Attch_5_-_XQPZ_12-0114_Sampling_Report.pdf

Limited Asbestos & Lead-Containing Paint

Sampling Report Sustain / Repair HVAC Units – Arnold Hall

U.S. Air Force Academy

Colorado Springs, Colorado

February 21, 2017

Terracon Project No. 23167154

Prepared for:

Farris Engineering

Prepared by:

Terracon Consultants, Inc.

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TABLE OF CONTENTS

Page No.

1.0 INTRODUCTION

1.1 Project Objective

1.2 Reliance

1.3 Asbestos

1.4 Lead-Containing Paint

2.0 BUILDING DESCRIPTION

3.0 FIELD ACTIVITIES

3.1.1 Asbestos

3.1.2 Lead-Containing Paint

3.2 Physical Assessment

3.2.1 Asbestos

3.2.2 Lead-Containing Paint

3.3 Sample Collection

3.3.1 Asbestos

3.3.2 Lead-Containing Paint

3.4 Sample Analysis

3.4.1 Asbestos

3.4.2 Lead-Containing Paint

4.0 REGULATORY OVERVIEW

4.1 Asbestos

4.2 Lead-Containing Paint

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos

5.2 Lead-Containing Paint

6.0 GENERAL COMMENTS

APPENDICES

APPENDIX A ASBESTOS AND LEAD PAINT SAMPLE SUMMARY

APPENDIX B EXHIBITS

APPENDIX C ASBESTOS AND LEAD PAINT ANALYTICAL LABORATORY DATA

APPENDIX D CERTIFICATIONS

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LIMITED ASBESTOS & LEAD-CONTAINING PAINT SAMPLING REPORT

SUSTAIN / REPAIR HVAC UNITS – ARNOLD HALL

U.S. AIR FORCE ACADEMY

COLORADO SPRINGS, COLORADO

Terracon Project No. 23167154

February 21, 2017

1.0 INTRODUCTION

Terracon conducted limited asbestos containing material (ACM) and lead-containing paint (LCP) sampling to support the Sustain / Repair HVAC Units – Arnold Hall project. Sample collection of suspect ACM and LCP materials included selected interior areas of the facility identified as being potentially affected by the proposed renovations. John Harness a Colorado-certified asbestos building inspector with Terracon conducted sampling efforts on November 22, 2016.

1.1 Project Objective

The objective of this project was to identify the presence or absence of ACM and LCP that may be impacted by the proposed renovation activities. Terracon’s scope was limited to two mechanical rooms including Mechanical Room 314 on the third floor, and the northwest mechanical room in the basement.

1.2 Reliance

This report is for the exclusive use of Farris Engineering for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and Farris

Engineering. Reliance on this report by Farris Engineering and all authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report and Terracon’s

Agreement for Services. The limitation of liability defined in Terracon’s Agreement for Services is the aggregate limit of Terracon’s liability to Farris Engineering.

Limited Asbestos & Lead-Containing Paint Sampling Report

Sustain / Repair HVAC Units – Arnold Hall ■ Colorado Springs, Colorado

Terracon Project No. 23167154 ■ February 21, 2017

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1.3 Asbestos

Asbestos sampling was performed to support the proposed renovation activities. EPA regulation

40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants (NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated asbestos-containing building materials be identified, classified and quantified prior to planned disturbances or demolition activities. Homogeneous areas of suspect ACM were visually identified and documented.

Suspect ACM samples were collected in general accordance with the sampling protocols outlined in EPA regulation 40 CFR 763 (Asbestos Hazard Emergency Response Act, AHERA). Samples were delivered to an accredited laboratory for analysis by polarized light microscopy.

1.4 Lead-Containing Paint

Samples of suspect LCP were collected from randomly selected and representative painted substrates (walls, I-beams, doorframes). Samples were delivered to an accredited laboratory for analysis using atomic absorption spectrophotometry (AAS) by U.S. EPA SW-846 Method 3050B

7000B.

The U.S. Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1926.62 –

Lead Exposure in Construction, established airborne lead concentration limits for the Construction

Industry. OSHA has not established limits for lead content in bulk materials. Their interpretation of this issue is that any amount of lead may cause airborne concentrations above the established limits when most lead-related construction tasks are performed. Therefore, during demolition/renovation activities which may disturb lead, employees must be protected from lead exposures above the OSHA Permissible Exposure Limit (PEL).

2.0 BUILDING DESCRIPTION

Arnold Hall is a multi-story building consisting of a concrete and steel structure. Terracon surveyed portions of the building including the mechanical room on the third floor (Mechanical

Room 314) and a mechanical room in the basement northwest side of the building. Arnold Hall was reportedly constructed in the 1960s.

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3.0 FIELD ACTIVITIES

The survey was conducted by John Harness, a Colorado-certified asbestos building inspector. A copy of the asbestos inspector’s licenses are attached as Appendix D. The survey was conducted in general accordance with the sample collection protocols established in EPA regulation 40 CFR 763, of AHERA. A summary of survey activities is provided below.

The limited LCP sampling was conducted to provide the client with information to help comply with

OSHA requirements for evaluating the potential for lead-in-air content during disturbance of painted materials. The LCP testing was not performed to the HUD “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing”, EPA regulation 40 CFR 745, Amendment to Final Rule: Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child-

Occupied Facilities; Certification Requirement and Work Practice Standards for Individuals and

Firms, or State of Colorado Regulation No. 19, “Lead-Based Paint Abatement” since these guidelines and regulation do not apply to commercial facilities, such as this site.

3.1 Visual Assessment

3.1.1 Asbestos

Terracon began survey activities with visual observation of the potentially affected areas to identify homogeneous areas of suspect ACM. A homogeneous area consists of building materials that appear similar throughout a given area in terms of color, texture and date of application. Terracon conducted an interior assessment throughout visually accessible areas of each area.

Per the client’s request, destructive sampling to access wall or ceiling voids was not conducted.

Building materials identified as concrete, glass, wood, masonry, metal or rubber were not considered suspect ACM.

3.1.2 Lead-Containing Paint

Terracon visually assessed interior areas of the site building to identify construction materials suspect for LCP. Painted/coated surfaces which appear similar throughout in terms of color, texture, substrate and date of application are treated as a homogeneous material for paint chip collection purposes. Painted/coated surfaces were visually assessed for evidence of distress, flaking, and/or peeling.

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3.2 Physical Assessment

3.2.1 Asbestos

Terracon conducted a physical assessment of each homogeneous area of suspect ACM to assess the friability and condition of the materials. A friable material is defined by the EPA as a material which can be crumbled, pulverized or reduced to powder by hand pressure when dry.

Friability was assessed by physically touching suspect materials.

3.2.2 Lead-Containing Paint

Terracon conducted a physical assessment of each selected painted surface was conducted to assess its condition. The painted surfaces were assessed as good, fair or poor condition depending on degree of cracking, peeling or chipping.

3.3 Sample Collection

3.3.1 Asbestos

Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA sampling protocols. Samples of suspect materials were collected in a random manor in each homogeneous area. Mr. Harness collected bulk samples using wet methods as applicable to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

Terracon collected 32 bulk samples from eight homogeneous areas of suspect ACM. A summary of suspect ACM samples collected during the sampling is included as Appendix A.

3.3.2 Lead-Containing Paint

Based on results of the visual observation, paint chip samples of painted substrates were collected from the interior surfaces of the subject structure. OSHA considers that surface coatings or materials that contain lead at concentrations exceeding the laboratory detection limit demonstrate the presence of lead surface coatings or material may constitute a health hazard to employees engaged in lead-related construction work. A negative exposure assessment should be conducted to determine if exposure during construction activities are below the required OSHA action and permissible levels. Twenty-one paint chip samples were collected from components of the HVAC system and floor of the site building. The suspect materials are tabulated in Appendix

A.

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3.4 Sample Analysis

3.4.1 Asbestos

Bulk samples were submitted under chain of custody to EMSL Laboratories (EMSL) in Denver, Colorado for analysis by polarized light microscopy with dispersion staining techniques per EPA methodology (EPA/600/R-93/116). The percentage of asbestos, where applicable, was determined by microscopical visual estimation. EMSL is accredited under the National

Voluntary Laboratory Accreditation Program (NVLAP Accreditation No. 200828-0). Copies of the analytical reports and chain-of-custody forms are provided in Appendix C.

3.4.2 Lead-Containing Paint

Twenty-one samples of suspect LCP were delivered under proper chain-of-custody to EMSL using AAS by USEPA SW-846 Method 3050B 7000B. Copies of the analytical reports and chain-of-custody forms are provided in Appendix C.

4.0 REGULATORY OVERVIEW

4.1 Asbestos

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing building materials prior to demolition or renovation activity. Under NESHAP, asbestos-containing building materials are classified as either friable, Category I non-friable or Category II non-friable

ACM. Friable materials are those that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Category I non-friable ACM includes packings, gaskets, resilient floor coverings and asphalt roofing products containing more than 1% asbestos. Category II non-friable ACM are any materials other than Category I materials that contain more than 1% asbestos.

Friable ACM, Category I and Category II non-friable ACM which is in poor condition and has become friable or which will be subjected to drilling, sanding, grinding, cutting or abrading and which could be crushed or pulverized during anticipated renovation or demolition activities are considered regulated ACM (RACM).

In the State of Colorado, asbestos activities are regulated by the Colorado Department of Public

Health and Environment (CDPHE) under the Regulation No. 8, Control of Hazardous Air

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Pollutants, Colorado Air Quality Control Division, Section III, Part 6. Regulation No. 8 requires that any asbestos-related activity conducted in a public or commercial building be performed by personnel licensed by the CDPHE. RACM must be removed prior to renovation or demolition activities which will disturb the materials. If the amount of RACM exceeds 260 linear feet (lf) of pipe insulation, more than 160 ft2 on other building components, or will generate more than one

55-gallon drum of waste, the owner or operator must provide the CDPHE with written notification of planned removal activities at least 10 working days prior to the commencement of asbestos abatement activities. Removal of RACM must be conducted by a State of Colorado-certified asbestos abatement contractor. Third-party clearance inspections and air monitoring must be conducted by a Colorado-certified Air Monitoring Specialist following the abatement activities.

Asbestos abatement of friable materials for projects greater than 1,000 lf of pipe insulation or more than 3,000 ft2 on other building components must be performed in accordance with a Project

Design prepared by a Colorado-certified Project Designer. Management Plans developed for the in-place management of asbestos-containing materials must be developed by a Colorado-certified Management Planner.

The OSHA Asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc). The

OSHA standard classifies construction and maintenance activities which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work. States which administer their own federally-approved state OSHA programs may require additional precautions.

4.2 Lead-Containing Paint

The LCP sampling was performed in general accordance with the procedures prescribed in the

EPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). Lead is regulated by the EPA and OSHA at the federal level and by CDPHE at the state level.

The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials.

Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

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Detectable lead quantities may constitute a lead dust hazard during renovation/demolition activities. Personnel performing renovation/demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure. OSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Currently, any proposed renovation/demolition is subject to the OSHA regulations

(29 CFR 1926.62 – Lead Exposure in Construction).

Contractors and employers are required to comply with 29 CFR 1926.62. Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection. The OSHA Standards also establish an action level of 30 g/m3, which if exceeded, triggers the requirement for medical monitoring. The OSHA standard does not define the amount of lead in paint that constitutes lead based paint. A negative exposure assessment per trigger task should be conducted to determine if actual airborne levels are below the required

OSHA action and permissible levels.

5.0 FINDINGS AND RECOMMENDATIONS

5.1 Asbestos

Laboratory analysis identified the presence of friable asbestos in thermal system insulation

(TSI) samples (TSI-02-01, -02, -03) obtained from a broken pipe elbow located in Mechanical

Room 314 next to “S-3-3M”; in TSI sample (TSI-04-03) obtained from a pipe fitting on the south side of “S-6”; and in TSI samples (TSI-06-01, -02, -03) obtained from pipe insulation on “P-15

EGS line”. Laboratory analytical reports are included in Appendix C. Approximate locations of confirmed ACM are shown on Exhibits 1 and 2, Appendix B.

Compliance with all applicable OSHA regulations regarding occupational exposure during renovation activities is mandatory. OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities be protected from asbestos fibers in excess of the permissible exposure limit of 0.1 f/cc of air. Contractors are advised to comply with applicable provisions of

OSHA 29 CFR 1926.1101 during renovation activities.

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5.2 Lead-Containing Paint

Lead was detected in white paint chip samples located on air handlers and I-beams, in brown paint chip samples on “pads”, in red paint chip samples on P-18 pump, and in gray paint chip samples on exterior louvers. The painted surfaces were noted to be in generally good (intact) condition. Laboratory results of surface coatings tested for lead are provided in Appendix C.

Approximate locations of confirmed LCP are shown on Exhibits 1 and 2, Appendix B.

The OSHA Interim Lead Standard for Construction (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions. Under this standard, construction includes, but is not limited to, the following:

Demolition or salvage of structures where lead or materials containing lead are present

Removal or encapsulation of materials containing lead

New construction, alteration, repair, or renovation of structures, substrates, or portions containing lead, or materials containing lead

Installation of products containing lead

Lead contamination/emergency clean-up

Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed

Maintenance operations associated with construction activities described above

6.0 GENERAL COMMENTS

The limited asbestos and lead-containing paint sampling were conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our sampling of the building. The information contained in this report is relevant to the date on which these samplings were performed, and should not be relied upon to represent conditions at a later date.

This report has been prepared on behalf of and exclusively for use by Farris Engineering for specific application to their project as discussed. This report is not a bidding document.

Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of

Responsive ■ Resourceful ■ Reliable 9 regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

APPENDIX A

LIMITED ASBESTOS & LEAD BASED PAINT SAMPLE

SUMMARY

Asbestos

U.S. Air Force Academy, Sustain / Repair HVAC Units – Arnold Hall

SAMPLE DATE SAMPLE NO. DESCRIPTION

SAMPLE

LOCATION

LAB

RESULTS

11/22/2016

TS-01-01

Yellow fiberglass - thermal system insulation (TSI)

Mech Room

314 S-3

ND

TS-01-02 ND

TS-01-03 ND

TS-01-04

S-2A above duct

ND

11/22/2016

TS-02-01

Hand pack fitting – white elbow

Broken elbow next to S-3-3M

12% Amosite, 4% Chrysotile

TS-02-02

10% Amosite, 4% Chrysotile

TS-02-03

12% Amosite, 6% Chrysotile

11/22/2016

TS-03-01

Outdoor air plenum N-AH

Yellow insulation with black paper

ND

TS-03-02 ND

TS-03-03 ND

11/22/2016

TS-04-01

White hand pack fitting/elbow

S. side of S-6 ND

TS-04-02 S. side of S-6 ND

TS-04-03 S. side of S-6 10% Amosite, 3% Chrysotile

TS-04-04 N. side of S-6 ND

11/22/2016

TS-05-01

Black foam, blue wrap

S-7 N. Side ND

TS-05-02 S-10 S. Side ND

TS-05-03 S-8 N. side ND

11/22/2016

VD-01-01

Vibration dampener

S-6 South ND

VD-01-02 S-6 North ND

VD-01-03 S-7 South ND

VD-01-04 S-7 North ND

VD-01-05 S-8 North ND

VD-01-06 S-9 South ND

VD-01-07 S-10 SW ND

VD-01-08 S-10 SE ND

VD-01-09 S-10 NE ND

11/22/2016

TS-06-01

Hand pack insulation

P-18 EGS West 12% Amosite, 5% Chrysotile

TS-06-02 P-18 EGS East 10% Amosite, 4% Chrysotile

SAMPLE DATE SAMPLE NO. DESCRIPTION

SAMPLE

LOCATION

LAB

RESULTS

TS-06-03 P-18 EGS East 10% Amosite, 4% Chrysotile

11/22/2016

TS-05-01

Yellow insulation / Black

Paper, Mastic

P-18 EGS East ND / ND

TS-05-02

Connect P-18-

CU-10

ND / ND

TS-05-03

CU-10 East

Side

ND / ND

ND = No asbestos detected

BOLD = Positive Identification of Asbestos

Lead Containing Paint

U.S. Air Force Academy, Sustain / Repair HVAC Units – Arnold Hall

Sample

Number Location Component Color Condition

Result

(% by weight)

LBP-01-01

E2 Air Handler

Room 314

Air Handler White Intact 0.36

LBP-01-02 Air Handler White Intact 0.36

LBP-01-03 Air Handler White Intact 0.30

LBP-02-01 S-6 Air Handler White Intact 0.20

LBP-02-02 S-9 Air Handler White Intact 0.21

LBP-02-03

S-10 NE

corner floor I-beam White Intact 0.14

LBP-03-01

Floor between

8-9

Concrete Gray Intact <0.014

LBP-03-02 Concrete Gray Intact <0.020

LBP-03-03 Concrete Gray Intact <0.043

LBP-04-01 S-6 Concrete Pad Brown Intact 0.035

LBP-04-02 S-8 Concrete Pad Brown Intact 0.047

LBP-04-03 S-10 Concrete Pad Brown Intact 0.045

LBP-05-01 P-18 Pump Red Intact 0.34

LBP-05-02 P-18 Pump Red Intact 0.41

LBP-05-03 P-18 Pump Red Intact 0.41

LBP-06-01 S-6 under

H2O Storage

Tank

Tank Support Yellow Intact NS

LBP-06-02 Tank Support Yellow Intact <0.032

LBP-06-03 Tank Support Yellow Intact NS

LBP-07-01

Outside louvers

Louver Gray Intact 0.071

LBP-07-02 Louver Gray Intact 0.16

LBP-07-03 Louver Gray Intact 0.16

Bold Lead concentrations above laboratory detection limits

Intact No visible damage or deterioration

Fair Less than or equal to 10% of the total surface area of the component is deteriorated

Poor More than 10% of the total surface area of the component is deteriorated

< Less than the laboratory detection limit

NS Sample not submitted

APPENDIX B

EXHIBITS

SAMPLE LOCATIONS

NORTH MECHANICAL ROOM

ARNOLD HALL

UNITED STATES AIR FORCE ACADEMY, COLORADO

4172 Center Park Drive Colorado Springs, CO 80916

PH. (719) 597-2116 FAX. (719) 597-2117

23167154

DEC 2016

JH

JH

LRK

LRK

AS SHOWN

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Fig 1

DIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

BASE DRAWING OBTAINED FROM THE

CLIENT AND MAY NOT REFLECT THE

CURRENT SITE CONDITIONS

TSI-

04-

01,02, TSI-04-

0T4

VD-01-

VD-01-

LBP-02-

LBP-06-

01,02,03

VD-01-

VD-01-

TSI-05-01

TSI-05-02 TSI-05-03

TSI-03-01,02,03

VD-01-05

LBP-03-

01,02,03

VD-01-09

VD-01-

LBP-02-02

LBP-02-03

Sample Locations

NORTH MECHANICAL ROOM

ARNOLD HALL

USAFA, COLORADO

4172 Center Park Drive Colorado Springs, CO 80916

PH. (719) 597-2116 FAX. (719) 597-2117

23167155

DEC 2016

JH

LRK

LRK

AS SHOWN

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Fig 2

DIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

BASE DRAWING OBTAINED FROM THE

CLIENT AND MAY NOT REFLECT THE

CURRENT SITE CONDITIONS

LBP-05-01,02,03

TS-07-

01,02,03

TS-06-

01,02,03

JH

SAMPLE LOCTAIONS

MECH ROOM 314

ARNOLD HALL

USAFA, COLORADO

4172 Center Park Drive Colorado Springs, CO 80916

PH. (719) 597-2116 FAX. (719) 597-2117

23167155

DEC 2016

JH

JH

LRK

LRK

AS SHOWN

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Fig 4

DIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

BASE DRAWING OBTAINED FROM THE

CLIENT AND MAY NOT REFLECT THE

CURRENT SITE CONDITIONS

TSI-01-01,02,03

TSI-01-04

LBP-01-01,02,03

APPENDIX C

ANALYTICAL LABORATORY DATA

ConcentrationAnalyzed RDL LeadClient SampleDescription Collected

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: John Harness Terracon Consultants, Inc.

4172 Center Park Drive Colorado Springs, CO 80916

Received: 11/23/16 11:30 AM

23167154

Fax: (719) 597-2117 Phone: (719) 597-2116

Project:

11/22/2016Collected:

201612905 CustomerID: TRRA26 CustomerPO: 23167154 ProjectID:

EMSL Order:

Site: C2 - A/C Handler - White Paint

0.36 % wt11/23/2016

201612905-0001 0.02711/22/2016LBP-01-01 % wt

Site: C2 - A/C Handler - White Paint

0.36 % wt11/23/2016

201612905-0002 0.03611/22/2016LBP-01-02 % wt

Site: C2 - A/C Handler - White Paint

0.30 % wt11/23/2016

201612905-0003 0.04511/22/2016LBP-01-03 % wt

Site: North Mech Room S-6-South

0.20 % wt11/23/2016

201612905-0004 0.01011/22/2016LBP-02-01 % wt

Site: North Mech Room S-9-South

0.21 % wt11/23/2016

201612905-0005 0.01511/22/2016LBP-02-02 % wt

Site: S-10 NE Corner Floor I-Beam- White

0.14 % wt11/23/2016

201612905-0006 0.01011/22/2016LBP-02-03 % wt

Site: Gray Floor Between S-9 - Gray Floor <0.014 % wt11/23/2016

201612905-0007 0.01411/22/2016LBP-03-01 % wt

Site: Gray Floor Between S-9 - Gray Floor <0.020 % wt11/23/2016

201612905-0008 0.02011/22/2016LBP-03-02 % wt

Site: Gray Floor Between S-9 - Gray Floor <0.043 % wt11/23/2016

201612905-0009 0.04311/22/2016LBP-03-03 % wt

Site: Brown Pad- S-6 - Brown

0.035 % wt11/23/2016

201612905-0010 0.01011/22/2016LBP-04-01 % wt

Site: Brown Pad- S-8 - Brown

0.047 % wt11/23/2016

201612905-0011 0.01011/22/2016LBP-04-02 % wt

Page 1 of 2Test Report PB w/RDL-7.32.3 Printed: 11/25/2016 9:40:04 AM

Phillip Worby, Lead Laboratory Manager or other approved signatory

*Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.010 % wt based on the minimum sample weight per our SOP. Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise.

Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 11/25/2016 09:40:04 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com

ConcentrationAnalyzed RDL LeadClient SampleDescription Collected

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3050B/7000B)*

EMSL Analytical, Inc.

200 Route 130 North, Cinnaminson, NJ 08077 Phone/Fax: (856) 303-2500 / (856) 786-5974 http://www.EMSL.com cinnaminsonleadlab@emsl.com

Attn: John Harness Terracon Consultants, Inc.

4172 Center Park Drive Colorado Springs, CO 80916

Received: 11/23/16 11:30 AM

23167154

Fax: (719) 597-2117 Phone: (719) 597-2116

Project:

11/22/2016Collected:

201612905 CustomerID: TRRA26 CustomerPO: 23167154 ProjectID:

EMSL Order:

Site: Brown Pad- S-10 - Brown

0.045 % wt11/23/2016

201612905-0012 0.01011/22/2016LBP-04-03 % wt

Site: P-18 Red

0.34 % wt11/23/2016

201612905-0013 0.01011/22/2016LBP-05-01 % wt

Site: P-18 Red

0.41 % wt11/23/2016

201612905-0014 0.01011/22/2016LBP-05-02 % wt

Site: P-18 Red

0.41 % wt11/23/2016

201612905-0015 0.01011/22/2016LBP-05-03 % wt

Site: S-6 Yellow Across Storage Tank - Yellow <0.032 % wt11/23/2016

201612905-0017 0.03211/22/2016LBP-06-02 % wt

Site: Outside Louvres -Grey

0.071 % wt11/23/2016

201612905-0019 0.01211/22/2016LBP-07-01 % wt

Site: Outside Louvres -Grey

0.16 % wt11/23/2016

201612905-0020 0.01011/22/2016LBP-07-02 % wt

Site: Outside Louvres -Grey

0.16 % wt11/23/2016

201612905-0021 0.01011/22/2016LBP-07-03 % wt

Page 2 of 2Test Report PB w/RDL-7.32.3 Printed: 11/25/2016 9:40:04 AM

Phillip Worby, Lead Laboratory Manager or other approved signatory

*Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.010 % wt based on the minimum sample weight per our SOP. Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. "<" (less than) result signifies that the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise.

Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NELAP Certifications: NJ 03036, NY 10872, PA 68-00367, AIHA-LAP, LLC ELLAP 100194, A2LA 2845.01

Initial report from 11/25/2016 09:40:04 http://www.EMSL.com mailto:cinnaminsonleadlab@emsl.com

OrderID: 201612905

OrderID: 201612905

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041632081EMSL Order:

Customer ID: TRRA26

Customer PO: 23167154

Project ID:

Attention: Phone:John Harness (719) 572-7707

Fax:Terracon Consultants, Inc. (719) 597-2117

Received Date:4172 Center Park Drive 11/23/2016 10:45 AM

Analysis Date:Colorado Springs, CO 80916 11/23/2016

Collected Date: 11/22/2016

Project: 23167154

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

TSI-01-01

041632081-0001

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Mechanical Room

314 S-3 - Thermal

System Insulation

Yellow Fiberglass

Insulation

HA: 1

TSI-01-02

041632081-0002

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Mechanical Room

314 S-3 - Thermal

System Insulation

Yellow Fiberglass

Insulation

HA: 1

TSI-01-03-Insulation

041632081-0003

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

Mechanical Room

314 S-3 - Thermal

System Insulation

Yellow Fiberglass

Insulation

HA: 1

TSI-01-03-Wrap

041632081-0003A

None DetectedNon-fibrous (Other)50%Cellulose

Glass

40%

10%

White/Silver

Fibrous

Homogeneous

Mechanical Room

314 S-3 - Wrap

HA: 1

TSI-02-01

041632081-0004

12%

4%

Amosite

Chrysotile

Non-fibrous (Other)54%Min. Wool30%Gray/White

Fibrous

Homogeneous

Broken Elbow Next to

S-3 - 314 - Hand

Pock Fitting White

Elbow

HA: 2

TSI-02-02

041632081-0005

10%

4%

Amosite

Chrysotile

Non-fibrous (Other)56%Min. Wool30%Gray/White

Fibrous

Homogeneous

Broken Elbow Next to

S-3 - 314 - Hand

Pock Fitting White

Elbow

HA: 2

TSI-02-03

041632081-0006

12%

6%

Amosite

Chrysotile

Non-fibrous (Other)57%Min. Wool25%Gray

Fibrous

Homogeneous

Broken Elbow Next to

S-3 - 314 - Hand

Pock Fitting White

Elbow

HA: 2

TSI-01-04

041632081-0007

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

S-2A above Duct -

White Insulation

Yellow Fib Yellow

Insulation w/Black

Ins.

HA: 1

TSI-03-01-Insulation

041632081-0008

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Yellow

Insulation

HA: 3

TSI-03-01-Mastic

041632081-0008A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Black Mastic

HA: 3

Initial report from: 11/25/2016 08:01:39

Page 1 of 4ASB_PLM_0008 - 1.71 Printed: 11/25/2016 8:01 AM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041632081EMSL Order:

Customer ID: TRRA26

Customer PO: 23167154

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

TSI-03-02-Insulation

041632081-0009

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Yellow

Insulation

HA: 3

TSI-03-02-Mastic

041632081-0009A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Black Mastic

HA: 3

TSI-03-03-Insulation

041632081-0010

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Yellow

Insulation

HA: 3

TSI-03-03-Mastic

041632081-0010A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Outdoor Air planum

N-AH 8 - Black Mastic

HA: 3

TSI-04-01-Insulation

041632081-0011

None DetectedNon-fibrous (Other)75%Min. Wool25%Gray

Fibrous

Homogeneous

S Side of S-6 Bottom

- White Hand Pack

HA: 4

TSI-04-01-Wrap

041632081-0011A

None DetectedNon-fibrous (Other)85%Cellulose15%White/Yellow

Fibrous

Homogeneous

S Side of S-6 Bottom

- Wrap

HA: 4

TSI-04-02-Insulation

041632081-0012

None DetectedNon-fibrous (Other)75%Min. Wool25%Gray

Fibrous

Homogeneous

S Side of S-6 Top -

White Hand Pack

HA: 4

TSI-04-02-Wrap

041632081-0012A

None DetectedNon-fibrous (Other)85%Cellulose15%White/Yellow

Fibrous

Homogeneous

S Side of S-6 Top -

Wrap

HA: 4

TSI-04-03-Insulation

041632081-0013

10%

3%

Amosite

Chrysotile

Non-fibrous (Other)67%Min. Wool20%White

Fibrous

Homogeneous

S Side of S-6 East -

White Hand Pack

The sample group is not homogeneous.

HA: 4

TSI-04-03-Wrap

041632081-0013A

None DetectedNon-fibrous (Other)80%Cellulose20%Yellow

Fibrous

Homogeneous

S Side of S-6 East -

Wrap

HA: 4

TSI-05-01

041632081-0014

None DetectedNon-fibrous (Other)100%Black/Blue

Non-Fibrous

Homogeneous

S-7 N Side - Black

Foam Blue Wrap

HA: 5

TSI-05-02

041632081-0015

None DetectedNon-fibrous (Other)100%Black/Blue

Non-Fibrous

Homogeneous

S-10 S Side - Black

Foam Blue Wrap

HA: 5

TSI-05-03

041632081-0016

None DetectedNon-fibrous (Other)100%Black/Blue

Non-Fibrous

Homogeneous

S-8 N Side - Black

Foam Blue Wrap

HA: 5

TSI-04-04

041632081-0017

Not SubmittedN Side S-6 Yellow -

White Hand Pock

Elbow

HA: 4

Page 2 of 4ASB_PLM_0008 - 1.71 Printed: 11/25/2016 8:01 AM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041632081EMSL Order:

Customer ID: TRRA26

Customer PO: 23167154

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

VD-01-01

041632081-0018

None DetectedNon-fibrous (Other)25%Glass75%Gray

Fibrous

Homogeneous

S-6 South - Vibration

Dampner

HA: 6

VD-01-02

041632081-0019

None DetectedNon-fibrous (Other)35%Glass65%Gray/Black

Fibrous

Homogeneous

S-6 North - Vibration

Dampner

HA: 6

VD-01-03

041632081-0020

None DetectedNon-fibrous (Other)35%Glass65%Gray/Black

Fibrous

Homogeneous

S-7 South - Vibration

Dampner

HA: 6

VD-01-04

041632081-0021

None DetectedNon-fibrous (Other)35%Glass65%Gray/Black

Fibrous

Homogeneous

S-7 North - Vibration

Dampner

HA: 6

VD-01-05

041632081-0022

None DetectedNon-fibrous (Other)35%Glass65%Gray/Black

Fibrous

Homogeneous

S-8 North - Vibration

Dampner

HA: 6

VD-01-06

041632081-0023

None DetectedNon-fibrous (Other)35%Glass65%Gray/Black

Fibrous

Homogeneous

S-9 South - Vibration

Dampner

HA: 6

VD-01-07

041632081-0024

None DetectedNon-fibrous (Other)55%Glass45%Gray/Black

Fibrous

Homogeneous

S-10 SW - Vibration

Dampner

HA: 6

VD-01-08

041632081-0025

None DetectedNon-fibrous (Other)55%Glass45%Gray/Black

Fibrous

Homogeneous

S-10 SE - Vibration

Dampner

HA: 6

VD-01-09

041632081-0026

None DetectedNon-fibrous (Other)55%Glass45%Gray/Black

Fibrous

Homogeneous

S-10 NE - Vibration

Dampner

HA: 6

TSI-06-01-Insulation

041632081-0027

12%

5%

Amosite

Chrysotile

Non-fibrous (Other)58%Min. Wool25%White

Fibrous

Homogeneous

P-18 EGS West -

Hand Pack Insulation

HA: 7

TSI-06-01-Wrap

041632081-0027A

None DetectedNon-fibrous (Other)60%Cellulose40%Blue

Fibrous

Homogeneous

P-18 EGS West -

Wrap

HA: 7

TSI-06-02-Insulation

041632081-0028

10%

4%

Amosite

Chrysotile

Non-fibrous (Other)61%Min. Wool25%White

Fibrous

Homogeneous

P-18 EGS East -

Hand Pack Insulation

HA: 7

TSI-06-02-Wrap

041632081-0028A

None DetectedNon-fibrous (Other)60%Cellulose40%Blue

Fibrous

Homogeneous

P-18 EGS East -

Wrap

HA: 7

TSI-06-03-Insulation

041632081-0029

10%

4%

Amosite

Chrysotile

Non-fibrous (Other)61%Min. Wool25%White

Fibrous

Homogeneous

P-18 EGS East -

Hand Pack Insulation

HA: 7

Page 3 of 4ASB_PLM_0008 - 1.71 Printed: 11/25/2016 8:01 AM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

041632081EMSL Order:

Customer ID: TRRA26

Customer PO: 23167154

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

TSI-06-03-Wrap

041632081-0029A

None DetectedNon-fibrous (Other)60%Cellulose40%Blue

Fibrous

Homogeneous

P-18 EGS East -

Wrap

HA: 7

TSI-07-01-Insulation

041632081-0030

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

P-18 EGS East -

Yellow Insulation

HA: 8

TSI-07-01-Tar Paper

041632081-0030A

None DetectedNon-fibrous (Other)35%Cellulose65%Black

Fibrous

Homogeneous

P-18 EGS East - Tar

Paper

HA: 8

TSI-07-01-Mastic

041632081-0030B

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

P-18 EGS East -

Mastic

HA: 8

TSI-07-01-Paper

041632081-0030C

None DetectedNon-fibrous (Other)15%Cellulose85%White

Fibrous

Homogeneous

P-18 EGS East -

Paper

HA: 8

TSI-07-02-Insulation

041632081-0031

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

Connect P-18-CU-10

- Yellow Insulation

HA: 8

TSI-07-02-Paper

041632081-0031A

None DetectedNon-fibrous (Other)15%Cellulose85%White

Fibrous

Homogeneous

Connect P-18-CU-10

- Paper

HA: 8

TSI-07-03-Insulation

041632081-0032

None DetectedNon-fibrous (Other)10%Glass90%Yellow

Fibrous

Homogeneous

CU-10 East Side -

Yellow Insulation

HA: 8

TSI-07-03-Wrap

041632081-0032A

None DetectedNon-fibrous (Other)50%Cellulose

Glass

40%

10%

White/Silver

Fibrous

Homogeneous

CU-10 East Side -

Wrap

HA: 8

Analyst(s)

Brett Polumbo (23)

Matthew Hermann (23)

Benjamin Ellis, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . This report relates only to the samples reported and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government . Non-friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis. Samples received in good condition unless otherwise noted. Estimated accuracy, precision and uncertainty data available upon request. Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Reporting limit is 1%

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA-LAP, LLC-IHLAP Lab 100194, NYS ELAP 10872, NJ DEP 03036, PA ID# 68-00367

Page 4 of 4ASB_PLM_0008 - 1.71 Printed: 11/25/2016 8:01 AM

OrderID: 041632081

OrderID: 041632081

APPENDIX D

CERTIFICATIONS