations, including but not limited to those summarized in this report.

TES appreciates the opportunity to be of service to you on this project. If there are any questions concerning the report, or if we may be of further assistance, please contact us at (888) 948-4826.

Sincerely, Titan Environmental Solutions, Inc.

Robert Menald, CIEC, CAC, LRCIA Ibrahim M. Sobeih, MS, MSPH, CIH, CAC, FAIHA Project Manager Director of Industrial Hygiene and Safety

Lead-Containing Materials Paint Chip Analysis

8500 Pena Blvd, Denver, CO 80249 Project Number 125602-LS

October 1, 2024

Attachments:

1. Laboratory Analytical Report and COC

Metals Analysis of Paints Client ID:

Report Number:

Date Received:

M262833

Job ID / Site: 125602-LS; Denver CO ASDE Tower; 8500 Pena Blvd , CO, 80249

TITAN Environmental Solutions, Inc.

Suite B

L1630

SGSFL Job ID:

Date Analyzed:

L1630

Tony Lam

Fullerton, CA 92831

1521 E. Orangethorpe Ave.

Date Printed: 09/04/24

09/04/24

First Reported: 09/04/24

08/29/24

Final Report

(AIHA-LAP, LLC Accreditation, Lab ID #101629)

Date(s) Collected: 08/22/2024 Total Samples Submitted:

Total Samples Analyzed:

Sample Number Lab Number Result Result Reporting Method

Analyte Units Limit* Reference

EPA 3050B/7000B480Pb01 LM274861 ppm 80

EPA 3050B/7000B900Pb02 LM274862 ppm 200

Comment: Sample submission below 0.1 grams.

EPA 3050B/7000B3700Pb03 LM274863 ppm 400

Analytical results and reports are generated by SGS at the request of and for the exclusive use of the person or entity (client) named on such report. Results, reports or copies of same will not be released by SGS to any third party without prior written request from client. This report applies only to the sample(s) tested. Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGS. The client is solely responsible for the use and interpretation of test results and reports requested from SGS. SGS is not able to assess the degree of hazard resulting from materials analyzed. SGS reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified. Any modifications that have been made to referenced test methods are documented in SGS Standard Operating Procedures Manual. Sample results have not been blank corrected. Quality control and sample receipt condition were acceptable unless otherwise noted.

Note* Sampling data used in this report was provided by the client as noted on the associated chain of custody form.

* The Reporting Limit represents the lowest amount of analyte that the laboratory can confidently detect in the sample, and is not a regulatory level. The Units for the Reporting Limit are the same as the Units for the Final Results.

Vincent To, Laboratory Supervisor, Carson Laboratory

20535 South Belshaw Avenue, Carson, CA 90746 | phone: 310.763.2374 / 800.813.9417 Fax: 310.763.4450 | https://falaboratories.sgs.com

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