Asbestos and TCLP Lead Survey Report JBLE 814_820_2802 May 2021 (1).pdf

dpSTUDIO environmental consulting & design www.dpSTUDIOenvironmental.com 804.402.0446

Prepared For:

733 MSG CED CEO

1407 WASHINGTON BLVD RM 110

FORT EUSTIS, VA 23604-1283

Attn: Mr. Michael B. Reilly

Prepared by:

dpSTUDIO environmental consulting & design LLC www.dpstudioenvironmental.com

Date of Report: May 10, 2021

Environmental Engineer: Dennis Papa, PE, BCEE

LIMITED HAZARDOUS MATERIALS SURVEY OF

JBLE Ft. Eustis Buildings 814, 820 and 2802 JBLE Ft. Eustis, VA 23604 http://www.dpstudioenvironmental.com/

Hazardous Materials Survey Report – JBLE Ft. Eustis Virginia May 2021

Page ii

TABLE OF CONTENTS

1.0 Introduction

2.0 Procedures and Results of Asbestos Survey

2.1 Definitions Under NESHAPS

2.2 Results Discussion

2.3 Inaccessible Areas

2.4 Recommendations

3.0 Procedures and Results of Lead Paint Sampling

3.1 Results Discussion

3.2 Recommendations

4.0 Other Environmental Conditions

5.0 Certifications and Limitations

LIST OF TABLES

Table 1: Asbestos Sampling Results Building 814 ..................................................................... …2 Table 2: Asbestos Sampling Results Building 820 ..................................................................... …5 Table 3: Asbestos Sampling Results Building 2802 ................................................................... …7 Table 4: Lead TCLP Sampling Results

LIST OF APPENDICES

Appendix A: Asbestos and TCLP Laboratory Analysis Data Appendix B: Sample Location Floor Plans

1.0 Introduction

This report presents the results of an asbestos-specific building survey and lead toxicity characteristic leaching procedure (TCLP) testing for Buildings 814, 820, and 2802 at Joint Base Langley Eustis (JBLE), Fort Eustis, Virginia.

Building 814 is a “225-man barracks” dormitory constructed of concrete masonry unit (CMU) in the 1950s. It is a three-story building with partial basement and is listed by JBLE as comprising 40,103 square feet (sq ft.). Building 820 is of similar age and construction, also with three stories and partial basement, and listed as 39,837 sq ft. Building 2802 is a 12 ft. by 12 ft. (144 sq ft.) CMU one-story building formerly used for railroad training and is currently gutted and vacant. The buildings appear to have had minor renovations and limited asbestos abatement in the past. Records of abatement or previous asbestos/lead paint surveys were not provided as part of this study.

2.0 Procedures and Results of Asbestos Survey

The asbestos survey was conducted in accordance with the U.S. Environmental Protection Agency’s (EPA) “National Emission Standards for Hazardous Air Pollutants; Asbestos NESHAP Final Rule, 40 CFR 61.” The asbestos survey was conducted on April 28-29, 2021 by Vincent White (Virginia Licensed Asbestos Inspector No. 3303002292) and Jim Bernard, project environmental scientist, with oversight by Project Manager Dennis Papa (Virginia Licensed Asbestos Inspector No.

3303002482). The asbestos inspector sampled suspect asbestos-containing materials (ACM) by Homogeneous Sampling Areas. A Homogeneous Sampling Area contains material that is uniform in texture and appearance, was installed at one time, and is unlikely to consist of more than one type, or formulation, of material. The asbestos survey included the physical assessment and sampling of suspect ACM from accessible areas of the buildings.

dpSTUDIO’s inspectors obtained base passes at approximately 10:00 am on April 28 and proceeded to Building 814 escorted by Mr. Mike Reilly of Ft. Eustis Engineering Flight, Civil Engineering Division (CED). Mr. Reilly provided keys to buildings 814 and 820 although several doors of both buildings were found to be unlocked. Inspectors surveyed all accessible areas of Building 814, and planned sample collection locations for suspect ACM and painted surfaces for TCLP Lead analysis. A total of 62 suspect ACM samples were collected along with four (4) composite samples for TCLP lead analysis. Inspectors then proceeded to Building 2802 and collected four (4) suspect ACM samples and one TCLP sample.

The inspectors returned to Ft. Eustis on April 29, 2021 and completed similar sampling procedures for suspect ACM and TCLP Lead in Building 820. A total of 57 suspect ACM and four (4) TCLP samples were collected at Building 820. Upon completion of field work, building keys were returned to Mr. Bob McRacken of CED. Inspectors did not lock doors that were previously unlocked.

Hazardous Materials Survey Report – JBLE Ft. Eustis, Virginia phone 804.402.0446 www.dpstudioenvironmental.com

Bulk samples were submitted to AmeriSci Laboratories, a National Voluntary Laboratory Accreditation Program (NVLAP) and American Industrial Hygiene Association (AIHA)-accredited asbestos analytical laboratory, located in Chesterfield, Virginia. The bulk samples were analyzed for asbestos content using Polarized Light Microscopy (PLM) with dispersion staining as prescribed in EPA 40 CFR Part 763.

Table 1 summarizes the homogeneous areas identified within the inspection areas at the subject property and details the results of the samples collected from each homogenous material. The sample identification (ID) number and Sample Result for each bulk sample are listed adjacent to the property location from which the sample was collected. Copies of laboratory analytical data sheets are attached in Appendix A and a site figure depicting sample locations and positive results is attached as Appendix B.

TABLE 1

Asbestos Sampling Results – JBLE Ft. Eustis Building 814

April 28, 2021 Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Drywall and Joint Compound

11,000 ft2 1st, 2nd, 3rd floor rooms and stairwells

814-01-1 814-01-2 814-01-3

2% Chrysotile asbestos

White/brown joint compound

Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

1st, 2nd, 3rd floor and stairwells

814-02-4 814-02-5 814-02-6

NAD

NAD

NAD

Ceiling dry wall Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

Restrooms, kitchen 814-03-7 814-03-8 814-03-9

NAD

NAD

NAD

Ceiling joint compound Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

Restrooms, kitchen 814-04-10 814-04-11 814-04-12

NAD

NAD

NAD

2’x2’ white ceiling tile 9,200 ft2 1st, 2nd, 3rd floor 814-05-13 814-05-14 814-05-15

NAD

NAD

NAD

2’x2’ bumpy pattern white ceiling tile

3,400 ft2 1st, 2nd, 3rd floor 814-06-16 814-06-17 814-06-18

NAD

NAD

Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Mastic under carpet 9,000 ft2 1st, 2nd, 3rd floor 814-07-19 814-07-20 814-07-21

NAD

NAD

NAD

Brown Floor tile and underlying black mastic

10,600 ft2 per floor 1st, 2nd, 3rd floor rooms and hallways, some areas under carpeting

814-08-22 814-08-23 814-08-24

2% Chrysotile asbestos in tile;

3% Chrysotile asbestos in mastic

12”x12” Brown Floor tile and underlying black

3,200 ft2 1st floor kitchen and foyer

814-09-25 814-09-26

2% Chrysotile asbestos in tile; 3% Chrysotile asbestos in mastic

12”x12” Blue & Cream Floor tile and underlying black/yellow

64 ft2 1st floor kitchen office 814-10-27 814-10-28

NAD tile; 2% in

Epoxy coating

>10,000 ft2 Stairwell floors 814-11-29 814-11-30 814-11-31

NAD

NAD

Black wall mastic

>400 ft2 1st, 2nd and 3rd floor pipe chase

814-12-32 814-12-33 814-12-34

5% Chrysotile

Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Door insulation

14 doors 1st, 2nd , 3rd floor stairwell fire doors

814-13-35 814-13-36 814-13-37

NAD

NAD

NAD

White seam mastic on ducts

150 lin ft 1st, 2nd , 3rd floor pipe chase

814-14-38 814-14-39 814-14-40

NAD

NAD

NAD

White seam mastic on newer ducts

130 lin ft 1st, 2nd , 3rd floor pipe chase

814-15-41 814-15-42 814-15-43

NAD

NAD

2” mudded pipe joint

8 joints 1st, 2nd , 3rd floor pipe chase

814-16-44 814-16-45 814-16-46

NAD

NAD

NAD

Remnant thermal system insulation

20 bags* Crawlspace 814-17-47 814-17-48 814-17-49

2% Chrysotile asbestos

Fibrous insulation, spray-on fireproofing

5,200 ft2 Crawlspace ceiling 814-18-50 814-18-51 814-18-52

NAD

NAD

NAD

Built-up roofing materials

– surface asphaltic layer, felt, fibrous under layer

15,600 ft2 Roof 814-19-53 814-19-54

Black roof vent mastic 10 ft2 Roof 814-20-55 814-20-56

NAD

NAD

White caulk 8 lin ft Exterior vents 814-21-57 814-21-58

NAD

NAD

White tank insulation material

245 ft2 Basement 814-22-59 814-22-60

NAD

NAD

Gray duct hanger

300 cubic ft (entire duct)

1st, 2nd, 3rd floor chase, behind duct seam mastic

814-23-61 814-23-62

4% Chrysotile asbestos

Exterior cementitious facing material

24,000 ft2 Building exterior 814-24-63 814-24-64

ACM = Asbestos Containing Material NAD = No asbestos detected

*all material quantities are approximate and should be verified prior to any abatement or other planning purposes.

Basement, crawlspace and other portions of the building appear to have been abated of thermal system insulation (TSI) at some time in the past.

For “Remnant thermal system insulation” samples 814-17-47, 48, & 49, the ACM was observed as broken pieces of insulation on the floor and other portions of the crawlspace. Not all material could be observed directly. The quantity estimate assumes that this material could fill approximately twenty (20) standard poly bags that are typically used for abatement.

TABLE 2

JBLE Ft. Eustis Building 820

April 29, 2021 Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Drywall and Joint Compound

12,000 ft2 1st, 2nd, 3rd floor, basement

820-01-1 820-01-2 820-01-3 820-01-4

NAD

NAD

NAD

NAD

White/brown Joint compound

Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

1st, 2nd, 3rd floor, basement

814-02-5 814-02-6 814-02-7 820-02-8

NAD

NAD

NAD

Ceiling dry wall Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

1st, 2nd, 3rd floor, basement

820-03-9 820-03-10 820-03-11 820-03-12

NAD

NAD

NAD

NAD

Ceiling joint compound Included in Drywall /Joint Compound total of 11,000 sq ft (see Area 01 (above)

1st, 2nd, 3rd floor, basement

820-04-13 820-04-14 820-04-15 820-04-16

NAD

NAD

NAD

NAD

Gray/white duct hanger

300 cubic ft (entire duct)

1st, 2nd, 3rd floor chase, behind duct seam mastic

820-05-17 3% Chrysotile

Square duct seam

130 lin ft 1st, 2nd, 3rd floor chase 820-06-18 820-06-19 820-06-20

NAD

NAD

NAD

Round duct seam mastic 150 lin ft 1st, 2nd, 3rd floor chase 820-07-21 820-07-22 820-07-23

NAD

Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Duct seam mastic 150 lin ft 1st, 2nd, 3rd floor chase 820-08-24 820-08-25 820-08-26

NAD

NAD

NAD

12”x12” white Floor tile and underlying yellow mastic

32,000 ft2 1st, 2nd, 3rd floor and basement

820-09-27 820-09-28 820-09-29 820-09-30

NAD

NAD

NAD

NAD

Cove base with mastic 42,000 lin ft 1st, 2nd, 3rd floor and basement

820-10-31 820-10-32 820-10-33 820-10-34

NAD

NAD

NAD

2’x2’ white ceiling tile

10,000 ft2 1st, 2nd, 3rd floor and basement

820-11-35 820-11-36 820-11-37 820-11-38

NAD

NAD

NAD

NAD

Black wall

>400 ft2 1st, 2nd and 3rd floor pipe chase

820-12-39 820-12-40 820-12-41

5% Chrysotile asbestos

Fibrous insulation, spray-on fireproofing

5,000 ft2 Crawlspace 820-13-42 820-13-43 820-13-44 820-13-45

NAD

NAD

NAD

NAD

Epoxy coating 600 ft2 Stairwells 820-14-46 820-14-47

NAD

NAD

Round gray mastic 150 lin ft Basement 820-15-48 820-15-49

NAD

NAD

Exterior cementitious facing material

24,000 ft2 Building exterior 820-16-50 820-16-51

NAD

NAD

Built-up roofing materials

– surface asphaltic layer, felt, fibrous under layer

15,600 ft2 Roof 820-17-52 820-17-53

NAD

NAD

Black roof vent mastic 10 ft2 Roof 820-18-54 820-18-55

NAD

NAD

White roof vent mastic 10 ft2 Roof 820-19-56 820-19-57

NAD

NAD

ACM = Asbestos Containing Material NAD = No asbestos detected

*all material quantities are approximate and should be verified prior to any abatement or other planning purposes.

Basement, crawlspace and other portions of the building appear to have been abated of thermal system insulation (TSI) at some time in the past.

TABLE 3

JBLE Ft. Eustis Building 2802

April 28, 2021 Homogeneous Area / Material Description

Approx Amount of Material*

Location Sample ID Sample Result

Gray roofing layer 144 ft2 Roof 2802-01-1 2802-01-2

Black fibrous sub-roof

144 ft2

Roof 2802-02-3 2802-02-4

NAD

NAD

ACM = Asbestos Containing Material NAD = No asbestos detected *all material quantities are approximate and should be verified prior to any abatement or other planning purposes.

2.1 Definitions Under NESHAPS

This asbestos survey is intended to quantify asbestos content through laboratory analysis, but also identifies the category and condition of each homogenous area/material in order to determine what asbestos-containing material (ACM) is regulated or un-regulated.

The EPA National Emission Standard for Hazardous Air Pollutants (NESHAP) distinguishes between an ACM that would easily release asbestos fibers when damaged or disturbed as being “Friable”, and an ACM that is less likely to have significant fiber release as “Non-Friable.” The NESHAP standard defines friable ACM as any material containing more than 1 percent asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. The Standard defines several categories of non-friable ACM as materials containing more than 1 percent asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Regulated Asbestos-Containing Material (RACM) means:

• Friable asbestos material,

• Category I non-friable ACM that has become friable,

• Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or

• Category II non-friable ACM 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 in the course of demolition or renovation operations.

Category I Non-friable Asbestos-Containing Material (ACM) means:

• Asbestos-containing packings, gaskets, resilient floor covering (i.e., asphalt and vinyl floor tile and sheet vinyl floor covering), and asphalt roofing products containing more than 1 percent asbestos.

Category II Non-friable Asbestos-Containing Material (ACM) means:

• Any material, excluding Category I non-friable ACM, containing more than 1 percent asbestos that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. This can include stucco ceiling, transite siding and wallboard, window glazing, etc.

2.2 Results Discussion

Building 814 Samples collected from the drywall and joint compound system (Samples 814-01-01, 814-01-02) contained 2% Chrysotile asbestos. The drywall system in the building includes drywall on outside walls of rooms in the 1st, 2nd, and 3rd floors; joint compound associated with the drywall; ceiling drywall; and joint compound associated with the ceiling drywall. There is estimated to be greater than 11,000 sq ft of this material in rooms, stairwells, restrooms, and kitchen. This ACM appeared to be in good condition. Note that other samples from the drywall system (samples 3 through 12) were NAD for asbestos. According to the EPA and Commonwealth of Virginia, samples collected from drywall or plaster and joint compound systems are considered a composite material, even if only individual portions of joint compound are positive for asbestos. It is therefore possible that other joint compound associated with drywall in other rooms besides those that tested positive also may be positive, and therefore render that portion of the drywall system positive. As a result, the entire drywall system in the building is assumed to be ACM unless additional testing is performed to further segregate potential non-ACM. Demolition or renovation activities affecting this material would be subject to OSHA regulations, and proper demolition methods, dust control, worker protection, and other requirements under OSHA standards would be required. The removal/demolition of drywall or plaster material where any components such as joint compound contain >1% asbestos must follow the work practices in the OSHA Construction Industry Standard

29 CFR 1926.1101.

The samples of brown vinyl floor tile and underlying mastic (Samples 814-08-22, 814-08-23, 814- 08-24, 814-09-25, and 814-09-26) contained 2% Chrysotile asbestos in the tile and 3% Chrysotile asbestos in the underlying mastic. There is estimated to be greater than 10,600 sq ft of this material per floor of the building and an additional 3,200 sq ft in the first floor kitchen and foyer of the building. This ACM appeared to be in good condition, but was covered by carpeting in many areas which prevented a thorough condition assessment. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

The samples collected from the blue and cream colored 12”x12” vinyl floor tile (Samples 814-10-27 and 814-10-28) contained 2% Chrysotile asbestos in the mastic. There is approximately 64 sq ft. of this material located in the first floor kitchen office. This ACM appeared to be in generally good condition with some localized wear. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

The samples of black wall mastic (Sample 814-12-32, 814-12-33, and 814-12-34) contained 5% Chrysotile asbestos. This material is located on walls within pipe chases along the 1st, 2nd, and 3rd floors. Total quantity of this material is estimated to be at a minimum of 400 sq ft., however not all areas of the chase could be observed. Where observed, this ACM appeared to be in generally good condition at the time of the survey. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

The samples of gray duct hanger mastic (Sample 814-23-61 and 814-23-62) contained 4% Chrysotile asbestos. This material is located on square ducts located within pipe chases along the 1st, 2nd, and 3rd floors, and is covered by white or gray non-ACM mastic. Total quantity of this material could not be estimated since it exists behind other mastic and is attached to non-ACM duct material. As a result the quantity estimate assumes that if abated, all duct material will be removed as ACM, which would include an estimated 300 cubic ft, of ducting. Where observed, this ACM appeared to be in generally good condition at the time of the survey. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

The crawlspace of the building includes remnant pieces of thermal system insulation (TSI) that contain 2% Chrysotile asbestos, based on positive samples 814-17-47, 814-17-48, and 814-17-49.

This Friable ACM was damaged and observed to be in the crawlspace soil and hanging on portions of pipes. Not all material could be observed directly. The quantity estimate assumes that this material could fill approximately twenty (20) standard poly bags that are typically used for abatement.

Building 820 The samples of black wall mastic (Sample 820-12-39, 820-12-40, and 820-12-41) contained 5% Chrysotile asbestos. This material is located on walls within pipe chases along the 1st, 2nd, and 3rd floors. Total quantity of this material is estimated to be at a minimum of 400 sq ft., however not all areas of the chase could be observed. Where observed, this ACM appeared to be in generally good condition at the time of the survey. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

The samples of gray duct hanger mastic (Sample 820-05-17) contained 3% Chrysotile asbestos.

Similar to Building 814, this material is located on square ducts located within pipe chases along the

1st, 2nd, and 3rd floors, and is covered by white or gray non-ACM mastic. Total quantity of this material could not be estimated since it exists behind other mastic and is attached to non-ACM duct material. As a result the quantity estimate assumes that all duct material will be removed as ACM, which would include an estimated 300 cubic ft. of ducting. Where observed, this ACM appeared to be in generally good condition at the time of the survey. This ACM is classified by the EPA Asbestos NESHAP regulations as a Category I Non-friable Material.

Building 2802 No ACM identified

2.3 Inaccessible Areas

Portions of the crawl space were visible through doors from the boiler room and outside walls. As visible from these portions of the crawl space, it appears that ACM thermal system insulation (TSI) has been abated and remnant ACM TSI exists. Not all areas of the crawl space were accessible or observed. Pipe chases were observed where accessible from doorways or wall penetrations. It is possible that other remnant ACM TSI, or other ACM, is located within walls, pipe chases, or otherwise inaccessible areas of Buildings 814 and 820.

2.4 Recommendations

The asbestos NESHAP requires that an owner or operator of a building containing Regulated Asbestos Containing Material (RACM) remove all such material from areas of the building that will be affected by demolition or renovation before any activity begins that would break up, dislodge, or similarly disturb the RACM or would prevent access to the RACM for subsequent removal.

ACM need not be removed before demolition if it:

1. Is a Category I non-friable ACM that is NOT damaged.

2. Is on a building component that is encased in concrete or similar material and is adequately wet whenever exposed during demolition.

3. Was not accessible for sampling and was not discovered until after demolition began and, as a result of the demolition, cannot be safely removed. If not removed for safety reasons, the exposed RACM and any asbestos-contaminated debris must be treated as asbestos-containing waste material and kept adequately wet at all times until disposed of.

4. Is a Category II non-friable ACM and the probability is low that the material will become crumbled, pulverized, or reduced to powder during demolition.

Asbestos-containing material (ACM) identified in this survey includes the following:

• Remnant thermal system insulation (TSI) in the crawlspace of Building 814

• Drywall and joint compound in Building 814

• Floor tile and mastic in Building 814

• Wall mastic in pipe chases of Building 814 and Building 820

• Duct hanger mastic on ducts in pipe chases of Building 814 and Building 820

The flooring and mastics are classified as Category I non-friable ACM. Under NESHAPS, it is not necessary to remove Category I non-friable asbestos-containing material. However, these materials may become regulated (RACM) if the materials become friable or will be subjected to sanding, grinding, cutting or abrading during renovation or demolition, at which time the materials will require special handling to reduce emissions of asbestos fibers into the air. Removal of ACM flooring and mastic is classified under OSHA regulations (Construction Industry Standard 29 CFR 1910.1101) as Class II asbestos work, which must be performed by EPA accredited asbestos workers and supervisors. If the materials will remain in the building during demolition, the disposal facility that will receive the construction debris must be notified that the demolition waste contains non-friable asbestos-containing materials.

Asbestos-containing thermal system insulation (TSI) and drywall are classified as Friable ACM and therefore RACM. These materials would require removal by an asbestos abatement contractor prior to demolition.

Future renovation or demolition may expose or release suspect asbestos-containing building materials that were inaccessible at the time of this inspection. If this should occur, renovation or demolition activities should stop until the suspect asbestos-containing building materials are sampled by a Virginia licensed asbestos inspector and analyzed by a laboratory accredited by NVLAP in asbestos identification.

3.0 Procedures and Results of Lead Paint Sampling

In place of a lead-paint survey, dpSTUDIO collected building material for analysis of leachable lead by the Toxicity Characteristic Leaching Procedure (TCLP) to determine if building demolition wastes would be considered hazardous wastes if disposed, such as in a construction & demolition (C&D) landfill. For each building, a composite sample including painted surfaces as part of the total debris was collected to represent as closely as possible the proportion of all materials in the building debris (i.e., paint, brick, glass, wood, etc.). Each sample was mixed to produce a minimum 100 gram sample. The TCLP sampling procedures were in general accordance with ASTM Standard Practice E1908-20 for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb).

TCLP samples were submitted to Environmental Hazards Services, LLC, a National Voluntary Laboratory Accreditation Program (NVLAP) and American Industrial Hygiene Association (AIHA)-accredited asbestos analytical laboratory for analysis of Lead by TCLP using EPA Method 1311.

The regulatory limit established by EPA for TCLP lead is 5.0 mg/L (milligrams per Liter, equivalent to parts per million). Under this regulatory requirement, any wastes that exhibit a TCLP lead level that exceeds 5.0 mg/L would be considered hazardous wastes and subject to handling and disposal requirements for hazardous wastes under the Resource Conservation and Recovery Act (RCRA). Wastes that do not fail the lead TCLP would not be considered hazardous for lead and can be disposed according to applicable solid waste regulations.

3.1 Results Discussion

TCLP sample results for each building composite sample are summarized in Table 4 below. None of the samples of composite building debris had detectable lead and therefore did not exceed the TCLP lead levels. Building debris, if generated as demolition wastes, can be disposed as solid wastes. If painted surfaces in the buildings are stripped or removed, the concentrated paint waste may still exceed the TCLP lead levels and become hazardous wastes.

TABLE 4

Toxicity Characteristic Leaching Procedure (TCLP) Lead Sampling Results –

JBLE Ft. Eustis Buildings 814, 820, 2802 April 28-29, 2021

Sample No. Sample Location/Description Sample Weight (grams)

TCLP Lead (mg/L)

Building 814

TCLP-2

Basement - Composite sample of Gloss White-painted CMU; Blue Epoxy coating in stairwells; white-painted ceiling tile; White-painted Concrete foundation wall and structural ceiling; Brown-painted Concrete stairs/walkway and Beige Stucco siding

100 <0.50

TCLP-3

1st Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

White-painted Concrete walls; and White-painted Structural Ceiling

100 <0.50

TCLP-4

2nd Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

and White-painted Structural Ceiling

100 <0.50

TCLP-5

3rd Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

and White-painted Structural Ceiling

100 <0.50

Building 820

TCLP-6

Basement - Composite sample of Gloss White-painted CMU; Blue Epoxy coating in stairwells; White-painted ceiling tile; White-painted Concrete foundation wall and structural ceiling; Brown-painted Concrete stairs/walkway and Beige Stucco siding

100 <0.50

TCLP-7

1st Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

White-painted Concrete walls; and White-painted Structural Ceiling

100 <0.50

TCLP-8

2nd Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

and White-painted Structural Ceiling

100 <0.50

TCLP-9

3rd Floor – composite of White-painted Drywall; Blue-painted Molding/Trim on doors/baseboards; Gloss White CMU; Blue Epoxy coating in stairwells; White ceiling tile;

and White-painted Structural Ceiling

100 <0.50

Building 2802

TCLP-1

Composite of green & white-painted CMU walls, green-painted concrete window sill, green-painted metal window, and white structural ceiling

100 <0.50 mg/L = milligrams per Liter. Regulatory limit for TCLP lead = 5.0 mg/L CMU = concrete masonry unit

3.2 Recommendations

All buildings contain painted surfaces that may contain total lead levels within the paint. Total lead concentration in paint was not tested as part of this scope of services. The OSHA Lead Exposure in Construction Standard (29 CFR 1926.62) does not identify a minimum concentration for lead, but must be followed when conducting any maintenance or construction activity that will affect painted surfaces with any detectable lead, including demolition. Composite samples of building materials from each building were tested for leachable lead by the Toxicity Characteristic Leaching Procedure (TCLP), and for all buildings the leachable lead levels were below regulatory limits. Based on this limited testing, building demolition wastes would NOT be considered hazardous wastes.

OSHA defines airborne concentrations and references specific types of work practices and operations from which a lead hazard may be generated. Environmental and personnel monitoring should be conducted during any removal/demolition process (as appropriate) to verify that actual personal exposures are below the Permissible Exposure Limit (PEL). Under OSHA requirements, the contractor performing the work will be required to conduct this monitoring and follow all of the other requirements found under 29 CFR 1926.62.

Per OSHA standards, dpSTUDIO recommends personnel monitoring to be conducted during any removal or demolition process (as appropriate) to determine actual personal exposure. This monitoring information can be used to determine the levels of personnel protection and environmental controls required for work involving specific removal/demolition processes on specific structures. Adequate personal protection should be provided to any personnel working on LBP or LCP surfaces, or other similar surfaces which are painted with the same painting history, when there is potential for generation of airborne lead dust or fumes (i.e., through grinding, cutting, or sanding). During demolition work, environmental controls will be required to capture lead dust that is generated. Lead dust and/or residue should be properly removed and disposed of in accordance with federal, state, and local regulations.

If paint is stripped or otherwise removed, the waste paint may be considered a regulated waste and require special handling due to its lead content. Some painted surfaces in the building were damaged as evidenced by chipped and peeling paint and accumulations of paint debris on floors, which can create a lead hazard from dust in the building, or on exterior surfaces in the case of lead-based paint on windows.

4.0 Other Environmental Conditions

The scope of services did not include and assessment of potential Universal Wastes in the buildings. EPA’s universal waste regulations are a subset of the Hazardous Waste Management regulations to promote collection and recycling and ease regulatory burden for certain hazardous waste that are commonly generated by a wide range of facilities, including schools and public buildings. The streamlined regulations, found at Title 40 of the Code of Federal Regulations (CFR) in part 273, address Batteries, Pesticides, Mercury-Containing Equipment, Lamps, and other common building wastes. Potential Universal wastes in Buildings 814 and 820 may include:

fluorescent light tubes and associated ballasts that may contain regulated (> 50 ppm) amounts of polychlorinated biphenyls (PCBs); smoke alarms that may contain radioactive materials, and thermostats that may contain Mercury (Hg) switches. If future renovation, demolition, or building maintenance activities are to affect these materials, a survey is recommended to identify potential PCBs, Hg and radioactive substances and plan for appropriate recycling or disposal in accordance with applicable regulations.

5.0 Certifications and Limitations

This survey report has been prepared for the exclusive use of JBLE CED, and its agents or direct assigns with respect to identifying asbestos-containing materials (ACM) and TCLP lead in buildings at the subject property only. This report identifies those suspect materials and the appropriate response actions in accordance with the pertinent OSHA and EPA regulations. The findings and conclusions herein are based solely upon information developed following the methodology and guidance obtained from the EPA’s Asbestos Hazard Emergency Response Act (AHERA) regulation (40 CFR Part 763), EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation (40 CFR Part 61), OSHA’s Asbestos Construction Standard (29 CFR 1926.1101), and Virginia Department of Professional and Occupational Regulations (VA DPOR).

An inspector properly trained by EPA-accredited training institutions and subsequently licensed in the Commonwealth of Virginia to perform asbestos inspections performed the building survey. The inspector reviewed available records pertaining to the facility's construction, previous inspections, and/or abatement/response actions when and if available. Attempts were made to gain access to all areas of the facility. As specified under AHERA, those areas that could not be accessed should be assumed to contain asbestos. Quantity estimates in this report are for planning purposes only. A more precise quantity estimate may be necessary prior to the development of abatement specifications and costs for abatement, if needed.

dpSTUDIO assumes no liability and makes no claims regarding ACM that was not accessible during the inspection process. This includes, but is not limited to items within walls, concrete decks, chases, or otherwise generally inaccessible.

Respectfully Submitted:

Dennis Papa, PE, BCEE Licensed Asbestos Inspector No. 3303002482 Licensed Professional Engineer No. 0402039735

APPENDIX A

LABORATORY ANALYSIS DATA

A

AmeriSci Richmond

13635 GENITO ROAD

MIDLOTHIAN, VIRGINIA 23112

TEL: (804) 763-1200 • FAX: (804) 763-1800

04/30/21 AmeriSci Job # 121042237 05/03/21

1 14 Fort Eustis; Bldg 814

PLM Bulk Asbestos Report Date Received Date Examined

RE:

ofPage

P.O. # Viro-Technology

1108 E. Main St.

Suite 702 Richmond, VA 23219

Attn: Vincent White

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-01-1 121042237-01 2% DW; Rm 339

Off-White, Heterogeneous, Non-Fibrous, Joint Compound Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-01-2 121042237-02 2% DW; Rm 216

Off-White, Heterogeneous, Non-Fibrous, Joint Compound Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-01-3 121042237-03 NAD DW; Stairwell

White, Heterogeneous, Non-Fibrous, Joint Compound

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-02-4 121042237-04 NAD JC; Rm 339

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-02-5 121042237-05 NAD JC; Rm 216

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

See Reporting notes on last page

AmeriSci Job #: 121042237 Page 2 of 14

Fort Eustis; Bldg 814

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-02-6 121042237-06 NAD JC; Stairwell

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-03-7 121042237-07 NAD CDW; Rm 216 Bathroom

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-03-8 121042237-08 NAD CDW; 1st FL Kitchen Men RR

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-03-9 121042237-09 NAD CDW; 1st FL Kitchen Women RR

White/Brown, Heterogeneous, Fibrous, Drywall

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-04-10 121042237-10 NAD CJC; Rm 216 Bathroom

White, Heterogeneous, Non-Fibrous, Joint Compound

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-04-11 121042237-11 NAD CJC; 1st FL Kitchen Men RR

White, Heterogeneous, Non-Fibrous, Joint Compound

Non-fibrous 100%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 3 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-04-12 121042237-12 NAD CJC; 1st FL Kitchen Women RR

White, Heterogeneous, Non-Fibrous, Joint Compound

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-05-13 121042237-13 NAD 2x2 CT; 1st

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-05-14 121042237-14 NAD 2x2 CT; 2nd FL

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-05-15 121042237-15 NAD 2x2 CT; 3rd FL

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-06-16 121042237-16 NAD 2x2 CT Bumpy; 3rd FL

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-06-17 121042237-17 NAD 2x2 CT Bumpy; 2nd FL

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 4 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-06-18 121042237-18 NAD 2x2 CT Bumpy; 1st FL

White/Gray, Heterogeneous, Fibrous, Ceiling Tile

Cellulose 65%, Fibrous glass 25%, Non-fibrous 10%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-07-19 121042237-19 NAD Carpet Mastic; 3rd FL

Transparent, Heterogeneous, Non-Fibrous, Carpet Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-07-20 121042237-20 NAD Carpet Mastic; 2nd FL

Transparent, Heterogeneous, Non-Fibrous, Carpet Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-07-21 121042237-21 NAD Carpet Mastic; 1st FL

Transparent, Heterogeneous, Non-Fibrous, Carpet Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-22 121042237-22L1 2% Tile/Mastic; Rm 339 3rd FL

Brown, Heterogeneous, Non-Fibrous, Floor Tile Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-22 121042237-22L2 3% Tile/Mastic; Rm 339 3rd FL

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 3.0 % Non-fibrous 97%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 5 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-23 121042237-23L1 2% Tile/Mastic; Rm 216 2nd FL

Brown, Heterogeneous, Non-Fibrous, Floor Tile Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-23 121042237-23L2 3% Tile/Mastic; Rm 216 2nd FL

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 3.0 % Non-fibrous 97%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-24 121042237-24L1 2% Tile/Mastic; Rm 1st FL Hall

Brown, Heterogeneous, Non-Fibrous, Floor Tile Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-08-24 121042237-24L2 3% Tile/Mastic; Rm 1st FL Hall

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 3.0 % Non-fibrous 97%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-09-25 121042237-25L1 2% 12x12/Mastic; 1st FL Kitchen

Brown, Heterogeneous, Non-Fibrous, Floor Tile Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-09-25 121042237-25L2 3% 12x12/Mastic; 1st FL Kitchen

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 3.0 % Non-fibrous 97%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 6 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-09-26 121042237-26L1 2% 12x12/Mastic; 1st FL Foyer

Brown, Heterogeneous, Non-Fibrous, Floor Tile Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-09-26 121042237-26L2 3% 12x12/Mastic; 1st FL Foyer

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 3.0 % Non-fibrous 97%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-10-27 121042237-27L1 NAD Blue 12x12/Mastic; 1st FL Kitchen Office

Blue, Heterogeneous, Non-Fibrous, Floor Tile

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-10-27 121042237-27L2 2% Blue 12x12/Mastic; 1st FL Kitchen Office

Black/Yellow, Heterogeneous, Non-Fibrous, Mastic Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-10-28 121042237-28L1 NAD Cream 12x12/Mastic; 1st FL Kitchen Office

White, Heterogeneous, Non-Fibrous, Floor Tile

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-10-28 121042237-28L2 2% Cream 12x12/Mastic; 1st FL Kitchen Office

Black/Yellow, Heterogeneous, Non-Fibrous, Mastic Chrysotile 2.0 % Non-fibrous 98%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 7 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-11-29 121042237-29 NAD Epoxy; Stairwell

Blue, Heterogeneous, Non-Fibrous, Epoxy Flooring

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-11-30 121042237-30 NAD Epoxy; Stairwell

Blue, Heterogeneous, Non-Fibrous, Epoxy Flooring

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-11-31 121042237-31 NAD Epoxy; Rm 216

Blue, Heterogeneous, Non-Fibrous, Epoxy Flooring

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-12-32 121042237-32 5% Black Wall Mastic; 3rd FL Chase

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 5.0 % Non-fibrous 95%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-12-33 121042237-33 5% Black Wall Mastic; 2nd FL Chase

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 5.0 % Non-fibrous 95%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-12-34 121042237-34 5% Black Wall Mastic; 2nd FL Chase

Black, Heterogeneous, Non-Fibrous, Mastic Chrysotile 5.0 % Non-fibrous 95%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 8 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-13-35 121042237-35 NAD Door Ins; 3rd FL

White, Heterogeneous, Fibrous, Insulation

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-13-36 121042237-36 NAD Door Ins; 2nd FL

White, Heterogeneous, Non-Fibrous, Insulation

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-13-37 121042237-37 NAD Door Ins; 1st FL

White, Heterogeneous, Non-Fibrous, Insulation

Cellulose 10%, Non-fibrous 90%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-14-38 121042237-38 NAD White Seam Mastic; 3rd FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-14-39 121042237-39 NAD White Seam Mastic; 2nd FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-14-40 121042237-40 NAD White Seam Mastic; 1st FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 9 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-15-41 121042237-41 NAD White Seam Mastic; Newer Duct 3rd FL

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-15-42 121042237-42 NAD White Seam Mastic; Newer Duct 2nd FL

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-15-43 121042237-43 NAD White Seam Mastic; Newer Duct 1st FL

White, Heterogeneous, Non-Fibrous, Mastic

Non-fibrous 100%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-16-44 121042237-44 NAD 2" MJP Lower; 3rd FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Fibrous glass 20%, Non-fibrous 80%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-16-45 121042237-45 NAD 2" MJP Lower; 2nd FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Fibrous glass 20%, Non-fibrous 80%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-16-46 121042237-46 NAD 2" MJP Lower; 1st FL Chase

White, Heterogeneous, Non-Fibrous, Mastic

Fibrous glass 20%, Non-fibrous 80%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 10 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-17-47 121042237-47 2% Pipe Ins; Crawlspace

Gray, Heterogeneous, Non-Fibrous, Insulation Chrysotile 2.0 % Fibrous glass 5%, Non-fibrous 93%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-17-48 121042237-48 2% Pipe Ins; Crawlspace

Gray, Heterogeneous, Non-Fibrous, Insulation Chrysotile 2.0 % Fibrous glass 5%, Non-fibrous 93%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

Yes814-17-49 121042237-49 2% Pipe Ins; Crawlspace

Gray, Heterogeneous, Non-Fibrous, Insulation Chrysotile 2.0 % Fibrous glass 5%, Non-fibrous 93%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-18-50 121042237-50 NAD Crawlspace Ceiling Material

Brown, Heterogeneous, Fibrous, Fibrous Material

Cellulose 98%, Non-fibrous 2%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-18-51 121042237-51 NAD Crawlspace Ceiling Material

Brown, Heterogeneous, Fibrous, Fibrous Material

Cellulose 98%, Non-fibrous 2%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-18-52 121042237-52 NAD Crawlspace Ceiling Material

Brown, Heterogeneous, Fibrous, Fibrous Material

Cellulose 98%, Non-fibrous 2%

(by CVES) by Virginia Jones

AmeriSci Job #: 121042237 Page 11 of 14

PLM Bulk Asbestos Report Client Name: Viro-Technology

Asbestos Present Total % AsbestosClient No. / HGA Lab No.

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-19-53 121042237-53L1 NAD BUR Roof

Black, Heterogeneous, Non-Fibrous, Shingle

Fibrous glass 15%, Non-fibrous 85%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-19-53 121042237-53L2 NAD BUR Roof

Black, Heterogeneous, Fibrous, Felt

Fibrous glass 20%, Non-fibrous 80%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-19-53 121042237-53L3 NAD BUR Roof

Off-White, Heterogeneous, Non-Fibrous, Powdery Material

Non-fibrous 95%, Vermiculite 5%

(by CVES) by Virginia Jones on 05/03/21

Location:

Analyst Description:

Asbestos Types:

Other Material:

No814-19-54 121042237-54L1 NAD BUR Roof

Black, Heterogeneous, Non-Fibrous, Shingle

Fibr…