ASBESTOS AND LEAD BASED PAINT SAMPLING ESTES PARK ...

400 N. Link Lane | Fort Collins, Colorado 80524

Telephone: 970-206-9455 | Fax: 970-206-9441

ASBESTOS AND LEAD BASED PAINT SAMPLING 543 ELM ROAD

ESTES PARK, COLORADO

Prepared for:

Larimer County 200 W Oak Street

Fort Collins, CO 80522

Attention:

Project No. FC08777.000-221

March 7, 2019

LARIMER COUNTY 543 ELM ROAD, ESTES PARK, CO CTL | T PROJECT NO. FC08777.000-221

TABLE OF CONTENTS

ACRONYMS .................................................................................................................... i

1.0 INTRODUCTION .................................................................................................. 1

2.0 ASBESTOS METHODOLOGY ............................................................................. 1

3.0 ASBESTOS INSPECTION PROCEDURE ........................................................... 2 3.1 Asbestos Sample Collection ...................................................................... 2 3.2 Asbestos/Lead Sample Analysis ................................................................ 2

4.0 ASBESTOS REGULATORY CRITERIA ............................................................... 3

5.0 ASBESTOS INSPECTION RESULTS .................................................................. 4

6.0 PAINT CHIP SAMPLING ...................................................................................... 4

SUMMARY OF FEDERAL AND STATE ASBESTOS REGULATIONS

TABLE 1 – ASBESTOS SURVEY SUMMARY

TABLE 2 – PAINT CHIP SAMPLE SUMMARY

FIGURE 1 – OVERVIEW

FIGURE 2 – MAIN BUILDING SAMPLE LOCATIONS

FIGURE 3 – SHED SAMPLE LOCATIONS

APPENDIX A – SITE PHOTOGRAPHS

APPENDIX B – ASBESTOS LABORATORY RESULTS AND CHAIN OF CUSTODY

APPENDIX C – LEAD PAINT LABORATORY RESULTS AND CHAIN OF CUSTODY

APPENDIX D – CTL│THOMPSON CERTIFICATIONS


i

ACRONYMS

Commonly Used Acronyms

ACBM Asbestos Containing Building Materials

ACM Asbestos Containing Materials

AHERA Asbestos Hazard Emergency Response Act

EPA Environmental Protection Agency

HA Homogeneous Area

HEPA High Efficiency Particulate Air

HVAC Heating Ventilation and Air Conditioning

NESHAP National Emission Standards for Hazardous Air Pollutants

O&M Operations and Maintenance

OSHA Occupational Safety and Health Administration

PCM Phase Contrast Microscopy

PLM Polarized Light Microscopy

RBM Regulated Building Material

TEM Transmission Electron Microscopy

TSI Thermal System Insulation


1

1.0 INTRODUCTION

Larimer County retained CTL | Thompson, Inc. (CTL) to perform an asbestos

survey and lead based paint sampling of three buildings located at 543 Elm Road in

Estes Park, Colorado. The Site buildings include the main maintenance building and two

sheds. Mr. Dana Harris, certified CDPHE Asbestos Inspector Cert#: 10152 performed

the survey on February 26, 2019. We observed and sampled suspect asbestos

containing building materials and lead based paint on the structures. All observed suspect

asbestos containing building materials were sampled according to AHERA regulations.

2.0 ASBESTOS METHODOLOGY

The purpose of the asbestos inspection was to identify the condition and location

of friable and non-friable asbestos materials that are present on the structures. During the

asbestos materials survey, CTL performed the following tasks:

Inspected accessible areas for suspected asbestos materials;

Determined friability of suspected asbestos materials by touching;

Developed a sampling plan for each material based on the homogeneous

material type, friability, accessibility, and material locations;

Assessed the condition and potential hazards of the suspected asbestos materials;

Collected samples of suspected homogeneous and non-homogeneous

materials and submitted them for laboratory analysis by Polarized Light Microscopy (PLM); and,

Documented findings and inspection protocol in accordance with accepted

industry standards.


2

3.0 ASBESTOS INSPECTION PROCEDURE

CTL was not provided with building specifications or as-built drawings. During

assessment and sampling, suspect ACMs were grouped into homogeneous areas, which

are defined as areas of suspect ACM that are uniform in color and texture.

Homogeneous areas of suspect ACM were identified by visually inspecting the following

systems in each portion of the building surveyed:

Flooring systems

Wall/partition systems

Ceiling systems

Miscellaneous systems

Exterior systems

3.1 Asbestos Sample Collection

CTL collected bulk samples of the suspected friable and non-friable (that would

become friable during demolition) asbestos materials in a random and representative

manner, as defined by the U.S. Environmental Protection Agency (EPA) statistical

sampling methods. The collected samples were packaged in sealed and labeled

containers.

3.2 Asbestos/Lead Sample Analysis

The bulk samples of suspected asbestos materials were submitted to Reservoirs

Environmental, Inc. for analysis. Reservoirs Environmental, Inc. is accredited by the

National Voluntary Laboratory Accreditation Program (NVLAP) (Lab Code 101896-0) and

the American Industrial Hygiene Association (AIHA) (Accreditation Certificate #101533).

Individual layers of the samples were analyzed by PLM (Polarized Light Microscopy) to

determine asbestos type and content. Unused portions of the samples were archived for

60 days, unless the client requested special handling. By regulation, any single positive


3

asbestos sample classifies the entire homogeneous material as asbestos-containing and

additional analysis is not required.

4.0 ASBESTOS REGULATORY CRITERIA

According to the Occupational Safety and Health Administration (OSHA), the

Environmental Protection Agency (EPA), and the Colorado Department of Public Health

and Environment (CDPHE), samples with asbestos concentrations greater than 1 percent

(>1%) are classified as asbestos containing materials and are a regulated material. If a

building structure is scheduled for renovation or demolition, friable samples that contain

Trace amounts of asbestos (1% or less) must be further analyzed by a more accurate

point-count analysis to determine if they exceed the 1 percent threshold, or the materials

must be assumed to contain asbestos and be classified as a regulated material.

The EPA and OSHA distinguish between friable and non-friable forms of asbestos

materials. Friable materials can be crumbled or reduced to powder by hand pressure

when dry. Non-friable materials cannot be crumbled, pulverized, or reduced to powder by

hand pressure when dry. Friable materials are more likely to be released into the air,

especially if impacted or damaged during normal use, renovation, or demolition of a

building. Therefore, the distinction between friable and non-friable asbestos materials is

important. The EPA further segregates non-friable asbestos materials into Category I or

Category II. Category I non-friable asbestos materials include floor tiles and roofing felts.

Removal of these asbestos materials is not required prior to demolition as long as they

are in good condition and not friable and/or rendered friable. Category II asbestos

materials are all other non-friable asbestos materials, and may be required to be removed

prior to demolition if those materials will be rendered friable.

Whether removed or remaining in a structure during demolition, the confirmed or

presumed asbestos materials are subject to EPA National Emission Standards for

Hazardous Air Pollutants (NESHAP) and OSHA regulations. In 40 CFR 61.145, NESHAP


4

requires that each owner or operator of a demolition activity provide the administrator with

written notice of intent. The CDPHE has implemented the NESHAP program.

5.0 ASBESTOS INSPECTION RESULTS

An overview of the Site is presented on Figure 1.

The main maintenance building was observed to be a steel and concrete structure,

with fiberglass batt insulation on the interior walls and ceilings. The main maintenance

building is divided into three bays, with northeast bay further divided into office and

storage areas. The main maintenance building is approximately 3,700 square feet in

size. The two sheds are wooden structures, with approximate square footages of 250

square feet (central shed) and 192 square feet (south shed).

Results of the asbestos analyses for the homogeneous materials collected are

summarized below and on Table 1, attached. Sample locations are shown on attached

Figures 2 and 3. Site photographs are presented in Appendix A. Laboratory reports for

the samples are presented in Appendix B.

As shown on the attached laboratory report, no asbestos was identified in the

samples collected from either shed. The following homogeneous areas within the main

maintenance building contained asbestos:

HA# 1 – window glazing/putty – this material contained trace chrysotile asbestos

and was nonfriable. Because this material did not contain greater than 1%

asbestos, it is not classified as an ACM and does not have to be removed prior to

demolition. However, if left in place, OSHA asbestos regulations will apply to

demolition workers potentially exposed to asbestos.

HA# 2 – drywall joint compound – the joint compound contained 1.25 % chrysotile

asbestos, as verified by point-count re-analysis. The composite analysis contained


5

0.05% asbestos. Because the composite result was not greater than 1%

asbestos, the material does not have to be removed prior to demolition. However,

if left in place, OSHA regulations will consider this material an ACM (because the

joint compound itself contained greater than 1% asbestos), the demolition will be

considered an OSHA Class II asbestos activity, and applicable OSHA regulations,

will apply to workers potentially exposed to asbestos during demolition. Among

other requirements, the OSHA requirements for Class II work include 8-32 hours of

specialized training, use of a properly-trained OSHA Competent Person, use of

wet methods, respiratory protection, and exposure monitoring.

6.0 PAINT CHIP SAMPLING

We conducted sampling for lead containing paint. One paint chip sample was

collected from each color of paint on each substrate. We collected a total of 5 paint chip

samples, as summarized on Table 2. We also collected one composite sample of

representative building materials that will end up as wastes for disposal upon demolition

of the buildings.

As shown on Table 2 and presented in Appendix C, the paint chip samples con-

tained up to 2.6% lead, which is above 20 times the lead characteristic hazardous waste

limit of 5 parts per million (5 ppm), or 0.01%/100 ppm. Therefore, the composite sample

of building components was submitted for lead TCLP analysis. As shown on Table 2

and presented in Appendix C, the TCLP lead concentration for the composite building

material sample was less than the laboratory reporting limit of 0.04 milligrams per liter

(mg/l). This is less than the hazardous waste characteristic limit for lead of 5 mg/l.

Based on this, building waste will not need to be treated as hazardous waste.

Note: Any contractor disturbing lead containing materials must comply with OSHA 29 CFR 1926.62 Lead in Construction Standard.


6

If we can be of further service discussing the contents of this report, please call us.

Very truly yours,

CTL | THOMPSON, INC. Dana L. Harris Environmental Department Manager Asbestos Inspector #10152 Reviewed by:

Brandon Edwards Environmental Technician Asbestos Inspector #24589


SUMMARY OF FEDERAL AND STATE ASBESTOS REGULATIONS

OSHA: U.S. Department of Labor, Occupational Safety, and Health Administration,

including but not limited to:

Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite;

Final Rules Title 29, Part 1910, Section 1325 and Part 1926, Section 1101

of the Code of Federal Regulations;

Respiratory Protection Standard Title 29, Part 1910, Section 134 of the Code of Federal Regulations;

Construction Industry Title 29, Part 1926, of the Code of Federal

Regulations;

Access to Employee Exposure and Medical Records Title 29, Part 1910, Section 2 of the Code of Federal Regulations;

Hazard Communication Title 29, Part 1926 Section 59 of the Code of

Federal Regulations; and

Specifications for Accident Prevention Signs and Tags Title 29, Part 1910, Section 145 of the Code of Federal Regulations.

DOT: U.S. Department of Transportation, including but not limited to:

Hazardous Substances Title 29, Part 171 and 172 of the Code of Federal Regulations.

EPA: U.S. Environmental Protection Agency, including but not limited to:

Asbestos Hazard Emergency Response Act (AHERA) Regulation; Asbestos Containing Materials in Schools Final Rule & Notice Title 40, Part

763 Sub-part E of the Code of Federal Regulations;

Training Requirements of (AHERA) Regulation;

Asbestos Containing Materials in Schools Final Rule & Notice Title 40,Part 763, Sub-part E, Appendix C of the Code of Federal Regulations;

National Emission Standard for Hazardous Air Pollutants (NESHAPS); and


National Emission Standard for Asbestos Title 40, Part 61, Sub-part A, Sub-part M (Revised Sub-part B) of the Code of Federal Regulations.

CDPHE: Colorado Department of Public Health and Environment, including but not limited to:

Air Quality Control Commission, Regulation No. 8, Part B “Emissions Standards for Asbestos”; and

Hazardous Materials and Waste Management Division, 6 CCR 1007-2,

Section 5 “Asbestos Waste Management.”

Figure 1. Overview map – Asbestos and Lead Survey, 543 Elm Road, Estes Park, Colorado. CTL Project No. FC08777.000-221.

Main Building Main Building

Southwest Shed

Middle Shed

N

Not To

Scale

Figure 2. Asbestos and Paint Chip Sample Locations and Confirmed Asbestos Locations, Main Building 543 Elm Road, Estes Park, Colorado. CTL Project No.

FC08777.000-221.

N

Not To

Scale 1

2

4

5, 6

7

8

9 10

Legend

1 Asbestos Sample Location (last two digits of sample no.)

LP-1 Paint chip sample location

HA#1 – window glazing/putty

HA# 2 – Drywall joint compound

Figure 3. Asbestos and Paint Chip Sample Locations and Confirmed Asbestos Locations, Sheds, 543 Elm Road, Estes Park, Colorado. CTL Project No. FC08777.000-221.

N

Not To

Scale

Legend

1 Asbestos Sample Location (last two digits of sample no.)

LP-1 Paint chip sample location

Table 1

Asbestos Survey Summary

543 Elm Road

Estes Park, Colorado

CTL Project No. FC08777.000-221

BuildingHA# Sample No. Description

Sample

Location

Sample Ht. (ft,

aprox.)Asbestos Content Locations Observed

Estimated

QuantityACM Friability

ACM

Condition1-WGL-1 Window glazing/putty, gray See Fig. 2 6 Trace Chrysotile

1-WGL-2 Window glazing/putty, gray See Fig. 2 6 Trace Chrysotile

2-DWJC-3 Drywall joint compound See Fig. 2 4 None Detected

2-DWJC-4 Drywall joint compound See Fig. 2 4

Drywall - ND

J.C. - 1.25%

Chrysotile (pt. ct.)

Composite: 0.05%

3-CPAD-5 Carpet adhesive, yellow See Fig. 2 0 None Detected

3-CPAD-6 Carpet adhesive, yellow See Fig. 2 0 None Detected4-CBA-7 Cove base adhesive, white See Fig. 2 1 None Detected

4-CBA-8 Cove base adhesive, white See Fig. 2 1 None Detected

5-FTMS-9 12" x 12" floor tile, tan and mastic See Fig. 2 0 None Detected

5-FTMS-10 12" x 12" floor tile, tan and mastic See Fig. 2 0 None Detected

6-DCLK-11 Door frame caulk, gray See Fig. 2 4 None Detected

6-DCLK-12 Door frame caulk, gray See Fig. 2 4 None Detected

7-WGL-13 Window glazing/putty, beige See Fig. 2 5 None Detected

7-WGL-14 Window glazing/putty, beige See Fig. 2 5 None Detected

8-CLK-15 Caulking, white See Fig. 2 4 None Detected

8-CLK-16 Caulking, white See Fig. 2 4 None Detected

9-WCLK-17 Window frame caulk, gray See Fig. 2 5 None Detected

9-WCLK-18 Window frame caulk, gray See Fig. 2 5 None Detected

10-WGL-19 Window glazing/putty, white See Fig. 3 5 None Detected

10-WGL-20 Window glazing/putty, white See Fig. 3 5 None Detected11-RSHG-21 Roof shingle, green See Fig. 3 7 None Detected

11-RSHG-22 Roof shingle, green See Fig. 3 7 None Detected

12-RSHG-23 Roof shingle, gray See Fig. 3 7 None Detected

12-RSHG-24 Roof shingle, gray See Fig. 3 7 None Detected



Middle

Shed

S-West

Shed

70 SF

1 SF

Windows

7

8

9

N/A

N/A

N/A

N/AMain

Building

2 SF

1390 SF

280 SF

10 SF

Central bay windows

NE office area

NE office area

1 SF

10 SF

1 SF

N/A

N/A

2 SF N/A N/A

Nonfriable

Nonfriable

N/A

N/A

N/AN/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

N/A

1 SF

168 SF

N/A168 SF

1

2

3

5

4 NE office area

NE bathroom

N. door6

10

11

NE-North window

Exterior

penetrations

NE-south window

Window

Roof - lower layer

13

Roof - upper layer12

Yellow highlight: ACM

Orange highlight: contains asbestos at or less than 1% Page 1 of 1

Table 2

Paint Chip Sample Summary

543 Elm Road, Estes Park, Colorado

CTL Project No. FC08777.000-221

Building Sample No. DescriptionSample

Location

Paint Chip Sample

Lead ContentTCLP Result

LP-1 White paint on drywall See Fig. 2 < 0.001 % N/A

LP-2 White paint on wood See Fig. 2 < 0.004 % N/A

LP-3 White paint on concrete See Fig. 2 < 0.003 %

LP-5 White paint on metal See Fig. 2 2.6 %

S-West

ShedLP-4

Gray paint on wood See Fig. 3 0.011 %N/A

All

BuildingsBLDGWASTE-1 Composite from all buildings

Composite

from

all buildingsN/A

< 0.04

milligrams per

liter

Main

BuildingN/A

Page 1 of 1


APPENDIX A

SITE PHOTOGRAPHS

Site Photographs – Asbestos/Lead Survey 543 Elm Road

Estes Park, Colorado February 2019

Page 1 of 3 CTL|T Project No. FC08777.000-200

HA# 1 – window glazing/putty HA# 2 – drywall joint compound

HA# 3 – carpet adhesive HA# 4 cove base adhesive




HA# 5 – floor tile HA# 6 – door frame caulk

HA# 7 – window galzing/putty HA# 8 - caulking




HA# 9 – window frame caulking HA# 10 – window glazing/putty

HA# 11, 12 – roof shingles HA# 13 – window glazing/putty


APPENDIX B

ASBESTOS LABORATORY RESULTS AND CHAIN OF CUSTODY

Reservoirs Environmental, Inc.

Reservoirs Environmental QA Manual

Effective April 2, 2018

Q:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

Subcontract Number: NA

Laboratory Report: RES 429210-3

Project # / P.O. # FC08777.000-221

Project Description: 543 Elm Rd., Estes Park, CO

RES 429210-3

Sincerely,

is the job number assigned to this study. This report is considered highly confidential

and the sole property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with

personnel other than those of the client. The results described in this report only apply to the samples analyzed.

This report must not be used to claim endorsement of products or analytical results by NVLAP or any agency of the

U.S. Government. This report shall not be reproduced except in full, without written approval from Reservoirs

Environmental, Inc. Samples will be disposed of after sixty days unless longer storage is requested. If you have any

questions about this report, please feel free to call 303-964-1986.

Jeanne Spencer

President

March 5, 2019

Dear Customer,

Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and

Environmental matrices by the National Voluntary Laboratory Accreditation Program (NVLAP), Lab Code 101896-0

for Transmission Electron Microscopy (TEM) and Polarized Light Microscopy (PLM) analysis and the American

Industrial Hygiene Association (AIHA), Lab ID 101533 - Accreditation Certificate #480 for Phase Contrast

Microscopy (PCM) analysis. This laboratory is currently proficient in both Proficiency Testing and PAT programs

respectively.

Reservoirs Environmental, Inc. has analyzed the following samples for asbestos content as per your request. The

analysis has been completed in general accordance with the appropriate methodology as stated in the attached

analysis table. The results have been submitted to your office.

CTL/Thompson, Inc. (Ft. Collins)

400 North Link Lane

Ft. Collins CO 80524

Dana Harris

P: 303-964-1986

F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

Page 1 of 1

1-866-RESI-ENV

www.reilab.com

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Turnaround:

Date Samples Analyzed:

RES 429210-3


FC08777.000-221

543 Elm Rd., Estes Park, CO

February 28, 2019

Priority

February 28, 2019

TABLE: PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME




Q:\QAQC\LAB\Reservoirs Environmental QA Manual.doc

RESERVOIRS ENVIRONMENTAL INC.

NVLAP Lab Code 101896-0

Client

Sample

Number

Lab

ID Number

LAYER

Mineral

Method: EPA 600/R-93/116 - Point Count, Bulk

PhysicalDescription

SubPart

(%)

Visual

Estimate

(%)

ND=None DetectedTR=Trace, <1% Visual EstimateTrem/Act=Tremolite/Actinolite

NonAsbestosFibrous

Components(%)

Non-Fibrous

Components

(%)

Asbestos Content

10001-WGL-1 EM 2260651 Gray glazingA 100 TR Chrysotile

10001-WGL-2 EM 2260652 Gray glazingA 100 TR Chrysotile

10002-DWJC-3 EM 2260653 Light beige paint w/ white compoundA 5 ND

8020Light pink/tan drywallB 95 ND

10002-DWJC-4 EM 2260654 Off white paint w/ off white compoundA 1 TR Chrysotile

0.75 Point Count980White paint w/ white compoundB 3 2 Chrysotile

1.25 Point Count1000Light beige paint w/ white compoundC 4 ND

6040White/tan drywallD 92 ND

0.05 Composite

10003-CPAD-5 EM 2260655 Gray paintA 10 ND

1000Tan adhesiveB 90 ND

TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Only compound, tape and wallboard layers are used in the calculation of a composite result.

P: 303-964-1986F: 303-477-4275

1-866-RESI-ENVwww.reilab.com

5801 Logan Street, Suite 100, Denver, CO 80216

Page 1 of 4

RES Job Number:

Client:




Turnaround:


RES 429210-3


FC08777.000-221


February 28, 2019

Priority

February 28, 2019








Client

Sample

Number

Lab

ID Number

LAYER

Mineral


PhysicalDescription

SubPart

(%)

Visual

Estimate

(%)


NonAsbestosFibrous

Components(%)

Non-Fibrous

Components

(%)

Asbestos Content

10003-CPAD-6 EM 2260656 Gray paintA 10 ND

1000Tan adhesiveB 90 ND

60404-CBA-7 EM 2260657 Off white paint w/ off white paperA 6 ND

1000Off white adhesiveB 9 ND

1000Gray cove baseC 85 ND

65354-CBA-8 EM 2260658 White paint w/ off white paperA 3 ND

1000Brown adhesive w/ white paintB 5 ND

1000Off white adhesiveC 7 ND

1000Gray cove baseD 85 ND

10005-FTMS-9 EM 2260659 Tan adhesive w/ gray paintA 7 ND

1000Light beige tileB 93 ND

9825-FTMS-10 EM 2260660 Light tan adhesiveA 2 ND

1000Light beige tileB 98 ND



P: 303-964-1986F: 303-477-4275



Page 2 of 4

RES Job Number:

Client:




Turnaround:


RES 429210-3


FC08777.000-221


February 28, 2019

Priority

February 28, 2019








Client

Sample

Number

Lab

ID Number

LAYER

Mineral


PhysicalDescription

SubPart

(%)

Visual

Estimate

(%)


NonAsbestosFibrous

Components(%)

Non-Fibrous

Components

(%)

Asbestos Content

10006-DCLK-11 EM 2260661 Colorless resinous materialA 100 ND

9826-DCLK-12 EM 2260662 Colorless resinous materialA 100 ND

10007-WGL-13 EM 2260663 Brown resinous materialA 100 ND

10007-WGL-14 EM 2260664 Brown resinous materialA 100 ND

10008-CLK-15 EM 2260665 Light gray resinous materialA 100 ND

10008-CLK-16 EM 2260666 Light gray resinous materialA 100 ND

10009-WCLK-17 EM 2260667 White caulkA 100 ND

10009-WCLK-18 EM 2260668 White caulkA 100 ND

100010-WGL-19 EM 2260669 Light tan glazingA 100 ND

100010-WGL-20 EM 2260670 Light tan glazingA 100 ND

653511-RSHG-21 EM 2260671 Green/black shingleA 100 ND

604011-RSHG-22 EM 2260672 Green/black shingleA 100 ND

653512-RSHG-23 EM 2260673 White/green/black shingleA 100 ND

653512-RSHG-24 EM 2260674 White/green/black shingleA 100 ND



P: 303-964-1986F: 303-477-4275



Page 3 of 4

RES Job Number:

Client:




Turnaround:


RES 429210-3


FC08777.000-221


February 28, 2019

Priority

February 28, 2019








Client

Sample

Number

Lab

ID Number

LAYER

Mineral


PhysicalDescription

SubPart

(%)

Visual

Estimate

(%)


NonAsbestosFibrous

Components(%)

Non-Fibrous

Components

(%)

Asbestos Content

100013-WGL-25 EM 2260675 White glazing w/ gray paintA 100 ND

100013-WGL-26 EM 2260676 Off white glazingA 5 ND

1000White glazing w/ gray paintB 95 ND


Data QAAnalystAnalystAnalystAnalyst


P: 303-964-1986F: 303-477-4275



Page 4 of 4


APPENDIX C

LEAD PAINT LABORATORY RESULTS AND CHAIN OF CUSTODY

Reservoirs Environmental, Inc. Reservoirs Environmental QA Manual

Effective April 2, 2018Q:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

Laboratory Code: RESSubcontract Number: NALaboratory Report: RES 429210-2Project # / PO #: FC08777.000-221Project Description:

RES 429210-2

Sincerely,

Jeanne Spencer

President

February 28, 2019

Dear Customer,

Reservoirs has analyzed the following sample(s) using Atomic Absorption Spectroscopy (AAS) / Inductively CoupledPlasma - Mass Spectrometry (ICP-MS) per your request. Reported sample results were not blank corrected. Theanalysis has been completed in general accordance with the appropriate methodology as stated in the analysis table.Results have been sent to your office.

property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with personnel other thanthose authorized by the client. The results described in this report only apply to the samples analyzed. This report shallnot be reproduced except in full, without written approval from Reservoirs Environmental, Inc. Samples will be disposedof after sixty days unless longer storage is requested. If you should have any questions about this report, please feelfree to call me at 303-964-1986.

Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene andEnvironmental matrices by the American Industrial Hygiene Association, Lab ID 101533 - Accreditation Certificate #480.The laboratory is currently proficient in both IHPAT & ELPAT programs respectively.

is the job number assigned to this study. This report is considered highly confidential and the sole


Ft. Collins CO 80524400 North Link Lane

Dana HarrisCTL/Thompson, Inc. (Ft. Collins)

P: 303-964-1986F: 303-477-4275


Page 1 of 2


Reservoirs Environmental, Inc. Reservoirs Environmental QA Manual

Effective April 2, 2018Q:\QAQC\Lab\Reservoirs Environmental QA Manual.doc

RES Job Number:Client:Client Project Number / P.O.:Client Project Description:Date Samples Received:Analysis Type:Turnaround:Date Samples Analyzed:

Client Lab Reporting LEAD

ID Number ID Number Limit CONCENTRATION(%) (%)

LP-1 EM 2260677 0.001 BRL

LP-2 EM 2260678 0.001 0.004

LP-3 EM 2260679 0.003 BRL

LP-4 EM 2260680 0.001 2.6

LP-5 EM 2260681 0.002 0.011

Analyst / Data QA:________________________

Priority

RESERVOIRS ENVIRONMENTAL, INC.5801 Logan St., Suite 100

Denver CO 80216

TABLE ANALYSIS: LEAD IN PAINT

RES 429210-2

February 28, 2019

* Unless otherwise noted, all quality control samples are performed within specifications established by the laboratory.

CTL/Thompson, Inc. (Ft. Collins)FC08777.000-221543 Elm Rd., Estes Park, COFebruary 28, 2019REI CHEMISTRY SOP / USEPA SW846 3050B/7420-M

P: 303-964-1986F: 303-477-4275


Page 2 of 2


1903038

Dana Harris

Wednesday, March 06, 2019

Ft. Collins, Colorado

CTL Thompson400 N. Link LaneFort Collins, CO 80524

ALS Workorder:Re:543 Elm RoadProject Name:FC08777.000-221Project Number:

LIMS Version: 6.893

One solid sample was received from CTL Thompson, on 3/1/2019. The sample was scheduled for the following analysis:

Dear Mr. Harris:

Page 1 of 1

Metals

The results for these analyses are contained in the enclosed reports.

Thank you for your confidence in ALS Environmental. Should you have any questions, please call.

Sincerely,

ALS EnvironmentalKatie M. OBrienProject Manager

The data contained in the following report have been reviewed and approved by the personnel listed below. In addition, ALS certifies that the analyses reported herein are true, complete and correct within the limits of the methods employed.

ADDRESS 225 Commerce Drive, Fort Collins, Colorado, USA 80524 | PHONE +1 970 490 1511 | FAX +1 970 490 1522ALS GROUP USA, CORP. Part of the ALS Laboratory Group An ALS Limited Company

1 of 9

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ALS Environmental – Fort Collins is accredited by the following accreditation bodies for various testing scopes in accordance with requirements of each accreditation body. All testing is performed under the laboratory management system, which is maintained to meet these requirement and regulations. Please contact the laboratory or accreditation body for the current scope testing parameters.

ALS Environmental – Fort Collins

Accreditation Body License or Certification Number AIHA 214884 Alaska (AK) UST-086 Alaska (AK) CO01099 Arizona (AZ) AZ0742 California (CA) 06251CA Colorado (CO) CO01099 Florida (FL) E87914 Idaho (ID) CO01099 Kansas (KS) E-10381 Kentucky (KY) 90137 PJ-LA (DoD ELAP/ISO 170250) 95377 Louisiana (LA) 05057 Maryland (MD) 285 Missouri (MO) 175 Nebraska(NE) NE-OS-24-13 Nevada (NV) CO000782008A New York (NY) 12036 North Dakota (ND) R-057 Oklahoma (OK) 1301 Pennsylvania (PA) 68-03116 Tennessee (TN) 2976 Texas (TX) T104704241 Utah (UT) CO01099 Washington (WA) C1280

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ADDRESS 225 Commerce Drive, Fort Collins Colorado 80524 USA PHONE +1 970 490 1511 FAX +1 970 490 1522

ALS GROUP USA, CORP. Part of the ALS Group An ALS Limited Company

1903038 Metals: The sample was analyzed following SW-846, 3rd Edition procedures. Analysis by Trace ICP followed method 6010D and the current revision of SOP 834. All acceptance criteria were met.

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OrderNum: 1903038Client Name: CTL Thompson

Client Project Name: 543 Elm RoadClient Project Number: FC08777.000-221

Client PO Number:

Lab Sample Number

Client Sample Number

Matrix Date Collected

Time Collected

COC Number

Sample Number(s) Cross-Reference Table

ALS -- Fort Collins

1903038-1BLDGWASTE-1 SOLID 01-Mar-19 15:451903038-2BLDGWASTE-1 LEACHAT 01-Mar-19 15:45

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ALS -- Fort Collins

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Project: FC08777.000-221 543 Elm RoadSample ID: BLDGWASTE-1

Collection Date: 3/1/2019 15:45Matrix: LEACHATE

Analyses Result Qual Units Date AnalyzedReport Limit

Client: CTL ThompsonWork Order: 1903038

Dilution Factor

Lab ID: 1903038-2

ALS -- Fort CollinsDate: 06-Mar-19

SAMPLE SUMMARY REPORT

Percent Moisture:Legal Location:

SW6010 PrepBy: JMLPrep Date: 3/5/2019TCLP ICP MetalsLEAD 3/5/2019 13:080.04 MG/L 1ND

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Project: FC08777.000-221 543 Elm RoadSample ID: BLDGWASTE-1

Collection Date: 3/1/2019 15:45Matrix: LEACHATE

Analyses Result Qual Units Date AnalyzedReport Limit


Dilution Factor

Lab ID: 1903038-2

ALS -- Fort CollinsDate: 06-Mar-19

SAMPLE SUMMARY REPORT

Percent Moisture:Legal Location:

Explanation of Qualifiers

Radiochemistry:

U or ND - Result is less than the sample specific MDC.

Y2 - Chemical Yield outside default limits.Y1 - Chemical Yield is in control at 100-110%. Quantitative yield is assumed.

W - DER is greater than Warning Limit of 1.42* - Aliquot Basis is 'As Received' while the Report Basis is 'Dry Weight'.# - Aliquot Basis is 'Dry Weight' while the Report Basis is 'As Received'.G - Sample density differs by more than 15% of LCS density.

M - Requested MDC not met.

L - LCS Recovery below lower control limit.H - LCS Recovery above upper control limit.P - LCS, Matrix Spike Recovery within control limits.N - Matrix Spike Recovery outside control limitsNC - Not Calculated for duplicate results less than 5 times MDC

B3 - Analyte concentration greater than MDC but less than Requested MDC.

B - Analyte concentration greater than MDC.

M3 - The requested MDC was not met, but the reported activity is greater than the reported MDC.

D - DER is greater than Control Limit

Inorganics:

B - Result is less than the requested reporting limit but greater than the instrument method detection limit (MDL).

E - The reported value is estimated because of the presence of interference. An explanatory note may be included in the narrative.U or ND - Indicates that the compound was analyzed for but not detected.

M - Duplicate injection precision was not met.N - Spiked sample recovery not within control limits. A post spike is analyzed for all ICP analyses when the matrix spike and or spike duplicate fail and the native sample concentration is less than four times the spike added concentration.Z - Spiked recovery not within control limits. An explanatory note may be included in the narrative.* - Duplicate analysis (relative percent difference) not within control limits.

Organics:

U or ND - Indicates that the compound was analyzed for but not detected.

E - Analyte concentration exceeds the upper level of the calibration range.B - Analyte is detected in the associated method blank as well as in the sample. It indicates probable blank contamination and warns the data user.

J - Estimated value. The result is less than the reporting limit but greater than the instrument method detection limit (MDL).A - A tentatively identified compound is a suspected aldol-condensation product.X - The analyte was diluted below an accurate quantitation level.* - The spike recovery is equal to or outside the control criteria used. + - The relative percent difference (RPD) equals or exceeds the control criteria. G - A pattern resembling gasoline was detected in this sample.

M - A pattern resembling motor oil was detected in this sample.D - A pattern resembling diesel was detected in this sample.

C - A pattern resembling crude oil was detected in this sample.4 - A pattern resembling JP-4 was detected in this sample.5 - A pattern resembling JP-5 was detected in this sample.H - Indicates that the fuel pattern was in the heavier end of the retention time window for the analyte of interest.L - Indicates that the fuel pattern was in the lighter end of the retention time window for the analyte of interest.Z - This flag indicates that a significant fraction of the reported result did not resemble the patterns of any of the following petroleum hydrocarbon products: - gasoline- JP-8- diesel- mineral spirits- motor oil- Stoddard solvent- bunker C

S - SAR value is estimated as one or more analytes used in the calculation were not detected above the detection limit.

- "Report Limit" is the MDC

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ALS -- Fort Collins 3/6/2019 11:49:Date:

Project: FC08777.000-221 543 Elm Road


QC BATCH REPORT

Batch ID: IP190305-2-2 Instrument ID ICPTrace2 Method: SW6010

Qual

Analysis Date: 3/5/2019 12:57

Prep Date: 3/5/2019

Analyte Result %REC

Units: MG/L

ReportLimit

Client ID:

LCS

Run ID: IT190305-1A14

SPK ValSPK Ref

ValueControl

Limit

DF: 1

Sample ID: IP190305-2

RPD Ref RPD

RPD Limit

Decision Level

5LEAD 104 80-120 200.045.2

Qual

Analysis Date: 3/5/2019 12:56

Prep Date: 3/5/2019

Analyte Result

Units: MG/L

ReportLimit

Client ID:

MB

Run ID: IT190305-1A14 DF: 1

Sample ID: EX190304-6

LEAD 0.04ND

The following samples were analyzed in this batch: 1903038-2

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APPENDIX D

CTL│THOMPSON CERTIFICATIONS

ASBESTOS AND LEAD BASED PAINT SAMPLING ESTES PARK ...

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