B.08.03 Amendment 0001 Building46_ Final_Hazmat survey120718.pdf

PRE-RENOVATION HAZARDOUS MATERIALS

SURVEY REPORT

For:

Building 46

Fort Leavenworth, Kansas

Prepared by:

Tetra Tech, Inc.

2000 Warrington Way, Suite 245

Louisville, Kentucky 40222

Tetra Tech Project No.

103IG6091

December 2018 i

Table of Contents

Section Page

1.0 INTRODUCTION

2.0 SITE STRUCTURE

3.0 FIELD SURVEY AND ANALYTICAL PROTOCOLS

3.1 ACM Field Survey and Analytical Protocols

3.2 LBP Field Survey and Analytical Protocols

3.3 Mold Field Survey and Analytical Protocols

4.0 FINDINGS

4.1 ACM Findings

4.2 LBP Findings

4.3 Mold

4.4 Hazardous Building Components

5.0 RECOMMENDATIONS

5.1 Confirmed Asbestos

5.2 Presumed ACM/ Assumed ACM

5.3 LBP

6.0 REGULATORY OVERVIEW

6.1 Regulatory Overview for Asbestos

6.2 Regulatory Overview for Lead-Based Paint

7.0 ABATEMENT COST ESTIMATES

8.0 LIMITATIONS

Tables

Table 1 PLM Results for ACM Samples

Table 2 AAS Results For Lead in Paint Samples

Table 3 Tape Lift Sample Results

Table 4 Hazardous Materials Inventoried

Table 5 ACM Abatement Estimates

Table 6 Lead Containing Paint Stabilization Cost Estimate ii

Figures

Figure 1. Basement Level Sampling Locations

Figure 2. First Floor Sampling Locations

Figure 3. Second Floor Sampling Locations

Appendices

A Survey Team Certifications

B Laboratory Reports and Chain-of-Custody Forms for Suspect Asbestos Samples

C Laboratory Report and Chain-of-Custody Form for Suspect Mold

D Photographic Log of Selected Photographs

1.0 INTRODUCTION

Tetra Tech, Inc., conducted a pre-renovation hazardous materials survey of Building 46, located

Fort Leavenworth, Kansas. The survey was a prerequisite to renovation of the structure and involved collecting and analyzing suspected asbestos-containing material (ACM), collecting and analyzing damaged and intact suspect lead-based paint (LBP) and coatings, collection of tape lift samples for microbial identification, and inventorying other hazardous materials observed during the walk-through inspection of the building

Tetra Tech’s Ms. Megan Sawyer and Mr. Tommy Rebecchi conducted the survey on November

7, 2018. Ms. Sawyer is an EPA accredited; Asbestos Hazard Environmental Response Act

(AHERA) asbestos building inspector licensed by the state of Kansas, and lead-based paint inspector. Mr. Rebecchi is an EPA accredited AHERA building inspector. The survey team’s credentials are provided in Appendix A.

The survey evaluated the interior and exterior of the structure for the presence, locations, quantity, and characterization of ACM that may require pre-renovation abatement in accordance with

National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations, as adopted by the U.S. Environmental Protection Agency (EPA). The intent of the asbestos NESHAP regulations is to protect the public (and workers) by minimizing the release of asbestos fibers during activities that involve processing, handling, and disposing of ACM.

Tetra Tech’s survey also included a similar evaluation of the interior and exterior areas of the structure for the presence, locations, and quantity of LBP or coatings with lead at concentrations that exceed hazard levels, which would necessitate Occupational Safety and Health Administration

(OSHA) worker safety precautions during renovation. Therefore, Tetra Tech also collected paint samples from damaged painted surfaces for analysis of lead. To maintain usability of finishes, tile samples were not collected.

A limited mold inspection was also conducted where evidence of moisture intrusion or microbial growth was observed. The mold inspection was limited to collection of tape lift samples from affected vents and quantification of affected materials.

A hazardous materials inventory was also conducted during the asbestos and lead-based paint survey. The inventory was limited to materials easily observed during the walk-through inspection of the structure.

Tetra Tech provided these services consistent with the level and skill ordinarily exercised by members of the profession currently practicing under similar conditions. This statement is in lieu of other statements either expressed or implied. The scope of services performed in executing this evaluation may not be appropriate to satisfy the needs of other users, and use or re-use of this document, the findings, conclusions, or recommendations is at the risk of said user. Although a reasonable attempt has been made to identify suspect ACM and LBP in all parts of the building, the inspection techniques used are inherently limited in the sense that only full demolition procedures can reveal all building materials of a structure and therefore all areas of potential ACM or LBP. This survey report does not warrant against future operations or conditions that may not be consistent with its recommendations. Moreover, completion of the survey does not guarantee identification of all hazardous materials, ACM, or LBP because of some limitations on destructive sampling during the survey. Hazardous materials may be present in voids of walls or ceilings.

This survey report presents the survey findings for ACM, LBP, mold and hazardous materials inventory. Section 2.0 of the report describes the site structure. Section 3.0 discusses field survey and analytical protocols. Section 4.0 presents findings. Section 5.0 provides recommendations based on the survey findings. Section 6.0 presents a regulatory overview. Section 7.0 presents abatement cost estimates. Section 8.0 presents limitations of the survey.

2.0 SITE STRUCTURE

Building 46 was evaluated during this survey effort. The structure consists of an approximately

18,000-square-foot (ft2), three-story building. The building is constructed of brick with an asphaltic built-up roofing (BUR).

Interior finishes include plaster drywall, ceramic tile; ceramic tile, vinyl floor tile, carpet flooring and concrete floors; and acoustical paneled ceilings.

3.0 FIELD SURVEY AND ANALYTICAL PROTOCOLS

The field survey and analytical protocols for the ACM and LBP surveys are discussed below.

3.1 ACM Field Survey and Analytical Protocols

Tetra Tech made every effort to inspect all areas of the structure. Minor demolition of materials was required during the survey effort. The inspector took care to ensure that the areas remained unoccupied during sample collection. A total of 64 bulk samples of suspected ACM were collected from the site structure, which totaled 123 analyzed sample layers. Bulk samples were collected of suspected ACM identified during the visual inspection. Suspected ACMs were grouped as homogeneous areas if the material was similar in appearance and texture. However, if the inspector decided that a material (for example, wall texturing) was not similar in appearance and texture to other materials in the building, the inspector would distinguish the material as unique and collect samples of each unique material. The classifications of suspected ACMs were assigned in accordance with the protocol recommended in 40 Code of Federal Regulations (CFR) Part 763, “Asbestos-Containing Materials in Schools; Final Rule and Notice.” Representative bulk samples were collected from each homogeneous and unique material identified.

Bulk samples of suspected ACM were obtained to ensure that each distinct layer of material would be collected. Tetra Tech attempted to obtain material from each individual layer. A wetting agent was applied to friable surfaces before the sample was collected to reduce the potential for fiber release. All samples were placed in plastic bags, labeled, and sealed immediately after they were collected. After each sample was collected, the sampling instruments were wiped clean using a wet, lint-free cloth to prevent cross-contamination between samples. A unique identification number was assigned to each sample.

Sample identification numbers identify each sample collected. The sample numbers nomenclature is described below:

For example, sample: 46-DWJC-1

46 = location Building 46

DWJC = drywall and joint compound homogenous material group

1 = sample number one in material group

The samples remained in the inspector’s custody until they were sent to the laboratory. When sampling was complete, the bulk samples were sent, along with chain-of-custody documentation to EMSL Analytical Laboratory Services (EMSL) in San Leandro, California. EMSL is accredited by the National Institute of Standards and Technology (NIST) and participates in the National

Voluntary Laboratory Accreditation Program (NVLAP). Bulk asbestos samples were analyzed using polarized light microscopy (PLM) in accordance with the EPA-recommended test method described in 40 CFR 763, Subpart F, Appendix A.

Appendix B of this report provides the ACM analytical results and chain-of-custody forms for the bulk samples.

3.2 LBP Field Survey and Analytical Protocols

Tetra Tech made every effort to inspect all areas of the structure. An XRF screening of suspected

LBP was performed according to protocols similar to the single-family housing inspection procedures in the HUD Guidelines. Tetra Tech utilized a Thermo Scientific XL3t-600 XRF analyzer to perform the LBP screening. The Thermo Scientific XL3t-600 is a state-of-the-art

XRF spectrum analyzing system for quantitative measurement of lead in paint on various substrates. Tetra Tech performed XRF screening of suspect painted surfaces that possibly would be impacted during renovation activities.

Tetra Tech utilized the XRF “Lead Paint Mode” for testing, standardized per the equipment instruction manual, and programmed the unit with an action level of 1.0 milligram per square centimeter (mg/cm2). The XL3t-600 XRF spectrometer automatically adjusts the measurement time to be the least time needed to make a definitive measurement based on the action level.

Paint containing greater than or equal to 1.0 mg/cm2 lead by XRF testing or 1.0 mg/cm2 lead by laboratory analysis is considered LBP.

Tetra Tech performed XRF calibration checks on the XL3t-600 XRF spectrometer according to

Thermo Scientific’s recommended protocol and the HUD Guidelines. These quality control readings were used to monitor performance of the XL3t-600 XRF spectrometer. Calibration-check readings were taken after every hour of operation from a Standard Reference Material (SRM) paint film, developed by the National Institute of Standards and Technology (NIST). Section 8.0 of this report summarizes results from XRF screening of samples of painted surfaces collected at the subject property.

Section 4.0 of this report summarized results from XRF screening of samples of painted surfaces collected at the subject property.

3.3 Mold Field Survey and Analytical Protocols

A limited visual inspection for mold was conducted during the site inspection. Apparent moisture intrusion sources in the building and visible suspect microbial growth on the interior surfaces were noted where observed or where reported by facility staff. Surface samples (tape slide) for laboratory analysis were collected where deemed necessary to confirm the observations of suspect microbial growth. Samples from surfaces were collected via a tape-lift procedure in which a prepared adhesive glass slide was pressed onto the suspect visible mold. Each slide was stored inside a sealed, plastic clamp container. The sample was then labeled and forwarded under chain of custody to Eurofins in Cary, North Carolina for analysis via direct microscopy for presence of mold. Mold samples are identified with an “TL” (TL-1). Laboratory analytical data sheets and chain-of-custody records are in Appendix C.

4.0 FINDINGS

Survey and analytical findings for the samples collected are summarized below. Sample collection locations are provided on Figures 1, 2, and 3. Appendix B present the ACM laboratory results, and Appendix C the mold laboratory results. A photograph log showing selected photographs is provided in Appendix D.

4.1 ACM Findings

The PLM results for the ACM samples are summarized in Table 1 below; the complete results are provided in the laboratory reports included as Appendix B.

Bold results in Table 1 indicate that asbestos was detected.

TABLE 1

PLM RESULTS FOR ACM SAMPLES

Figure

ID Sample ID Material Description Material Locations Analytical Result % 1

1 46-CBM-1 4” Red cove base 2nd floor throughout ND

2 46-CBM-2 4” Red cove base 2nd floor throughout ND

3 46-CBM-3 4” Red cove base 2nd floor throughout ND

4 46-IN-1 White insulation Attic ND

5 46-IN-2 White insulation Attic ND

6 46-IN-3 White insulation Attic ND

46-DWJC-1 Drywall and joint compound Throughout 1st and

2nd floor

ND – drywall

<0.25%– joint compound2

>1% Composite

46-DWJC-2 Drywall and joint compound Throughout 1st and

2nd floor

ND – drywall

Positive stop – joint compound

>1% Composite

46-DWJC-3 Drywall and joint compound Throughout 1st and

2nd floor

ND – drywall

Positive stop – joint compound

>1% Composite

46-DWJC-4 Drywall and joint compound Throughout 1st and

2nd floor

ND – drywall

Positive stop – joint compound

>1% Composite

46-DWJC-5 Drywall and joint compound Throughout 1st and

2nd floor

ND – drywall

Positive stop – joint compound

>1% Composite

TABLE 1

PLM RESULTS FOR ACM SAMPLES

Figure

ID Sample ID Material Description Material Locations Analytical Result % 1

12 46-CM-1 Carpet mastic 1st floor throughout ND

13 46-CM-2 Carpet mastic 1st floor throughout ND

14 46-CM-3 Carpet mastic 1st floor throughout ND

15 46-FT-1 12x12 gray floor tile Rooms 202, 109, 111 ND

16 46-FT-2 12x12 gray floor tile Rooms 202, 109, 111 ND

17 46-FT-3 12x12 gray floor tile Rooms 202, 109, 111 ND

18 46-CT-1

2x4 white fissure and pinhole ceiling tile

1st and 2nd floor throughout

ND

19 46-CT-2

2x4 white fissure and pinhole ceiling tile

1st and 2nd floor throughout

ND

20 46-CT-3

2x4 white fissure and pinhole ceiling tile

1st and 2nd floor throughout

ND

21 46-CTM-1 White ceramic wall tile mastic 1st and 2nd floor bathrooms

ND

22 46-CTM-2 White ceramic wall tile mastic 1st and 2nd floor bathrooms

ND

23 46-CTM-3 White ceramic wall tile mastic 1st and 2nd floor bathrooms

ND

46-CTG-1

Tan ceramic wall tile grout 1st and 2nd floor bathrooms

ND

46-CTG-2

Tan ceramic wall tile grout 1st and 2nd floor bathrooms

ND

46-CTG-3

Tan ceramic wall tile grout 1st and 2nd floor bathrooms

ND

46-CTG2-1 Gray ceramic floor tile grout 1st and 2nd floor bathrooms

ND

46-CTG2-2 Gray ceramic floor tile grout 1st and 2nd floor bathrooms

ND

46-CTG2-3 Gray ceramic floor tile grout 1st and 2nd floor bathrooms

ND

46-FB-1 Gray floor backing Room 104, 1st floor hall, 2nd floor in front of bathroom

ND

46-FB-2 Gray floor backing Room 104, 1st floor hall, 2nd floor in front of bathroom

ND

46-FB-3 Gray floor backing Room 104, 1st floor hall, 2nd floor in front of bathroom

ND

46-STM-1

Stair tread mastic 1st to 2nd floor, 1st to basement

ND

46-STM-2

Stair tread mastic 1st to 2nd floor, 1st to basement

ND

46-STM-3

Stair tread mastic 1st to 2nd floor, 1st to basement

ND

36 46-SC-1 Skim coat Basement brick walls ND

37 46-SC-2 Skim coat Basement brick walls ND

38 46-SC-3 Skim coat Basement brick walls ND

39 46-FT2-1 12x12 white floor tile Basement ND

PLM RESULTS FOR ACM SAMPLES

Figure

ID Sample ID Material Description Material Locations Analytical Result % 1

40 46-FT2-2 12x12 white floor tile Basement ND

41 46-FT2-3 12x12 white floor tile Basement ND

42 46-FT3-1 12x12 tan floor tile Basement near furnace

ND

43 46-FT3-2 12x12 tan floor tile Basement near furnace

ND

44 46-FT3-3 12x12 tan floor tile Basement near furnace

ND

45 46-CM2-1 Carpet mastic 2nd floor throughout ND

46 46-CM2-2 Carpet mastic 2nd floor throughout ND

47 46-CM2-3 Carpet mastic 2nd floor throughout ND

48 46-CMB2-1 8’ Brown cove base mastic 1st floor right offices ND

49 46-CMB2-2 8’ Brown cove base mastic 1st floor right offices ND

50 46-CMB2-3 8’ Brown cove base mastic 1st floor right offices ND

51 46-CT2-1 4x4 White gypsum ceiling tile 1st floor bathroom ND

52 46-CT2-2 4x4 White gypsum ceiling tile 1st floor bathroom ND

53 46-CT2-3 4x4 White gypsum ceiling tile 1st floor bathroom ND

54 46-PLSC-1 Plaster with skim coat Basement

ND – plaster

ND – skim coat 1

0.25% Chrys – skim coat 22

55 46-PLSC-2 Plaster with skim coat Basement

ND – plaster

ND – skim coat 1

Positive stop – skim coat 2

56 46-PLSC-3 Plaster with skim coat Basement

ND – plaster

ND – skim coat 1

Positive stop – skim coat 2

57 46-CTX-1 Ceiling texture Basement 0.25% Chrys 2

58 46-CTX-2 Ceiling texture Basement Positive Stop

59 46-CTX-3 Ceiling texture Basement Positive Stop

60 46-WC-1 Window caulk Exterior windows around metal frame

ND

61 46-WC-2 Window caulk Exterior windows around metal frame

ND

62 46-WC-3 Window caulk Exterior windows around metal frame

ND

63 46-DC-1 Door caulk White doors 10% Chrys

64 46-DC-2 Door caulk White doors Positive stop

65 46-DC-3 Door caulk White doors Positive stop

66 46-RS-1 Gray shingle Throughout ND

67 46-RS-2 Gray shingle Throughout ND

68 46-RS-3 Gray shingle Throughout ND

69 46-RS2-1 Red shingle Throughout ND

70 46-RS2-2 Red shingle Throughout ND

71 46-RS2-3 Red shingle Throughout ND

72 46-RP-1 Roofing paper Throughout ND

73 46-RP-2 Roofing paper Throughout ND

PLM RESULTS FOR ACM SAMPLES

Figure

ID Sample ID Material Description Material Locations Analytical Result % 1

74 46-RP-3 Roofing paper Throughout ND

Notes:

Bold values indicate asbestos was detected

1 Result includes all layers unless otherwise specified Chrys. Chrysotile asbestos

2 Result confirmed by 400-point count analysis % Percent

ND Asbestos not detected ACM Asbestos-containing material

PLM Polarized light microscopy

4.2 LBP Findings

A summary of screening results for LBP by use of the XRF spectrometer at the subject property appears in Table 2 below. Bolded results in Table 2 indicate where LBP was detected at concentration greater than 1.0 mg/cm2. Positive (greater than 1.0 mg/cm2) results for LBP are shown on Table.

TABLE 2

SUMMARY OF LBP SCREENING LOCATIONS

No. Color Location Component Substrate

XRF

Reading

(mg/cm2)

Damaged1

Quantity2

1 White Exterior Door Metal 0.00 NA NA

2 White Exterior Door Frame Wood 0.00 NA NA

3 White Exterior Door Frame Metal 0.00 NA NA

4 White Exterior Wall Wood 0.09 NA NA

5 Red Exterior (Shop) Support Beam Wood 0.09 NA NA

6 Black Exterior Rail Metal 0.00 NA NA

7 White Lobby Door Frame Wood >5.00 Y 200 LF

8 White Lobby Wall Drywall 0.00 NA NA

9 Brown Hallway Door Metal 0.00 NA NA

10 Brown 1st floor restroom Door Frame Metal 0.00 NA NA

11 White 1st floor restroom Floor Ceramic Tile 0.02 NA NA

12 Tan 1st floor restroom Floor Ceramic Tile 0.01 NA NA

13 White 1st floor restroom Wall Ceramic Tile >1.00 N 3,300 ft2

14 Tan 1st floor restroom Wall Ceramic Tile 0.14 NA NA

15 Tan 1st floor restroom Wall Drywall 0.00 NA NA

16 White Room 110 Wall Drywall 0.00 NA NA

17 White Room 110 Wall Plaster 1.95 N 120 ft2

18 White Room 110 Window Frame Wood 0.11 NA NA

19 White Room 110 Wall Plaster 0.00 NA NA

20 Blue 2nd floor hallway Stairs Wood 0.83 NA NA

21 White 2nd floor hallway Rail Wood 0.00 NA NA

22 White 2nd floor hallway Door Frame Wood 2.57 Y 20 LF

23 White Attic Stairs Wood >1.00 Y 100 ft2

24 White 1st floor lobby Stairs Wood 1.13 N 100 ft2

TABLE 2

SUMMARY OF LBP SCREENING LOCATIONS

No. Color Location Component Substrate

XRF

Reading

(mg/cm2)

Damaged1

Quantity2

25 Black 1st floor lobby Rail Metal 0.00 NA NA

26 Tan 2nd floor restroom Wall Concrete 0.01 NA NA

27 White 2nd floor restroom Window Frame Wood 0.44 NA NA

28 Tan 2nd floor restroom Wall Wood 0.01 NA NA

29 Tan 2nd floor restroom Wall Plaster 0.05 NA NA

30 White Room 201 Wall Plaster 0.00 NA NA

31 White Room 201 Window Sill Wood 0.08 NA NA

32 White Room 201 Window Frame Wood 1.66 N 700 LF

Dark

Tan

Room 201 Door Wood

0.05 NA NA

34 White Room 203 Wall Plaster 0.00 NA NA

35 White Room 106 Wall Drywall 0.01 NA NA

36 White Basement Wall Rock 0.02 NA NA

37 White Basement Wall Brick 0.02 NA NA

38 White Basement Ceiling Wood 0.00 NA NA

39 Blue Basement Wall Brick 0.00 NA NA

40 White Basement Wall Metal 0.00 NA NA

41 Gray Basement Support Beam Metal >5.00 Y 10 LF

42 White Basement Support Beam Metal 4.70 Y 50 LF

43 Blue Basement Support Beam Metal >5.00 Y 10 LF

44 Yellow Basement Floor Concrete 0.97 NA NA

45 White Basement Ceiling Wood 0.01 NA NA

46 Blue Basement Door Wood 0.00 NA NA

47 Black Basement Door Frame Wood 2.99 Y 25 LF

48 Gray Basement Floor Concrete 0.01 NA NA

49 White Basement Door Wood >5.00 Y 50 ft2

50 White Basement Door Frame Wood >5.00 Y 30 LF

51 White Basement Stairs Wood >1.00 Y 100 ft2

White Conference

Room Floor Board Concrete 2.95 Y

80 LF

53 White Conference

Room Door Frame Wood >5.00 Y

30 LF

Notes:

1 This column identifies LBP surfaces that are damaged. If no damage is present prior to renovation activities, preliminary removal of chipping and peeling paint is not necessary prior to the encapsulation process.

2 This is only an estimated quantity and should not be used for bidding purposes.

mg/cm2 Milligrams per square centimeter LF Linear feet ft2 Square food LBP Lead-based paint

XRF X-ray fluorescence NA Not applicable

4.3 Mold

Site assessment observations identified moisture intrusion issues in rooms 110, 201, 203, and conference room. Mold was detected as shown in Table 3 below. Laboratory results are provided in Appendix C.

TABLE 3

TAPE LIFT SAMPLE RESULTS

Sample

ID

Location Spore Counts

Observations or

Suspect Mold

Issues

TL-1 Room 110 Abundant Cladosporium and Aspergillus/Penicillium

Moderate Fungal mycelial fragments

Low growth.

Brown

TL-2 Conference room Abundant Cladosporium and Fungal mycelial fragments

Low growth.

White

TL-3 2nd floor offices 201

Abundant Cladosporium

Moderate Fungal mycelial fragments

Low Alternaria

Low growth.

White

TL-4 2nd floor offices 203

Abundant unspecified spores, Cladosporium, and

Fungal mycelial fragments

Low Aspergillus/Penicillium

Low growth.

White

Note: Lift samples were not submitted for culturable analysis; only a qualitative analysis of relative abundance of mold spores was performed.

4.4 Hazardous Building Components

Tetra Tech searched for other hazardous building components such as fluorescent light fixtures with mercury-containing ltight tubes and light ballasts possibly containing polychlorinated biphenyls (PCBs), mercury-containing thermostats, hazardous and household chemicals, transformers, and emergency exit lighting. The inventory was limited to materials easily observed during the walk-through inspection of the structure. Fluorescent light ballasts observed were marked non-PCB; however, not all ballasts were inspected, and PCB containing ballasts may be present. Appliances containing Freon were observed throughout the interior of the structure. Each appliance planned for removal should be properly evacuated of gases before it is disturbed, removed, or disassembled from the structure.

Break room refrigerators, minor cleaning supplies, maintenance materials, safety equipment, and some stock chemicals used during occupants’ regular course of business were counted; however, it is unlikely that these materials would impede renovation plans or require disposal prior to demolition activities.

Table 4 below provides a summary of the hazardous materials inventoried.

TABLE 4- HAZARDOUS MATERIALS INVENTORIED

MATERIAL TOTAL

Mercury switches 11 each

Fluorescent tubes Approx. 200 each

Fluorescent light ballasts Approx. 565 each

TABLE 4- HAZARDOUS MATERIALS INVENTORIED

MATERIAL TOTAL

Emergency lights/exits (batteries) 15 lights/ 11 batteries

Microwave 5 each

Copy machines, printers, fax machines, scanners 11 each

Televisions, computer monitors 59 each

Refrigeration /air conditioning units 3 each

Refrigerators 8 each

5.0 RECOMMENDATIONS

Recommendations are provided below for asbestos building materials and lead-containing paint coatings.

5.1 Confirmed Asbestos

Sixty-four samples of suspected ACM were collected from the site structure, totaling 98 individual analyzed sample layers. Fourteen samples representing four homogenous materials tested positive or were assumed positive based on a first-stop analysis per sample group. Of those fourteen samples, three contained more than 1 percent asbestos, and eleven samples contained less than 1 percent asbestos (trace asbestos). Asbestos was not detected in the other samples collected. ACM identified during the survey are summarized below.

• Approximately 50 square feet of ACM white window caulk is located around the exterior window metal frames. The caulk contains 10 percent chrysotile asbestos and is represented by samples 46-CK-01, -02, and -03. The caulking must be removed by a licensed asbestos abatement contractor before renovation disturbs the ACM. The removed waste must be transported to a disposal site able to accept Category II non-friable ACM.

5.2 Presumed ACM/ Assumed ACM

During the survey, Tetra Tech observed one fire door in the structure. Typically, it is less costly to assume fire doors contain asbestos and dispose of them, than to open and sample them in an asbestos-regulated enclosure. Tetra Tech recommends that the suspect fire door on site be handled and disposed of as potentially friable ACM if renovation plans will disturb the materials.

5.3 LBP

Of the 53 XRF readings of suspected LBP from painted surfaces and lead-containing materials in

Building 46, sixteen indicated reportable lead concentrations exceeding 1.0 milligrams per square centimeter (mg/cm2):

• Approximately 200 LF of white painted wooden door frames in the lobby of the building tested positive for LBP, with XRF reading of >5.00 mg/cm2.

• Approximately 3,300 sf2 of white ceramic wall tile in the first-floor restroom of the building tested positive for LBP, with XRF reading of >1.00 mg/cm2.

• Approximately 120 sf2 of white painted wall plaster of room 110 in the building tested positive for LBP, with XRF reading of 1.95 mg/cm2.

• Approximately 20 LF of white painted wood door frame in the second-floor hallway of the building tested positive for LBP, with XRF reading of 2.57 mg/cm2.

• Approximately 100 sf2 of white painted wood stairs in the attic of the building tested positive for

LBP, with XRF reading of >1.00 mg/cm2.

• Approximately 100 sf2 of white painted wood stairs in the first-floor lobby of the building tested positive for LBP, with XRF reading of 1.13 mg/cm2.

• Approximately 700 LF of white painted wood window frame in room 201 of the building tested positive for LBP, with XRF reading of 1.66 mg/cm2.

• Approximately 10 LF of gray painted metal support beams in the basement of the building tested positive for LBP, with XRF reading of >5.00 mg/cm2.

• Approximately 50 LF of white painted metal support beams in the basement of the building tested positive for LBP, with XRF reading of 4.70 mg/cm2

• Approximately 10 LF of blue painted metal support beams in the basement of the building tested positive for LBP, with XRF reading of >5.00 mg/cm2

• Approximately 25 LF of black painted wood door frames in basement tested positive for LBP, with XRF reading of 2.99 mg/cm2.

• Approximately 50 sf2 white painted wood door in basement tested positive for LBP, with XRF reading of >5.00 mg/cm2.

• Approximately 30 LF of white painted wood door frames in basement tested positive for LBP, with XRF reading of >5.00 mg/cm2.

• Approximately 100 sf2 of white painted stairs in basement tested positive for LBP, with XRF reading of >1.00 mg/cm2.

• Approximately 80 LF of white painted concrete floor board tested positive for LBP, with XRF reading of 2.95 mg/cm2.

• Approximately 30 LF of white painted wood door frames tested positive for LBP, with XRF reading of >5.00 mg/cm2.

6.0 REGULATORY OVERVIEW

Regulatory oversight of management, removal, and disposal of ACM and LBP is provided by a variety of federal, state, and local agencies. Section 6.1 overviews regulations regarding ACM, and Section 6.2 overviews regulations regarding LBP.

6.1 Regulatory Overview for Asbestos

Regulatory oversight of management, removal, and disposal of ACM is provided by a variety of federal, state, and local agencies.

Regulatory agencies enforce the following three primary regulations pertaining to various activities (inspection, assessment, and abatement) relating to ACM: AHERA, NESHAP, and the

Asbestos Construction Safety Standard (as codified in federal OSHA). EPA regulations regarding identification, handling, management, and abatement of ACM (as specified in AHERA and

NESHAP) are implemented by the Kansas Department of Health and Environment (KSDHE).

Federal OSHA and KSDHE regulate asbestos as a worker health and safety issue. Transportation and disposal of asbestos-containing wastes are overseen by the EPA and KSDHE. The federal

OSHA, EPA, and KSDHE define ACM as materials containing greater than 1 percent asbestos.

The following are brief descriptions of the three major regulations relating to ACM:

Asbestos Hazard Emergency Response Act (AHERA)

AHERA, as implemented by EPA (40 CFR Part 763), primarily pertains to assessment and management of ACM in kindergarten through 12, public, private, and nonprofit schools. However, many of the procedures, training requirements, and certifications specified by AHERA have become the industry standard for all other facilities. During this survey, AHERA protocols were generally used in efforts to identify, assess, and sample building materials suspected to contain asbestos.

National Emission Standard for Hazardous Air Pollutants (NESHAP)

NESHAP (40 CFR Part 61) is an asbestos standard that protects the public from exposure to asbestos that would result from renovation or demolition. NESHAP requires surveying for suspect materials (as defined above), notifying of intent to renovate or demolish, removing regulated ACM

(RACM) before renovation or demolition, and properly managing asbestos containing wastes. A

RACM is defined by NESHAP as follows:

• Any friable ACM

• A Category I non-friable ACM (such as floor tiles and asphalt roofing products) that has become friable or will be subject to sanding, grinding, cutting, or abrading during renovation or demolition

• A Category II non-friable ACM (all other non-friable ACMs) that has a high probability of becoming friable during demolition or renovation.

Note that while NESHAP regulates renovation and demolition, it does not protect individual workers conducting asbestos abatement or provide instructions for how asbestos abatement projects should proceed.

Asbestos Standard for the Construction Industry

The Asbestos Standard for the Construction Industry (federal OSHA, 29 CFR 1926.1101) and

Kansas, regulates asbestos exposure in the work place. This standard includes both persons working in a building containing ACMs and asbestos abatement workers and contractors. The

Asbestos Standard for Construction (Construction Standard) and Chapter 33 regulates the following for abatement workers and contractors:

• Protection of workers and the public during the removal

• Medical surveillance requirements for workers

• Detailed requirements for how asbestos is to be removed

• Training requirements for abatement personnel.

6.2 Regulatory Overview for Lead-Based Paint

EPA, the Department of Housing and Urban Development (HUD), define LBPs as paints containing greater than 0.5 percent lead by weight or 5,000 ppm or 1 milligram per square centimeter (mg/cm2) total lead. Federal OSHA (Lead Construction Standard) and TDHS regulations define “lead-based paint,” and refer to the EPA and HUD numbers cited above.

The federal OSHA Lead Construction Standard specifies a Permissible Exposure Limit (PEL) for worker exposure to airborne lead particles of 50 mg/cm3 of air for an 8-hour, time-weighted average. The federal OSHA Lead Construction Standard also lists an action level of 30 mg/cm3 for an 8-hour, time-weighted average. Therefore, demolition activities that include materials with lead at any concentration could, under certain circumstances, trigger federal OSHA regulations.

7.0 ABATEMENT COST ESTIMATES

Estimated costs asbestos abatement are summarized in Table 5.

TABLE 5

ACM ABATEMENT COST ESTIMATES

Material Location Unit Rate Quantity1 Abatement

Cost Estimate

Caulk Exterior metal window frames $2.00 to $5.00/ft2 50 ft2 $100 to $250

Fire door (assumed) Boiler room $50 each 1 count $50

Notes 1 Estimated quantity requires field verification ft2 Square foot

ACM Asbestos-containing material

Estimated costs for stabilization of LBP are summarized in Table 6.

TABLE 6

LEAD-BASED PAINT STABILIZATION COST ESTIMATE

Material Location Unit Rate Quantity 1

Stabilization

Cost Estimate

Paint, white on wood door frame Exterior $12.00/ft2 200 LF $800

Paint, white on ceramic wall tile 1st floor restroom $12.00/ft2 3,300 ft2 $39,600

Paint, white on plaster wall Room 110 $12.00/ft2 120 ft2 $1,400

Paint, white on wood door frame 2nd floor hallway $12.00/ft2 20 LF $240

Paint, white on wood stairs Attic $12.00/ft2 100 ft2 $1,200

Paint, white on wood stairs 1st floor lobby $12.00/ft2 100 ft2 $1,200

Paint, white wood window frame Room 201 $12.00/ft2 700 ft2 $8,400

Paint, gray on metal support beam Basement $12.00/ft2 10 LF $40

Paint, white on metal support beam Basement $12.00/ft2 50 LF $200

Paint, blue on metal support beam Basement $12.00/ft2 10 LF $40

Paint, blue on wood door frame Basement $12.00/ft2 25 LF $85

Paint, white on wood door Basement $12.00/ft2 50 ft2 $600

Paint, white on wood door frame Basement $12.00/ft2 30 LF $120

Paint, white on wood stairs Basement $12.00/ft2 100 ft2 $1,200

Paint, white on concrete floor board Conference room $12.00/ft2 80 LF $320

Paint, white on wood door frame Conference room $12.00/ft2 30 LF $120

Notes:

1 Estimated quantity requires field verification ft2 Square feet

LF Linear feet

8.0 LIMITATIONS

Only minor demolition of materials (destructive sampling) was employed during the renovation survey, which limited the inspection for suspect materials. Thus, additional suspect materials could be present in walls, voids, attics, equipment chases, subsurface utilities, and in other concealed areas.

If any suspected ACM/LBP are identified during the renovation processes that are not listed in the

ACM summary table (Table 1) or represented on the LBP summary table (Table 2), the owner or contractor should employ Kansas accredited asbestos/lead-paint building inspector to obtain representative analytical results, or as an alternative, should handle and dispose of these materials as assumed ACM/LBP and follow all OSHA requirements for protecting workers and building occupants.

Site Figures

57 58

42 43

49 50

36 37

ASBESTOS SAMPLE LOCATION#

LEAD-BASED PAINT SAMPLE LOCATION#

C

C A

D D

\I \G

\F t- Le a ve n w o rt h _w o rk in g

_A C

M _m a p

.d w g

/6

/2

:2

:0

P

M , d a le

.v o n b u sc h

17 64 65

69 74 16

2?

53 51 52 24

67 73

71 72

14 11 13

606361

101712 20

ASBESTOS SAMPLE LOCATION#

C

C A

D D

\I \G

\F t- Le a ve n w o rt h _w o rk in g

_A C

M _m a p

.d w g

/6

/2

:5

:0

P

M , d a le

.v o n b u

31 32

1 46

45 23 26

47 92

ASBESTOS SAMPLE LOCATION#

C

C A

D D

\I \G

\F t- Le a ve n w o rt h _w o rk in g

_A C

M _m a p

.d w g

/6

/2

:5

:1

P

M , d a le

.v o n b u

Appendix A

Survey Team Certificates

Appendix B

Laboratory Reports and Chain-of-Custody Forms for ACM Samples

EMSL Analytical, Inc.

464 McCormick Street San Leandro, CA 94577

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

Project ID:

Attention: Phone:Jeffrey Mitchell (816) 412-1773

Fax:TETRA TECH

Received Date:415 Oak St 11/12/2018 9:00 AM

Analysis Date:Kansas City, MO 64106 11/16/2018 - 12/03/2018

Collected Date: 11/07/2018

Project: 10376091

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

46-CBM-1-Cove Base

091824632-0001

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

15%

70%

15%

Brown/Red

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-1-Mastic

091824632-0001A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

20%

70%

10%

White

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-1-Compound

091824632-0001B

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

White

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-2-Cove Base

091824632-0002

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

15%

70%

15%

Brown/Red

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-2-Mastic

091824632-0002A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

20%

70%

10%

White

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-2-Compound

091824632-0002B

None DetectedCa Carbonate

Perlite

Non-fibrous (Other)

70%

10%

20%

White

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-3-Cove Base

091824632-0003

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

15%

70%

15%

Brown/Red

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-CBM-3-Mastic

091824632-0003A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

15%

70%

15%

White

Non-Fibrous

Homogeneous

RED 4" COVE BASE

MASTIC

46-IN-1

091824632-0004

None DetectedGlass100%White

Fibrous

Homogeneous

INSULATION ATTIC

46-IN-2

091824632-0005

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

Fibrous

Homogeneous

INSULATION ATTIC

46-IN-3

091824632-0006

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

Fibrous

Homogeneous

INSULATION ATTIC

46-DWJC-1-Drywall

091824632-0007

None DetectedGypsum

Non-fibrous (Other)

90%

10%

White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-1-Joint

Compound

091824632-0007A

2% ChrysotileQuartz

Ca Carbonate

Non-fibrous (Other)

2%

80%

16%

White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-1-Composite

091824632-0007B

<1% ChrysotileCa Carbonate

Gypsum

Non-fibrous (Other)

40%

40%

20%

Gray/White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-2-Drywall

091824632-0008

None DetectedGypsum

Non-fibrous (Other)

80%

16%

Cellulose4%White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

Report amended: 12/03/2018 13:05:12 Replaces initial report from: 11/16/2018 19:13:19 Reason Code: Client-Additional Analysis

Page 1 of 8ASB_PLM_0008_0001 - 1.78 Printed: 12/3/2018 1:05 PM

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

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

46-DWJC-2-Joint

Compound

091824632-0008A

Positive Stop (Not Analyzed)DRYWALL W/JOINT

COMPOUND

46-DWJC-2-Composite

091824632-0008B

<1% ChrysotileCa Carbonate

Gypsum

Non-fibrous (Other)

40%

40%

20%

Gray/White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-3-Drywall

091824632-0009

None DetectedGypsum

Non-fibrous (Other)

80%

17%

Cellulose3%White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-3-Joint

Compound

091824632-0009A

Positive Stop (Not Analyzed)DRYWALL W/JOINT

COMPOUND

46-DWJC-3-Composite

091824632-0009B

<1% ChrysotileCa Carbonate

Gypsum

Non-fibrous (Other)

40%

40%

20%

Gray/White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-4-Drywall

091824632-0010

None DetectedGypsum

Non-fibrous (Other)

90%

10%

White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-4-Joint

Compound

091824632-0010A

Positive Stop (Not Analyzed)DRYWALL W/JOINT

COMPOUND

46-DWJC-4-Composite

091824632-0010B

<1% ChrysotileCa Carbonate

Gypsum

Non-fibrous (Other)

40%

40%

20%

Gray/White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-5-Drywall

091824632-0011

None DetectedGypsum

Non-fibrous (Other)

90%

10%

White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-DWJC-5-Joint

Compound

091824632-0011A

Positive Stop (Not Analyzed)DRYWALL W/JOINT

COMPOUND

46-DWJC-5-Composite

091824632-0011B

<1% ChrysotileCa Carbonate

Gypsum

Non-fibrous (Other)

40%

40%

20%

Gray/White

Non-Fibrous

Homogeneous

DRYWALL W/JOINT

COMPOUND

46-CM-1-Carpet

091824632-0012

None DetectedNon-fibrous (Other)10%Synthetic90%Brown

Non-Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-1-Mastic

091824632-0012A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

25%

60%

15%

White

Non-Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-1-Mastic 2

091824632-0012B

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Yellow

Non-Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-2-Carpet

091824632-0013

None DetectedSynthetic100%Brown

Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-2-Mastic

091824632-0013A

None DetectedMatrix

Non-fibrous (Other)

40%

10%

Synthetic50%White

Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-2-Mastic 2

091824632-0013B

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

5%

80%

15%

Tan/Orange

Non-Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-3-Carpet

091824632-0014

None DetectedSynthetic100%Brown

Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

Report amended: 12/03/2018 13:05:12 Replaces initial report from: 11/16/2018 19:13:19 Reason Code: Client-Additional Analysis

Page 2 of 8ASB_PLM_0008_0001 - 1.78 Printed: 12/3/2018 1:05 PM

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

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

46-CM-3-Mastic

091824632-0014A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

10%

40%

10%

Synthetic40%White

Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-CM-3-Mastic 2

091824632-0014B

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

5%

80%

15%

Tan/Orange

Non-Fibrous

Homogeneous

CARPET MASTIC

FIRST FLOOR

46-FT-1-Floor Tile

091824632-0015

None DetectedCa Carbonate

Non-fibrous (Other)

50%

50%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-1-Mastic

091824632-0015A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Yellow

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-1-Leveler

091824632-0015B

None DetectedCa Carbonate

Non-fibrous (Other)

35%

65%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-2-Floor Tile

091824632-0016

None DetectedCa Carbonate

Non-fibrous (Other)

40%

60%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-2-Mastic

091824632-0016A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

10%

70%

20%

Yellow

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-2-Leveler

091824632-0016B

None DetectedCa Carbonate

Non-fibrous (Other)

30%

70%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-3-Floor Tile

091824632-0017

None DetectedCa Carbonate

Non-fibrous (Other)

40%

60%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-3-Mastic

091824632-0017A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

5%

80%

15%

Yellow

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-FT-3-Leveler

091824632-0017B

None DetectedCa Carbonate

Non-fibrous (Other)

30%

70%

Gray

Non-Fibrous

Homogeneous

12X12 GRAY FLOOR

TILE

46-CT-1

091824632-0018

None DetectedPerlite

Non-fibrous (Other)

20%

20%

Cellulose60%White

Fibrous

Homogeneous

2X4 WHITE

FISSURE + PINHOLE

CEILING TILE

46-CT-2

091824632-0019

None DetectedPerlite

Non-fibrous (Other)

20%

20%

Cellulose60%White

Fibrous

Homogeneous

2X4 WHITE

FISSURE + PINHOLE

CEILING TILE

46-CT-3

091824632-0020

None DetectedPerlite

Non-fibrous (Other)

20%

20%

Cellulose60%White

Fibrous

Homogeneous

2X4 WHITE

FISSURE + PINHOLE

CEILING TILE

46-CRTM-1-Ceramic

Tile

091824632-0021

None DetectedQuartz

Non-fibrous (Other)

20%

80%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

46-CRTM-1-Mastic

091824632-0021A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

25%

60%

15%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

46-CRTM-2-Ceramic

Tile

091824632-0022

None DetectedQuartz

Non-fibrous (Other)

20%

80%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

46-CRTM-2-Mastic

091824632-0022A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

25%

60%

15%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

Report amended: 12/03/2018 13:05:12 Replaces initial report from: 11/16/2018 19:13:19 Reason Code: Client-Additional Analysis

Page 3 of 8ASB_PLM_0008_0001 - 1.78 Printed: 12/3/2018 1:05 PM

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

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

46-CRTM-3-Ceramic

Tile

091824632-0023

None DetectedQuartz

Non-fibrous (Other)

20%

80%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

46-CRTM-3-Mastic

091824632-0023A

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

25%

60%

15%

White

Non-Fibrous

Homogeneous

CERAMIC TILE

WALL MASTIC,

WHITE

46-CTG-1

091824632-0024

None DetectedCa Carbonate

Non-fibrous (Other)

65%

35%

Beige

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT TAN WALL

46-CTG-2

091824632-0025

None DetectedCa Carbonate

Non-fibrous (Other)

65%

35%

Beige

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT TAN WALL

46-CTG-3

091824632-0026

None DetectedCa Carbonate

Non-fibrous (Other)

65%

35%

Beige

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT TAN WALL

46-CTG2-1

091824632-0027

None DetectedQuartz

Ca Carbonate

Gypsum

Non-fibrous (Other)

35%

20%

20%

25%

Gray

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT GRAY

46-CTG2-2

091824632-0028

None DetectedQuartz

Ca Carbonate

Gypsum

Non-fibrous (Other)

35%

15%

20%

30%

Gray

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT GRAY

46-CTG2-3

091824632-0029

None DetectedQuartz

Ca Carbonate

Gypsum

Non-fibrous (Other)

35%

15%

20%

30%

Gray

Non-Fibrous

Homogeneous

CERAMIC TILE

GROUT GRAY

46-FB-1

091824632-0030

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

10%

70%

20%

Brown

Non-Fibrous

Homogeneous

FLOOR BACKING

46-FB-2

091824632-0031

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

10%

70%

20%

Brown

Non-Fibrous

Homogeneous

FLOOR BACKING

46-FB-3

091824632-0032

None DetectedQuartz

Ca Carbonate

Non-fibrous (Other)

10%

70%

20%

Brown

Non-Fibrous

Homogeneous

FLOOR BACKING

46-STM-1-Cove Base

091824632-0033

None DetectedMatrix100%Gray

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-STM-1-Mastic

091824632-0033A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/White

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-STM-2-Cove Base

091824632-0034

None DetectedMatrix100%Gray

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-STM-2-Mastic

091824632-0034A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/White

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-STM-3-Cove Base

091824632-0035

None DetectedMatrix100%Gray

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-STM-3-Mastic

091824632-0035A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/White

Non-Fibrous

Homogeneous

STAIR TRED

MASTIC

46-SC-1

091824632-0036

None DetectedCa Carbonate

Non-fibrous (Other)

95%

5%

Tan

Non-Fibrous

Homogeneous

SKIM COAT,

BASEMENT WALLS

Report amended: 12/03/2018 13:05:12 Replaces initial report from: 11/16/2018 19:13:19 Reason Code: Client-Additional Analysis

Page 4 of 8ASB_PLM_0008_0001 - 1.78 Printed: 12/3/2018 1:05 PM

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

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

46-SC-2

091824632-0037

None DetectedCa Carbonate

Non-fibrous (Other)

95%

5%

Tan

Non-Fibrous

Homogeneous

SKIM COAT,

BASEMENT WALLS

46-SC-3

091824632-0038

None DetectedCa Carbonate

Non-fibrous (Other)

95%

5%

Tan

Non-Fibrous

Homogeneous

SKIM COAT,

BASEMENT WALLS

46-FT2-1-Floor Tile

091824632-0039

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Tan/White

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT2-1-Mastic

091824632-0039A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Yellow

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT2-2-Floor Tile

091824632-0040

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Tan/White

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT2-2-Mastic

091824632-0040A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Yellow

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT2-3-Floor Tile

091824632-0041

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Tan/White

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT2-3-Mastic

091824632-0041A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Yellow

Non-Fibrous

Homogeneous

12X12 WHITE

FLOOR TILE

46-FT3-1-Floor Tile

091824632-0042

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-FT3-1-Mastic

091824632-0042A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-FT3-2-Floor Tile

091824632-0043

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Tan/Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-FT3-2-Mastic

091824632-0043A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-FT3-3-Floor Tile

091824632-0044

None DetectedCa Carbonate

Non-fibrous (Other)

80%

20%

Tan/Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-FT3-3-Mastic

091824632-0044A

None DetectedMatrix

Non-fibrous (Other)

90%

10%

Tan/Beige

Non-Fibrous

Homogeneous

12X12 TAN FLOOR

TILE

46-CM2-1-Carpet

091824632-0045

None DetectedNon-fibrous (Other)2%Synthetic98%Brown/Red

Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

46-CM2-1-Mastic

091824632-0045A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Yellow

Non-Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

46-CM2-2-Carpet

091824632-0046

None DetectedNon-fibrous (Other)2%Synthetic98%Brown/Red

Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

46-CM2-2-Mastic

091824632-0046A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Yellow

Non-Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

46-CM2-3-Carpet

091824632-0047

None DetectedNon-fibrous (Other)2%Synthetic98%Brown/Red

Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

Report amended: 12/03/2018 13:05:12 Replaces initial report from: 11/16/2018 19:13:19 Reason Code: Client-Additional Analysis

Page 5 of 8ASB_PLM_0008_0001 - 1.78 Printed: 12/3/2018 1:05 PM

Tel/Fax: (510) 895-3675 / (510) 895-3680 http://www.EMSL.com / sanleandrolab@emsl.com

091824632EMSL Order:

Customer ID: MAX80

Customer PO: 10376091

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

46-CM2-3-Mastic

091824632-0047A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Yellow

Non-Fibrous

Homogeneous

CARPET MASTIC,

2ND FLOOR

46-CBM2-1-Cove Base

091824632-0048

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

10%

80%

10%

Brown

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CBM2-1-Mastic

091824632-0048A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CBM2-2-Cove Base

091824632-0049

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

10%

80%

10%

Brown

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CBM2-2-Mastic

091824632-0049A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CBM2-3-Cove Base

091824632-0050

None DetectedCa Carbonate

Matrix

Non-fibrous (Other)

10%

80%

10%

Brown

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CBM2-3-Mastic

091824632-0050A

None DetectedMatrix

Non-fibrous (Other)

80%

20%

Tan

Non-Fibrous

Homogeneous

8" BROWN COVE

BASE MASTIC

46-CT2-1

091824632-0051

None DetectedGypsum

Non-fibrous (Other)

80%

11%

Cellulose

Glas…