S02_Attachment 5_Hazardous Material Survey Report_829CM3018.pdf

Baton Rouge National Cemetery

Demo Maintenance Building – Construct New Restroom

Bid Documents

Appendix D – Hazardous Materials Survey Report

Baton Rouge National Cemetery

Demo Maintenance Building – Construct New Restroom

Bid Documents

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© 2021, Mabbett & Associates, Inc. S:\ADMINA\2021050 Integrity Federal\Baton Rouge NC HAZMAT Report.docx

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Mabbett & Associates, Inc.

105 Central Street, Suite 4100 Stoneham, MA 02180-1260 Tel: 781-275-6050 info@mabbett.com www.mabbett.com

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Scientists | Engineers | Program Managers Since 1980

October 28, 2021

Mr. Andrew Nguyen, PE Integrity Federal Services 148 S. Queen Street, Suite 201 Martinsburg, WV 25401

Submitted via email: anguyen@ifs-ae.com

Subject: Hazardous Materials Survey Report

Baton Rouge National Cemetery, Equipment and Storage Building Mabbett Project No.: R2021050.000

Dear Mr. Nguyen:

As requested, Mabbett & Associates, Inc. (Mabbett®) is pleased to provide results to Integrity Federal Services for hazardous material inspection services related to the Equipment and Storage Building at the Baton Rouge National Cemetery located at 220 N 19th Street in Baton Rouge, Louisiana. The inspection was conducted on October 14th and 25th, 2021, with the objective of the survey to identify asbestos containing materials (ACM), lead containing paint (LCP) and other hazardous materials (OHMs) within the interior and exterior of the building so that an abatement scope and associated cost can be incorporated into design documents being developed for building renovation.

Mabbett team members from ECS were able to accomplish the sampling objective during the site visit. Thirty-two

(32) representative bulk ACM samples were collected and submitted under chain of custody (COC) procedures to a National Voluntary Laboratory Accreditation Program (NVLAP) laboratory for Polarized Light Microscopy (PLM) analysis. Bulk sampling locations and results are identified in the attached Hazardous Materials Assessment Report prepared by ECS. The laboratory reported analytical data indicates that one (1) of the homogenous material samples had greater than 1% asbestos and are considered ACM. The joint compound associated with the gypsum board finishes located in the restrooms contained 2% Chrysotile asbestos, estimated quantity is 100 square feet.

This material is considered ACM and must be abated and properly disposed of prior to disturbance by state licensed and properly trained contractors. Abatement must be performed in accordance with federal, state, and local requirements. Any suspect materials encountered during demolition or renovation activities that were not identified in the attached report as being non-ACM, should be assumed to be ACM unless sample results prove otherwise.

ECS conducted a LCP sampling program to measure lead concentrations in selected painted surfaces of the Equipment and Storage Building and collected ten (10) paint chip samples for submittal for analysis of lead content. Based on laboratory analysis of paint chips, three (3) of the collected samples revealed concentrations of lead in paint that exceeded the U.S. Department of Housing and Urban Development (HUD) threshold of 0.5 percent by weight.

HAZARDOUS MATERIALS ASSESSMENT

19TH STREET PROPERTY

220 NORTH 19TH STREET

BATON ROUGE, LOUISIANA 70806

ECS PROJECT NO. 49:15394

FOR: MABBETT AND ASSOCIATES, INC.

OCTOBER 27, 2021

October 27, 2021

Mr. Michael Delaney

Mabbett and Associates, Inc.

105 Central Street

Suite 4100

Stoneham, Maryland 02180

ECS Project No. 49:15394

Reference: Hazardous Materials Assessment, 19th Street Property, 220 North 19th Street, Baton Rouge, Louisiana

Dear Mr. Delaney:

ECS Southeast, LLP (ECS) is pleased to provide Mabbett and Associates, Inc. with the results of the above referenced Hazardous Materials Assessment performed at 19th Street Property located at 220 North 19th Street in Baton Rouge, Louisiana. This report summarizes our observations, analytical results, findings, and recommendations related to the work performed. The work described in this report was performed by ECS in general accordance with the Scope of Services described in ECS Proposal Number 49:27047P and the terms and conditions of the agreement authorizing those services.

ECS appreciates this opportunity to provide Mabbett and Associates, Inc. with our services. If we can be of further assistance to you, please do not hesitate to contact us.

Sincerely, ECS Southeast, LLP

Bill Penick Justin Roth, CHMM Senior Project Manager Environmental Principal bpenick@ecslimited.com jroth@ecslimited.com 225-224-3145 843-654-4448

11115 Industriplex Boulevard, Suite 200, Baton Rouge, Louisiana 70809 • T: 225-224-2583 • F: 703-834-5527 • ecslimited.com

EXECUTIVE SUMMARY

The subject property is improved with a 1,860 square foot, mixed-use building located at 220 North 19th Street in Baton Rouge, East Baton Rouge Parish, Louisiana. The building was reportedly originally constructed in 1932. The building consisted of restrooms and storage rooms. Building finishes observed within the building appeared to consist of a wood sub-floor ceramic tiles, and painted concrete floors, the wall systems consist of drywall wallboard and CMU block walls, and the ceiling systems consist of drywall ceiling. The exterior walls of the building consist mainly of brick with wood soffit board. At the time of our survey, the subject building was vacant, used for storage, and is currently scheduled for interior renovation. The asbestos-containing roof was replaced in 1992 with the current shingled roof.

The purpose of the survey was to determine if asbestos-containing materials (ACMs) and lead-based paints (LBPs) are present on the subject property. The survey was performed within interior and exterior areas of the subject building as well as the roof of the main building.

Based on the laboratory analysis of the bulk samples collected during the survey, the following materials were reported to contain asbestos:

• Beige joint compound located in restrooms.

The lead-based paint survey was performed by a Louisiana licensed Lead Inspector. Painted and/ or glazed surfaces were assessed for lead content by collecting paint chip samples. Detectable concentrations of lead were identified in the samples collected and analyzed from interior and exterior painted surfaces. Since OSHA has no specific action level for lead in paint, all paint on the site found to have a measurable concentration of lead should be assumed to be lead-containing. Work performed which may disturb lead-containing paint is regulated under OSHA as referenced under 29

CFR 1926.62.

In addition to survey for ACMs and LBPs, ECS surveyed the building for various materials classified as universal or hazardous waste which may require special handling or disposal if removed from the building. Based on our findings, ECS recommends disposing of materials not being used in accordance with applicable state, federal, and local regulations that include, but are not limited to, used gasoline cans, fertilizer, biological solutions, herbicides, and a sealed acid battery.

Recommendations regarding the removal and disposal of the ACMs, LBPs, and hazardous/universal waste identified by ECS can be found in Section 5.0 of this report.

The executive summary is an integral portion of this report, however, ECS recommends the report be read in its entirety.

ECS Project # 49:15394

PAGETABLE OF CONTENTS

1.0 SITE DESCRIPTION

2.0 PURPOSE

3.0 METHODOLOGY

3.1 Asbestos-Containing Materials

3.2 Lead in Paint and Surface Coatings

3.3 Universal Waste and Suspect Liquid PCB-Containing Equipment

4.0 RESULTS

4.1 Asbestos-Containing Materials

4.2 Suspect or Assumed Asbestos-Containing Materials

4.3 Lead in Paint and Surface Coatings

4.4 Universal Waste and Liquid Suspect PCB-Containing Equipment

4.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

4.4.2 Mercury-Containing Components

4.4.3 Batteries

4.4.4 Pesticides

4.4.5 Other Materials Observed

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

5.1 Asbestos-Containing Materials

5.2 Lead in Paint and Surface Coatings

5.3 Universal Waste and Liquid PCBs in Equipment

5.3.1 Other Hazardous and Regulated Waste

6.0 LIMITATIONS

TABLE OF APPENDICES

Appendix I: Figures

Appendix II: Site Photographs

Appendix III: Asbestos Bulk Sample Results

Appendix IV: Lead Laboratory Analytical Results

Appendix V: Certifications/Licenses

1.0 SITE DESCRIPTION

The subject property is improved with a 1,860 square foot, mixed-use building located at 220 North 19th Street in Baton Rouge, East Baton Rouge Parish, Louisiana. The building was reportedly originally constructed in 1932. The building consisted of restrooms and storage rooms. Building finishes observed within the building appeared to consist of a wood sub-floor ceramic tyles, and painted concrete floors, the wall systems consist of drywall wallboard and CMU block walls, and the ceiling systems consist of drywall ceiling. The exterior walls of the building consist mainly of brick with wood soffit board. The asbestos-containing roof was replaced in 1992 with the current shingled roof. At the time of our survey, the subject building was vacant, used for storage, and is currently scheduled to be renovated inside the building.

2.0 PURPOSE

The purpose of the Hazardous Materials Assessment was to identify asbestos-containing materials (ACMs), lead-based paint (LBP), universal waste and suspect liquid poly-chlorinated biphenyl (PCB) containing equipment in fixtures which may require special handling and/or disposal if removed during construction activities. The identification of ACMs may require trained labor, regulated work practices, and special disposal. The identification of LBP or other lead hazards may require disclosure to contractors and monitoring of lead exposure. The identification of other regulated materials such as universal waste may require personal protective equipment, training, special handling, packaging, and disposal.

3.0 METHODOLOGY

ECS performed the authorized Scope of Services in general accordance with our proposal, standard industry practice(s) and methods specified by regulation(s) for the identification of ACMs, LBPs, and universal waste and suspect liquid PCB-containing equipment and fixtures.

3.1 Asbestos-Containing Materials

The non-destructive asbestos survey was performed on October 14 and 25, 2021 by Mr. Bill Penick (Accreditation Number JI149609), an asbestos inspector who has received EPA accredited training and is licensed by the Stare of Louisiana Department of Environmental Quality (LDEQ). Samples of suspect ACMs were collected utilizing hand tools and placed into individual, labeled plastic bags.

Unique bulk suspect ACM samples were submitted to EMSL Analytical, Inc. (EMSL) in Baton Rouge, Louisiana for analysis via Polarized Light Microscopy (PLM) in accordance with current EPA-600 methodology. Materials consisting of additional layers were analyzed separately. EMSL is listed as an accredited laboratory by the National Voluntary Laboratory Accreditation Plan (NVLAP) managed by the National Institute of Standards and Technology (NIST) for bulk sample analysis by currently approved EPA methodology by PLM.

During the survey, ECS attempted to identify suspect ACMs in readily accessible areas. However, due to the destructive means required to identify some materials, certain areas were deemed inaccessible (i.e. behind walls or sub grade materials) and were not surveyed for suspect ACMs. Unidentified suspect ACMs may be located in these and/or other inaccessible areas.

October 27, 2021

Samples were collected in general accordance with EPA Standard 40 CFR 763 Subpart E, Asbestos Hazard Emergency Response Act (AHERA) and OSHA Standard 29 CFR 1926.1101 Inspection Protocol.

Multiple samples of each unique material were submitted.

3.2 Lead in Paint and Surface Coatings

The Lead-Based Paint (LBP) survey was performed by Mr. Pack and Mr. Penick on October 14, 2021.

The survey was conducted by collecting paint chip samples from the interior and exterior of the structure. The paint chip samples were submitted to EMSL. EMSL participates in the American Industrial Hygiene Association (AIHA) Environmental Lead Proficiency Analytical Testing (ELPAT) Programs for analysis of lead concentrations (percent by weight) using Flame Atomic Absorption Spectroscopy. Activities which disturb lead-containing paints and glazing (while not lead-based paints by the U.S. EPA definition) are regulated by OSHA (29 CFR 1926.62).

Because the current or proposed use of the property is not residential or child-occupied, the scope of the LBP survey was not conducted in accordance with HUD Chapter 7 requirements. Paint chip samples were collected from walls, floors, and exterior walls.

3.3 Universal Waste and Suspect Liquid PCB-Containing Equipment

ECS performed a visual survey of within the building and exterior for the presence of universal waste materials and suspect liquid PCB-containing equipment. ECS entered the accessible areas to identify universal waste materials including batteries, stored pesticides, mercury-containing equipment and lamps. Additionally, lamp ballasts suspected of containing PCBs and lead-containing equipment were documented if observed.

No sampling or other characterization was performed as part of this scope of service. Additionally, ECS did not access any energized electrical equipment or other equipment/devices which were in use or that may pose a hazard to ECS personnel or building occupants.

4.0 RESULTS

The following is a summary of laboratory results, findings and observations.

4.1 Asbestos-Containing Materials

In total, 19 bulk samples from five homogeneous areas were submitted to the laboratory of which 18 layers were analyzed.

An ACM is defined as any material containing more than one percent (>1%) asbestos as determined using the method specified in Appendix E, Subpart E, 40 CFR Part 763, Section 1, PLM. Materials are categorized by the U.S. EPA in the following categories:

• Friable ACMs are defined as any ACM that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure. Non-friable ACMs are defined as any ACM that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

October 27, 2021

• Category I non-friable ACM are listed as following: packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than one percent (>1%) asbestos.

• Category II non-friable ACM are listed as any material, excluding Category I non-friable ACM, containing more than one percent (>1%) asbestos.

Regulated Asbestos Containing Materials (RACMs) are friable ACMs or non-friable ACMs that will be or has been subjected to sanding, grinding, cutting, or abrading or has crumbled, been pulverized, or reduced to powder in the course of renovation and/or demolition operations.

EMSL submitted a signed final laboratory report to ECS on October 18, 2021 and October 26, 2021.

One of the bulk samples submitted for analysis were reported to contain asbestos in detectable concentrations. These materials are summarized below. A complete list of the sampled materials submitted for analysis and sample locations are located in the Appendix of this report. Additional details regarding the overall locations of the materials identified as asbestos-containing are provided further in the report. Photographs of collected samples reported as asbestos-containing are also located in the Appendix of this report.

Summary of Asbestos-Containing Materials Identified

Sample ID Location Material Description

Analytical Result Category

A-1, 2, 3 Drywall ceiling

White and brown drywall, white joint compound, and beige joint compound

Drywall:

None Detected

(ND)

White JC:

ND

Beige JC restroom ceiling: 2% Chrysotile

Friable, The beige joint compound in the restroom contained approximately 64 square feet.

A - 1, 2, 3, 4, 5 October 25, Concrete masonry unit interior wall

Gray mortar ND NA

A - 6, 7, 8, 9, 10 October 25, Brick interior wall

Gray and red mortar ND NA

October 27, 2021

Sample ID Location Material Description

Analytical Result Category

A - 11, 12, 13 October 25, Brick exterior wall

Gray mortar ND NA

R-1, 2, 3 Shingled roof

Black and gray shingles, black tar, and brown, black, and beige felt

ND, ND,

ND

NA

4.2 Suspect or Assumed Asbestos-Containing Materials

Due to the inaccessibility or the destructive means that asbestos sampling requires, additional suspect ACMs may remain within the building hidden behind inaccessible areas that include, but are not limited to, sub-grade walls, structural members, topping slabs, sub-grade sealants, flooring located below underlayments, areas behind exterior walls, pipe trenches, and subsurface utilities, etc.

These areas were deemed inaccessible and were not assessed.

If these materials are discovered during construction activities, they should be presumed to contain asbestos and be treated as ACMs or be sampled immediately upon discovery and prior to disturbance for asbestos content by a certified asbestos inspector in accordance with 29 CFR 1926.1101.

4.3 Lead in Paint and Surface Coatings

Paint and surface coatings which contain detectable concentrations of lead are considered “lead-containing paints”. Since OSHA has no specific action level for lead in paint, all paint on the site found to have a measurable concentration of lead should be assumed to be lead-containing. Work performed which may disturb lead-containing paint is regulated under OSHA as referenced under 29 CFR 1926.62. A total of ten paint chip samples were collected during the survey. Laboratory results indicated the lead concentrations were above the method detection limit.

Summary of Lead Paint Chip Results

Sample ID / Location Color Substrate Component

Lead Concentration (% by Weight)

L-1 White Wood Interior Sliding Door

0.90

L-2 Tanish white

Brick and concrete masonry units

Interior wall 0.035

L-3 Gray Concrete Floor 0.057

October 27, 2021

Sample ID / Location Color Substrate Component

Lead Concentration (% by Weight)

L-4 White and tan

Wood Exterior door 5.8

L-5 Gray Concrete Exterior floor near restrooms

0.050

L-6 Black Iron Exterior Fence and door guards

0.024

L-7 Gray Metal Interior Shower 0.17

L-8 White Drywall Above ceiling 0.11

L-9 Red Wood Interior Wall 10

L-10 White Wood Exterior walls 0.20

4.4 Universal Waste and Liquid Suspect PCB-Containing Equipment

The disposal of fixtures and equipment in buildings which contain various substances such as mercury or lead are regulated by local, state, and federal regulation. Collectively most mercury-containing materials and batteries which may contain lead, along with stored pesticides are classified as "Universal Waste". The disposal of lamp ballasts and electrical transformers which contain suspect PCB-containing oils is also regulated at the state and federal level.

4.4.1 Suspect Polychlorinated Biphenyl (PCB) Containing Ballasts and Equipment

Polychlorinated biphenyls (PCBs) are toxic coolants or lubricating oils used in some electrical transformers and capacitors, hydraulically-operated equipment, light ballasts, and other similar equipment.

As part of our survey, ECS attempted to identify potential liquid PCB-containing materials and equipment. At the time of the Hazardous Materials Assessment, fluorescent light ballasts were not observed to be present in accessible areas of the structure.

4.4.2 Mercury-Containing Components

The EPA classifies mercury as both hazardous and toxic. Equipment which could contain mercury, such as thermostats, transformers, fluorescent lamps, and switch-containing devices were not observed in accessible areas of the structure during our site visit.

4.4.3 Batteries

One sealed acid battery was observed in the alarm panel along the interior wall. No evidence of leaking or damage was observed.

October 27, 2021

4.4.4 Pesticides

ECS observed D/2 biological solution and four 2.5 gallons of herbicide located on the concrete floor inside of the building. These containers were observed to be in good condition with no evidence of leaking or spills.

4.4.5 Other Materials Observed

During the site inspection, ECS observed several portable gas cans and several bags of fertilizer inside of the building. No staining was observed.

5.0 RECOMMENDATIONS AND REGULATORY REQUIREMENTS

Based on our understanding of the purpose of the Hazardous Materials Assessment, the results of laboratory analysis, and our findings and observations, ECS presents the following recommendations.

5.1 Asbestos-Containing Materials

ECS recommends where a material type has been identified as asbestos-containing that other materials with similar color, texture, age and size throughout the building’s interior and exterior be assumed to contain asbestos. Please refer to Section 4.1 for a complete list of building materials that were reported positive for asbestos and to Section 4.2 for materials that were assumed to contain asbestos.

The beige joint compound sample A-3 in the restroom, should be removed by a licensed asbestos abatement contractor and disposed of a certified landfill that excepts asbestos containing material.

If ACMs are to be removed, it is recommended that an industrial hygienist monitor the project.

This involves collecting air samples from within and outside abatement work areas to monitor the asbestos abatement contractor’s work practices over the course of the project. The industrial hygienist should evaluate if the asbestos abatement work is in accordance with project specifications, U.S. EPA regulation 40 CFR Part 61-National Emission Standards for Hazardous Air Pollutants Subpart M: National Emission Standard for Asbestos, and U.S. Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1926.1101 – Asbestos in Construction. The industrial hygienist should assess each work area to monitor the removal of ACMs. Only after the industrial hygienist has determined the identified ACMs have been removed should final clearance air samples be collected (if necessary).

Suspect ACMs not observed due to inaccessibility or not sampled due to the destructive means that sampling would require may also be encountered during construction activities. At the time of the survey, only limited destructive means were used to locate or sample suspect ACMs; therefore, additional suspect ACMs may remain within inaccessible areas that include, but are not limited to, [sub-grade walls, structural members, topping slabs, exterior areas, sub-grade sealants, flooring located below underlayments, vapor barriers, pipe trenches and other subsurface utilities, etc.] If additional suspect ACMs are uncovered which were not accessible during this survey, it is recommended that these materials either be assumed to contain asbestos or be sampled prior to disturbance upon discovery for asbestos content by an asbestos inspector in accordance with 29 CFR 1926.1101.

October 27, 2021

5.2 Lead in Paint and Surface Coatings

Based on the findings of the lead survey, detectable concentrations of lead were identified on some paints and surface coatings.

The presence of lead is a concern primarily when conditions exist where it may be inhaled or ingested.

Regardless of the analytical results of a material, all painted and/or glazed surfaces may still contain concentrations of lead in the paint, which when disturbed, may generate lead dust greater than the Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter (ug/m3) as an 8-hour Time Weighted Average (TWA) established by the OSHA “Lead Exposure in Construction Rule (29 CFR 1926.62).”

The OSHA standard gives no guidance on acceptable levels of lead in paint at which no exposure to airborne lead (above the action level) would be expected. Rather, OSHA defines airborne concentrations, and references specific types of work practices and operations from which a lead hazard may be generated (reference 29 CFR 1926.62, section d). Environmental and personnel monitoring should be conducted during any removal/demolition process (as appropriate) to verify that actual personal exposures are below the PEL of 50 µg/m3 as an 8-hour TWA. Under OSHA requirements, the contractor performing renovation work will be required to conduct this monitoring and follow applicable requirements under 29 CFR 1926.62 if disturbing lead-containing paint.

5.3 Universal Waste and Liquid PCBs in Equipment

Fluorescent lamp ballasts manufactured prior to 1979 may contain small quantities of PCBs.

Additionally, regardless of “PCB labeling,” ballasts produced between 1980 and 1991 may contain di-ethyl hexyl phthalate (DEHP) which is classified as a potential carcinogen by the EPA. Additionally, DEHP contamination on Superfund sites is common and responsible parties are subject to liability under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) should cleanup of DEHP be necessary. ECS recommends that all ballasts suspected to contain PCBs be properly recycled or disposed of in accordance with US EPA and regulations. In practice many ballasts lacking the "No-PCBs" label have been removed from buildings as part of routine maintenance; however, inspection of each ballast by the contractor performing removal is still recommended to ensure proper disposal into the proper waste stream.

ECS recommends that fluorescent lamp tubes/bulbs suspected to contain mercury be properly recycled or disposed of in accordance with EPA and Louisiana regulations. Recycling is the most environmental friendly means of disposal for these materials. Fluorescent lamps may be disposed as universal waste if they remain unbroken during removal. If bulbs are crushed or broken prior to disposal, they are classified as hazardous waste by the EPA.

The disposal of universal waste and lamp ballasts must be performed in a manner by which the individual wastes are segregated and disposed of properly as required by federal regulations. If any of these materials are observed to be leaking or otherwise damaged prior to disposal they must be disposed of as hazardous waste in accordance with EPA regulations. Handling, packaging, labeling, and disposal of hazardous materials should be performed in accordance with EPA and Department of Transportation regulations.

October 27, 2021

Generators of universal and hazardous waste must obtain an EPA Generator ID number in order to dispose of these materials.

5.3.1 Other Hazardous and Regulated Waste

During the site inspection, ECS observed several portable gas cans, a sealed acid battery, and several bags of fertilizer inside of the building. No staining was observed.

6.0 LIMITATIONS

The conclusions and recommendations presented within this report are based upon a reasonable level of assessment within normal bounds and standards of professional practice for a site in this particular geographic setting. ECS is not responsible or liable for the discovery and elimination of hazards that may potentially cause damage, accidents, or injuries.

The observations, conclusions, and recommendations pertaining to environmental conditions at the subject site are necessarily limited to conditions observed, and/or materials reviewed at the time this study was undertaken. No warranty, expressed or implied, is made with regard to the conclusions and recommendations presented within this report. This report is provided for the exclusive use of the client. This report is not intended to be used or relied upon in connection with other projects or by other unidentified third parties without the written consent of ECS and the client.

Our recommendations are in part based on federal, state, and local regulations and guidelines. ECS does not assume the responsibility of the person(s) in charge of the site, or otherwise undertake responsibility for reporting to any local, state, or federal public agencies, any conditions at the site that may present a potential danger to public health, safety, or the environment. Under this scope of services, ECS assumes no responsibility regarding any response actions initiated as a result of these findings. General compliance with regulations and response actions are the sole responsibility of the Client and should be conducted in accordance with local, state, and/or federal requirements.

October 27, 2021

Appendix I: Figures

Legend:

A-# Sample Location

Sample Negative

Sample Positive

Notes:

Not to scale

Figure 2 Asbestos Sample Locations

19th Street Property 220 N 19th Street

Baton Rouge, Louisiana ECS Project No. 49:15394

Storage room

Restrooms

Restroom

A-3

A-1

A-2 R-1

R-2

R-3

A-3-10/25/21

A-2-10/25/21

A-1-10/25/21

A-4-10/25/21 A-5-10/25/21

A-8-10/25/21

A-7-10/25/21

A-6-10/25/21

A-10-10/25/21

A-9-10/25/21

A-12-10/25/21

A-11-10/25/21

A-13-10/25/21

Legend:

L-# Sample Location

Sample Negative

Lead-Containing Paint Sample

Notes:

Not to scale

Figure 3 Lead Paint Chip Sample Locations

19th Street Property 220 N 19th Street

Baton Rouge, Louisiana ECS Project No. 49:15394

L-6

L-1

L-3

L-2

L-9

Restrooms

Patio

Storage room

L-7 L-4

L-5

L-8

L-10

Appendix II: Site Photographs

1 - Men's restroom

2 - Supply closet

3 - Men's restroom

4 - Women's restroom

5 - Algae and mold remover

6 - Algae and mold remover

7 - Bags of fertilizer

8 - Fertilizer

9 - Containers of herbicide

10 - Herbicide

11 - Gasoline can

12 - Gasoline can

13 - Natural gas heater

14 - Natural gas heater

15 - Lead acid battery

16 - Thermostat

17 - Inside of thermostat

18 - Thermostat label

19 - Garage area

20 - Garage area

21 - Storage area entryway

22 - Storage area

23 - Storage area

24 - Garage area entryway

25 - Storage area

26 - Storage area

27 - Restroom

28 - Restroom

29 - Storage area

30 - Supply closet

31 - Red paint on the interior brick wall near the sliding doors.

32 - Baton Rouge National Cemetery Building From the southwest

33 - Appearance of white CMU interior walls.

34 - Appearance of white CMU interior walls.

35 - Appearance of white brick interior walls.

36 - Appearance of white brick interior walls.

37 - Appearance of white CMU interior walls.

38 - Appearance of exterior red brick wall and gray mortar.

Appendix III: Asbestos Bulk Sample Results

EMSL Analytical, Inc.

18369 Petroleum Drive Baton Rouge, LA 70809

Tel/Fax: (225) 755-1920 / (225) 755-1989 http://www.EMSL.com / batonrougelab@emsl.com

252106737EMSL Order:

Customer ID: ENCS55

Customer PO:

Project ID:

Attention: Phone:Bill Penick (225) 771-9629

Fax:ECS Southeast, LLP (864) 987-1615

Received Date:1200 Woodruff Rd. 10/15/2021 8:30 AM

Analysis Date:Greenville, SC 29607 10/18/2021

Collected Date: 10/14/2021

Project: 49-15394 19th Street Property

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

A-1-Drywall

252106737-0001

None DetectedNon-fibrous (Other)80%Cellulose20%Brown/White

Fibrous

Heterogeneous

Interior Ceiling -

White Drywall & Joint

Compound

A-1-Joint Compound

252106737-0001A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Interior Ceiling -

White Drywall & Joint

Compound

A-2-Drywall

252106737-0002

None DetectedNon-fibrous (Other)100%Brown/White

Fibrous

Heterogeneous

Interior Ceiling -

White Drywall & Joint

Compound

A-2-Joint Compound

252106737-0002A

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Interior Ceiling -

White Drywall & Joint

Compound

A-3-Drywall

252106737-0003

None DetectedNon-fibrous (Other)80%Cellulose20%Brown/White

Fibrous

Heterogeneous

Interior Ceiling -

White Drywall & Joint

Compound

A-3-Joint Compound

252106737-0003A

2% ChrysotileNon-fibrous (Other)98%Beige

Non-Fibrous

Homogeneous

Interior Ceiling -

White Drywall & Joint

Compound

R-1-Shingle

252106737-0004

None DetectedNon-fibrous (Other)90%Glass10%Black

Fibrous

Heterogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-1-Tar

252106737-0004A

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-1-Felt

252106737-0004B

None DetectedNon-fibrous (Other)55%Cellulose45%Black

Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-1-Felt Paper

252106737-0004C

None DetectedNon-fibrous (Other)5%Cellulose95%Brown/Beige

Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-2-Shingle 1

252106737-0005

None DetectedNon-fibrous (Other)90%Glass10%Black

Fibrous

Heterogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

No Tar or Felt Paper present for analysis

R-2-Shingle 2

252106737-0005A

None DetectedNon-fibrous (Other)90%Glass10%Gray/Black

Fibrous

Heterogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-2-Felts

252106737-0005B

None DetectedNon-fibrous (Other)50%Cellulose50%Black

Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-2-Wood Material

252106737-0005C

None DetectedNon-fibrous (Other)2%Cellulose98%Brown

Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-3-Shingle 1

252106737-0006

None DetectedNon-fibrous (Other)90%Glass10%Black

Fibrous

Heterogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-3-Shingle 2

252106737-0006A

None DetectedNon-fibrous (Other)90%Glass10%Gray/Black

Fibrous

Heterogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

Initial report from: 10/18/2021 12:06:49

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 10/18/2021 12:44 PM

Tel/Fax: (225) 755-1920 / (225) 755-1989 http://www.EMSL.com / batonrougelab@emsl.com

252106737EMSL Order:

Customer ID: ENCS55

Customer PO:

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

R-3-Tar

252106737-0006B

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

R-3-Felts

252106737-0006C

None DetectedNon-fibrous (Other)45%Cellulose55%Black

Fibrous

Homogeneous

Main Roof - Black

Shingles/Tar/Felt

Paper

Analyst(s)

Humberto Espinoza Bajo (12)

Joel Paruli (6)

Jamie Laginess, Laboratory Operations Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. 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 or analytical method limitations . The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. 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 . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by LA Testing South Pasadena, CA NVLAP Lab Code 200232-0, CA ELAP 2283

Initial report from: 10/18/2021 12:06:49

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 10/18/2021 12:44 PM

OrderID: 252106737

Tel/Fax: (225) 755-1920 / (225) 755-1989 http://www.EMSL.com / batonrougelab@emsl.com

252106955EMSL Order:

Customer ID: ENCS55

Customer PO:

Project ID:

Attention: Phone:Bill Penick (225) 771-9629

Fax:ECS Southeast, LLP (864) 987-1615

Received Date:1200 Woodruff Rd. 10/25/2021 10:25 AM

Analysis Date:Greenville, SC 29607 10/26/2021

Collected Date: 10/25/2021

Project: 49-15394 19th St Property

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

A-1

252106955-0001

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Interior CMU Wall -

White Mortar

A-2

252106955-0002

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Interior CMU Wall -

White Mortar

A-3

252106955-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Interior CMU Wall -

White Mortar

A-4

252106955-0004

None DetectedNon-fibrous (Other)100%Gray/Various

Non-Fibrous

Homogeneous

Interior CMU Wall -

White Mortar

A-5

252106955-0005

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Interior CMU Wall -

White Mortar

A-6

252106955-0006

None DetectedNon-fibrous (Other)100%Gray/Red

Non-Fibrous

Homogeneous

Interior Brick Wall -

White Mortar

A-7

252106955-0007

None DetectedNon-fibrous (Other)100%Gray/Red

Non-Fibrous

Homogeneous

Interior Brick Wall -

White Mortar

A-8

252106955-0008

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Interior Brick Wall -

White Mortar

A-9

252106955-0009

None DetectedNon-fibrous (Other)100%Gray/Red/Various

Non-Fibrous

Homogeneous

Interior Brick Wall -

White Mortar

A-10

252106955-0010

None DetectedNon-fibrous (Other)100%Gray/Various

Non-Fibrous

Homogeneous

Interior Brick Wall -

White Mortar

A-11

252106955-0011

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Exterior Brick Wall -

Gray Mortar

A-12

252106955-0012

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Exterior Brick Wall -

Gray Mortar

A-13

252106955-0013

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Exterior Brick Wall -

Gray Mortar

Initial report from: 10/26/2021 15:49:27

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 10/26/2021 2:49 PM

Tel/Fax: (225) 755-1920 / (225) 755-1989 http://www.EMSL.com / batonrougelab@emsl.com

252106955EMSL Order:

Customer ID: ENCS55

Customer PO:

Project ID:

Analyst(s)

Haley Young (8)

Joshua Vu (5)

Jamie Laginess, Laboratory Operations Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. 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 or analytical method limitations . The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. 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 . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Baton Rouge, LA NVLAP Lab Code 200375-0, LELAP 01950, TX 300238

Initial report from: 10/26/2021 15:49:27

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 10/26/2021 2:49 PM

OrderID: 252106955

Appendix IV: Lead Laboratory Analytical Results

Client Sample Description ConcentrationLab ID Analyzed Weight Lead

Collected

EMSL Analytical, Inc.

18369 Petroleum Drive, Baton Rouge, LA 70809 Phone/Fax: (225) 755-1920 / (225) 755-1989 http://www.EMSL.com batonrougelab@emsl.com

Attn: Bill Penick ECS Southeast, LLP 1200 Woodruff Rd.

Greenville, SC 29607

Received: 10/15/2021 08:30 AM

49-15394 19th Street Property

Fax: (864) 987-1615 Phone: (225) 771-9629

Project:

10/14/2021Collected:

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

252106736 CustomerID: ENCS55 CustomerPO:

ProjectID:

EMSL Order:

0.2584

Site: Interior Sliding Door

252106736-0001L-1 White & Green Paint

0.90 % wt10/19/2021 g10/14/2021

0.2514 Site: Interior Brick Walls 252106736-0002L-2 White Paint 0.035 % wt10/19/2021 g10/14/2021

0.2584 Site: Interior Concrete Floor 252106736-0003L-3 Gray Paint 0.057 % wt10/19/2021 g10/14/2021

0.2551 Site: Exterior Door 252106736-0004L-4 White & Tan Paint 5.8 % wt10/19/2021 g10/14/2021

0.2556 Site: Exterior Concrete Floor 252106736-0005L-5 Gray Paint 0.050 % wt10/19/2021 g10/14/2021

0.2513 Site: Exterior Fence & Door Guards 252106736-0006L-6 Black Paint 0.024 % wt10/19/2021 g10/14/2021

0.2501 Site: Interior Shower 252106736-0007L-7 Gray Paint 0.17 % wt10/19/2021 g10/14/2021

0.2560 Site: Interior Above Ceiling 252106736-0008L-8 White Paint 0.011 % wt10/19/2021 g10/14/2021

0.2470 Site: Interior Wall Near Fire Extinguisher 252106736-0009L-9 Red Paint 10 % wt10/19/2021 g10/14/2021

0.2528 Site: Exterior Walls 252106736-0010L-10 White Paint 0.20 % wt10/19/2021 g10/14/2021

Jamie Laginess, Laboratory Operations Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 10/19/2021 11:46:20 AM

EMSL maintains liability limited to cost of analysis. Interpretation and use of test results are the responsibility of the client. 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 or analytical method limitations. The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted.

Analysis following Lead in Paint by EMSL SOP/Determination of Environmental Lead by FLAA. Reporting limit is 0.008% wt based on the minimum sample weight per our SOP. "<" (less than) result signifies the analyte was not detected at or above the reporting limit. Measurement of uncertainty is available upon request. Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Baton Rouge, LA LELAP 01950; A2LA Accredited Environmental Testing Cert. #2845.03.

Initial report from 10/19/2021 11:46:20 http://www.EMSL.com mailto:batonrougelab@emsl.com

OrderID: 252106736

OrderID: 252106736

Appendix V: Certifications/ Licenses

STATE OF LOUISIANA

DEPARTMENT OF ENVIRONMENTAL QUALITY

certifies that

William F Penick

Has complied with all requirements of the Louisiana Department of Environmental Quality and is authorized to perform the duties of

Asbestos Inspector

Accreditation No. JI149609 AI No. 149609

Date of Issuance June 25, 2021 Expiration June 11, 2022

Failure to comply with all applicable provisions of La. R.S. 2025.E. (1)(a) and La. R.S. 2025.F. (2)(a) may result in civil and/or criminal enforcement actions by the State.

Permit Support Services Division

Office of Environmental Services

Taylor Pack

Asbestos Inspector

Accreditation No. AI230277 AI No. 230277

Date of Issuance October 12, 2021 Expiration August 11, 2022

Failure to comply with all applicable provisions of La. R.S. 2025.E. (1)(a) and La. R.S. 2025.F. (2)(a)

Permit Support Services Division

Taylor Pack

Lead Inspector

Accreditation No. AI230277 AI No. 230277

Date of Issuance September 10, 2021 Expiration August 19, 2022

Failure to comply with all applicable provisions of La. R.S. 2025.E. (1)(a) and La. R.S. 2025.F. (2)(a)

Public Participation & Permit Support Division