f_CE0965_BJ000567_Hazmat Report.pdf

Targeted Regulated Building Materials Inspection Report

Building No. J00567 and Building No. J01207 Joint Base Lewis-McChord, Washington January 8, 2024 Terracon Project No. 81237391 Pond & Company Project No. 1230679

Prepared for:

Pond & Company Peachtree Corners, Georgia

21905 64th Ave West, Suite 100 Mountlake Terrace, Washington 98043 P (425) 771-3304

21905 64th Ave West, Suite 100 Mountlake Terrace, WA 98043

P (425) 771-3304 Terracon.com

January 8, 2024

Pond & Company 3500 Parkway Lane, Suite 500 Peachtree Corners, Georgia 30092

Attn: Mr. Erik Adami

RE: Targeted Regulated Building Materials Inspection Buildings J00567 and J01207 Joint Base Lewis-McChord, Washington

Terracon Project No. 81237391 Pond & Company Project No. 1230679

Dear Mr. Adami:

This report presents the results of the targeted regulated building materials inspection conducted in support of the future renovation of the Buildings J00567 and J01207, located in Joint Base Lewis-McChord, Washington. The scope of the services provided is described in Terracon Proposal Number P81237391 dated July 18, 2023.

We appreciate the opportunity to be of service to you on this project. If there are any questions regarding this report or if we may be of further assistance, please do not hesitate to contact us.

Sincerely, Terracon Consultants, Inc.

For Daniel Sheppard Scott Parker

Industrial Hygienist Principal / Department Manager

TABLE OF CONTENTS

Executive Summary.....................................................................................................i

Introduction

Project Background

2.1 Sources of Information

2.2 Building Description

Asbestos Assessment

3.1 Building Assessment

3.2 Sampling Procedures

3.3 Analytical Methodology

3.4 Asbestos Results

Lead Assessment

4.1 Sampling Methodology

4.2 Lead Sampling Results

Other Regulated Building Materials

5.1 Methodology – Universal Wastes

5.2 Results

Conclusions and Recommendations

6.1 Asbestos

6.2 Lead

6.3 Other Regulated Building Materials

Limitations

7.1 Reliance

Appendices Appendix A. Sample Location Figures Appendix B. Photographs Appendix C. Asbestos Laboratory Analytical Results Appendix D. Lead Laboratory Analytical Results Appendix E. Personnel and Laboratory Certifications and Accreditations

Targeted Regulated Building Materials Inspection Report Buildings J00567 and J01207 Joint Base Lewis-McChord, Washington January 8, 2024 Terracon Project No. 81237391 i

Executive Summary

Pond & Company retained Terracon Consultants, Inc. (Terracon) to conduct a targeted regulated building materials inspection of the Buildings J00567 and J01207, located in Joint Base Lewis- McChord, Washington. Terracon’s representatives, Mr. Daniel Sheppard and Mr. John McCaslin, conducted the inspection on December 12, 2023.

Terracon inspected the project areas for the following regulated building materials:

Asbestos-containing materials (ACM) Assumed asbestos-containing materials Lead-containing coatings (paints) Mercury-containing light tubes, switches, and thermostats Suspected high-intensity discharge (HID) lamps Suspected Polychlorinated biphenyls (PCB)-containing fluorescent light ballasts

Asbestos

Ninety bulk samples of suspect asbestos-containing materials were collected and analyzed using Polarized Light Microscopy (PLM). None of the of the sampled materials were found to contain asbestos and two materials were assumed to be ACM. In addition, one of the materials was visually inspected and determined to be non-suspect.

Lead

Five paint chip samples were collected and analyzed for total lead content. One of the paint chip samples was found to contain detectable concentrations of lead.

Other Regulated Materials

Mercury-containing fluorescent light tubes were identified in the buildings. Light ballasts associated with fluorescent light fixtures were assumed to be PCB-containing.

Mercury-containing switches and thermostats were not observed in the project area.

High intensity discharge lamps were not observed in the project area.

January 8, 2024 Terracon Project No. 81237391

Introduction

Pond & Company retained Terracon Consultants, Inc. (Terracon) to conduct a targeted regulated building materials inspection of the Buildings J00567 and J01207, located in Joint Base Lewis-McChord, Washington. Terracon’s representatives, Mr. Daniel Sheppard and Mr.

John McCaslin, conducted the inspection on December 12, 2023.

Terracon inspected the building project areas for the following regulated building materials:

Asbestos-containing materials (ACM) Assumed asbestos-containing materials Lead-containing coatings (paints) Mercury-containing light tubes, switches, and thermostats Suspected high-intensity discharge (HID) lamps Suspected Polychlorinated biphenyls (PCB)-containing fluorescent light ballasts

Project Background

This report presents the results of our targeted regulated building materials inspection conducted in support of the future renovation of the Buildings J00567 and J01207. The purpose of the inspection was to identify potential asbestos-containing material, lead-containing coatings, PCB-containing light ballasts, and mercury-containing components prior to building renovation and for purposes of hazard communication and on-going management.

The inspection included accessible areas of the interior of Buildings J00567 and J01207 where materials will be impacted by the planned HVAC upgrade (project area). The inspection was limited to the project area as described and did not include exteriors, roofs, or other interior areas of the buildings.

During the inspection, the following areas were not accessible and therefore not included in the inspection:

Dormitory suites of building J00567 were inaccessible, except for suite 101.

This inspection report will assist Pond & Company with communicating the presence of regulated building materials, and the presence, location, and quantity of ACM to employees, vendors, and contractors working in the project area and to meet the requirements for an asbestos survey for the Puget Sound Clean Air Agency (PSCAA) and a good faith inspection as required by Washington State Department of Labor and Industries’ Division of Occupational Safety and Health (DOSH) regulations prior to renovation in the project area. Regulations require that a complete copy of this report be kept in a conspicuous location on-site at all times during activities that may impact known and suspect ACM.

2.1 Sources of Information

During the course of the inspection, the following individuals and drawings provided assistance to the Terracon inspectors:

Mr. Chris Brixey, Project Manager USAFR Floor plans, Air Mobility Command A-1, provided by client

January 8, 2024 Terracon Project No. 81237391

2.2 Building Description

BUILDING INFORMATION FOR BUILDING NUMBER J000567

Address Joint Base Lewis-McChord, Washington

Building Use Dormitory

Number of Floors 2

Main Structure Brick and mortar

Flooring Substrate Reinforced concrete

Flooring Finishes Concrete

Interior Wall Finishes Gypsum wallboard with wall texture in places

Ceiling Finishes Popcorn ceiling texture on concrete and gypsum

Heating System Wall mounted heating units and exterior courtyard mounted HVAC equipment

Pipe Insulation Heating and cooling water lines are insulated with canvas wrapped fiberglass, paper wrapped fiberglass straight runs with plastic wrapped fiberglass fittings, and fiberglass fabric blanket

BUILDING INFORMATION FOR BUILDING NUMBER J01207

Address Joint Base Lewis-McChord, Washington

Building Use Office building

Number of Floors 1

Construction Date(s) NA

Flooring Substrate Reinforced concrete

Flooring Finishes Floor coating on concrete in mechanical room

Interior Wall Finishes Wallboard and tilt up concrete walls

Ceiling Finishes Suspended acoustical ceiling tile

Heating System Exterior courtyard mounted HVAC equipment

Pipe Insulation Heating and cooling water lines are insulated with neoprene, foam, paper wrapped fiberglass straight runs, and fiberglass fabric blankets

Asbestos Assessment

3.1 Building Assessment

Mr. Daniel Sheppard and Mr. John McCaslin, both Asbestos Hazard Emergency Response Act (AHERA)-accredited building inspectors (Certification 189943, expiration date: 6/22/2024 and Certification 187335, expiration date: 1/5/2024, respectively) from Terracon, performed the sampling on December 12, 2023. Terracon’s inspectors collected 90 samples of materials identified as suspect ACM.

This inspection was conducted using a modified protocol adapted from AHERA. The protocol is as follows:

January 8, 2024 Terracon Project No. 81237391

Identify suspect asbestos-containing materials.

Group materials into homogeneous sampling areas/materials.

Quantify each homogeneous material and collect representative samples. The number of samples collected of miscellaneous materials was determined by the inspector.

Samples of each material were taken to the substrate, ensuring that all components and layers of the material were included.

Sample locations are referenced on the field data forms according to sample number.

Sampling was performed by an AHERA-accredited building inspector, and the use of proper protective equipment and procedures were followed.

3.2 Sampling Procedures

The sampling was conducted using the following procedures:

1. Spread the plastic drop cloth (if needed) and set up other equipment, e.g., ladder.

2. Don protective equipment (respirator and protective clothing if needed).

3. Label sample container with its identification number and record number. Record sample location and type of material sampled on a sampling data form.

4. Moisten area where sample is to be extracted (spray the immediate area with water).

5. Extract sample using a clean knife, drill capsule, or cork boring tool to cut out or scrape off approximately one tablespoon of the material. Penetrate all layers of material.

6. Place sample in a container and tightly seal it.

7. Wipe the exterior of the container with a wet wipe to remove material that may have adhered to it during sampling.

8. Clean tools with wet wipes and wet mop; or vacuum area with HEPA vacuum to clean all debris.

9. Discard protective clothing, wet wipes and rags, cartridge filters, and drop cloth in a labeled plastic waste bag.

3.3 Analytical Methodology

Suspect ACMs were sampled in general accordance with 40 CFR 763.86 by an Environmental Protection Agency (EPA) AHERA-accredited building inspector. Each sample was collected and stored in a heavy-duty, self-sealing plastic bag, and delivered to NVL Laboratories in Seattle, Washington. Samples were analyzed via polarized light microscopy (PLM) in accordance with EPA/600/R-93/116. NVL Laboratories is accredited to perform PLM analysis by the National Institute of Standards and Technology National Voluntary Laboratory Accreditation Program

(NVLAP).

3.4 Asbestos Results

Table 3.4-1 provides a list of suspect homogeneous material sample descriptions, material locations, and results for this sampling. Also indicated within the table is the AHERA classification of Surfacing (S), Thermal System Insulation (TSI), or Miscellaneous (M).

Asbestos-containing materials and assumed asbestos-containing materials are presented in bold text. Refer to the attached Figures for sample locations. Refer to the Appendix for photographs that are representative the homogenous materials.

January 8, 2024 Terracon Project No. 81237391

Table 3.4-1. Results of Bulk Sample Analyses

Material No. Material Description Material Location Results

Building J00567

(M)

White gypsum wallboard

White joint compound with paper

Walls throughout boiler room

ND (all layers)

(T)

White paper with yellow mastic and foil

Yellow fiberglass straight run insulation

White bridging sealant

Predominate paper wrapped pipe insulation in places throughout boiler room

ND (all layers)

(T)

White canvas wrap

Beige bridging compound

White mesh with paper, foil, and yellow mastic

Yellow fiberglass insulation

Tan compressed material with mastic

Canvas wrapped pipe insulation in places throughout boiler room

ND (all layers)

(T)

White woven blanket

White fiberglass insulation

In places throughout boiler room

ND (all layers)

(M)

Grey pipe dope

Beige pipe dope

White thread tape

Associated with joints in piping throughout project area

ND (all layers)

(T)

Grey fibrous blanket

White fiberglass insulation

Associated with pipe joints in places throughout boiler room

ND (all layers)

(M)

Flange gaskets In places throughout boiler room

Assumed to be present and contain asbestos

(M)

White sealant

Beige sealant

Yellow fiberglass insulation

Sealant around seams in tank insulation in boiler room

ND (all layers)

January 8, 2024 Terracon Project No. 81237391

Table 3.4-1. Results of Bulk Sample Analyses

Material No. Material Description Material Location Results

(T)

White canvas wrap

Beige crumbly material

White paper with yellow mastic and foil

Yellow fiberglass insulation

Insulation around tank in boiler room

ND (all layers)

(M)

Red fire stop sealant Wall penetrations in places throughout project area

ND

(T)

Black paper

Yellow fiberglass insulation

Associated with radiators in unit 101

ND (all layers)

(M)

Grey window sealant Window sealant around window frame in unit 101

ND

(M)

White wall texture

White joint compound

Walls and ceiling throughout unit 101

ND (all layers)

(M)

White wall texture

White joint compound

White gypsum wallboard

Walls and ceiling throughout unit 101

ND (all layers)

(M)

Silver sealant Associated with exterior HVAC unit

ND

(S)

White popcorn texture Ceiling texture in kitchen and recreation rooms on gypsum wallboard

ND)

(S)

White popcorn texture Ceiling texture in laundry room on concrete

ND

Building J01207

(M)

White joint compound

White gypsum wallboard

Walls throughout project area

ND (all layers)

(M)

White sealant

White mesh with paper, foil, and yellow mastic

Yellow fiberglass insulation

Sealant associated with foil wrapped fiberglass insulation

January 8, 2024 Terracon Project No. 81237391

Table 3.4-1. Results of Bulk Sample Analyses

Material No. Material Description Material Location Results

(M)

White bridging compound

White paper wrap with yellow mastic

Yellow fiberglass insulation

Paper wrapped fiberglass straight runs in places throughout project area

ND (all layers)

(T)

White fabric blanket

Yellow fiberglass insulation

Silver metal

Insulation blankets associated with piping joints in places throughout project area

ND (all layers)

(M)

White pipe dope Associated with pipe joints in places throughout project area

ND

(M)

Grey sealant Associated with metal HVAC ducting in places throughout project are

ND

(M)

Green flange gaskets

Gaskets associated with piping joints in places throughout mechanical room

ND

(M)

Black vibration isolator

Exterior courtyard and mechanical room

Assumed contain asbestos

(T)

Black neoprene pipe insulation

Associated with piping in places throughout project area

Visually assessed and determined to be non-suspect

(T)

Black foam pipe insulation

Associated with piping in places throughout project area

Visually assessed and determined to be non-suspect

(M)

Red firestop sealant

White gypsum wallboard

Sealant associated with wall penetrations in places throughout project area

ND (all layers)

(M)

Black built up asphaltic roofing

Black foam

Beige perlite

Black vapor barrier

Flat roofing throughout floor of attic

January 8, 2024 Terracon Project No. 81237391

Table 3.4-1. Results of Bulk Sample Analyses

Material No. Material Description Material Location Results

(S)

Grey floor coating Floor coating in mechanical room

ND

(T)

Silver insulation blanket

Yellow fiberglass insulation

Insulation blanket on exterior HVAC piping joints

ND (all layers)

(M)

Silver sealant

White foam

Yellow fiberglass insulation

Sealant associated with seams in exterior HVAC piping

ND (all layers)

(M)

Grey sealant Sealant on seams on exterior HVAC unit housing

ND

(M)

2’x2’ White suspended ceiling tiles with pin holes

Predominate ceiling throughout building

ND

ND: none detected, Material No.: homogenous material that is uniform in color, texture, general appearance, and construction and application date, S: Surfacing material per AHERA, T: Thermal system insulation per AHERA, M: Miscellaneous material per AHERA.

If the analytical results indicate that all the samples collected per homogenous material do not contain asbestos, then the material is not considered an ACM. However, if the analytical results of one or more of the samples collected per homogenous material indicate that asbestos is present in quantities of greater than one percent as defined by the EPA, the homogeneous material is considered to be ACM regardless of other analytical results (unless a representative number of samples have been analyzed by PLM point counting as described below, and the results indicate the material contains less than one percent asbestos).

Any material that contains greater than one percent asbestos is considered an ACM and must be handled according to Occupational Safety and Health Administration (OSHA), EPA, and applicable state and local regulations. The EPA National Emission Standard for Hazardous Air Pollutants (NESHAP) 40 CFR 61, Subparts A and M has a requirement related to inspection of suspect ACM in buildings. When the asbestos content of a friable material is visually estimated by PLM to be detectable but less than ten percent, your firm may elect to (1) assume the amount is greater than one percent and treat the material as asbestos-containing or (2) require verification of the amount by the PLM point counting technique. If the results obtained by point counting and visual estimation are different, the point count result must be used.

When no asbestos is detected by PLM, point counting is not required.

Lead Assessment

Homogeneous areas of suspected lead-containing coatings (paints) were identified and sampled in accessible areas throughout the Buildings J00567 and J01207 located in Joint Base

January 8, 2024 Terracon Project No. 81237391

Lewis-McChord, Washington. Homogeneous painted surfaces were defined by substrate, application, and color.

4.1 Sampling Methodology

Paint chip samples were collected to the substrate to ensure that all layers present at the location sampled were included in the laboratory analysis. Each sample was collected and stored in a heavy-duty, self-sealing plastic bag and delivered to NVL Laboratories in Seattle, Washington. Samples were analyzed via Atomic Absorption Spectrophotometry in accordance with Method EPA 7000B. NVL Laboratories in Seattle, Washington is accredited by the American Industrial Hygiene Association (AIHA) for lead analysis.

4.2 Lead Sampling Results

Five paint chip samples were collected and analyzed for lead. One sample had reportable concentrations of lead. The results of the analyses are presented in Table 4.2-1.

Table 4.2-1. Paint Chip Sample Results

Paint Number and Description

Paint Location Sample Result

(in ppm)

Building J00567

Pb1: White paint on gypsum wallboard

Walls throughout boiler room <55

Pb2: White paint on gypsum wallboard

Walls and ceilings throughout unit 101 and kitchen

<47

Pb3: White paint on concrete Associated with ceiling in laundry room <49

Building J01207

Pb1: Grey paint on concrete Floor coating in mechanical room 80

Pb2: White paint on gypsum wallboard

Walls throughout mechanical room <50

<: below the reporting limit, ppm: parts per million, BOLD: lead detected

Other Regulated Building Materials

5.1 Methodology – Universal Wastes

An inventory of fluorescent light tubes, HID lamps, and potential PCB-containing ballasts was conducted in accessible areas of the project.

Where fluorescent light fixtures were accessible, the ballast covers were removed, and the ballast labels were visually examined. Different types of fluorescent fixtures were distinguished by shield shape, fixture dimension, diffuser type, and the manner in which the ballast covers were connected to the fixture. Inspectors attempted to visually inspect at least two of each type of fluorescent light fixture.

January 8, 2024 Terracon Project No. 81237391

Where fluorescent light fixtures could not be visually examined, the number of potential PCB-containing ballasts in fixtures was estimated based on the following assumptions:

Each single light tube fluorescent fixture contains one ballast Each multiple light tube fluorescent fixture contains one ballast for every pair of light tubes Each multiple light tube fluorescent light fixture contains one ballast for every pair of light tubes (four-foot length) and two ballasts for every pair of light tubes (eight feet or greater in length) All light ballasts are assumed to contain PCBs unless the manufacturer’s label indicates they are electronic ballasts

Mercury-containing light tubes were counted and documented in an inventory by length. Light tubes were determined to be four-foot tubes.

Magnetic ballasts are suspected of containing PCBs in the potting material or in the dielectric fluid in the capacitor. Electronic ballasts are not suspected of containing PCBs. A Philips Advance Sensor Switch “ballast checker” was used to identify magnetic versus electronic ballasts. The ballast checker is used by pointing the device at a powered light fixture, and the device indicates whether the ballast is electronic or magnetic.

5.2 Results

Fluorescent light tubes were observed throughout the building interiors. Light ballasts associated with fluorescent light fixtures were assumed to be PCB-containing. Mercury-containing switches and thermostats were not observed in the project area. Universal wastes were identified in the following quantities:

Table 5.2-1. Universal Wastes Results

Other Regulated Building Materials Description Approximate Quantity (EA)

Building J00567

Mechanical room and common areas

Mercury-containing fluorescent light tubes (4’ length) 20

Assumed PCB-containing light ballasts 7

Dormitory suites (EA Unit)

Mercury-containing fluorescent light tubes (4’ length) 5

Assumed PCB-containing light ballasts 3

Building J01207

Mercury-containing fluorescent light tubes (4’ length) 310

Assumed PCB-containing light ballasts 85

EA: each

January 8, 2024 Terracon Project No. 81237391

Conclusions and Recommendations

On December 12, 2023, Terracon conducted a targeted regulated building materials inspection of the Buildings J00567 and J01207 located in Joint Base Lewis-McChord, Washington

6.1 Asbestos

The results of the asbestos inspection conducted at Buildings J00567 and J01207 indicate that the following building materials sampled are ACMs or are assumed to contain greater than one percent asbestos.

Table 6.1-1. ACM and Assumed ACM

Material No.

Material Description Material Location Approximate

Quantity

Building J00567

(M) Flange gaskets

In places throughout boiler room

2 EA

Building J01207

(M) Black vibration isolator

Exterior courtyard and mechanical room

4 EA

Material No.: Homogenous material that is uniform in color, texture, general appearance, and construction and application date, M: Miscellaneous material per AHERA, EA: Each

Access was only granted in unit 101. Additional suspect ACMs may be present in areas not granted access to be inspected or that were inaccessible or concealed. These spaces include, but are not limited to, dwelling suites and common spaces that were not accessed, above hard ceiling decks, electrical systems, pipe chases, spaces between wall/ceiling/door/floor cavities, interior of mechanical components, beneath foundation pads, etc. If future maintenance, renovation, and/or demolition activities make these areas accessible, Terracon recommends that a thorough inspection of these spaces be conducted at that time to identify and confirm the presence or absence of additional suspect ACMs. Until then, all such unidentified materials must be treated as assumed ACM in accordance with applicable federal, state, and local regulations.

6.2 Lead

One of the samples analyzed was found to contain detectable concentrations of lead.

The Washington State Department of Labor and Industries requires an exposure assessment be conducted during operations that may disturb the lead paint in such a way that the airborne exposure may reach or exceed the Action level of 30 micrograms per cubic meter (µg/m3) or the Permissible Exposure Limit of 50 µg/m3. The worker protection requirements of WAC 296-155-176 "Lead in Construction" may apply.

Some of the coatings contained detectable concentrations of lead. If this building or portions of it will be demolished and disposed of, a toxicity characteristic leachate procedure (TCLP) sample that is representative of the waste stream must be collected and analyzed per the requirements of WAC 173-303. If the results of the TCLP analysis determine the waste to be a

January 8, 2024 Terracon Project No. 81237391

"dangerous waste" as defined by WAC 173-303, it must be disposed of accordingly.

6.3 Other Regulated Building Materials

Fluorescent light tubes, HID lamps, switches, and thermostats may contain mercury.

Fluorescent light ballasts and HID lamp ballasts may contain PCBs. In Washington State, even ballasts labeled with "No PCBs" may have regulated quantities of PCBs and therefore should be handled in accordance with Washington Department of Ecology requirements. Employers must inform their employees of mercury and PCB hazards in accordance with WAC 296-800-170.

Limitations

This report presents the results of the regulated building materials conducted at the Buildings J00567 and J01207 located at in Joint Base Lewis-McChord, Washington. The inspection was for the purposes of identifying ACM, lead-containing paint, PCB caulking, mercury-containing components, PCB ballasts, and HID lamps prior to renovation.

The lead paint chip sampling and reporting conducted as a part of this inspection does not nor is intended to meet the requirements of the Environmental Protection Agency’s Lead;

Renovation, Repair, and Painting rule (RRP). Refer to EPA regulation 40CFR745 and Washington State regulation WAC 365-230 for additional information.

Regulated building material inspections are non-comprehensive and subject to many limitations, including those presented below. Our inspection has considered risks pertaining to asbestos, lead in coatings, heavy metals in paint, fluorescent lamps, mercury switches, PCB ballasts, and HID lamps; however, this inspection is limited to only those locations and materials included in the inspection. This inspection was not designed to identify all potential concerns or to eliminate all risks associated with renovation, demolition, material removal, construction, or transferring of property title. Evaluation of other risks not specifically described in the Scope of Work have not been included; for example: structural integrity;

engineering loads; electrical; mechanical; radon gas; slope stability; building settlement; and evaluation of toxic and hazardous substances in, or in contact with, soil and groundwater. No warranty, expressed or implied, is made.

Terracon has performed the services set forth in the Scope of Work in accordance with generally accepted industrial hygiene practices in the same or similar localities, related to the nature of the work accomplished, at the time the services were performed.

The regulated building materials and conditions presented in this report represent those observed on the dates we conducted the sampling. This sampling is intended for the exclusive use of Pond & Company for specific application to the referenced property. This report does not replace nor can be used as professionally developed construction or demolition plans, specifications, or bidding documents. This report is not a legal opinion.

7.1 Reliance

This Report(s) was prepared for the exclusive use and reliance of the Client. Reliance by any other party is prohibited without the written authorization of the Client and Terracon. If the Client is aware of additional parties that will require reliance on the Report, the names, addresses and relationship of these parties must be provided for to Terracon for approval.

Terracon will grant reliance on the Report to those approved parties upon receipt of a fully

January 8, 2024 Terracon Project No. 81237391 executed Reliance Agreement (available upon request) and receipt of an additional fee of $350.00 per relying party.

Reliance on the Report by the Client and all authorized parties will be subject to the terms, conditions and limitations stated in the Agreement for Services (and sections of this proposal incorporated therein), the Reliance Agreement, and the Report.

APPENDIX A

Appendix A Sample Location Figure(s)

APPENDIX B

Appendix B Photographs

Building J00567

Material 01 Material 02

Material 03 Material 04

Material 05 Material 06

Material 07 Material 08

Material 09 Material 10

Material 11 Material 12

Material 13 Material 14

Material 15 Material 16

Material 17

Building J01207

Material 01 Material 02

Material 03 Material 04

Material 05 Material 06

Material 07 Material 08

Material 09 Material 10

Material 11 Material 12

Material 13 Material 14

Material 15 Material 16

Material 17

APPENDIX C

Appendix C Asbestos Laboratory Analytical Results

Kunga Woser, Senior Laboratory Analyst

Client Project: 81237391 Location: JBLM Building J00567

Dear Mr. McCaslin, Enclosed please find test results for the 47 sample(s) submitted to our laboratory for analysis on 12/13/2023.

Examination of these samples was conducted for the presence of identifiable asbestos fibers using polarized light microscopy (PLM) with dispersion staining in accordance with U. S. EPA 40 CFR Appendix E to Subpart E of Part 763, Interim Method for the Determination of Asbestos in Bulk Insulation Samples and EPA 600/R-93/116, Method for the Determination of Asbestos in Bulk Building Materials.

For samples containing more than one separable layer of materials, the report will include findings for each layer (labeled Layer 1 and Layer 2, etc. for each individual layer). The asbestos concentration in the sample is determined by calibrated visual estimation.

For those samples with asbestos concentrations between 1 and 10 percent based on visual estimation, the EPA recommends a procedure known as point counting (NESHAPS, 40 CFR Part 61). Point counting is a statistically more accurate means of quantification for samples with low concentrations of asbestos.

The detection limit for the calibrated visual estimation is <1%, 400 point counts is 0.25% and 1000 point counts is 0.1%

Samples are archived for two weeks following analysis. Samples that are not retrieved by the client are discarded after two weeks.

Thank you for using our laboratory services. Please do not hesitate to call if there is anything further we can assist you with.

Sincerely, Enc.: Sample Results

December 19, 2023

John McCaslin Terracon - Mountlake Terrace 21905 64th Ave. W #100 Mountlake Terrace, WA 98043

RE: Bulk Asbestos Fiber Analysis; NVL Batch # 2319392.00

< Client:

Address:

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

23115684Lab ID: Client Sample #:

Location: JBLM Building J00567

567-01A

Layer 1 of 2 Description: White compacted powdery material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Calcareous binder, Calcareous particles, Paint 6%Cellulose None Detected ND

Layer 2 of 2 Description: White chalky material with paper

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Gypsum/Binder, Calcareous particles 23%Cellulose None Detected ND

7%Glass fibers

23115685Lab ID: Client Sample #:

Location: JBLM Building J00567

567-01B

Layer 1 of 2 Description: White compacted powdery material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Calcareous binder, Calcareous particles, Paint 4%Cellulose None Detected ND

Layer 2 of 2 Description: White chalky material with paper

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Gypsum/Binder, Calcareous particles 22%Cellulose None Detected ND

9%Glass fibers

23115686Lab ID: Client Sample #:

Location: JBLM Building J00567

567-01C

Layer 1 of 3 Description: White compacted powdery material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Calcareous binder, Calcareous particles, Paint 3%Cellulose None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

ASB-02

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

Layer 2 of 3 Description: White thin compacted powdery material with paper

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Calcareous binder, Calcareous particles 28%Cellulose None Detected ND

Layer 3 of 3 Description: White chalky material with paper

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Gypsum/Binder, Calcareous particles 23%Cellulose None Detected ND

7%Glass fibers

23115687Lab ID: Client Sample #:

Location: JBLM Building J00567

Comments: Unsure of correct layer sequence.

567-02A

Layer 1 of 3 Description: White fibrous mesh with paper & yellow mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Metal foil, Paint 30%Cellulose None Detected ND

20%Glass fibers

Layer 2 of 3 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

Layer 3 of 3 Description: White crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 2%Glass fibers None Detected ND

23115688Lab ID: Client Sample #:

Location: JBLM Building J00567

Comments: Unsure of correct layer sequence.

567-02B

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

Layer 1 of 3 Description: White fibrous mesh with paper & yellow mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Metal foil, Paint 33%Cellulose None Detected ND

21%Glass fibers

Layer 2 of 3 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 93%Glass fibers None Detected ND

Layer 3 of 3 Description: White crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 3%Glass fibers None Detected ND

23115689Lab ID: Client Sample #:

Location: JBLM Building J00567

Comments: Unsure of correct layer sequence.

567-02C

Layer 1 of 3 Description: White fibrous mesh with paper & yellow mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Metal foil, Paint 32%Cellulose None Detected ND

22%Glass fibers

Layer 2 of 3 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 92%Glass fibers None Detected ND

Layer 3 of 3 Description: White crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 2%Glass fibers None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

23115690Lab ID: Client Sample #:

Location: JBLM Building J00567

Comments: Unsure of correct layer sequence.

567-03A

Layer 1 of 5 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 91%Glass fibers None Detected ND

Layer 2 of 5 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 4%Wollastonite None Detected ND

Layer 3 of 5 Description: Yellow soft mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Mastic/Binder, Metal foil NDNone Detected None Detected ND

Layer 4 of 5 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 91%Glass fibers None Detected ND

Layer 5 of 5 Description: Tan compressed fibrous material with adhesive

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Adhesive/Binder 77%Cellulose None Detected ND

23115691Lab ID: Client Sample #:

Location: JBLM Building J00567

567-03B

Layer 1 of 4 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 92%Glass fibers None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

Layer 2 of 4 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 2%Wollastonite None Detected ND

Layer 3 of 4 Description: White fibrous mesh with paper & yellow mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Mastic, Metal foil 32%Cellulose None Detected ND

25%Glass fibers

Layer 4 of 4 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

23115692Lab ID: Client Sample #:

Location: JBLM Building J00567

567-03C

Layer 1 of 4 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 93%Glass fibers None Detected ND

Layer 2 of 4 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 3%Wollastonite None Detected ND

Layer 3 of 4 Description: White fibrous mesh with paper & yellow mastic with foil

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Mastic, Metal foil 33%Cellulose None Detected ND

24%Glass fibers

Layer 4 of 4 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 93%Glass fibers None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

23115693Lab ID: Client Sample #:

Location: JBLM Building J00567

567-04A

Layer 1 of 2 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

Layer 2 of 2 Description: White fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

23115694Lab ID: Client Sample #:

Location: JBLM Building J00567

567-04B

Layer 1 of 2 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 92%Glass fibers None Detected ND

Layer 2 of 2 Description: White fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 95%Glass fibers None Detected ND

23115695Lab ID: Client Sample #:

Location: JBLM Building J00567

567-04C

Layer 1 of 1 Description: White interwoven fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 93%Glass fibers None Detected ND

23115696Lab ID: Client Sample #:

Location: JBLM Building J00567

567-05A

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

Layer 1 of 2 Description: Gray soft material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler NDNone Detected None Detected ND

Layer 2 of 2 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 5%Glass fibers None Detected ND

23115697Lab ID: Client Sample #:

Location: JBLM Building J00567

567-05B

Layer 1 of 2 Description: Yellow soft material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler NDNone Detected None Detected ND

Layer 2 of 2 Description: Gray brittle material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 3%Wollastonite None Detected ND

23115698Lab ID: Client Sample #:

Location: JBLM Building J00567

567-05C

Layer 1 of 2 Description: White flexible material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler NDNone Detected None Detected ND

Layer 2 of 2 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 2%Cellulose None Detected ND

23115699Lab ID: Client Sample #:

Location: JBLM Building J00567

567-06A

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th Ave. W #100 Mountlake Terrace, WA 98043

Method: EPA/600/R-93/116

Samples Analyzed: 47

Project Location:

Batch #: 2319392.00

Date Received: 12/13/2023

Layer 1 of 2 Description: White interwoven fibrous material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Paint 81%Glass fibers None Detected ND

Layer 2 of 2 Description: White fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

23115700Lab ID: Client Sample #:

Location: JBLM Building J00567

567-06B

Layer 1 of 2 Description: White interwoven fibrous material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Paint 83%Glass fibers None Detected ND

Layer 2 of 2 Description: White fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 92%Glass fibers None Detected ND

23115701Lab ID: Client Sample #:

Location: JBLM Building J00567

Comments: Unsure of correct layer sequence.

567-08A

Layer 1 of 3 Description: Beige crumbly material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Fine particles 4%Wollastonite None Detected ND

Layer 2 of 3 Description: Yellow fibrous material

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler 90%Glass fibers None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA 600/R-93/116 and EPA 40 CFR Appendix E to Subpart E of Part 763 with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Carenna LanAnalyzed by:

Kunga WoserReviewed by:

12/18/2023 Date:

12/19/2023Date:

Sampled by:

Kunga Woser, Senior Laboratory Analyst

Attention: Mr. John McCaslin

JBLM Building J00567

Client Project #: 81237391

Samples Received: 47

By Polarized Light Microscopy Bulk Asbestos Fibers Analysis

Terracon - Mountlake Terrace

21905 64th…