Enclosure (3) CGX Asbestos Inspection of March 2024.pdf

Pre-Renovation Asbestos Inspection Report U.S. Coast Guard Exchange 2420 South Lincoln Memorial Drive, Milwaukee, WI

PREPARED FOR

CWO Jason Smith Facilities Engineering Officer

U.S. Coast Guard Sector - Lake Michigan 2420 South Lincoln Memorial Drive

Milwaukee, Wisconsin

PREPARED BY

Project Number – 22524-B

March 2024

Table of Contents

1. Introduction

2. Site Background

3. Asbestos Inspection, Sample Collection and Analysis

4. Summary of Results

5. Regulatory Discussion

6. Qualifications and Recommendations of Report

7. State and Local Reporting Requirements

Figure Figure 1 – Sample Location Map - Asbestos

Appendices A. Credential – Asbestos Inspector Certification Documentation B. Laboratory Analytical Report, Chain of Custody, and Facility Walk-Through Documentation C. Previous Asbestos Inspection Report

Page | 1 I:\US Coast Guard\090 Reports\Asbestos\2024-03-21 - Asb Report Pre-Reno - #22524 B.docx

1. Introduction

The U.S. Coast Guard retained The Sigma Group, Inc. (Sigma) to perform a pre-renovation asbestos inspection within select rooms of the Milwaukee Coast guard Station building located at 2420 S. Lincoln Memorial Drive, Milwaukee, WI. The portion of the facility designated as the Coast Guard Exchange (CG Exchange) which is an active commissary/retail store area is scheduled for renovation. Federal, State, and local regulations/ordinances require that an asbestos inspection be performed prior to building renovation to identify suspect asbestos-containing building materials (ACBMs). The inspection was performed on February 28, 2004.

2. Site Background

The Coast Guard Station Building is a 2-story slab-on-grade building with a steel frame, concrete block and brick walls, and flat roofs that was constructed in approximately 1970. The CG Exchange store is located on the first floor of the west side of the building immediately north of, and adjacent to the front main entrance. The floor plan provided by Chief Warrant Officer (CWO) Jason Smith indicates that the CG Exchange renovation project area consists of Rooms 114, 114a and an adjacent storage room. Renovation activities are in the planning phase, but will be limited to primarily updating floor, wall, and ceiling finishes.

Wall removal is not planned. The CG Exchange is currently occupied and in use.

CWO Smith also provided laboratory results from asbestos sampling performed in April 2023 by Wing Three WI, Inc., Waukesha, WI. The sampling appears to have focused on flooring on the first and second floors throughout the facility. Review of the lab reports indicates that twenty-two samples of carpet glue/adhesive/mastic and one sample of drywall were collected. Based on the analytical data, it appears asbestos was only detected in samples that had a layer of black mastic. The lab report did not note the presence of black mastic in samples collected from the first floor. Four samples (#6 through #9) of blue carpet and yellow adhesive were collected from the “Store” (assumed to be the CG Exchange). Asbestos was not detected in the yellow adhesive. No floor plans or sample location maps were provided with the report.

A thorough pre-renovation asbestos inspection is required by the USEPA NESHAP regulations provided in 40 CFR 61 and the WDNR Control of Asbestos Emissions defined in Chapter NR 447 prior to the commencement of the renovation activities that may disturb suspect ACBMs. The CG Exchange is currently occupied and in use.

3. Asbestos Inspection, Sample Collection and Analysis

Asbestos inspection and sampling activities were performed within the CG Exchange on February 28, 2024 by State of Wisconsin certified asbestos inspector Mr. Thomas McCoy (AII-117261). A copy of Mr. McCoy’s certification card is included as Appendix A. The inspection included visual observation of accessible areas, identification of suspect ACBMs, material sampling, and laboratory analysis of the suspect ACBMs.

Material sampling was limited to suspect building materials that were visible and could be accessed and sampled with minimal destruction to building materials and components and minimal disruption to tenant operations. Areas and materials that could not be accessed/inspected are listed in Section 6 - Qualifications of Report. Suspect asbestos-containing materials that were not sampled were identified as “assumed to contain” (ATC) asbestos. This pre-renovation asbestos inspection was performed in substantial compliance with the United States Environmental Protection Agency’s (USEPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) asbestos regulations (40 CFR 61, Subpart M), Page | 2 the Wisconsin Department of Natural Resources (WDNR) Control of Asbestos Emissions (WAC Chapter NR 447), and the City of Milwaukee inspection and sampling requirements with the exception of items and/or areas listed in Section 6 - Qualifications of Report.

The structure was occupied at the time of this inspection. Floor plans for the inspected areas were provided to Sigma prior to the assessment. The floor plan was used to prepare a field sketch which provides approximate sample locations and is included as Figure 1.

4. Summary of Results

The following suspect ACBMs identified within the proposed renovation area were sampled and submitted for laboratory analysis. The analytical results are presented in the following table.

Suspect Asbestos-Containing Building Materials Identified, Sampled, and Analyzed

Material Code

Material Description Sample

Number(s)

Location (Room #) - Direction Within Room

(N, S, E, or W)

Asbestos Concentration

MC-1 CAULK – Door, White 1 114 – NW ND

MC-2 CAULK – Vent, Brown 2 114 – SW ND

MCBM CONCRETE BLOCK MORTAR 3, 4, 5 114 – NW, SW, E ND

MCM-1 CARPET MASTIC – Tan 6, 7, 8 114 – SW, NW, NE ND

MDWC DRYWALL & JOINT COMPOUND 9, 10, 11 114 – E; 114A – NE;

114B– SE ND

MV4-1 4”VINYL BASEBOARD & MASTIC – Cream 12 114 – SE ND

MV4-2 4”VINYL BASEBOARD & MASTIC – Gray 13 114A - S ND

MV4-3 4”VINYL BASEBOARD & MASTIC - Black 14 114B - N ND

MCDC-1 CLOTH DUCT CONNECTOR 15 114 – NE ND

MC-3 CAULK – Window, White 16 Exterior ND

ND = None Detected

Asbestos was not detected in any of the suspect ACBM samples collected from rooms #114, #114A, #114B, or the exterior windows of room #114. No ACBMs were identified as “assumed to contain”. The CG Exchange floor plan indicating room numbers and approximate sample locations is provided as Figure 1.

Laboratory analytical reports are provided in Appendix B.

Page | 3

5. Regulatory Discussion

The USEPA, WDNR, and Occupational Safety and Health Act (OSHA) regulate activities involving asbestos.

The following provides a brief summary of the requirements specific to asbestos.

USEPA and WDNR The NESHAP regulations authorized under the Clean Air Act and administered by the USEPA and the WDNR cover a wide variety of substances, including asbestos. NESHAP defines ACBM that must be removed prior to Renovation and those ACBMs that can remain.

Friable Asbestos Friable asbestos material is defined as a material containing more than one percent asbestos that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable Category I Asbestos Non-friable Category I ACBM is generally defined as packings, gaskets, resilient floor covering, and asphalt roofing containing more than one percent asbestos that when dry cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable Category II Asbestos Non-friable Category II ACBM is defined as any material, excluding non-friable Category I ACBM, containing more than one percent asbestos that when dry cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos Containing Material (RACM):

NESHAP defines Regulated Asbestos Containing Material (RACM) as:

• Friable asbestos material; or

• Non-friable Category I ACBM that has become friable; or

• Non-friable Category I ACBM that will be or has been subject to sanding, grinding, cutting, or abrading; or

• Non-friable Category II ACBM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material during Renovation operations.

With limited exceptions, Section NR 447.08 of the Wisconsin Administrative code generally requires that all RACM be removed from a facility being demolished or renovated before any activity that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal.

Chapter NR 447 also has specific requirements that pertain to the disposal of wastes containing asbestos.

In addition to the requirements stated above, a trained individual knowledgeable with the requirements of 40 CFR Part 61, Subpart M must be onsite during renovation activities and be available during normal business hours. If any ACBM material becomes damaged or rendered friable during renovation, proper abatement measures must be immediately initiated by appropriately trained State of Wisconsin certified abatement personnel.

Page | 4

OSHA regulates employee exposure to hazardous conditions. 29 Code of Federal Regulations (CFR) 1926 regulates employee exposure to hazardous substances in the construction industry. 29 CFR 1926.1101 regulates activities which may impact materials containing asbestos. OSHA defines asbestos as chrysotile, amosite, crocidolite, tremolite asbestos, anthophyllite asbestos, actinolite asbestos, and any of these minerals that have been chemically treated and/or altered. While materials determined to contain asbestos at less than one percent are not classified as ACBM and are therefore not regulated by the USEPA and WDNR, OSHA does regulate employee activities involving these materials and associated employee notification, exposure, and protection.

Sigma recommends that the Owner and Contractor(s) be aware of OSHA requirements for activities involving materials containing asbestos. Additional recommendations are provided in the Qualifications of Report section provided below.

6. Qualifications and Recommendations of Report

The findings and recommendations included herein are based on information obtained during the site visit and from previous experience. The limitations of the report and recommended actions are as follows:

1. The material condition assessment reflects conditions at the date and time of the inspection.

Material conditions may change due to age, use, maintenance, and other building conditions.

It is recommended that the ACBM material condition be assessed prior to initiating renovation activities.

2. An assessment/inspection of non-building components including but not limited to office equipment, chairs, desks, tables, cabinets, wall hangings, and other equipment and materials used or stored by the current occupant was not conducted.

It is recommended that these items be managed in accordance with all local, state, and federal rules and regulations.

3. Homogeneous material samples were collected from reasonably accessible areas only.

Destructive investigation methods (opening of walls, soffits, or building cavities) were not employed to identify additional materials not readily visible (plumbing, HVAC, and electrical system components). During renovation and/or further inspection, a potential exists for encountering asbestos and/or other hazardous materials not previously identified to become revealed.

It is recommended that there is one individual on-site during renovation that is designated as a “Competent Person”. At a minimum, this individual shall be familiar with applicable asbestos and hazardous material related regulations; have the experience to recognize potential work crew and environmental exposures; institute proper personal protective equipment and personnel monitoring as necessary; have the authority to stop work; and meet training requirements established by the State of Wisconsin. Discovery of suspect asbestos and/or other hazardous materials should be reported immediately to the Owner so that appropriate measures can be implemented. Further sampling of newly discovered materials may be required to confirm the presence of ACBM within walls and other areas that were not visible or reasonably accessible during the asbestos inspection.

Page | 5

4. The following materials, building systems, and/or areas were not evaluated for the presence of asbestos:

• None – No inaccessible areas were observed by the inspector and no suspect ACBMs were designated as “Assumed to Contain” (ATC) asbestos because they were inaccessible or could not be sampled.

5. Additional Possible Hidden ACBMs

• Carpet/Residual Flooring Mastic – Three relatively small approximate 6” triangles of carpet were cut and lifted to inspect for and collect carpet or flooring mastic samples. Large areas of carpeting were not lifted/removed as the retail space was active and occupied during the inspection. The previous asbestos inspection (Appendix C) indicated that there was residual asbestos-containing black mastic in some carpet mastic samples on the 2nd floor but black mastic was not observed at sample locations in the 1st floor CG Exchange during the previous or current inspection.

It is recommended that if black mastic is observed when carpet or floor covering are removed during renovation, that the black mastic be assumed to contain asbestos and be managed in accordance with applicable regulations unless further sampling and testing indicates that the material does not contain asbestos.

7. State and Local Reporting Requirements

The WDNR and the Department of Health Services (DHS) require notification (WDNR Form 4500-113) at least ten working days prior to asbestos abatement or demolition projects. The City of Milwaukee should be consulted for applicability of additional local ordinances, codes, and permits.

Figure

Figure 1 – Floor Plan - Sample Location Map

FIGURE 1 - SAMPLE LOCATION MAP

U.S. Coast Guard Exchange

Appendix A

Credential – Asbestos Inspector Certification Documentation

Appendix B

Laboratory Analytical Reports / Certificate of Analysis and Chain of Custody / Facility Walk-Through Documentation

Lab No.: 7735484 Client No.: 22524-B-01

Analyst Observation: White Caulk Client Description:

Location:

Facility:

Percent Asbestos:

None Detected

Percent Non-Asbestos Fibrous Material:

Percent Non-Fibrous Material:

Lab No.: 7735485 Client No.: 22524-B-02

Analyst Observation: Grey Caulk

Lab No.: 7735486 Client No.: 22524-B-03

Analyst Observation: Tan Texture

Lab No.: 7735486(L2) Client No.: 22524-B-03

Analyst Observation: Grey Cementitious

Lab No.: 7735487 Client No.: 22524-B-04

Lab No.: 7735487(L2) Client No.: 22524-B-04

Laboratory Director

Approved By:

Date Analyzed:

3/1/2024Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Aidan Becker

03/08/2024 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services

1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

PLM BULK SAMPLE ANALYSIS SUMMARY

Client: SIG225

Dated : 3/14/2024 11:44:10 Page 1 of 8

Lab No.: 7735488 Client No.: 22524-B-05

Insufficient material provided to verify results.

Lab No.: 7735488(L2) Client No.: 22524-B-05

Lab No.: 7735489 Client No.: 22524-B-06

Analyst Observation: Yellow Mastic

Lab No.: 7735490 Client No.: 22524-B-07

Lab No.: 7735491 Client No.: 22524-B-08

Lab No.: 7735492 Client No.: 22524-B-09

Analyst Observation: White Drywall

5 Cellulose

Laboratory Director

Approved By:

Date Analyzed:

3/1/2024Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Aidan Becker

03/08/2024 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services

1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 3/14/2024 11:44:10 Page 2 of 8

Lab No.: 7735492(L2) Client No.: 22524-B-09

Analyst Observation: White Joint Compound

Lab No.: 7735493 Client No.: 22524-B-10

Lab No.: 7735493(L2) Client No.: 22524-B-10

Lab No.: 7735494 Client No.: 22524-B-11

Lab No.: 7735494(L2) Client No.: 22524-B-11

Lab No.: 7735495 Client No.: 22524-B-12

Analyst Observation: Lt. Blue Cove Base

Laboratory Director

Approved By:

Date Analyzed:

3/1/2024Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Aidan Becker

03/08/2024 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services

1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 3/14/2024 11:44:10 Page 3 of 8

Lab No.: 7735495(L2) Client No.: 22524-B-12

Analyst Observation: Tan Mastic

Lab No.: 7735496 Client No.: 22524-B-13

Analyst Observation: Lt. Blue Cove Base

Lab No.: 7735496(L2)

Lab No.: 7735496(L3)

Lab No.: 7735497 Client No.: 22524-B-14

Analyst Observation: Blue Cove Base

Lab No.: 7735497(L2) Client No.: 22524-B-14

Laboratory Director

Approved By:

Date Analyzed:

3/1/2024Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Aidan Becker

03/08/2024 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services

1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 3/14/2024 11:44:10 Page 4 of 8

Lab No.: 7735498 Client No.: 22524-B-15

Analyst Observation: Black Woven Material

80 None Detected

Lab No.: 7735499 Client No.: 22524-B-16

Analyst Observation: White Caulk

Laboratory Director

Approved By:

Date Analyzed:

3/1/2024Date Received:

Analyst:

Please refer to the Appendix of this report for further information regarding your analysis.

Signature:

Aidan Becker

03/08/2024 Frank E. Ehrenfeld, III

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services

1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

PLM BULK SAMPLE ANALYSIS SUMMARY

Dated : 3/14/2024 11:44:10 Page 5 of 8

Appendix to Analytical Report Customer Contact:

Method:40 CFR Appendix E to Subpart E of Part 763, interim method for the Determination of Asbestos in Bulk Insulation Samples, USEPA 600, R93-116 and NYSDOH ELAP 198.1 as needed.

This appendix seeks to promote greater understanding of any observations, exceptions, special instructions, or circumstances that the laboratory needs to communicate to the client concerning the above samples. The information below is used to help promote your ability to make the most informed decisions for you and your customers.

Please note the following points of contact for any questions you may have.

iATL Customer Service: customerservice@iatl.com iATL Office Manager:wchampion@iatl.com iATL Account Representative: Kelly Klippel Sample Login Notes: See Batch Sheet Attached Sample Matrix: Bulk Building Materials Exceptions Noted: See Following Pages

General Terms, Warrants, Limits, Qualifiers:

General information about iATL capabilities and client/laboratory relationships and responsibilities are spelled out in iATL policies that are listed at www.iATL.com and in our Quality Assurance Manual per ISO 17025 standard requirements. The information therein is a representation of iATL definitions and policies for turnaround times, sample submittal, collection media, blank definitions, quantification issues and limit of detection, analytical methods and procedures, sub-contracting policies, results reporting options, fees, terms, and discounts, confidentiality, sample archival and disposal, and data interpretation.

iATL warrants the test results to be of a precision normal for the type and methodology employed for each sample submitted. iATL disclaims any other warrants, expressed or implied, including warranty of fitness for a particular purpose and warranty of merchantability. iATL accepts no legal responsibility for the purpose for which the client uses test results. Any analytical work performed must be governed by our Standard Terms and Conditions. Prices, methods and detection limits may be changed without notification. Please contact your Customer Service Representative for the most current information.

This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA LAP LLC, or any agency of local, state or province governments nor of any agency of the U.S. government.

This report shall not be reproduced except in full, without written approval of the laboratory.

Information Pertinent to this Report:

Analysis by US EPA 600 93-116: Determination of Asbestos in Bulk Building Materials by Polarized Light Microscopy (PLM).

Certifications:

NIST-NVLAP No. 101165-0• NYSDOH-ELAP No. 11021• AIHA-LAP, LLC No. 100188•

Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not quantifiable under the Point Counting regimen. PC Trace represents a <0.25% amount. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.

Analytical Methodology Alternatives: Your initial request for analysis may not have accounted for recent advances in regulatory requirements or advances in technology that are routinely used in similar situations for other qualified projects. You may have the option to explore additional analysis for further information. Below are a few options, listed as the matrix followed by the appropriate methodology. Also included are links to more information on our website.

Bulk Building Materials that are Non-Friable Organically Bound (NOB) by Gravimetric Reduction techniques employing PLM and TEM: ELAP 198.6 (PLM-NOB), ELAP 198.4 (TEM-NOB) See additional information at the end of this appendix.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services 1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

Page 6 of 8Dated : 3/14/2024 11:44:10

Loose Fill Vermiculite Insulation, Attic Insulation, Zonolite (copyright), etc.: US EPA 600 R-4/004 (multi-tiered analytical process) Sprayed On Insulation/Fireproofing with Vermiculite (SOF-V): ELAP 198.8 (PLM-SOF-V)

Soil, sludge, sediment, aggregate, and like materials analyzed for asbestos or other elongated mineral particles (ex. erionite, etc.): ASTM D7521, CARB 435, and other options available

Asbestos in Surface Dust according to one of ASTM's Methods (very dependent on sampling collection technique – by TEM): ASTM D 5755, D5756, or D6480

Various other asbestos matrices (air, water, etc.) and analytical methods are available.

Disclaimers / Qualifiers:

There may be some samples in this project that have a "NOTE:" associated with a sample result. We use added disclaimers or qualifiers to inform the client about something that requires further explanation. Here is a list with highlighted disclaimers that may be pertinent to this project. For a full explanation of these and other disclaimers, please inquire at customerservice@iatl.com.

1) Note: No mastic provided for analysis.

2) Note: Insufficient mastic provided for analysis.

3) Note: Insufficient material provided for analysis.

4) Note: Insufficient sample provided for QC reanalysis.

5) Note: Different material than indicated on Sample Log / Description.

6) Note: Sample not submitted.

7) Note: Attached to asbestos containing material.

8) Note: Received wet.

9) Note: Possible surface contamination.

10) Note: Not building material. 1% threshold may not apply.

11) Note: Recommend TEM-NOB analysis as per EPA recommendations.

12) Note: Asbestos detected but not quantifiable.

13) Note: Multiple identical samples submitted, only one analyzed.

14) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.080%.

15) Note: Analyzed by EPA 600/R-93/116. Point Counting detection limit at 0.125%.

16) Note: This sample contains >10% vermiculite mineral. See Appendix for Recommendations for Vermiculite Analysis.

Recommendations for Vermiculite Analysis:

Several analytical protocols exist for the analysis of asbestos in vermiculite. These analytical approaches vary depending upon the nature of the vermiculite mineral being tested (e.g. un-processed gange, homogeneous exfoliated books of mica, or mixed mineral composites).Please contact your client representative for pricing and turnaround time options available.

iATL recommends initial testing using the EPA 600/R-93/116 method. This method is specifically designed for the analysis of asbestos in bulk building materials. It provides an acceptable starting point for primary screening of vermiculite for possible asbestos.

Results from this testing may be inconclusive. EPA suggests proceeding to a multi-tiered analysis involving wet separation techniques in conjunction with PLM and TEM gravimetric analysis (EPA 600/R-04/004).

For New York State customers, NYSDOH requires disclaimers and qualifiers for various vermiculite containing samples that direct analysis via ELAP198.6 and ELAP198.8 for samples that contain >10% vermiculite mineral where ELAP198.6 may be used to evaluate the asbestos content of the material. However, any test result using ELAP198.6 will be reported with the following disclaimer: “ELAP198.6 method does not remove vermiculite and may underestimate the level of asbestos present in a sample containing >10% vermiculite.”

Further information on this method and other vermiculite and asbestos issues can be found at the following: Agency for Toxic Substances and Disease Registry (ATSDR) www.atsdr.cdc.gov, United States Geological Survey (USGS) www.minerals.usgs.gov/minerals/, US EPA www.epa.gov/asbestos. The USEPA also has an informative brochure "Current Best Practices for Vermiculite Attic Insulation" EPA 747F03001 May 2003, that may assist the health and remediation professional. NYS customers please follow current NYSDOH ELAP requirements per policy on subject of surfacing and vermiculite, May 6, 2016, Testing Requirements for Surfacing Material Containing Vermiculite (https://www.wadsworth.org/sites/default/files/WebDoc/I198_8_02_2.pdf)

The following is a summary of the analytical process outlines in the EPA 600/R-04/004 Method:

1)Analytical Step/Method: Initial Screening by PLM, EPA 600R-93/116 Requirements/Comments: Minimum of 0.1 g of sample. ~0.25% for most samples.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services 1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

Page 7 of 8Dated : 3/14/2024 11:44:10

2)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

3)Analytical Step/Method:Wet Separation by PLM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Floats" only.

4)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Sinks" only.

5)Analytical Step/Method:Wet Separation by TEM Gravimetric Technique, EPA R-04/004 Requirements/Comments: Minimum 50g** of dry sample. Analysis of "Suspension" only.

*With advance notice and confirmation by the laboratory.

**Approximately 1 Liter of sample in double-bagged container (~9x6 inch bag of sample).

New York State Department of Health requires that samples originating from NYS that they categorize as Non-friable Organically Bound materials can only be confirmed as None Detected for asbestos by method 198.4. See the table below for a list of those materials. (ENVIRONMENTAL LABORATORY APPROVAL PROGRAM CERTIFICATION MANUAL - ITEM No. 198.1, Revision Date 5/6/16)

*Asphalt Shingles, Caulking, Ceiling Tiles with Cellulose, Duct Wrap, Glazing, Mastic, Paint Chips, Resilient Floor Tiles, Rubberized Asbestos Gaskets, Siding Shingles, Vinyl Asbestos Tile, NOB materials (other that SM-V) with <10% vermiculite, Any material (Friable or NOB other than SM-V) with >10% vermiculite.

Statistically derived uncertainty with any measure should be taken into consideration when reviewing and interpreting all reported data and results. A more comprehensive listing of accuracy, precision, and uncertainty as it impacts this method is available upon request.

9000 Commerce Parkway Suite B Mt. Laurel, New Jersey 08054

Telephone: 856-231-9449 Email: customerservice@iatl.com

CERTIFICATE OF ANALYSIS

Client: Sigma Environmental Services 1300 West Canal Street Milwaukee WI 53233

3/8/2024Report Date:

Report No.: 697130 - PLM Project: U.S. Coast Guard Project No.: 22524-B

Page 8 of 8Dated : 3/14/2024 11:44:10

Appendix C

Previous Asbestos Inspection Report

#23015701

Analysis Report prepared for

Wing Three WI, Inc.

1111 S West Ave

Waukesha, WI 53186

Phone: (262) 832-1194

WT23-0027

Jesse Decker

2420 S Lincoln Memorial Dr Milwaukee, WI 53207

Collected: April 13, 2023 Received: April 14, 2023 Reported: April 20, 2023

We would like to thank you for trusting Hayes Microbial for your analytical needs!

We received 23 samples by FedEx in good condition for this project on April 14th, 2023.

The results in this analysis pertain only to this job, collected on the stated date, and should not be used in the interpretation of any other job. Information supplied by the customer can affect the validity of results. These results apply only to the samples as received. This report may not be duplicated, except in full, without the written consent of Hayes Microbial Consulting, LLC.

All information provided to Hayes Microbial is confidential information relating to our customers and their clients. We will not disclose, copy, or distribute any information verbally or written, except to those designated by the customer(s). We take confidentiality very seriously. No changes to the distribution list will be made without the express consent of the customer.

This laboratory bears no responsibility for sample collection activities, analytical method limitations, or your use of the test results. Interpretation and use of test results are your responsibility. Any reference to health effects or interpretation of mold levels is strictly the opinion of Hayes Microbial. In no event, shall Hayes Microbial or any of its employees be liable for lost profits or any special, incidental or consequential damages arising out of the use of these test results.

Steve Hayes, BSMT(ASCP) Laboratory Director Hayes Microbial Consulting, LLC.

EPA Laboratory ID: VA01419

Lab ID: #188863

DPH License: #PH-0198

Hayes Microbial Consulting, LLC. 3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 1 of 6

# Sample Material Description Non-Asbestos Fibers Asbestos Fibers

1 #1 - Carpet Glue ESD 1st Fl Front Left Carpet / Blue 50% Synthetic Fibers None Detected

Adhesive / Clear/Yellow None Detected

2 #2 - Carpet Glue ESD 1st Fl Front Right Carpet / Blue 50% Synthetic Fibers None Detected

Adhesive / Clear/Yellow None Detected

3 #3 - Carpet Glue ESD 1st Fl Back Right Carpet / Blue 50% Synthetic Fibers None Detected

Adhesive / Gray None Detected

4 #4 - Carpet Glue ESD 1st Fl Back Left Office Carpet / Blue 50% Synthetic Fibers None Detected

Adhesive / Clear None Detected

5 #5 - Carpet Glue ESD 1st Fl Center of Room Carpet / Blue 50% Synthetic Fibers None Detected

Adhesive / Clear/Green None Detected

6 #6 - Carpet Glue Store 1st Fl Back Left Carpet / Blue 85% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

7 #7 - Carpet Glue Store 1st Fl Front Left Carpet / Blue 85% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

Sean Wing Three WI, Inc.

1111 S West Ave Waukesha, WI 53186

(262) 832-1194

WT23-0027

Jesse Decker 2420 S Lincoln Memorial Dr Milwaukee, WI 53207

#23015701

Asbestos PLM Bulk

EPA 600/R-93, M-4/82-020

Project Analyst:

Kristina King, Kristina King Date:

04 - 20 - 2023 Reviewed By:

David McDonald, PHR David McD�nald Date:

04 - 20 - 2023

Collected:Apr 13, 2023 Received: Apr 14, 2023 Reported: Apr 20, 2023

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 2 of 6

8 #8 - Carpet Glue Store 1st Fl Front Rt / Cashier Carpet / Blue 85% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

9 #9 - Carpet Glue Store 1st Fl Back Right Carpet / Blue 85% Synthetic Fibers None Detected

Adhesive / Gray None Detected

10 #10 - Carpet Glue Store 1st Fl Center of Floor ( Not Analyzed )

Lab Note: Sample Not Submitted

11 #11 - Carpet Glue Room 208 2nd Fl Back Left Carpet / Blue 80% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

12 #12 - Carpet Glue Room 208 2nd Fl Back Right Carpet / Blue 80% Synthetic Fibers None Detected

Lab Note: Adhesive Not Observed.

13 #13 - Carpet Glue Room 208 2nd Fl Front Right Carpet / Blue 80% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 3% Chrysotile

14 #14 - Carpet Glue Room 208 2nd Fl Front Left Carpet / Blue 80% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 3% Chrysotile

Sean Wing Three WI, Inc.

1111 S West Ave Waukesha, WI 53186

(262) 832-1194

WT23-0027

Jesse Decker 2420 S Lincoln Memorial Dr Milwaukee, WI 53207

#23015701

Asbestos PLM Bulk

EPA 600/R-93, M-4/82-020

Project Analyst:

Kristina King, Kristina King Date:

04 - 20 - 2023 Reviewed By:

David McDonald, PHR David McD�nald Date:

04 - 20 - 2023

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 3 of 6

15 #15 - Carpet Glue Room 208 2nd Fl Center of Floor Carpet / Blue 80% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 3% Chrysotile

Leveler / Gray None Detected

16 #16 - Carpet Glue Room 206 2nd Fl Back Right Carpet / Blue 75% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 2% Chrysotile

17 #17 - Carpet Glue Room 206 2nd Fl Back Left Carpet / Blue 75% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 3% Chrysotile

18 #18 - Carpet Glue Room 208 2nd Fl Front Right Carpet / Blue 75% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

Mastic / Black 3% Chrysotile

19 #19 - Carpet Glue Room 208 2nd Fl Front Left Carpet / Blue 75% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 2% Chrysotile

20 #20 - Carpet Glue Room 208 2nd Fl Center of Flr Carpet / Blue 75% Synthetic Fibers None Detected

Adhesive/Mastic / Yellow/Black 2% Chrysotile

21 #21 - Drywall Room 208 2nd Fl Right Wall Drywall / White 6% Cellulose Fibers None Detected

Sean Wing Three WI, Inc.

1111 S West Ave Waukesha, WI 53186

(262) 832-1194

WT23-0027

Jesse Decker 2420 S Lincoln Memorial Dr Milwaukee, WI 53207

#23015701

Asbestos PLM Bulk

EPA 600/R-93, M-4/82-020

Project Analyst:

Kristina King, Kristina King Date:

04 - 20 - 2023 Reviewed By:

David McDonald, PHR David McD�nald Date:

04 - 20 - 2023

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 4 of 6

22 22 - Carpet Carpet / Blue 90% Synthetic Fibers None Detected

Adhesive / Yellow None Detected

Lab Note: Extra Unlabeled Sample.

23 23 - Carpet Carpet / Blue 95% Synthetic Fibers None Detected

Adhesive / Gray None Detected

Lab Note: Extra Unlabeled Sample.

Sean Wing Three WI, Inc.

1111 S West Ave Waukesha, WI 53186

(262) 832-1194

WT23-0027

Jesse Decker 2420 S Lincoln Memorial Dr Milwaukee, WI 53207

#23015701

Asbestos PLM Bulk

EPA 600/R-93, M-4/82-020

Project Analyst:

Kristina King, Kristina King Date:

04 - 20 - 2023 Reviewed By:

David McDonald, PHR David McD�nald Date:

04 - 20 - 2023

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 5 of 6

Analysis Details All samples were received in acceptable condition unless otherwise noted on the report. This report must not be used by the client to claim product certification, approval, or endorsement by AIHA, NIST, NVLAP, NY ELAP, or any agency. The results relate only to the items tested. Hayes Microbial Consulting reserves the right to dispose of all samples after a period of 60 days in compliance with state and federal guidelines.

PLM Analysis All Polarized Light Microscopy (PLM) results include an inherent uncertainty of measurement associated with estimating percentages by PLM.

Materials with interfering matrix, low asbestos content, or small fiber size may require additional analysis via TEM Analysis.

TEM Analysis Analysis by TEM is capable of providing positive identification of asbestos type(s) and semi-quantitation of asbestos content.

Definitions 'None Detected' - Below the detected reporting limit of 1% unless point counting is performed, then the detected reporting limit is .25%.

New York ELAP Per NY ELAP198.6 (NOB), TEM is the only reliable method to declare an NOB material as Non-Asbestos Containing.

Any NY ELAP samples that are subcontracted to another laboratory will display the name and ELAP Lab Identification number in the report page heading of those samples. The original report provided to Hayes Microbial Consulting is available upon request.

Sean Wing Three WI, Inc.

1111 S West Ave Waukesha, WI 53186

(262) 832-1194

WT23-0027

Jesse Decker 2420 S Lincoln Memorial Dr Milwaukee, WI 53207

#23015701

Asbestos Analysis Information

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 6 of 6