Asbestos Lead-Containing Paint Report - NYARNG Roofs RochesterSyracuse.pdf

Asbestos Survey & Lead Paint

Testing Report

New York Air National Guard Roofs

Combined Support Maintenance Shop “C”

Rochester, Monroe County, New York

Syracuse Armory

East Syracuse, Onondaga County, New York

December 9, 2019

Terracon Project No. J5197049

Prepared for:

Pond & Company

Peachtree Corners, Georgia

Prepared by:

Terracon Consultants-NY, Inc.

Rochester, New York

Terracon Consultants -NY, Inc. 15 Marway Circle Rochester , New York 14624

P [585] 247 3471 terracon.com

December 9, 2019

Pond & Company 3500 Parkway Lane, Suite 600 Norcross, GA 30092-2861

Attn: Mr. Matt Allinson

Senior Project Manager

P: (678) 336-7740

E: AllinsonM@ponco.com

Re: Asbestos Survey and Lead Paint Testing Report

Combined Support Maintenance Shop “C”

Roof Areas “B”

1500 East Rochester Road

Rochester, NY 14623

Syracuse Armory

Roof Areas “A” & “A1”

6900 Thompson Road

Syracuse, NY 13211

Dear Mr. Allinson:

Terracon Consultants-NY, Inc. (Terracon) is pleased to submit the attached report for the two (2) above-referenced project sites to Pond & Company (Pond). The purpose of this report is to present the results of an asbestos survey and lead paint testing which was performed on November 19 and

November 20, 2019 regarding specific roof sections/areas and select rooftop mounted mechanical systems to be replaced. The scope of services was conducted in accordance with

Terracon’s proposal dated October 21, 2019.

Asbestos and lead paint was detected in collected samples. Please refer to the report for details.

We trust this report meets your needs at this time. If you have any questions regarding this report, please feel free to contact us.

Sincerely, Terracon Consultants, Inc.

Tony Hill Joe Tussey, CHMM

Project Manager Authorized Project Reviewer

TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................... i

INTRODUCTION

1.1 Project Objective

Project DESCRIPTION

FIELD ACTIVITIES

3.1 Asbestos Survey

3.2 Visual Assessment

Physical Assessment Sample Collection Sample Analysis

3.3 Limited Lead-containing Paint Testing

REGULATORY OVERVIEW

4.1 Asbestos

4.2 Lead-Containing Paint (LCP)

FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Survey Results

5.2 Limited Lead Paint Testing

LIMITATIONS/GENERAL COMMENTS

LIST OF APPENDICES

APPENDIX A IDENTIFIED ASBESTOS-CONTAINING MATERIALS BY HOMOGENEOUS AREA (HA)

APPENDIX B ASBESTOS SURVEY SAMPLE SUMMARY

APPENDIX C ANALYTICAL LABORATORY DATA

APPENDIX D LICENSES AND CERTIFICATIONS

Asbestos Survey & Lead Paint Testing

NYANG Roofs ■ Rochester & Syracuse, New York

December 9, 2019 ■ Terracon Project No. J5197059

Responsive ■ Resourceful ■ Reliable i

EXECUTIVE SUMMARY

Terracon Consultants-NY, Inc. (Terracon) conducted an asbestos survey and lead paint testing regarding specific roof sections/areas at the New York Air National Guard’s Combined Support

Maintenance Shop “C” (CSMS-C) (roof area “B”) located in Rochester, New York and the

Syracuse Armory (roof sections “A” and “A1”) located in Rochester, New York. The subject roof areas/sections and select rooftop mounted mechanical systems of these buildings are scheduled for replacement. The purposes of our services was to identify asbestos-containing materials

(ACM) and lead-containing paint (LCP), if any, prior to the commencement of the renovation project.

The site visit was conducted on November 19 and November 20, 2019 by Terracon representative

Mr. Tony Hill, a New York state certified asbestos building inspector (Inspector Certification No.

06-02018), in accordance with the sampling protocols established in Environmental Protection

Agency (EPA) 40 Code of Federal Regulations (CFR) Part 763-Asbestos Subpart E-Asbestos-

Containing Materials in Schools, known as the Asbestos Hazard Emergency Response Act

(AHERA). Terracon collected nine bulk samples from three homogeneous areas of suspect ACM from the CSMS-C roof (area “B”) and six bulk samples from two homogeneous areas of suspect

ACM from the Syracuse Armory roof sections (sections “A” and “A1”). With respect to the scope of the survey, laboratory analysis did not identify the presence of >1% asbestos (the EPA threshold) in the samples collected from the subject buildings. However, laboratory analysis identified <1% asbestos in black built-up roofing material samples collected from CSMC-C roof area “B” (bottom roof layer, approximately 19,000 square feet of material). Materials containing <1% asbestos are not regulated by the EPA but are regulated under OSHA (29 CFR 1926.1101 – Asbestos in

Construction) due to the potential for worker exposure when disturbed.

While on site for the asbestos survey, Mr. Hill collected two paint chips from the CSMS-C roof mechanical components and two paint chips from the Syracuse Armory roof mechanical components. Lead was detected above the laboratory analytical method’s detection limit in each of the four samples. The disturbance of LCP is regulated under OSHA (29 CFR 1926.62 – Lead in

Construction) due to the potential for worker exposure.

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ASBESTOS SURVEY & LEAD PAINT TESTING

NEW YORK AIR NATIONAL GUARD ROOFS

COMBINED SUPPORT MAINTENANCE SHOP “C” - ROOF AREA “B”,

ROCHESTER, NY

SYRACUSE ARMORY - ROOF AREAS “A” AND “A1”, SYRACUSE, NY

TERRACON PROJECT NO. J5197049

INTRODUCTION

Terracon Consultants-NY, Inc. (Terracon) conducted an asbestos survey and lead paint testing regarding specific roof sections/areas at the New York Air National Guard’s Combined Support

Maintenance Shop “C” (CSMS-C) (roof area “B”) located in Rochester, New York and the

Syracuse Armory (roof sections “A” and “A1”) located in Rochester, New York. The subject roof sections/areas and select rooftop mounted mechanical systems of these buildings are scheduled for replacement. The purposes of our services was to identify asbestos-containing materials

(ACM) and lead-containing paint (LCP), if any, prior to the commencement of the renovation project.

The site visit was conducted on November 19 and November 20, 2019 by Terracon representative

Mr. Tony Hill, who is a state of New York certified asbestos building inspector. With respect to the specific roof sections/areas, homogeneous areas of suspect asbestos-containing materials

(ACM) were visually identified and documented. Suspect ACM samples were collected in accordance with the sampling protocols outlined in Environmental Protection Agency (EPA) 40

Code of Federal Regulations (CFR) Part 763-Asbestos Subpart E-Asbestos-Containing Materials in Schools, known as the Asbestos Hazard Emergency Response Act (AHERA). Samples were delivered to an accredited laboratory for analysis by polarized light microscopy (PLM), PLM-non-friable organically bound (PLM-NOB), and transmission electron microscopy (TEM)-NOB (as required by New York State regulations). While conducted the asbestos survey of the specific roof sections/areas, Mr. Hill also collected paint samples from select rooftop mounted mechanical systems for the purpose of determined lead-content by laboratory analysis.

1.1 Project Objective

We understand the asbestos survey and lead paint testing was requested prior to the planned roof replacement projects of the above-referenced site structures.

EPA regulation 40 CFR 61, Subpart M, National Emission Standards for Hazardous Air Pollutants

(NESHAP), prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires that potentially regulated ACM be identified, classified and quantified prior to planned disturbances or demolition activities.

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The Occupational Safety and Health Administration (OSHA) Lead Standard for Construction (29

CFR 1926.62) regulates lead exposure to workers where an employee may be occupationally exposed to lead. All work related to construction, alteration, or repair (including painting and decorating) is included. The lead-in-construction standard applies to any detectable concentration of lead in paint, as even small concentrations of lead can result in unacceptable employee exposures depending upon on the method of removal and other workplace conditions.

PROJECT DESCRIPTION

We understand that roof sections/areas associated with the two (2) subject facilities are scheduled to be replaced due to age, delamination and to increase energy efficiency. Associated rooftop mechanical systems will also be removed and/or replaced during the roof replacement project.

The CSMS-C roof area “B” located in Rochester, NY is approximately 19,000 square feet (SF) and the Syracuse Armory roof sections “A” and “A1” are approximately 34,000 SF and 7,900 SF, respectively.

FIELD ACTIVITIES

3.1 Asbestos Survey

We understand the asbestos survey was requested due to the planned roof replacements of specific sections/areas of the existing buildings to satisfy requirements of the USEPA 40 CFR

Part 61, Subpart M, the NESHAP regulation. The purpose of the survey was to sample suspect

ACM for laboratory analysis, and provide information regarding the identity, location, condition and approximate quantities of ACM, if any, in roofing components.

The asbestos survey was performed on November 19 and November 20, 2019 by Mr. Tony Hill, USEPA AHERA-accredited and state of New York certified asbestos inspector (Inspector

Certification Nos. 06-02018). A copy of Mr. Hill’s asbestos inspector certifications is attached as

Appendix D. The survey was conducted in general accordance with the sample collection protocols established in USEPA 40 CFR Part 763 Subpart E 763.86, AHERA. A summary of survey activities is provided below.

3.2 Visual Assessment

Survey activities were initiated with visual observation of the accessible specified roof areas/sections of to identify homogeneous areas of suspect ACM. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color and texture with consideration given to the date of application. Roof materials identified as concrete, glass, wood, metal or rubber were not considered suspect ACM.

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Terracon inspected the varying layers of each subject roof sections/areas to the identify roof composition down to the decking at each building. Suspect ACM was not observed below the rubber roof membrane of the Syracuse Armory roof areas “A” and “A1”.

Physical Assessment

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

Sample Collection

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

The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content.

Terracon collected nine bulk samples from three homogeneous areas of suspect ACM from the

CSMS-C roof area “B” and six bulk samples from two homogeneous areas of suspect ACM from the Syracuse Armory roof Sections “A” and “A1”. A summary of suspect ACM samples collected during the survey is included as Appendix B.

Sample Analysis

Bulk samples were submitted under chain of custody to EMSL Analytical, Inc. (EMSL) of

Rochester, New York, a New York State Department of Health (NYSDOH) Environmental

Laboratory Accreditation Program (ELAP) accredited laboratory, accreditation number 12088.

EMSL is also accredited under the National Voluntary Laboratory Accreditation Program

(NVLAP), accreditation number 600183-0.

As per NYSDOH-ELAP, friable materials were analyzed by PLM Method 198.1, nonfriable organically bound (NOB) materials (e.g., floor tiles and caulking) were analyzed using PLM-NOB

Method 198.6, and inconclusive NOBs were additionally analyzed using transmission electron microscopy (TEM) Method 198.4 for a conclusive result. The laboratory analytical data reports are included as Appendix C.

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3.3 Limited Lead-containing Paint Testing

While conducting the asbestos survey, Terracon collected limited paint chip samples for laboratory analysis to determine lead-content from select painted roof top mounted mechanical components.

The paint chip samples were submitted for lead-content analysis by flame atomic absorption spectrophotometry (Flame AAS; EPA Method SW 846 3050B/7000B) to EMSL of Carle Place, New

York, a laboratory participating in the Environmental Lead Laboratory Accreditation Program

(ELLAP), accreditation number 102344. Terracon collected two paint chips from the CSMS-C roof mechanical components and two paint chips from the Syracuse Armory roof mechanical components.

REGULATORY OVERVIEW

4.1 Asbestos

The federal asbestos National Emission Standards for Hazard Air Pollutants (NESHAP; 40 CFR

Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices.

NESHAP requires an asbestos survey of structures prior to renovation and demolition projects and has specific requirements for the removal of certain categories of ACM prior to renovation and demolition projects. Friable ACM is a material containing more than 1% asbestos that, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. All friable ACM is considered regulated asbestos-containing material (RACM).

The NESHAP regulation classifies ACM as either RACM, Category I non-friable ACM or Category

II non-friable ACM. RACM includes all friable ACM, along with Category I and Category II non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading, or ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I non-friable

ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category

II non-friable ACM are all other non-friable materials other than Category I non-friable ACM that contain more than 1% asbestos.

In the State of New York, asbestos abatement activities are regulated by the New York State

Department of Labor (NYSDOL) under the Part 56 of Title 12 of the Official Compilation of Codes, Rules and Regulations of the State of New York (12 NYCRR Part 56). New York regulations require that any asbestos-related activity conducted in the state be performed by personnel licensed by

NYSDOL. NYSDOL 12 NYCRR has instituted nine different certifications for asbestos related activities that include: Handler; Allied Trades; Air Sampling Technician; Inspector; Operations and

Maintenance; Supervisor; Project Designer; Project Monitor; and Management Planner. The owner or operator must provide the NYSDOL with written notification of planned asbestos removal

Responsive ■ Resourceful ■ Reliable 5 activities at least 10 working days prior to the commencement of a large project (greater than or equal to 160 square feet or 260 linear feet). Removal of ACM must be conducted by a State of New

York certified asbestos abatement contractor.

NYSDOL enforces the federal Occupational Safety and Health Administration (OSHA) standards at 29 CFR 1910.1001 and 29 CFR 1926.1101, which regulates employee exposure to asbestos.

The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained at or below 0.1 fibers per cubic centimeter of air (0.1 f/cc) as an eight hour time weighted average

(TWA) and not exceed 1.0 fibers per cubic centimeter of air (1.0 f/cc) over a 30 minute time period known as an excursion limit (EL). The TWA and EL are known as OSHA’s permissible exposure limits (PELs). The OSHA standard classifies construction and maintenance activities which could disturb ACM, and specifies work practices and precautions which employers must follow when engaging in each class of regulated work.

4.2 Lead-Containing Paint (LCP)

Lead is regulated by the USEPA, New York State Department of Health (NYSDOH), and OSHA.

The EPA and NYSDOH regulate lead use, removal, and disposal, and OSHA regulates lead exposure to workers. The USEPA defines Lead-Based Paint (LBP) as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 mg/cm2, 5,000 mg/Kg, or

0.5% by dry weight as determined by laboratory analysis. For the purpose of the OSHA lead standard, lead includes metallic lead, all inorganic lead compounds, and organic lead soaps.

Lead containing paint (LCP), is paint with any detectable levels of lead (levels above the analytical method’s limit of detection). A synopsis of the OSHA regulations (29 CFR 1926.62) and the applicability are as follows:

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

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

Removal or encapsulation of materials containing lead

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

Installation of products containing lead

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Lead contamination/emergency clean-up

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

Maintenance operations associated with construction activities described above

FINDINGS AND RECOMMENDATIONS

5.1 Asbestos Survey Results

Based on laboratory analytic results, and with respect to the scope of the survey, asbestos >1%

(the EPA threshold) was not identified in the samples collected from each of the specific roof sections/areas pertaining to the two sites. However, the material listed in the table below was identified by laboratory analysis to contain <1% asbestos. Materials containing 1% or less asbestos are not regulated by EPA (under NESHAP). However, materials containing <1% asbestos are regulated under OSHA given the potential for exposure when disturbed. Contractors who disturb the material containing <1% asbestos would need to comply with the OSHA asbestos provisions found in 29 CFR 1926.1101.

MATERIALS CONTAINING 1% OR LESS ASBESTOS

CSMS-C Roof Area “B”

Material Description Material Location Estimated Quantity

Black Built-up Roofing Area “B” Roof – Bottom Layer ~19,000 Square Feet (SF)

A summary of samples collected during this survey is included in Appendix B, and the laboratory analytical report is included in Appendix C.

It should be noted that suspect materials, other than those identified during the survey may exist.

Should suspect materials other than those which were identified during the survey be uncovered prior to or during the roof replacement project, those materials must be assumed as asbestos-containing (>1%) until sampled by an accredited inspector and laboratory analysis can refute the positive assumption.

5.2 Limited Lead Paint Testing

A total of four paint chip samples were collected during this limited sampling event; each of the four samples was identified by laboratory analysis to contain detectable concentrations of lead. A summary of the paint chip samples collected and the analytical results is presented in the table below. Data highlighted in bold indicates LCP. A copy of the laboratory report is attached in

Appendix C.

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Table 5.2.1 - Summary of Paint Chip Lead Analysis – CSMS-C Roof Area “B”

Sample ID Color Substrate Component Location Analytical Result

(% lead by wt.)

PNT-001 Grey Metal

Exhaust

Fan

Housing

Area “B” Roof –

South Side

Center

0.014 %

PNT-002 Green/Brown Metal

Curved

Exhaust

Duct

Area “B” Roof –

South Side East

End

4.7 %

Table 5.2.2 - Summary of Paint Chip Lead Analysis – Syracuse Armory Roof Sections “A” & “A1”

Sample ID Color Substrate Component Location Analytical Result

(% lead by wt.)

PNT-001 Grey Metal Large A/C

Housing

Area “A” Roof –

Southwest

0.11 %

PNT-002 Brown/Grey Metal

Tall Round

Exhaust

Housing

Area “A” Roof –

Northwest

Corner

0.044 %

As summarized above, lead was detected above the laboratory detection limit in all four of the samples collected and analyzed. OSHA construction rules do not specify any "safe" or acceptable levels of lead within paints or other surface coatings for the purposes of occupational exposures.

Construction work LCP must be completed in accordance with OSHA regulations, not limited to the lead standard, 29 CFR 1926.62. Contractors completing work in areas found to contain lead, or where it is reasonable to assume lead may be present, should be notified of the presence (and potential presence) of lead and proper work protocols should be used.

The LCP sampling was limited to visible and accessible surfaces described herein, and the scope of work outlined in our proposal. It should be understood that this limited LCP sampling is not considered to be comprehensive in nature, and the results are not intended to be used to determine lead hazards, develop abatement plans, or prepare detailed cost estimates for abatement. Any untested paints should be assumed as lead-containing.

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LIMITATIONS/GENERAL COMMENTS

The asbestos survey and lead paint testing was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed at the time of our site visit. The information contained in this report is relevant to the date on which our services were performed and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by Pond for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding quantities and any further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories, or other third-parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

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APPENDIX A

New York Air National Guard Roofs

MATERIALS CONTAINING 1% OR LESS ASBESTOS BY HA

CSMS-C Roof Area “A”

HA No. Material Description Material Location % and Type

Asbestos Condition

Estimated

Quantity

1 Black Built-up Roofing Area “B” Roof – Bottom Layer

<1% Chrysotile - confirmed by transmission electron microscopy

(TEM)

Good ~19,000 Square

Feet (SF)

Asbestos was not identified in the samples collected and analyzed with respect to the Syracuse Armory Roof Areas “A” & “A1”.

Materials containing less than 1% asbestos are not regulated by EPA NESHAP; however, the OSHA personal exposure limits (0.1 f/cc of air as an eight hour time weighted average or 1.0 f/cc of air over 30 minutes) for asbestos apply when materials containing 1% asbestos or less are disturbed during renovations or demolitions.

A listing of materials that contain 1% asbestos or less is provided above to enable the renovation/demolition contractor to make appropriate decisions concerning compliance issues with applicable OSHA regulations.

December 9, 2019 ■ Terracon Project No. J5197049

APPENDIX B

ASBESTOS SURVEY SAMPLE SUMMARY

CSMS-C Roof Area “B”

HA No. Sample Number Material Description Sample Location Lab Results

1A Black Built Up Roofing Area B Roof Field Northwest Bottom

Layer <1% Chrysotile (by TEM)

1B Black Built Up Roofing Area B Roof Field South Center Bottom

Layer <1% Chrysotile (by TEM)

1C Black Built Up Roofing Area B Roof Field Southeast Bottom

Layer <1% Chrysotile (by TEM)

2A Grey Gypsum Roof Decking Area B Roof deck Northwest No Asbestos Detected

2B Grey Gypsum Roof Decking Area B Roof deck South Center No Asbestos Detected

2C Grey Gypsum Roof Decking Area B Roof deck Southeast No Asbestos Detected

3A Black/Grey Caulking Area B Termination Bar No Asbestos Detected

3B Black/Grey Caulking Area B Exhaust Curb on Metal No Asbestos Detected

3C Black/Grey Caulking Area B Exhaust Curb on Metal No Asbestos Detected

December 9, 2019 ■ Terracon Project No. J5197049

Syracuse Armory Roof Areas “A” & “A1”

HA No. Sample Number Material Description Sample Location Lab Results

1A Black/Grey Roof Cement "A1" Roof Tie Down Pitch Pocket No Asbestos Detected

1B Black/Grey Roof Cement "A1" Roof Tie Down Pitch Pocket No Asbestos Detected

1C Black/Grey Roof Cement "A1" Roof Tie Down Pitch Pocket No Asbestos Detected

2A Black Seam Sealant "A" Roof EPDM Seam No Asbestos Detected

2B Black Seam Sealant "A" Roof EPDM Seam No Asbestos Detected

2C Black Seam Sealant "A" Roof Exhaust Boot No Asbestos Detected

APPENDIX C

ASBESTOS AND LEAD LABORATORY ANALYTICAL DATA

EMSL Analytical, Inc.

2975 Brighton Henrietta Town Line Rd ,100 Ste 130 Rochester, NY 14623

Tel/Fax: (585) 957-9436 / (585) 957-9437 http://www.EMSL.com / rochesterlab@EMSL.com

531901871EMSL Order:

Customer ID: TRNY42

Customer PO: J5197049

Project ID:

Attention: Phone:Tony Hill (585) 739-0663

Fax:Terracon Consultants, Inc

Received Date:15 Marway Circle 11/20/2019 4:23 PM

Analysis Date:Suite 2B 11/21/2019 - 11/25/2019

Collected Date:Rochester, NY 14624 11/19/2019

Project: NYANG Roofs, Henrietta

Test Report:Asbestos Analysis of Bulk Material

Test Color

Analyzed

Date Fibrous Non-Fibrous Asbestos

Non-Asbestos

Sample ID 1A Description Area B Roof Field Northwest Bottom Layer - Black Built Up Roofing

531901871-0001 Homogeneity Heterogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Black11/21/2019 <1.00% Glass 100.00% Other Inconclusive : <1% Chrysotile

Inseparable black tar between homogeneous layers of roof felt.

Final Residue <1% of original subsample –trace ACM, not analyzed by TEM.

TEM NYS 198.4 NOB Not Analyzed

Sample ID 1B Description Area B Roof Field South Center Bottom Layer - Black Built Up Roofing

531901871-0002 Homogeneity Heterogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Black11/21/2019 <1.00% Glass 100.00% Other Inconclusive : <1% Chrysotile

Inseparable black tar between homogeneous layers of roof felt.

Final Residue <1% of original subsample – trace ACM, not analyzed by TEM.

TEM NYS 198.4 NOB Not Analyzed

Sample ID 1C Description Area B Roof Field Southeast Bottom Layer - Black Built Up Roofing

531901871-0003 Homogeneity Heterogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Black11/21/2019 <1.00% Glass 100.00% Other Inconclusive : <1% Chrysotile

Inseparable black tar between homogeneous layers of roof felt.

TEM NYS 198.4 NOB Black11/25/2019 None 100.00% Other <1% Chrysotile

Sample ID 2A Description Area B Roof deck Northwest - Grey Gypsum Roof Decking

531901871-0004 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected11/21/2019 2.00% Cellulose 85.00%

13.00%

Gypsum

Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 2B Description Area B Roof deck South Center - Grey Gypsum Roof Decking

531901871-0005 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected11/21/2019 2.00% Cellulose 85.00%

13.00%

Gypsum

Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Initial report from: 11/25/2019 15:26:45

Page 1 of 3ASB_198x_0009 - 1.71 Printed 11/25/2019 3:26:48PM

Tel/Fax: (585) 957-9436 / (585) 957-9437 http://www.EMSL.com / rochesterlab@EMSL.com

531901871EMSL Order:

Customer ID: TRNY42

Customer PO: J5197049

Project ID:

Test Report:Asbestos Analysis of Bulk Material

Test Color

Analyzed

Date Fibrous Non-Fibrous Asbestos

Non-Asbestos

Sample ID 2C Description Area B Roof deck Southeast - Grey Gypsum Roof Decking

531901871-0006 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected11/21/2019 2.00% Cellulose 85.00%

13.00%

Gypsum

Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 3A Description Area B Termination Bar - Black/Grey Caulking

531901871-0007 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected11/21/2019 100.00% Other

Final Residue <1% of original subsample – Non-ACM, not analyzed by TEM.

TEM NYS 198.4 NOB Not Analyzed

Sample ID 3B Description Area B Exhaust Curb on Metal - Black/Grey Caulking

531901871-0008 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected11/21/2019 100.00% Other

Final Residue <1% of original subsample – Non-ACM, not analyzed by TEM.

TEM NYS 198.4 NOB Not Analyzed

Sample ID 3C Description Area B Exhaust Curb on Metal - Black/Grey Caulking

531901871-0009 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected11/21/2019 100.00% Other

TEM NYS 198.4 NOB Gray None Detected11/25/2019 100.00% Other

Page 2 of 3ASB_198x_0009 - 1.71 Printed 11/25/2019 3:26:48PM

Tel/Fax: (585) 957-9436 / (585) 957-9437 http://www.EMSL.com / rochesterlab@EMSL.com

531901871EMSL Order:

Customer ID: TRNY42

Customer PO: J5197049

Project ID:

Test Report:Asbestos Analysis of Bulk Material

The samples in this report were submitted to EMSL for analysis by Asbestos Analysis of Bulk Materials via NYS ELAP Approved Methods . The reference number for these samples is the EMSL Order ID above. Please use this reference number when calling about these samples.

Report Comments:

Sample Receipt Date:

Analysis Completed Date: Analysis Completed Time:

Sample Receipt Time:11/20/2019 4:23 PM

11/21/2019 4:16 PM

Analyst(s):

Melissa Hartwig PLM NYS 198.1 Friable (3) Melissa Hartwig PLM NYS 198.6 NOB (6)

Peter Donato TEM NYS 198.4 NOB (2)

Samples reviewed and approved by:

Peter Donato Asbestos Laboratory Manager or Other Approved Signatory

NOB = Non Friable Organically Bound N/A = Not Applicable VCM = Vermiculite Containing Material

-In New York State, TEM is currently the only method that can be used to determine if NOB materials can be considered or treated as non-asbestos containing.

All samples examined for the presence of vermiculite when analyzed via NYS 198.1.

-NYS Guidelines for Vermiculite containing samples are available at http ://www.wadsworth.org/labcert/elapcert/forms/VermiculiteInterimGuidance_Rev070913.pdf EMSL maintains liability limited to cost of analysis. 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 . Interpretation and use of test results are the responsibility of the client.

Samples were received in good condition unless otherwise noted.

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. This report may contain data that is not covered by the NVLAP accreditation .

Samples analyzed by EMSL Analytical, Inc. Rochester, NY NYS ELAP 12088

Page 3 of 3ASB_198x_0009 - 1.71 Printed 11/25/2019 3:26:48PM

OrderID: 531901871

Client Sample Description ConcentrationLab ID Analyzed Lead

Collected

EMSL Analytical, Inc.

528 Mineola Avenue, Carle Place, NY 11514 Phone/Fax: (516) 997-7251 / (516) 997-7528 http://www.EMSL.com carleplacelab@emsl.com

Attn: Tony Hill Terracon Consultants, Inc 15 Marway Circle Suite 2B Rochester, NY 14624

Received: 11/21/19 10:17 AM

NYANG Roofs J5187049, Henrietta, New York.

Fax:

Phone: (585) 247-3471

Project:

11/19/2019Collected:

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3051A/7000B)*

061926361 CustomerID: TRNY42 CustomerPO: J5187049 ProjectID:

EMSL Order:

Site: Area "B" Roof Exhaust Fan Housing Desc: Grey

061926361-0001PNT-001 0.014 % wt11/29/201911/19/2019

Site: Area "B" Roof Curved Exhaust Duct Desc: Green/Brown

061926361-0002PNT-002 4.7 % wt11/29/201911/19/2019

Alger Liang, Lead Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 11/29/2019 4:41:17 PM

*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. Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. "<" (less than) result signifies the analyte was not detected at or above the warning limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise.

Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Carle Place, NY Lab ID 102344 is accredited by the AIHA LAP, LLC in the Environmental Lead accred. program for Lead in Dust, CT PH-0249, NYS ELAP

11469, CA 2339.

Initial report from 11/29/2019 16:41:17 http://www.EMSL.com mailto:carleplacelab@emsl.com

OrderID: 061926361

Analyzed Date Asbestos Fibrous Non-FibrousTest Color

Non Asbestos

Test Report:Asbestos Analysis of Bulk Material

EMSL Analytical, Inc.

2975 Brighton Henrietta Town Line Rd ,100 Ste 130, Rochester, NY 14623 Phone/Fax: (585) 957-9436 / (585) 957-9437 http://www.EMSL.com rochesterlab@EMSL.com

531901872 CustomerID: TRNY42 CustomerPO: J5197049 ProjectID:

EMSL Order:

Attn: Tony Hill Terracon Consultants, Inc 15 Marway Circle Suite 2B Rochester, NY 14624

Received: 11/20/19 4:31 PM

NYANG Roofs, J5197049

Fax:

Phone: (585) 247-3471

Project:

11/26/2019Analysis Date:

11/20/2019Collected:

1A 531901872-0001

Description "A1" Roof Tie Down Pitch Pocket - Black/Grey Roof Cement

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Gray/Black

Gray/Black

Sample ID

Result includes a small amount of inseparable attached material.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

1B 531901872-0002

Description "A1" Roof Tie Down Pitch Pocket - Black/Grey Roof Cement

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Gray/Silver

Gray/Silver

Sample ID

Inseparable layer of silver paint included in analysis.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

1C 531901872-0003

Description "A1" Roof Tie Down Pitch Pocket - Black/Grey Roof Cement

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Gray/Silver

Gray/Silver

Sample ID

Inseparable layer of silver paint included in analysis.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

2A 531901872-0004

Description "A" Roof EPDM Seam - Black Seam Sealant

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Brown/White/ Black

Brown/White/ Black

Sample ID

Result includes a small amount of inseparable attached material.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

Page 1Test Report 198VCM-7.30.0 Printed: 11/26/2019 2:22:17 PM

Initial Report From 11/26/2019 14:22:17 mailto:rochesterlab@EMSL.com

Asbestos Fibrous Non-FibrousTest Color Non Asbestos

Test Report:Asbestos Analysis of Bulk Material

EMSL Analytical, Inc.

2975 Brighton Henrietta Town Line Rd ,100 Ste 130, Rochester, NY 14623 Phone/Fax: (585) 957-9436 / (585) 957-9437 http://www.EMSL.com rochesterlab@EMSL.com

531901872 CustomerID: TRNY42 CustomerPO: J5197049 ProjectID:

EMSL Order:

2B 531901872-0005

Description "A" Roof EPDM Seam - Black Seam Sealant

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Brown/White/ Black

Brown/White/ Black

Sample ID

Result includes a small amount of inseparable attached material.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

2C 531901872-0006

Description "A" Roof Exhaust Boot - Black Seam Sealant

PLM NYS 198.1 Friable

PLM NYS 198.6 NOB

TEM NYS 198.4 NOB

11/25/2019

11/26/2019

Not Analyzed

Inconclusive: None Detected

None Detected

Brown/White/ Black

Brown/White/ Black

Sample ID

Result includes a small amount of inseparable attached material.

Homogeneity Heterogeneous

PLM NYS 198.6 VCM Not Analyzed

Other100%

Other100%

-In New York State, TEM is currently the only method that can be used to determine if NOB materials can be considered or treated as non-asbestos containing.

All samples examined for the presence of vermiculite when analyzed via NYS 198.1.

-NYS Guidelines for Vermiculite containing samples are available at http://www.wadsworth.org/labcert/elapcert/forms/VermiculiteInterimGuidance_Rev070913.pdf EMSL maintains liability limited to cost of analysis. 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. Interpretation and use of test results are the responsibility of the client. Samples were received in good condition unless otherwise noted.

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. This report may contain data that is not covered by the NVLAP accreditation.

Peter Donato Asbestos Laboratory Manager or other approved signatory

Analyst(s)

NOB = Non Friable Organically Bound N/A = Not Applicable VCM = Vermiculite Containing Material

Melissa Hartwig

Peter Donato

Samples analyzed by EMSL Analytical, Inc. Rochester, NY NYS ELAP 12088

Page 2THIS IS THE LAST PAGE OF THE REPORT.Test Report 198VCM-7.30.0 Printed: 11/26/2019 2:22:17 PM

Initial Report From 11/26/2019 14:22:17 http://www.EMSL.com mailto:rochesterlab@EMSL.com http://www.wadsworth.org/labcert/elapcert/forms/VermiculiteInterimGuidance_Rev070913.pdf

OrderID: 531901872

Client Sample Description ConcentrationLab ID Analyzed Lead

Collected

EMSL Analytical, Inc.

528 Mineola Avenue, Carle Place, NY 11514 Phone/Fax: (516) 997-7251 / (516) 997-7528 http://www.EMSL.com carleplacelab@emsl.com

Attn: Tony Hill Terracon Consultants, Inc 15 Marway Circle Suite 2B Rochester, NY 14624

Received: 11/21/19 12:00 AM

NYANG Roofs J5187049. Syracuse, NY.

Fax:

Phone: (585) 247-3471

Project:

11/20/2019Collected:

Test Report: Lead in Paint Chips by Flame AAS (SW 846 3051A/7000B)*

061926341 CustomerID: TRNY42 CustomerPO: J5187049 ProjectID:

EMSL Order:

Site: "A" Roof Large Air Conditioner Housing Desc: Grey

061926341-0001PNT-001 0.11 % wt11/29/201911/20/2019

Site: "A" Rood Tall Air Conditioner Housing Desc: Brown/Grey

061926341-0002PNT-002 0.044 % wt11/29/201911/20/2019

Alger Liang, Lead Laboratory Manager or other approved signatory

Test Report ChmSnglePrm/nQC-7.32.3 Printed: 11/29/2019 4:43:21 PM

*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. Unless noted, results in this report are not blank corrected. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities. Samples received in good condition unless otherwise noted. "<" (less than) result signifies the analyte was not detected at or above the warning limit. Measurement of uncertainty is available upon request. The QC data associated with the sample results included in this report meet the recovery and precision requirements unless specifically indicated otherwise.

Definitions of modifications are available upon request.

Samples analyzed by EMSL Analytical, Inc. Carle Place, NY Lab ID 102344 is accredited by the AIHA LAP, LLC in the Environmental Lead accred. program for Lead in Dust, CT PH-0249, NYS ELAP

11469, CA 2339.

Initial report from 11/29/2019 16:43:21 mailto:carleplacelab@emsl.com

OrderID: 061926341

APPENDIX D

LICENSES AND CERTIFICATIONS

New York State – Department of Labor Division of Safety and Health License and Certificate Unit State Campus, Building 12

Albany, NY 12240

ASBESTOS HANDLING LICENSE

Terracon Consultants, Inc.

10841 S. Ridgeview Road

Olathe, KS 66061

FILE NUMBER: 16-93056

LICENSE NUMBER: 93056

LICENSE CLASS: RESTRICTED

DATE OF ISSUE: 04/30/2019

EXPIRATION DATE: 04/30/2020

Duly Authorized Representative – Charles Guzzetta:

This license has been issued in accordance with applicable provisions of Article 30 of the Labor Law of New York State and of the New York State Codes, Rules and Regulations (12 NYCRR Part 56). It is subject to suspension or revocation for a (1) serious violation of state, federal or local laws with regard to the conduct of an asbestos project, or (2) demonstrated lack of responsibility in the conduct of any job involving asbestos or asbestos material.

This license is valid only for the contractor named above and this license or a photocopy must be prominently displayed at the asbestos project worksite. This license verifies that all persons employed by the licensee on an asbestos project in New York State have been issued an Asbestos Certificate, appropriate for the type of work they perform, by the New York State Department of Labor.

Eileen M. Franko, Director SH 432 (8/12) For the Commissioner of Labor