Final Asbestos Inspection Report and Lead Paint Survey

Transcription

1 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # East Powell Boulevard Gresham, Multnomah County, Oregon October 7, 2011 Terracon Project No Prepared for: PACLAND Portland, Oregon Prepared by: Terracon Consultants, Inc. Portland, Oregon

2 October 7, 2011 PACLAND 6400 SE Lake Road, Suite 300 Portland, Oregon Attention: Mr. Shawn Nguy Re: Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # East Powell Boulevard Gresham, Multnomah County, Oregon Project No Dear Mr. Nguy: Terracon Consultants, Inc. is pleased to present the Final Asbestos Inspection Report and Lead Paint Survey (FAIR) with the results of the asbestos survey performed on August 2, 2011, at the Proposed Retail Takeover, Store # located at 2444 East Powell Boulevard, Gresham, Multnomah County, Oregon. This survey was performed in accordance with PACLAND s Subconsultant Agreement dated April 5, 2011, the Retailer s Environmental Due Diligence Protocols for When Buildings Are Present, dated July 1, 2011, and Terracon Proposal Number P , dated May 27, We understand that this FAIR was requested due to the proposed takeover of the existing structure. This report includes the sampling of all accessible interior and exterior suspect materials including the roof of the existing structure. Additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas. In the event that unsampled, suspect ACM is discovered during renovation activities, Terracon recommends that the renovation contractor contact the Civil Engineering Consultant (CEC) and Environmental Consultant immediately upon discovery, and that samples of the suspect ACM be collected and analyzed in order to classify, and/or quantify the material. This report presents the results of samples collected and analyzed and includes a figure showing the locations of the samples collected. Details of the sampling and analysis program are provided in the body of the attached report. Terracon Consultants, Inc SE International Way, Suite 300 Portland, Oregon P [503] F [503] terracon.com

3 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No Terracon appreciates the opportunity to provide this service to PACLAND. If you have any questions regarding this report, or if you need assistance with project oversight and sampling during demolition, please contact the undersigned at Sincerely, TERRACON CONSULTANTS Martin L. Eversaul Senior Staff Geologist AHERA Building Inspector No Matt Y. Wheaton, L.G. Senior Project Manager

4 TABLE OF CONTENTS 1.0 INTRODUCTION Project Objective Reliance BUILDING DESCRIPTION FIELD ACTIVITIES Visual Assessment Physical Assessment Sample Collection Sample Analysis REGULATORY OVERVIEW FINDINGS AND RECOMMENDATIONS GENERAL COMMENTS... 8 LIST OF APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Asbestos Survey Sample Summary Lead Paint Survey Sample Summary Confirmed Asbestos-Containing Materials Analytical Laboratory Data Licenses and Certifications Sample Location Plans

5 FINAL ASBESTOS INSPECTION REPORT AND LEAD PAINT SURVEY PROPOSED RETAIL TAKEOVER, STORE # East Powell Boulevard GRESHAM, MULTNOMAH COUNTY, OREGON Project No October 7, INTRODUCTION Terracon Consultants, Inc. (Terracon) conducted a Final Asbestos Inspection and Lead Paint Survey on the existing retail structure located at 2444 East Powell Boulevard in Gresham, Multnomah County, Oregon. The sampling was conducted by an AHERA-accredited asbestos building inspector in general accordance with PACLAND s Subconsultant Agreement dated April 5, 2011, the Retailer s Environmental Due Diligence Protocols for When Buildings Are Present, dated July 1, 2011, and Terracon Proposal Number P , dated May 27, Accessible, interior and exterior building components were surveyed and homogeneous areas of suspect asbestos-containing materials (ACM) were visually identified and documented. Although reasonable effort was made to survey all accessible suspect materials, additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in Environmental Protection Agency (EPA) regulation 40 Code of Federal Regulations (CFR) 763 Asbestos Hazard Emergency Response Act (AHERA). All suspect ACM and lead paint samples were delivered to an accredited laboratory for analysis by polarized light microscopy (PLM) and flame atomic adsorption (FAA), respectively. 1.1 Project Objective We understand this Final Asbestos Inspection Report (FAIR) and Lead Paint Survey were requested due to the proposed takeover and renovation of the existing 60,000-square foot, vacant retail store. The purpose of the inspection is to determine, generally, if ACM are prevalent in the structure. Therefore, representative interior and exterior building materials, as well as roofing material, were sampled as a part of the FAIR. 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 expansion or demolition activities. The asbestos NESHAP requires that potentially regulated asbestos-containing building materials be identified, classified, and quantified prior to planned disturbances during expansion or demolition activities. The NESHAP authority for Multnomah County is the Oregon Department of Environmental Quality (DEQ).

6 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No The lead paint survey was conducted to meet informational needs to comply with OSHA requirements for lead-in-air content during disturbance of painted materials. The survey was not designed to meet the requirements of the U.S. Department of Housing and Urban Development (HUD). 1.2 Reliance This report is certified to, can be relied upon by, and has been prepared for the exclusive use of the following entities: PACLAND, Inc.; Salter Joyce Ziker, PLLC; Wal-Mart Real Estate Business Trust, a Delaware Statutory Trust and their respective successors, assigns, affiliates, and subsidiaries. Use or reliance by any other party is prohibited without the written authorization of PACLAND and Wal-Mart Real Estate Business Trust, a Delaware Statutory Trust and Terracon. 2.0 BUILDING DESCRIPTION The site is currently developed with an approximately 60,000-square foot structure built in The building consisted of a CMU-block structure atop a poured concrete slab. Main sales area ceilings consisted of open steel trusses. Interior walls of the main sales floor consisted of painted CMU-block. Main floor and mezzanine level office ceilings consisted of 2-foot by 4-foot (2 x 4 ) drop-down ceiling tiles and gypsum wallboard with a painted finish. Main floor mezzanine level office walls consisted of painted and textured gypsum wallboard. Main sales area floors consisted of bare sealed concrete. Main floor and mezzanine office floors consisted of 12-inch by 12-inch (12 x 12 ) vinyl floor tiles with associated mastic. The structure was heated with roof mounted HVAC systems. Exposed heating duct was observed on the warehouse ceilings. 3.0 FIELD ACTIVITIES The final survey was conducted by Martin Eversaul, AHERA-accredited asbestos building inspector, on August 2, A copy of Mr. Eversaul s inspector license is attached as Appendix D. A summary of survey activities is provided below. 3.1 Visual Assessment Our survey activities began with visual observations of the interior and exterior of the building to identify apparent homogeneous areas of suspect ACM and lead paint. A homogeneous area consists of building materials that appear similar throughout in terms of color, texture, and if known, date of application. Interior assessment was conducted throughout visually accessible areas of the building. No inaccessible areas were noted during this survey. The exterior survey included an assessment of the exterior walls, the roof and parking lot areas. Building materials identified as concrete, glass, wood, masonry, metal, plastic, or rubber are not considered suspect ACM. 2

7 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No Physical Assessment A physical assessment of each homogeneous area of suspect ACM was conducted to assess the friability and/or the condition of the materials. A friable ACM is defined by the EPA as a material which can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect asbestos-containing materials. Homogeneous areas of suspect lead paint were observed to assess possible damage or deterioration to the paint. 3.3 Sample Collection Based on results of the visual observation, bulk samples of suspect ACM were collected in general accordance with AHERA protocols. Random samples of suspect materials were collected 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. A total of 94 bulk samples were collected from 26 homogeneous areas of suspect ACM. Bulk samples were collected from the following suspect interior materials identified: Painted, textured gypsum wallboard, joint compound, tape 4 cove base with mastic 2 x4 drop-down ceiling tile Door caulking 12 x12 vinyl flooring and associated mastic Stair tread Sheet vinyl flooring and associated mastic Sheet vinyl wainscoting and associated mastic Heating, ventilation and air-conditioning (HVAC) duct insulation Various mastics Concrete Masonry Unit (CMU) Wall Seam Building wall and cooler insulation Stucco façade Roof tar Built-up roofing material Concurrent with the final asbestos inspection, Terracon collected paint chip samples of suspect lead paint from painted substrates (walls, doors, door jambs, etc.). Paint chip samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. 3

8 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No A total of 26 paint chip samples were collected from various painted surfaces of suspect lead paint in the store structure. A summary of suspect ACM and lead paint samples collected during the survey is included as Appendix A. The approximate location of suspect lead paint samples is indicated on figures included in Appendix E. 3.4 Sample Analysis Bulk ACM samples were submitted under chain of custody to Seattle Asbestos Test of Lynnwood, Washington for analysis by polarized light microscopy (PLM) with dispersion staining techniques per EPA methodology (EPA/600/R-93/116). The percentage of asbestos, where applicable, was determined by microscopic visual estimation. Seattle Asbestos Test is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP Accreditation No ). Paint chip samples were collected and submitted to NVL Laboratories, Inc. of Seattle, Washington for analysis by flame atomic absorption spectroscopy (AAS) per EPA Method 7000B. Laboratory analytical results are provided following the Lead Paint Sample Summary Table. 4.0 REGULATORY OVERVIEW Asbestos The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. It also requires the identification and classification of existing asbestos-containing material (ACM) according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1 percent (%) 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 nonfriable ACM. RACM includes friable ACM, along with Category I non-friable ACM that has become friable or will be or has been subjected to sanding, grinding, cutting or abrading, and Category II nonfriable 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 nonfriable ACMs are exclusively asbestos-containing packings, gaskets, resilient floor coverings, floor coverings and associated mastic, 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. RACM must be removed prior to renovation or demolition activities. 4

9 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No In Multnomah County, the NESHAP requirements are administered by the Oregon DEQ. Specifically, Oregon Administrative Rule (OAR) states that the owner, operator or the contractor must provide DEQ with written notification at least 10 working days prior beginning any friable abatement project and at least five days before beginning any non-friable asbestos abatement project. Removal of RACM must be conducted by a DEQ-licensed asbestos abatement contractor. The OSHA Asbestos standard for construction (29 CFR ) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below 0.1 asbestos fibers per cubic centimeter of air (0.1 f/cc) as an eight hour time weighted average. 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. Oregon OSHA adopted the federal OSHA exposure standard of 0.1 f/cc in 1995 (OAR ). Lead Lead is regulated by the EPA, DEQ and Oregon OSHA. The EPA and DEQ regulate lead use, removal, and disposal, and OSHA regulates lead exposure to workers. Oregon OSHA has adopted the federal regulations by reference in Oregon Administrative Rule (OAR) The EPA regulates lead use, removal, and disposal, and OSHA regulates lead exposure to workers. The EPA defines LBP as paint, varnish, stain, or other applied coating that contains lead equal to or greater than 1.0 mg/cm 2, 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. A synopsis of the OSHA regulations (29 CFR ) and the applicability are as follows: The OSHA Interim Lead Standard for Construction (29 CFR ) 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-inconstruction 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 Lead contamination/emergency clean-up 5

10 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No 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 29 CFR established an Action Level for lead concentrations in air of 30 micrograms per cubic meter of air (µg/m 3 ) and a permissible exposure level (PEL) for lead concentrations in air of 50 µg/m 3 as an eight hour time weighted average. At this time, OSHA has not established limits for lead content in bulk paint (non-airborne). Their interpretation on this issue is that any amount of lead may cause airborne concentrations above the established limits. 5.0 FINDINGS AND RECOMMENDATIONS Based on the results of laboratory analysis, samples of the following materials were identified to contain asbestos: Black roof tar flashing associated with the metal roof vents Appendix A identifies the homogeneous areas sampled, sample identification numbers, material descriptions, and analytical results. Laboratory analytical reports and chains of custody are included in Appendix B. The asbestos-containing roofing materials are considered Category I non-friable ACM in fair condition, and contained approximately 3% to 5% chrysotile asbestos. According to the EPA, tar-impregnated roofing felts, asphalt tiles, asphalts and mastics that are non-friable and will remain non-friable during proposed demolition methods are exempt from NESHAP requirements and need not be removed prior to demolition or renovation. However, this exemption assumes the demolition of the building does not include deliberate burning or activities that powder or otherwise damage and render the materials friable. Because the proposed renovation activities may crush or pulverize the ACM roofing materials, Terracon recommends that they be removed from areas that may be potentially disturbed during renovation activities by an Oregon State-certified asbestos abatement contractor. As discussed in Section 1.0, the FAIR included the sampling of all accessible suspect materials, additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas. In the event that unsampled, suspect ACM is discovered during renovation activities, Terracon recommends that the renovation contractor contact the CEC and Environmental Consultant immediately upon discovery, and that samples of the suspect ACM be collected and analyzed in order to classify, and/or quantify the material. In addition, laboratory analysis indicated that lead was present in coated surfaces samples during this assessment: 6

11 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No White paint for the parking lot lines on asphalt pavement at a concentration of 1.6% by weight, and; Red paint for northwestern and southwestern concrete curbs at % and % by weight Remaining coated surfaces sampled during this assessment from the interior and exterior of the building did not contain lead above laboratory reporting limits (0.0048% to % by weight). In accordance with the retailer s Environmental Due Diligence Protocols for When Buildings are Present dated July 1, 2011, Terracon recommends that representative samples of the leadcontaining waste material be segregated prior to demolition and/or renovation and tested through laboratory analyses in order to determine if the waste is hazardous. Specifically, in the event that the above-identified material is planned to be removed and/or disposed off-site, one composite toxicity characteristics leaching procedure (TCLP) sample should be collected from each material and analyzed for leachable lead. If the sample is reported with a leaching lead concentration of 5.0 mg/l or more, then the waste must be classified and disposed of as dangerous waste. This lead survey was limited to readily observable and accessible surfaces. Terracon cannot guarantee remaining portions of the building or property to be lead-free as the possibility exists that lead-containing coated surfaces may be hidden from sight or in inaccessible locations, or the homogeneous construction areas identified may not be truly homogeneous. This limited lead survey was not performed to the HUD Guidelines for the Evaluation and Control of Lead- Based Paint Hazards in Housing standards. It should be understood that this limited lead survey 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. 7

12 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No GENERAL COMMENTS This asbestos and lead survey 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 during our survey of the building. The information contained in this report is relevant to the date on which this survey was 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 PACLAND, Inc.; Salter Joyce Ziker, PLLC; Wal-Mart Stores, Inc.; and Wal-Mart Real Estate Business Trust, a Delaware Statutory Trust 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 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. 8

13 APPENDIX A Asbestos Survey Sample Summary Lead Paint Survey Sample Summary

14 APPENDIX A ASBESTOS SURVEY SAMPLE SUMMARY Proposed Retail Takeover, Store # East Powell Boulevard Gresham, Multnomah County, Oregon HOMOGENEOUS AREA SAMPLE NO. 1-1 DESCRIPTION SAMPLE LOCATION Southwest corner 1-2 South-central 1-3 Southeast corner 1-4 East-central 1-5 Built-up roofing material Center 1-6 West-central 1-7 Northwest corner 1-8 West-central 1-9 Northeast corner 2-1 Northeast corner 2-2 Rolled roofing wall cover Northwest corner 2-3 South-central 3-1 Northeast corner 3-2 Roof tar South-central 3-3 Southeast corner 4-1 North-central 4-2 Tan stucco facade entrance North-central 5-2 Rolled roof patch entrance Fire riser room North mezzanine 6-2 Pink wall insulation ceiling northwest corner 6-3 South storage area 7-1 North mezzanine x4 textured ceiling tile ceiling brown cove base and mastic North mezzanine

15 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No HOMOGENEOUS AREA SAMPLE NO DESCRIPTION 12 x12 tan floor tile Brown stair tread Stair wall sheeting and mastic SAMPLE LOCATION North mezzanine, northwest North mezzanine, northeast North office, northwest Northeast building Northeast building North mezzanine 12-1 level wall CMU expansion joint 12-2 East-central building caulking West-central 12-3 building 13-1 North mezzanine northeast corner 13-2 North mezzanine northeast corner Textured gypsum wallboard, joint compound, tape North mezzanine northwest corner North office northeast corner North office northwest corner Entryway northeast corner Entryway northwest corner 2

16 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No HOMOGENEOUS AREA SAMPLE NO DESCRIPTION Sheet flooring and mastic SAMPLE LOCATION North men s restroom North men s restroom North women s restroom South mezzanine break room South mezzanine south room South mezzanine hallway South mezzanine hallway 15-4 Textured gypsum wallboard, joint 15-5 compound, tape Southeast storage 15-6 South-central storage 15-7 North central storage 15-8 Southeast storage 15-9 Northeast storage 16-1 South mezzanine east x12 tan floor tile South mezzanine south 16-3 South mezzanine west 17-1 South mezzanine east tan cove base South mezzanine south 17-3 South mezzanine west 3

17 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Takeover, Store # Gresham, OR October 7, 2011 Terracon Project No HOMOGENEOUS AREA 18 SAMPLE NO DESCRIPTION 2 x4 textured ceiling tile SAMPLE LOCATION South mezzanine east South mezzanine south South mezzanine west Fiberglass sheeting Southeast storage 19-2 mastic area Southeast storage x4 smooth ceiling tile area Yellow fiberglass cooler Southwest cooler, 21-2 insulation center Yellow foam cooler Southwest cooler, 22-2 insulation west door Southeast storage Yellow spray foam Central storage 23-3 Southwest storage Southeast storage Yellow fiberglass pipe 24-2 Central storage insulation 24-3 Southwest storage 25-1 Northeast building Gray door caulking Northwest building 25-3 Southeast building White door caulking Southwest building Bold indicates asbestos containing material identified at concentrations greater than 1% HVAC = Heating, ventilation and air conditioning CBU = Concrete Block Unit 4

18 APPENDIX A LEAD PAINT CHIP SAMPLE SUMMARY Proposed Retail Takeover, Store # East Powell Boulevard Gresham, Multnomah County, Oregon SAMPLE ID COLOR SUBSTRATE SAMPLE LOCATION LAB RESULTS (% BY WEIGHT) North-central LBP-1 Metal < building Yellow Southeast LBP-2 CMU Block < building North-central LBP-3 Wood < building White Southeast LBP-4 CMU Block < building LBP-5 North-central Black Wood building < LBP-6 Northeast building < CONDITION (INTACT, FAIR OR POOR) Intact Intact Intact LBP-7 LBP-8 Brown Gypsum wallboard Northeast building corner stairway < Intact LBP-9 LBP-10 LBP-11 LBP-12 LBP-13 LBP-14 Light yellow Tan Gray Metal CMU Block Metal Northeast corner of roof < Southwest corner of roof < North building entrance < North building entrance < Men s restroom < Women s restroom < North building < entrance LBP-15 Pink Concrete LBP-16 < Intact Intact Intact Intact

19 Final Asbestos Inspection Report and Lead Paint Survey Proposed Retail Expansion, Store # Gresham, OR October 7, 2011 Terracon Project No SAMPLE ID COLOR SUBSTRATE SAMPLE LOCATION LAB RESULTS (% BY WEIGHT) CONDITION (INTACT, FAIR OR POOR) Southeast LBP-17 < building corner Gray CMU Block South-central LBP-18 < building Intact South-central LBP-19 < handrail Yellow Metal West-central LBP-20 < handrail Intact LBP-21 Southwest curb Intact Red Concrete LBP-22 Northwest curb Intact Northwest LBP-23 corner parking Intact White Asphalt line LBP-24 Northeast crosswalk < Intact LBP-25 LBP-26 Black Fiberglass Northeast light pole Northwest light pole < < Bold indicates lead containing material identified at concentrations greater than 0.5% by weight Intact

20 APPENDIX B Confirmed Asbestos Containing Material

21 APPENDIX B CONFIRMED ASBESTOS-CONTAINING MATERIALS Proposed Retail Takeover, Store # East Powell Boulevard Gresham, Multnomah County, Oregon HA DESCRIPTION MATERIAL LOCATION PERCENT/TYPE ASBESTOS NESHAP CLASSIFICATION CONDITION ESTIMATED QUANTITY 3-1 3% C Black roof tar Metal roof vents Category I Non- Friable Fair 20 ft % C HA = Homogeneous Area ND = Not Detected C = Chrysotile ft 2 = square feet lf = linear feet Category I: Includes asbestos-containing packings, gaskets, asphaltic roofing products, resilient flooring, pliable sealants and pliable mastics

22 APPENDIX C Analytical Laboratory Data

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48 APPENDIX D Licenses and Certifications

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50 APPENDIX E Sample Location Plans

51 LP-3 LP LP-6 LP LP-7 LP LP LP SITE BUILDING LP-4 LP Notes: 1-7 Asbestos Sample Location Paint Chip Sample Location DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES Project Manager: CAB Drawn by: MLE Checked by: CAB Approved by: CAB SAMPLE LOCATION PLAN INTERIOR Project No Scale: Unknown PROPOSED RETAIL TAKEOVER, STORE # File Name: 2444 EAST POWELL BOULEVARD Date: 4103 SE International Way, Suite 300 Portland, OR GRESHAM, MULTNOMAH COUNTY, OREGON August 2011 PH. (503) FAX. (503) FIGURE 1

52 LP-26 LP-25 LP-22 LP-15 LP-24 LP-16 LP-23 LP LP SITE BUILDING LP-20 LP-12 LP LP-18 LP-17 LP-21 LP-19 Notes: Asbestos Sample Location Paint Chip Sample Location Parking Median DIAGRAM IS FOR GENERAL LOCATION ONLY, AND IS NOT INTENDED FOR CONSTRUCTION PURPOSES Light Pole Project Manager: CAB Drawn by: MLE Checked by: CAB Approved by: CAB SAMPLE LOCATION PLAN ROOF/EXTERIOR Project No Scale: Unknown PROPOSED RETAIL TAKEOVER, STORE # File Name: 2444 EAST POWELL BOULEVARD Date: 4103 SE International Way, Suite 300 Portland, OR GRESHAM, MULTNOMAH COUNTY, OREGON August 2011 PH. (503) FAX. (503) FIGURE 2