Nogales_Asbestos_and_Lead-Paint_Survey.pdf

Asbestos & Lead‐Paint Survey Report

USIBWC Nogales Field Office

Rio Rico, Arizona

Prepared for:

Submitted by:

7600 North 16th Street, Suite 110

Phoenix, Arizona 85020 Telephone: (602) 266-8288 Facsimile: (602) 266-9355

April 15, 2014

Asbestos and Lead-Based Paint Survey Report Page i IBWC Nogales Field Office, Rio Rico, AZ April 15, 2014

Table of Contents

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTIONS

3.0 BACKGROUND

3.1 Asbestos Containing Materials

3.2 Asbestos Sampling and Analytical Procedures

4.0 ASBESTOS FINDINGS

4.1 Asbestos Containing Materials (>1%)

4.2 Negative Materials

5.0 ASBESTOS RECOMMENDATIONS

6.0 LEAD-BASED PAINT INSPECTION

6.1 Definition of Lead-Based Paint

6.2 Sampling and Analytical Procedures

7.0 SUMMARY OF LEAD-BASED PAINT TESTING RESULTS

8.0 LEAD-BASED PAINT RECOMMENDATIONS

8.1 Regulatory Requirements

9.0 DISCLAIMER

10.0 SIGNATORY

Table 1 – Homogeneous Materials Tables

Appendices:

Appendix A-Bulk Asbestos Sample Laboratory Report

Appendix B-Lead-Based Paint XRF Field Data sheets

Appendix C-Sample Location Drawings

Appendix D - Photographs

Appendix E-Inspector Certifications

Asbestos and Lead-Based Paint Survey Report Page 1

1.0 Introduction

TRC Environmental Corporation (TRC) was contracted by the United States International Boundary and Water Commission (IBWC) to conduct an asbestos and a lead based paint survey at the Nogales Field Office located at 865 Rio Rico Industrial Park, Rio Rico, Arizona. The survey was performed on November 6-7, 2013, by Mr. Paul Semper, an EPA Accredited AHERA Asbestos Building inspector and EPA Lead Risk assessor employed by TRC. The survey included the inspection and assessment of accessible interior and exterior construction materials associated with the building structures on site.

The asbestos and lead-based paint survey findings will be used to effectively manage asbestos-containing materials (ACM) and Lead-Based Paint (LBP) in the scope areas of the Nogales Field Office structures (the “Site”). The accumulated assessment information may be used in operations and maintenance plans for the facility designed to prevent accidental disturbance to ACM and LBP.

2.0 Building Descriptions

The following provides a summary of the Nogales Field Office areas defined as the scope of work areas under Contract # IBM09D0010. All of the structures are located on federal land, were considered non-public buildings, are secured by fencing/locked gates, and have industrial processes. A description of the building structures are as follows:

Building Name Construction Type/Description

Administration Building

The building is of metal and wood construction built slab on grade with stucco exterior. The interior walls are drywall construction with vinyl cove base. The flooring consists of ceramic and vinyl floor tile and carpeting.

The building houses offices, conference room, restrooms, shop, and locker rooms. The building comprises approximately 4177 square feet of area and is single-story.

Control Building

The building is of block construction built slab on grade. The interior walls are drywall construction with vinyl cove base. The flooring consists of ceramic and vinyl floor tile and carpeting. The building houses offices, break room, restrooms, and lab. The building comprises approximately 1612 square feet of area and is single-story.

Operations Building / Tool Room

The building is of block construction built slab on grade. The interior walls are of block construction. The flooring consists of concrete. The building houses tool storage and shop. The building comprises approximately 700 square feet of area and is single-story.

Double Wide Trailer

The building is of metal and wood construction. The interior walls are wrapped drywall panels with vinyl cove base. The flooring consists of linoleum, vinyl floor tile, and carpeting. The building houses offices, restrooms, and open area. The building comprises approximately 1440 square feet of area and is single-story.

Sulfur Dioxide (SO2) Building

The building is of block construction built slab on grade. The flooring consists of concrete. The building houses sampler storage. The building comprises approximately 182 square feet of area and is single-story.

Asbestos and Lead-Based Paint Survey Report Page 2

Building Name Construction Type/Description

Single Wide Trailer

The building is of metal and wood construction. The interior walls are wrapped drywall panels with faux wood paneling. The flooring consists of carpeting. The building houses offices, restrooms, and open area. The building is vacant and is approximately 672 square feet of area and is single-story.

Connex #1, #2, #3, #4, #5, #6 & #7

These structures are of metal construction and used for storage;

approximately 160 square feet each.

Connex #8 The structure is of metal construction and used for storage; approximately 152 square feet.

Polymer Building The structure is constructed of fiberglass and houses the polymer feed system; approximately 80 square feet.

Oil Storage The structure is constructed of metal and houses the oil storage;

approximately 48 square feet.

Chlorine (CL2) Building

The structure is constructed of metal and houses the chlorine storage;

approximately 552 square feet.

Chlorine (CL2) Storage

The building is of block construction built slab on grade. The interior walls are of block construction. The flooring consists of concrete. The building houses motor and pump storage. The building comprises approximately 520 square feet of area and is single-story.

Effluent Sample Shack

The building is constructed of wood with a shingle roof used for sampling;

approximately 100 square feet.

Pumping Plant The structure is constructed of metal and used for pump control;

approximately 25 square feet.

Border Sample Shed

The structure is constructed of fiberglass and is approximately 15 square feet.

3.0 Background

3.1 Asbestos Containing Materials

The Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) define an asbestos-containing material (ACM) as any material containing more than one percent (>1.0%) asbestos by weight. In addition, ACMs are designated by the EPA into one of three characteristic categories as follows:

Friable asbestos - material which can be crumbled, pulverized or reduced to powder by hand pressure, a.k.a. Regulated Asbestos Containing Material (RACM)

Category I Non-friable - includes resilient floor coverings, asphalt roofing products, gaskets and packing. These materials may become friable if degraded or damaged to the point where the material can be crumbled, pulverized or reduced to powder by hand pressure.

Category II Non-friable - any non-friable ACM that is not in Category I (i.e. Asbestos-cement (Transite®) siding or roofing mastics).

Olga Castro Highlight

Asbestos and Lead-Based Paint Survey Report Page 3

3.2 Asbestos Sampling and Analytical Procedures

Representative bulk samples of suspect asbestos-containing building materials were randomly collected from the identified homogenous building material applications. Homogenous material determination was based on the following criteria:

Similar physical characteristics (same appearance, age, color and texture, etc.), Application (e.g. sprayed or trowel-on, assembly into a system, etc.), Material function (e.g. thermal insulation, floor tile, wallboard system, etc.).

Laboratory services were provided by TRC’s laboratory located in Windsor, Connecticut. TRC’s analytical laboratory is a National Voluntary Laboratory Accreditation Program (NVLAP) certified laboratory (NVLAP code # 101424-0) and is in compliance with the National Environmental Laboratory Accreditation Conference (NELAC) requirements.

Bulk samples were analyzed by polarized light microscopy (PLM) utilizing the EPA’s Test Methods: Methods for the Determination of Asbestos in Bulk Building Materials (EPA 600/R- 93/116, July 1993) and the McCrone Research Institute’s The Asbestos Particle Atlas as method references.

Analysis by PLM was performed by visual observation of the bulk sample and by microscopic analysis using dispersion staining PLM methodology. The samples were analyzed for asbestiform minerals (Chrysotile, Amosite, Crocidolite, Anthophyllite, Actinolite, and Tremolite), fibrous non-asbestos constituents (mineral wool, cellulose, etc.) and non-fibrous constituents. Using a stereoscope, the microscopist visually estimates the relative amounts of each constituent by determining the estimated area of the asbestos compared with the area estimate of the total sample.

4.0 Asbestos Findings

Suspect Asbestos-Containing Materials (ACM), including building materials/finishes, insulated wire, and equipment/machinery components, e.g., gaskets, packing, dampening materials and insulation were inspected, sampled and analyzed for asbestos. Typical suspect building materials include finishes (e.g. drywall systems, suspended ceiling panels, glued ceiling tiles, floor tiles, vinyl sheet flooring, floor finish adhesives, cove base, cove base adhesive, textured coatings, roofing materials, caulks, sealants, and plasters. Non-suspect asbestos materials are items purely composed of glass, metal, wood, concrete, rubber, brick, CMU block, cement motar, ceramic, grouts, fiberglass, foam, foam glass, Styrofoam, and paper.

According to federal regulations, regulated ACM are ACMs containing greater than 1% asbestos by weight.

4.1 Asbestos Containing Materials (>1%)

Asbestos was either detected in concentrations exceeding one percent in the following materials sampled during the asbestos survey or the listed component/materials was presumed to have asbestos, based on limitations of sampling feasibility. Results of the asbestos survey indicated the presence of detectable asbestos in the following materials:

Asbestos and Lead-Based Paint Survey Report Page 4

Control Building

Material Location Percentage/

Type Approx

Quantity*

NESHAP

Category Condition

Exterior Door/Window

Frame Caulking

Throughout Exterior Door and Window Frames

5% Chrysotile

50 SF CAT II Good

Operations Building / Tool Room

Material Location Percentage/ Type

Approx Quantity*

NESHAP

Category

Condition

Black Penetration Mastic

Throughout Roof 10%

80 SF CAT I Good

Connex #3

Percentage/

Type Approx

Quantity*

NESHAP

Category Condition

Yellow Caulking Throughout 3%

8 SF CAT II Good

Chlorine (CL2) Storage

Percentage/

Type Approx

Quantity*

NESHAP

Category

Condition

Black Flashing Mastic

Throughout Roof 3%

180 SF CAT I Good

Sulfur Dioxide (SO2) Building

Material Location Percentage/ Type

Approx Quantity*

NESHAP

Category

Condition

Black Mastic Associated with Roof Flashing

Throughout Roof 10%

168 SF CAT I Good

*Estimated quantities of ACMs listed are provided as a guide to the building owner. The material quantities listed in the table are approximations and TRC is not responsible for the accuracy of the quantities and measurements provided.

4.2 Negative Materials

Samples of the following suspect materials were collected in the locations noted below and were reported with no detectable asbestos, as indicated by laboratory PLM analysis:

Asbestos and Lead-Based Paint Survey Report Page 5

Administration Building Material Sample Locations

Exterior Stucco Exterior White 12" x 12" Floor Tile and Mastic Throughout except Offices, Conference Room

Gray Cove Base and Mastic Throughout 2’ x 2’ Ceiling Tile Throughout

Orange Peel Drywall Throughout Carpet Mastic Offices, Conference Room

Control Building

Blue 12" x 12" Floor Tile and Mastic Rooms B and E Blue Cove Base and Mastic Rooms B, D, and E

Orange Peel Drywall Throughout 2’ x 2’ Ceiling Tile Throughout

Tan Cove Base and Mastic Room C Gray Cove Base and Mastic Lab

Carpet Mastic Rooms C and D Self-Stick 12" x 12" Floor Tile and Mastic and

White 12" x 12" Floor Tile and Mastic Lab

Expansion Joint Compound Exterior Roll-on Roof Cross-Section Roof Black Penetration Mastic Roof

White Flashing Mastic Roof

Roll-on Roof Cross-Section Roof

Double Wide Trailer

White 12" x 12" Floor Tile and Mastic Throughout Gray Cove Base and Mastic Throughout

2’ x 4’ Ceiling Tile Throughout Wrapped Drywall Panels Throughout

Carpet Mastic Rooms A, C, and E Tile Pattern Linoleum and Mastic Restrooms

Black Cove Base and Mastic Restrooms Roll-on Roof Cross-Section Roof Shingle Roof Cross-Section Roof

Penetration Mastic Roof White Sink Undercoating Sink Outside Restrooms

Orange Peel Drywall Room F

Asbestos and Lead-Based Paint Survey Report Page 6

Single Wide Trailer

Carpet Mastic Throughout Purple Board, Joint Compound, and

Caulking Shower Stalls

Wrapped Drywall Panels Partition Walls Penetration Mastic Roof

Roof Cap Sheet Roof

Connex #1

Tan Caulking Throughout

Connex #2

White Caulking Throughout

Connex #4

Wall Mastic Back Wall Vibration Dampener Air Duct

A/C Caulking A/C Unit

Connex #5

Yellow Mastic Interior Gray Mastic Exterior

Connex #6

Asbestos and Lead-Based Paint Survey Report Page 7

Connex #7

Oil Storage

Roof Mastic Roof

CL2 Storage

Roll-on Roof Cross-Section Main Roof Awning Shingle Roof and Felt Awning Roof

Door Frame Caulking Entry Door

SO2 Building

Door Frame Caulking Entry Door Flat Roof Cross-Section Roof

Flashing Roofing Roof Flashing Caulking Roof

Effluent Sample Shack

Shingle Roof and Felt Roof

5.0 Asbestos Recommendations

Results of bulk sample analysis confirmed that asbestos was identified in regulated concentrations within some of the building materials sampled. The ACM was found to be in good condition at the time of the inspection. If damaged ACM is encountered, it should be repaired, encapsulated, or removed as soon as feasible. Access to the damaged ACM by building occupants should be restricted in the areas of damage until abatement response actions can be completed. Such abatement methods should be performed by a qualified/licensed asbestos abatement contractor, and ACM should be handled, stored, and disposed of according to all local, state, and federal regulations.

Persons performing construction or maintenance work in the Site should be aware of the types and locations of ACM and that additional materials (not identified in this report), which are

Asbestos and Lead-Based Paint Survey Report Page 8 either inaccessible or hidden, may exist at the Site. Care should be used when performing work that disturbs building materials. Any suspect asbestos containing materials uncovered during maintenance, renovation, or demolition activities that are not addressed in this inspection report, or presumed asbestos containing materials (e.g. fire doors with asbestos laden cores), must be sampled by an accredited asbestos inspector prior to disturbance, or they must otherwise be assumed and treated as asbestos containing.

6.0 Lead-Based Paint Inspection

TRC conducted a lead-based paint (LBP) inspection for the determination of LBP and/or lead-based components at the Power Plant and Warehouse building structures (the “Site”). The LBP inspection was conducted in accordance with the United States Housing and Urban Development (HUD) guidance document, entitled “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing,” 1997 Revision.

The general purpose of this investigation was to document the general condition of interior and exterior painted building surfaces and to characterize the composition of painted surfaces with regard to lead content. Information derived from this investigation may be used to further refine the scope of LBP abatement activities in support of future procurement activities with regard to LBP. The scope of work associated with this investigation included the following elements:

Visual inspection of interior and exterior building painted surfaces and components and Field testing of painted surfaces and components using an X-Ray Fluorescence (XRF) analyzer

The lead based paint testing was conducted by Mr. Paul Semper, an EPA, Department of Housing and Urban Development (HUD) certified Lead-Based Paint Building Inspector/Risk Assessor. The inspection was conducted on November 6 and 7, 2013.

6.1 Definition of Lead-Based Paint

The United States Department of Housing and Urban Development (HUD), and United States Environmental Protection Agency define lead-based paint as a paint or other surface coatings that contain an amount of lead equal to, or in excess of:

One milligram per square centimeter (1.0 mg/cm2); or One-half of one percent (0.5%) by weight.

6.2 Sampling and Analytical Procedures

All lead-based paint testing was performed using a RMD Model LPA-1B, X-ray Fluorescence (XRF) spectrum analyzer, serial #1124. Assessment activities and XRF testing were performed in accordance with the United States HUD guidance document, entitled “Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing,” 1997 Revision.

The RMD Model LPA-1B XRF uses a 12 milicurie Cobalt 57 sealed radioactive source which has a half life of 18 months. The XRF measures the L & K electron shell energy released by the excited atoms of the test material such as the painted and/or coated surface location to calculate the concentrations of a specific metal on the surface coating down to the substrate. The RMD Model LPA-1B XRF does not have an inconclusive range such as the older generation XRF machines.

Asbestos and Lead-Based Paint Survey Report Page 9

At the beginning and end of each work day and at various times during the day, the XRF was calibrated in order to ensure that the instrument was functioning properly. A series of three calibrated readings were obtained using a 1.9 mg/cm2 NIST Paint Film Standard in accordance with the instrument manufacturer’s protocol. In all cases, the instrument was functioning within the standard deviation as defined by the manufacturer and the Performance Characteristic Sheets. All validation readings were recorded in a logbook, which accompanies the instrument. A total of fifteen calibration tests were performed during the course of this investigation.

During this investigation, a total of thirty six (36) painted or coated substrate measurements were obtained using the XRF. The XRF field test data sheets with the results of the paint test measurements are presented in Appendix B-Lead-Based Paint XRF Field Data sheets.

7.0 Summary of Lead-Based Paint Testing Results

The XRF test results indicate that select painted surfaces and building components were found to be containing lead above the United States Department of Housing and Urban Development, and United States Environmental Protection Agency definition of lead-based paint. A summary of paints/coatings determined to be LBP by XRF analysis is provided below:

Component(s) Color Location(s) Lead XRF

Result (mg/cm²)

Approximate Quantity Condition

Awning Support Black Exterior 2.2 40 SF Intact

Window Bars Black Exterior 1.4 70 SF Intact

Lead XRF

Result (mg/cm²)

Approximate Quantity

Condition

Interior Walls Yellow Interior 5.1 210 SF Fair

Exterior Walls Brown Exterior 6.0 210 SF Intact

Connex #2

Lead XRF

Result (mg/cm²)

Approx.

Quantity

Condition

Lead-based paint components were not found in Connex #2.

Asbestos and Lead-Based Paint Survey Report Page 10

Connex #4

Lead XRF

Result (mg/cm²)

Approx.

Quantity

Lead-based paint components were not found in Connex #4.

Connex #8

Lead XRF

Result (mg/cm²)

Approx.

Quantity Condition

Lead-based paint components were not found in Connex #8.

Chlorine (CL2) Storage

Lead XRF

Result (mg/cm²)

Approx.

Quantity

Lead-based paint components were not found in CL2 Storage.

8.0 Lead-Based Paint Recommendations

Disturbance of lead based paint should be performed by a contractor who has experience and expertise in LBP, abatement, handling and disposal and who can protect the employees of IBWC Amistad Power Plant, and the environment from lead exposure hazards. For construction work where an employee may be occupationally exposed to lead in any amount, the workers and contractor must comply with Federal Occupational Safety and Health (OSHA) worker lead exposure regulations 29 CFR 1910.1025 and 1926.62 (lead in construction). Additionally, lead containing waste must be characterized and profiled for proper disposal according to applicable federal State and local regulations.

TRC recommends that interior and exterior painted surfaces containing lead at concentrations greater than or equal to 1.0. mg/cm2 and that are in poor condition be abated and/or stabilized.

Based on the results of this assessment, the following materials meet the criteria for abatement and/or stabilization:

Lead XRF

Result (mg/cm²)

Approximate Quantity

Interior Walls Yellow Interior 5.1 210 SF Fair

Asbestos and Lead-Based Paint Survey Report Page 11

8.1 Regulatory Requirements

Lead is a hazardous substance and its condition, handling and disposal are regulated by Federal, State and local agencies. Lead-containing materials, Lead-based paint, and Lead-Containing Paint generally do not pose a health risk unless the material is disturbed or sufficiently deteriorated to produce dust, which may become airborne and inhaled or ingested. Future site maintenance activities, including surface preparation and painting, may involve practices that could disturb lead-containing materials. The following paragraphs provide a general overview of applicable regulatory standards that relate to the management and/or disposal of lead-based paint:

The Federal Occupational Safety and Health (OSHA) 29 CFR 1910.1025 and 1926.62 (lead in construction) do not provide a definition for “lead-based paint”. Rather, the Lead Construction Standard provides a Permissible Exposure Limit (PEL) for worker exposure to airborne lead particles of 50 micrograms per cubic meter of air (50 µg/m3 for an 8-hour time-weighted average). All employees (workers) and supervisors, who are engaged in lead-related construction activities and shown to be exposed to lead at or above the Permissible Exposure Limit, shall be trained by state-accredited training providers and certified by the Environmental Protection Agency. The OSHA Lead in Construction Standard states that “negative” readings i.e. those below the HUD/EPA definition of what constitutes LBP (1.0 mg/cm2), “DO NOT” relieve contractors from performing exposure assessments (personal exposure monitoring) on their employees per the OSHA Lead Standard, and should not be interpreted as lead is not present.

Although a reading may indicate “negative” result or lead concentration, concentrations of airborne lead may still exceed the OSHA Action Level or the OSHA Permissible Exposure Limit (PEL) depending on the work activity.

Future site maintenance activities, including repair, surface preparation and painting, sand/shot blasting, and sanding, in areas where lead-based paint has been identified may result in the liberation of lead at concentrations in excess of the OSHA PEL. TRC recommends the removal and/or stabilization of building materials during planned renovation. Lead-based painted materials should only be removed, handled or stabilized by lead trained personnel in accordance with all applicable federal, state, and local regulations. These requirements include, but are not limited to, the following: Exposure Assessments; Methods of Compliance including work practices, administrative, and engineering controls; Respiratory Protection; Protective Clothing and Equipment;

Housekeeping; Hygiene Facilities; Medical Surveillance; and Employee Information and Training. The waste materials generated must be segregated accordingly and must be subjected to waste characterization testing and disposed of according to applicable regulations.

Lead containing waste must be disposed of in accordance with all applicable federal, state, county or local regulations and guidelines. It is the sole responsibility of the Contractor to assure compliance with all laws and regulations relating to the disposal.

The abatement contractor should comply with the requirements of the Resource Conservation and Recovery Act (RCRA). Waste materials shall be segregated into separate waste streams (i.e. paint chips, personal protective equipment, plastic, etc.) and placed into labeled, leak-tight containers. Wastewater from the washing facilities should be captured, filtered, and sampled for lead content prior to disposal into the sanitary sewer system. Additional details regarding waste characterization sampling and analysis are provided in the following section.

Asbestos and Lead‐Based Paint Survey Report Page 12

9.0 DISCLAIMER

The content presented in this report is based on data collected during the site inspection and survey, review of pertinent regulations, requirements, guidelines and commonly followed industry standards, and information provided (if any) by the property owner, their clients, agents, and representatives.

The work has been conducted in an objective and unbiased manner and in accordance with generally accepted professional practice for this type of work. TRC believes the data and analysis to be accurate and relevant, but cannot accept responsibility for the accuracy or completeness of available documentation or possible withholding of information of other parties. Structures or components thereof surveyed may contain hidden surfaces or materials requiring destructive access to inspect and/or sample. It is possible that additional materials could be discovered during destructive or demolition activities. In the event additional materials (not identified herein) are discovered during such activities, additional investigation and sampling may be necessary.

This asbestos survey and lead-based paint inspection report is designed to aid the property owner, architect, construction manager, general contractor, and asbestos or LBP abatement contractor in locating ACM and/or LBP . This report is not intended for, and may not be utilized as, a bidding document or as an abatement project specification document.

10.0 SIGNATORY

This asbestos and lead-based paint survey activities and report of the findings were provided by TRC, was conducted by a licensed professional, experienced in the inspection and survey for asbestos containing materials and lead-based paint in building structures and associated components thereof. If there are any questions concerning information contained in this report, you may contact one of the undersigned in our Irvine, California office, phone # 949.727.9336.

Sincerely, TRC Environmental Corporation

Paul Semper Karen A. Terry, CIH Industrial Hygienist Senior Project Manager

Table 1

Homogeneous Materials Tables

TABLES – HOMOGENOUS MATERIALS SUMMARY

International Boundary & Water Commission – Nogales, AZ Page 1

Building Name Sample Numbers Material Material Location(s) Analytical Results Approx

Quantity

NESHAP

Category

Administration Building

PLM-1 through PLM-3 Exterior Stucco Exterior ND 7,400 SF NA

Administration Building

PLM-4 through PLM-6 12” x 12” White Floor

Tile and Mastic

Throughout except Offices, Conference Room

ND 1,100 SF NA

Administration Building

PLM-7 through PLM-9 Gray Cove Base and

Mastic Throughout

ND 350 SF NA

Administration Building

PLM-10 through PLM-12 2’ x 2’ Ceiling Tile Throughout

ND 4,100 SF NA

Administration Building

PLM-13 through PLM-15 Orange Peel Texture and

Drywall Throughout

ND 13,400 SF NA

Administration Building

PLM-16 through PLM-18 Carpet Mastic Offices, Conference Room

ND 1,500 SF NA

Quantity

NESHAP

Category

CL2 Storage PLM-1 through PLM-3 Roll on Roofing C/S Throughout ND 500 SF NA CL2 Storage PLM-4 through PLM-6 Flashing Mastic Roof Flashing 3% Chrysotile 15 SF Cat II

CL2 Storage PLM-7 through PLM-9 Awning Shingle Roof and

Felt Awning Roof ND 70 SF NA

CL2 Storage PLM-10 through PLM-12 Door Frame Caulking Doors ND 8 SF NA

Quantity

NESHAP

Category

Connex #1 PLM-1 through PLM-3 Tan Caulking Throughout ND 60 SF NA

International Boundary & Water Commission – Nogales, AZ Page 2

Building Name Sample Numbers Material Material Location(s) Analytical Results Approx

Quantity

NESHAP

Connex #2 PLM-1 through PLM-3 White Caulking Throughout ND 30 SF NA

Quantity

NESHAP

Connex #3 PLM-1 through PLM-3 Yellow Caulking Throughout 3% Chrysotile 60 SF Cat I

Quantity

NESHAP

Category

Connex #4 PLM-1 through PLM-3 Wall Mastic Throughout ND 40 SF NA Connex #4 PLM-4 through PLM-6 Vibration Damper Air Duct ND 2 SF NA

Connex #4 PLM-7 through PLM-9 Air Conditioning

Caulking Air Conditioning

Unit

ND 4 SF NA

Quantity

NESHAP

Category

Connex #5 PLM-1 through PLM-3 Yellow Mastic Throughout ND 40 SF NA Connex #5 PLM-4 through PLM-6 Gray Mastic Throughout ND 20 SF NA

Quantity

NESHAP

Category

Connex #6 PLM-1 through PLM-3 Yellow Mastic Throughout ND 40 SF NA Connex #6 PLM-4 through PLM-6 Gray Mastic Throughout ND 20 SF NA

International Boundary & Water Commission – Nogales, AZ Page 3

Building Name Sample Numbers Material Material Location(s) Analytical Results Approx

Quantity

NESHAP

Category

Connex #7 PLM-1 through PLM-3 Yellow Mastic Throughout ND 40 SF NA Connex #7 PLM-4 through PLM-6 Gray Mastic Throughout ND 20 SF NA

Building Name Sample Numbers Material Material

Location(s) Analytical Results

Approx Quantity

NESHAP

Category

Control Building PLM-1 through PLM-3 12” x 12” Blue Floor Tile and Mastic Rooms B and E ND 450 SF NA

Control Building PLM-4 through PLM-6 Blue Cove Base and Mastic Rooms B and D ND 60 SF NA

Control Building PLM-7 through PLM-9 Orange Peel Texture and

Drywall Throughout ND 4,000 SF NA

Control Building PLM-10 through PLM-12 2’ x 2’ Ceiling Tile Throughout ND 1,510 SF NA

Control Building PLM-13 through PLM-15 Tan Cove Base and Mastic Room C – Control

Room

ND 22 SF NA

Control Building PLM-16 through PLM-18 Gray Cove Base and Mastic Lab ND 67 SF NA Control Building PLM-19 through PLM-21 Carpet Mastic Room C and D ND 500 SF NA

Control Building PLM-22 through PLM-24

Self-Stick 12” x 12” Floor Tile and Mastic and White 12” x 12” Floor Tile and

Black Mastic

Lab – Room A ND 450 SF NA

Control Building PLM-25 through PLM-27 Expansion Joint Compound Exterior ND 18 SF NA

Control Building PLM-28 through PLM-30 Exterior Door/Window

Frame Caulking Exterior 5% Chrysotile 25 SF Cat I

Control Building PLM-31 through PLM-33 Roll-on Roof C/S Roof ND 1,500 SF NA Control Building PLM-34 through PLM-36 Black Penetration Mastic Roof ND 40 SF NA Control Building PLM-37 through PLM-39 White Flashing Mastic Roof ND 10 SF NA

International Boundary & Water Commission – Nogales, AZ Page 4

Location(s) Analytical Results

Approx Quantity

NESHAP

Category

Double Wide Trailer

PLM-1 through PLM-3 12” x 12” White Floor Tile and Mastic Throughout ND 1,000 SF NA

Double Wide Trailer

PLM-4 through PLM-6 Gray Cove Base and Mastic Throughout ND 80 SF NA

Double Wide Trailer

PLM-7 through PLM-9 2’ x 4’ Ceiling Tile Throughout ND 1,440 SF NA

Double Wide Trailer

PLM-10 through PLM-12 Wrapped Drywall Panels Throughout ND 3,800 SF NA

Double Wide Trailer

PLM-13 through PLM-15 Carpet Mastic Throughout ND 440 SF NA

Double Wide Trailer

PLM-16 through PLM-18 Tile Pattern Linoleum and

Mastic Restrooms ND 100 SF NA

Double Wide Trailer

PLM-19 through PLM-21 Black Cove Base and

Mastic Restrooms ND 28 SF NA

Double Wide Trailer

PLM-22 through PLM-24 Roll-on Roof C/S Roof ND 1,400 SF NA

Double Wide Trailer

PLM-25 through PLM-27 Shingle Roof C/S Roof ND 1,440 SF NA

Double Wide Trailer

PLM-28 through PLM-30 Penetration Mastic Roof ND 12 SF NA

Double Wide Trailer

PLM-31 through PLM-33 White Sink Undercoating Sink Outside Restrooms

ND 8 SF NA

Double Wide Trailer

PLM-34 through PLM-36 Orange Peel Texture and

Drywall Room F ND 200 SF NA

Quantity

NESHAP

Category

Effluent Sample Shack

PLM-1 through PLM-3 Shingle Roof and Felt Roof - Throughout ND 100 SF NA

International Boundary & Water Commission – Nogales, AZ Page 5

Building Name Sample Numbers Material Material Location(s) Analytical Results Approx

Quantity

NESHAP

Oil Storage PLM-1 through PLM-3 Roof Mastic Roof – Throughout ND 40 SF NA

Location(s) Analytical Results

Approx Quantity

NESHAP

Category

Single Wide Trailer

PLM-1 through PLM-3 Carpet Mastic Throughout ND 672 SF NA

Single Wide Trailer

PLM-4 through PLM-6 Purple Wallboard, Joint

Compound and Caulking Shower Stalls ND 400 SF NA

Single Wide Trailer

PLM-7 through PLM-9 Wrapped Drywall Board Partition Walls ND 300 SF NA

Single Wide Trailer

PLM-10 through PLM-12 Penetration Mastic Roof –

Throughout

ND 8 SF NA

Single Wide Trailer

PLM-13 through PLM-15 Roof Cap Sheet Roof –

Throughout

ND 680 SF NA

Location(s) Analytical Results

Approx Quantity

NESHAP

Category

SO2 Building PLM-1 through PLM-3 Door Frame Caulking Door ND 8 SF NA

SO2 Building PLM-4 through PLM-6 Flat Roof C/S Roof –

Throughout

ND 160 SF NA

SO2 Building PLM-7 through PLM-9 Black Flashing Mastic Roof – Around

Perimeter 10% Chrysotile 110 SF Cat II

SO2 Building PLM-10 through PLM-12 Flashing Caulking Roof –

Throughout Top Flashing

ND 40 SF NA

International Boundary & Water Commission – Nogales, AZ Page 6

Location(s) Analytical Results

Approx Quantity

NESHAP

Category

Operations Building / Tool

Room PLM-1 through PLM-3 Roll-on Roof C/S

Roof – Throughout

ND 700 SF NA

Operations Building / Tool

Room PLM-4 through PLM-6 Black Penetration Mastic

Roof – Throughout

10% Chrysotile 45 SF Cat II

Table Key

ND – None Detected NA – Not Applicable SF – Square Feet LF – Linear Feet Cu Ft – Cubic Feet Cat I – Category I Non-Friable Asbestos Containing Material Cat II - Category II Non-Friable Asbestos Containing Material RACM – Regulated Asbestos Containing Material (Friable) ACM – Asbestos Containing Material; Contains greater than 1% asbestos by weight NESHAP – National Emissions Standards for Hazardous Air Pollutants (EPA asbestos regulation)

Appendix A

Bulk Asbestos Sample Laboratory Analytical Report

And Chain of Custody

Asbestos Detected

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134192

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-ADMIN BLDG

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

NoStucco, Gray None Detected0134192-001 PLM-1 Carbonates

Quartz Gypsum Mica Binder/Filler

100%

NoStucco, Gray None Detected0134192-002 PLM-2 Carbonates

Quartz Gypsum

NoLAYER 1 Stucco-Scratch Coat, Lt. Gray

None Detected0134192-003 PLM-3 Carbonates

Quartz Mica Perlite

NoLAYER 2 Stucco-Finish Coat, Gray

None Detected

Carbonates Quartz Gypsum

12"x12" Floor Tile, White

None Detected0134192-004 PLM-4 Carbonates

Quartz

Cellulose FiberNoLAYER 2 Mastic, Tan

None Detected <1%

Carbonates

99%

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134192

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-ADMIN BLDG

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

NoLAYER 1 12"x12" Floor Tile, White

None Detected0134192-005 PLM-5 Carbonates

Mastic, Tan

None Detected 1%

Carbonates

12"x12" Floor Tile, White

None Detected0134192-006 PLM-6 Carbonates

Mastic, Tan

None Detected 1%

Carbonates

Cove Base, Gray

None Detected0134192-007 PLM-7 Carbonates

Mastic, Beige

None Detected <1%

Carbonates

Cove Base, Gray

None Detected0134192-008 PLM-8 Carbonates

Mastic, Beige

None Detected <1%

Carbonates

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134192

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-ADMIN BLDG

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

NoLAYER 1 Cove Base, Gray

None Detected0134192-009 PLM-9 Carbonates

Mastic, Beige

None Detected 1%

Carbonates

Mineral Wool Cellulose Fiber

No2x2 Ceiling Tile, White/ Gray None Detected0134192-010

PLM-10

45% 40%

Carbonates

15%

Cellulose Fiber

No2x2 Ceiling Tile, White/ Gray None Detected0134192-011

PLM-11

45% 40%

Carbonates

Cellulose Fiber

No2x2 Ceiling Tile, White/ Gray None Detected0134192-012

PLM-12

45% 40%

Carbonates

Cellulose Fiber Fibrous Glass

NoLAYER 1 Drywall, White/ Brown

None Detected0134192-013

PLM-13

10% 2%

Gypsum Carbonates

88%

Orange Peel Texture, White

None Detected

Carbonates Mica Quartz

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134192

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-ADMIN BLDG

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Cellulose Fiber Fibrous Glass

NoLAYER 1 Drywall, White/ Brown

None Detected0134192-014

PLM-14

10% 2%

Gypsum

Orange Peel Texture, White

None Detected

Carbonates Mica Quartz

Fibrous Glass

NoLAYER 1 Drywall, White/ Brown

None Detected0134192-015

PLM-15

10% 2%

Gypsum

Orange Peel Texture, White

None Detected

Carbonates Mica Quartz

Synthetic Fiber Cellulose Fiber

NoCarpet Mastic, Tan None Detected0134192-016

PLM-16

1% <1%

Carbonates

98%

Synthetic Fiber Cellulose Fiber

NoCarpet Mastic, Tan None Detected0134192-017

PLM-17

1% 1%

Carbonates

Synthetic FiberNoCarpet Mastic, Tan None Detected0134192-018

PLM-18

1%

Carbonates

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134192

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-ADMIN BLDG

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Distinctly stratified, easily separable layers of samples are analyzed as subsamples of the whole and are reported separately for each discernible layer. All analyses are derived from calibrated visual estimate and measured in area percent unless otherwise noted. The report applies to the standards or procedures identified and to the sample(s) tested. The test results are not necessarily indicated or representative of the qualities of the lot from which the sample was taken or of apparently identical or similar products, nor do they represent an ongoing quality assurance program unless so noted. These reports are for the exclusive use of the addressed client and that they will not be reproduced wholly or in part for advertising or other purposes over our signature or in connection with our name without special written permission. The report shall not be reproduced except in full, without written approval by our laboratory. The samples not destroyed in testing are retained a maximum of thirty days. The laboratory measurement of uncertainty for the test method is approximately less than 1 by area percent.

Accredited by the National Institute of Standards and Technology, Voluntary Laboratory Accreditation Program for selected test method for asbestos. The accreditation or any reports generated by this laboratory in no way constitutes or implies product certification, approval, or endorsement by the National Institute of Standards and Technology. The 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. Polarized Light Microscopy may not be consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials.

Analyst - Kenneth Scheske Signatory - Lab Director - Kurt Kettler

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Fibrous GlassNoLAYER 1 Roll On Roof, White/ Black

None Detected0134191-001 ROOF

PLM-1

15%

Carbonates

85%

Fibrous GlassNoLAYER 2 Roll On Roof, Black

None Detected 20%

Carbonates

80%

Fibrous GlassNoLAYER 3 Roll On Roof, Black

None Detected 35%

Gypsum

65%

Fibrous GlassNoLAYER 4 Roll On Roof, Black

None Detected 35%

Gypsum

Please see EMC Labs Sample Number 0134191-013 for Additional Layers

Fibrous GlassNoLAYER 1 Roll On Roof, White/ Black

None Detected0134191-002 ROOF

PLM-2

15%

Carbonates

Roll On Roof, Black

None Detected 20%

Carbonates

Roll On Roof, Black

None Detected 40%

Carbonates Gypsum

60%

Roll On Roof, Black

None Detected 35%

Gypsum

Please see EMC Labs Sample Number 0134191-014 for Additional Layers

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Fibrous GlassNoLAYER 1 Roll On Roof, White/ Black

None Detected0134191-003 ROOF

PLM-3

15%

Carbonates

Roll On Roof, Black

None Detected 20%

Carbonates

Roll On Roof, Black

None Detected 35%

Gypsum

Roll On Roof, Black

None Detected 35%

Gypsum

Please see EMC Labs Sample Number 0134191-015 for Additional Layers

Cellulose FiberYesFlashing Mastic, Black Chrysotile0134191-004 FLASHING

PLM-4

3% 10%

Carbonates

87%

Flashing Mastic, Black Note: *Not analyzed per client request

0134191-005 FLASHING

PLM-5

Flashing Mastic, Black Note: *Not analyzed per client request

0134191-006 FLASHING

PLM-6

Fibrous GlassNoLAYER 1 Roof Shingle, Brown/ Orange/ Tan/ Black

None Detected0134191-007 AWNING ROOF

PLM-7

20%

Carbonates

Felt, Black

None Detected 65%

35%

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Fibrous GlassNoLAYER 1 Roof Shingle, Brown/ Orange/ Tan/ Black

None Detected0134191-008 AWNING ROOF

PLM-8

20%

Carbonates

Felt, Black

None Detected 65%

Fibrous GlassNoLAYER 1 Roof Shingle, Brown/ Orange/ Tan/ Black

None Detected0134191-009 AWNING ROOF

PLM-9

20%

Carbonates

Felt, Black

None Detected 65%

Synthetic FiberNoLAYER 1 Door Frame Caulk, Dk. Brown

None Detected0134191-010 ENTRY DOOR

PLM-10

5%

95%

Door Frame Caulk, Black

None Detected

Gypsum

Synthetic FiberNoLAYER 1 Door Frame Caulk, Dk. Brown

None Detected0134191-011 ENTRY DOOR

PLM-11

5%

Door Frame Caulk, Black

None Detected

Gypsum

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Synthetic FiberNoLAYER 1 Door Frame Caulk, Dk. Brown

None Detected0134191-012 ENTRY DOOR

PLM-12

5%

Door Frame Caulk, Black

None Detected

Gypsum

Roll On Roof, Black

None Detected0134191-013 ROOF -

ADDITIONAL

LAYERS

PLM-1

40%

Gypsum

Roll On Roof, Black

None Detected 35%

Carbonates Gypsum

Cellulose FiberNoLAYER 3 Roll On Roof Insulation, Brown

None Detected 80%

Perlite Gypsum

20%

NoLAYER 4 Roll On Roof Foam, Yellow

None Detected

Foam

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Fibrous GlassNoLAYER 1 Roll On Roof, Black

None Detected0134191-014 ROOF -

ADDITIONAL

LAYERS

PLM-2

40%

Gypsum

Roll On Roof, Black

None Detected 35%

Carbonates Gypsum

Roll On Roof Insulation, Brown

None Detected 80%

Perlite

Roll On Roof Foam, Yellow

None Detected

Foam

Roll On Roof, Black

None Detected0134191-015 ROOF -

ADDITIONAL

LAYERS

PLM-3

40%

Gypsum

Roll On Roof, Black

None Detected 50%

50%

Roll On Roof Insulation, Brown

None Detected 80%

Perlite

Roll On Roof Foam, Yellow

None Detected

Foam

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134191

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/07/2013

EPA Method: Project Name: IBWC-CL 2 STORAGE

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

Distinctly stratified, easily separable layers of samples are analyzed as subsamples of the whole and are reported separately for each discernible layer. All analyses are derived from calibrated visual estimate and measured in area percent unless otherwise noted. The report applies to the standards or procedures identified and to the sample(s) tested. The test results are not necessarily indicated or representative of the qualities of the lot from which the sample was taken or of apparently identical or similar products, nor do they represent an ongoing quality assurance program unless so noted. These reports are for the exclusive use of the addressed client and that they will not be reproduced wholly or in part for advertising or other purposes over our signature or in connection with our name without special written permission. The report shall not be reproduced except in full, without written approval by our laboratory. The samples not destroyed in testing are retained a maximum of thirty days. The laboratory measurement of uncertainty for the test method is approximately less than 1 by area percent.

Accredited by the National Institute of Standards and Technology, Voluntary Laboratory Accreditation Program for selected test method for asbestos. The accreditation or any reports generated by this laboratory in no way constitutes or implies product certification, approval, or endorsement by the National Institute of Standards and Technology. The 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. Polarized Light Microscopy may not be consistently reliable in detecting asbestos in floor coverings and similar non-friable organically bound materials.

Analyst - Kurt Kettler Signatory - Lab Manager - Ken Scheske

Layer Name / Sample Description

Lab ID Sample Location

Bulk Asbestos Analysis by Polarized Light Microscopy

Non-Asbestos Constituents

Laboratory Report

0134177

NVLAP#101926-0

Client ID

Client:

Address: 7600 N. 16TH STREET, STE 110

PHOENIX AZ 85020

TRC SOLUTION

Date Received: 11/15/2013

11/22/2013Date Analyzed:

209058Job# / P.O. #:

EMC LABS, INC.

Collected: 11/06/2013

EPA Method: Project Name: IBWC-CONNEX #1

Submitted By: PAUL SEMPERAddress:

Collected By:

9830 S. 51st Street, Suite B109, Phoenix, AZ 85044 Phone: 800-362-3373 or 480-940-5294 - Fax: (480) 893-1726

11/22/2013Date Reported:

EPA 600/R-93/116

Asbestos Type

NoCaulking, Tan/ Gray None Detected0134177-001 EXTERIOR

PLM-1 Gypsum

Cellulose FiberNoCaulking, Tan/ Gray None Detected0134177-002 EXTERIOR

PLM-2

<1%

Gypsum

NoCaulking, Tan/ Gray None Detected0134177-003 EXTERIOR

PLM-3 Gypsum

Distinctly stratified, easily separable layers of samples are analyzed as subsamples of the whole and are reported separately for each discernible layer. All analyses are derived from calibrated visual estimate and measured in area percent unless otherwise noted. The report applies to the standards or procedures identified and to the sample(s) tested.