LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY. Wal-Mart # Highway 51 North Ripley, TN ATC Project Number

Transcription

1 LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY Wal-Mart # Highway 51 North Ripley, TN ATC Project Number Prepared for: Wal-Mart Stores, Inc. Ms. Vicki Ingram Store Planning - Plans Administrator 2001 SE 10th Street Bentonville, AR August 1, 2006

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3 TABLE OF CONTENTS LETTER OF TRANSMITTAL... i 1.0 PURPOSE AND SCOPE OF SERVICES GENERAL SITE CONDITIONS REGULATORY STANDARDS Asbestos Regulations LIMITED ASBESTOS-CONTAINING MATERIAL SURVEY Homogeneous Areas Hazard Assessment Factors Sampling Strategy Suspect Asbestos-Containing Material Laboratory Analytical Results RECOMMENDATIONS AND CONCLUSIONS ASSUMPTIONS AND LIMITATIONS...9 APPENDICES APPENDIX A: APPENDIX B: APPENDIX C: APPENDIX D: ACM LABORATORY ANALYTICAL RESULTS SAMPLE LOCATION DRAWING PHOTO LOG INSPECTOR AND LABORATORY ACCREDITATIONS

4 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY 1.0 PURPOSE AND SCOPE OF SERVICES The purpose of this project was to conduct a Limited Asbestos-Containing Building Materials (ACBM) Survey of the Wal-Mart #0097 located at 628 Highway 51 North, Ripley, Tennessee, hereinafter referred to as the site, to assist Wal-Mart Stores, Inc. (the client) with these issues as they pertain to the planned renovation/demolition of parts of the building. ATC Associates Inc. (ATC) provided the services as outlined below: Conduct a representative asbestos survey in the identified building areas, which includes the following: 1. Review existing asbestos reports for the building areas, if provided. 2. Survey all of the interior areas of the store. 3. Identify accessible suspect ACBMs using Environmental Protection Agency (EPA) Asbestos Hazard Emergency Response Act (AHERA) protocols. 4. Collect and analyze bulk samples of suspect friable and non-friable materials to eliminate suspect materials as asbestos containing. 5. Quantify ACBMs, including material condition and location. 2.0 GENERAL SITE CONDITIONS The Wal-Mart #0097 limited survey included all of the interior areas of the store. The store is a one-story building comprised of interior finishes that include drywall/joint compound, floor tiles and associate adhesive, ceiling tiles, baseboard/adhesive, carpet/adhesive, wall panel adhesive, wood, metal, concrete block walls, brick, and concrete. The structure was erected in 1994 as a Supercenter and contains approximately 120,000 square feet under roof, not including the Garden Center or other temporary outside structures. Although the store is a Supercenter, it does not have the usual bakery, deli or automotive (TLE) like others. Approximately three years ago, this store had the carpet insets in the sales areas replaced. Nearly eight years ago, it received a facelift that included paint and signage. 1

5 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY 3.0 REGULATORY STANDARDS 3.1 Asbestos Regulations The Occupational Safety and Health Administration (OSHA) and the United States Environmental Protection Agency (USEPA) regulate airborne levels of asbestos fibers. These governmental agencies have promulgated standards for permissible airborne concentrations of asbestos fibers and specific requirements for repair and abatement. The laws are designed to protect the worker (OSHA) and the general environment (USEPA). In addition, each state may have adopted its own requirements, which may be more stringent than those called for by OSHA or the USEPA. OSHA established an asbestos general industry standard in 1971, primarily directed toward industrial applications (29 CFR ). In response to the growing asbestos abatement industry and the additional concern regarding asbestos exposure, a standard for the construction industry (29 CFR ) became effective on July 21, These standards specifically outline asbestos removal procedures, respirator selection and fit testing, air sampling, the analysis of asbestos air samples, and employee protection from exposure to airborne asbestos fibers. The standards include a time-weighted average (TWA) permissible exposure limit (PEL) of 0.2 fibers per cubic centimeter of air (f/cc), and a short-term excursion limit of 1.0 f/cc. Concentrations above these levels require specific employer-initiated activities such as instituting a respiratory protection program and medical surveillance for exposed employees. OSHA changed these standards in October of 1994 to include the reduction of the PEL for an 8-hour TWA to 0.1 f/cc in its revised construction industry standard of 29 CFR and the revised general industry standard 29 CFR These revisions also specify that building owners are now required to communicate to employees, 2

6 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY subcontractors, and tenants the location and quantity of asbestos-containing materials (ACMs) identified in this survey. The USEPA has also published a "visible emissions" standard under the National Emission Standard for Hazardous Air Pollutants (NESHAP, 40 CFR ). The standard also regulates specific procedures for notification for renovation and demolition projects, and land disposal of ACMs. 4.0 LIMITED ASBESTOS-CONTAINING MATERIAL SURVEY ATC representative Mr. Rod Cooper, Certified Asbestos Building Inspector (Certification Number MOIR8037), conducted the asbestos survey of the interior areas of the building on July 19, The scope of the Limited Asbestos-Containing Building Materials Survey included all of the interior areas of the store. The building areas were visually inspected for the presence of building materials that are suspected to contain asbestos. Bulk samples of identified suspect ACBMs were collected and placed into individual containers for transport to a National Voluntary Laboratory Accreditation Program (NVLAP)/American Industrial Hygiene Association (AIHA)- accredited laboratory for analysis. Materials visibly identified as non-asbestos (fibrous glass, foam rubber, wood, etc.) were not sampled. The asbestos survey consisted of three basic procedures: 1) conducting a visual inspection of the structures; 2) identifying homogeneous areas (HAs) of suspect surfacing, thermal system insulation, and miscellaneous materials; and 3) sampling accessible, friable and non-friable suspect materials. 4.1 Homogeneous Areas 3

7 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY Prior to collecting any samples, HAs were identified and listed to develop a sampling strategy. A homogeneous sampling area can be described as one or more areas of material that are similar in appearance and texture and that have the same installation date and function. The actual number of samples collected from each homogeneous sampling area may vary, based on the type of material and the professional judgment of the inspector. 4.2 Hazard Assessment Factors From the list of suspect homogeneous materials, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, assessing the potential for disturbance, and determining the friability of each material. Friability is a term used to describe the ease in which a building material inherently lends itself to disturbance. By definition, "friable" materials are those that can be crumbled or reduced to powder by hand pressure when dry. Each material on the list was further classified into one of three categories, which have specific sampling requirements for each category. Surfacing Materials: Thermal System Insulation: Miscellaneous Materials: Refers to spray-applied or troweled surfaces such as plaster ceilings and walls, fireproofing, textured paints, textured plasters, and spray-applied acoustical surfaces. Refers to insulation used to inhibit heat gain or loss on pipes, boilers, tanks, ducts, and various other building components. Refers to friable and non-friable products and materials that do not fit in any of the above two categories such as resilient floor covering, baseboards, mastics, adhesives, roofing material, caulking, glazing, and siding. This category also contains wallboard and ceiling tile. All suspect ACBMs were then assessed by their condition as good (intact), fair (damaged), or poor (significantly damaged) per Title 40 Code of Federal Regulations Part 763. Material with localized significant damage was also assessed as poor when observed. 4

8 4.3 Sampling Strategy Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY The asbestos inspection was conducted in general accordance with the AHERA requirements using a minimum number of samples collected from each HA, which also meets the sampling requirement found in 29 CFR Sample collection depends on the category that the HA falls into and the amount of material present, as follows: AHERA GUIDELINES FOR DETERMINING THE NUMBER OF SAMPLES TO TAKE HA CATEGORY HA SIZE SAMPLES REQUIRED Surfacing Materials <1,000 SF 3 1,000-5,000 SF 5 >5,000 SF 7 or more Thermal System Insulation No Stipulation 3+ (Must also sample all repair patches) Miscellaneous Materials No Stipulation Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos" typically 1-3 samples based upon inspector judgement. If the analytical results indicated that all the samples collected per HA did not contain asbestos, then the HA (material) would be considered a non-acbm. However, if the analytical results of one or more of the samples collected per HA indicate that asbestos is present in quantities of greater than 1 percent asbestos by weight (as defined by EPA), all of the HA (material) would be treated as an ACBM regardless of any other analytical results. Materials which can visually be determined to be non-asbestos (i.e., fibrous glass, foam rubber, etc.) by the accredited inspector are not required to be sampled. Miscellaneous materials require adequately representative sampling, which is typically done by collecting from one to three samples per material. Inspectors typically rely on other survey observations such as the condition, friability, and quantity of material to determine what would be a sufficient amount of samples to accurately evaluate the presence or absence of asbestos content. 5

9 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY Actual collection of a bulk asbestos sample involves physically removing a small piece of material and placing it in a marked, airtight container. Sample containers are marked with a unique identification number, which is also noted in the field notes. 4.4 Suspect Asbestos-Containing Material Eleven (11) bulk asbestos samples were collected from the building and analyzed by Polarized Light Microscopy (PLM) based on the number of distinct layers (materials) associated with each bulk sample. For example, floor tile and associated mastic are collected as one bulk sample but are analyzed as two distinct materials by the asbestos laboratory, as required by NVLAP. A summary of identified, accessible suspect and confirmed ACBMs follows: TABLE 1: ACBM BULK SAMPLING RESULTS WAL-MART # HIGHWAY 51 NORTH RIPLEY, TENNESSEE Material (Classification) Location of Material Condition Friable Yes/No Quantity (NESHAP Category) Asbestos Content 12" x 12" White with Gray Floor Tile and Yellow Mastic Front of Store, Break Room, Back Rooms, and Sales Floor Good No NA ND Cove Base Adhesive, Tan Vision Center, Tenant Stores, Auto, Sales Floor, and Perimeter Walls Good No NA ND Drywall and Joint Compound Hair Care, Produce, Vision Center, Deli, Stockroom, and throughout building Good No NA ND Gray 3/32 Seamless Flooring Meat Prep Area, Dry Produce, Bakery Good No NA ND ND =, NA = Not Applicable 6

10 Sampling Limitations Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY ATC did not conduct any destructive investigation (cutting selective access holes in walls, ceilings, pipe chases, mechanical equipment, etc. to assess concealed materials). ATC did not conduct sampling of the roofing materials or of suspect materials that may be present in movable equipment such as freezers, kitchen equipment and hoods. ATC typically investigated for flooring beneath carpeting by lifting small corner sections of carpet. If tiles were seen, they have been identified in the report. If tiles were not seen at corners under the carpet it does not imply that there are no tiles beneath the carpeted floor. ATC did not conduct any destructive investigation on floors to identify multilayered tile/underlayment systems/concealed paper, vapor barriers, floor tiles/mastics under wood floor systems. ATC did not conduct any destructive investigation of doors in the building to determine if the doors were insulated for fire-rating purposes. ACBM may be present at the site in inaccessible or concealed spaces. These spaces include, but are not limited to, pipe chases, spaces between wall/ceiling/door/floor cavities, interior of mechanical components such as boiler cavities, interior ducts, beneath foundation pads, etc. If future maintenance/renovation/demolition activities make these areas accessible, ATC recommends that a thorough assessment of these spaces be conducted at that time to identify and confirm the presence or absence of additional ACBMs. Until then, all such unidentified materials should be treated as Presumed ACM (PACM) in accordance with 29 CFR and Laboratory Analytical Results Bulk samples were analyzed by ATC Associates laboratory located in Centennial, Colorado, using PLM according to EPA method 600/M This laboratory participates in the NVLAP, a quality assurance program for PLM, and is accredited by the National Institute of Standards and Technology (NIST). 7

11 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY Any material that contains greater than 1 percent asbestos by PLM is considered an ACBM and must be handled according to OSHA, EPA, and applicable state and local regulations. For Friable materials, when the amount of asbestos in the sample material is reported as None-Detected by PLM analysis, no further verification of the sample results by Point Counting Methodology is recommended. For friable materials, when the amount of asbestos in the sample material is reported as Trace Asbestos Detected or less than 10% asbestos by PLM analysis, the client may either assume the amount to be greater than 1% and treat the material as ACBM or require further verification of the amount by Point Counting Methods. If the result obtained by Point Counting is different from the result obtained by PLM analysis, the Point Count Method result should be used. ATC was not authorized to conduct such analysis. For non-friable materials, when the amount of asbestos in the sample material is reported as greater than 1% asbestos by PLM analysis, no further verification of the sample results by alternative methods of identification such as Transmission Electron Microscopy (TEM) Chatfield Method is recommended. For non-friable materials such as vinyl/asphaltic products (floor tiles/ floor sheeting, mastics, shingles etc), where small, thin asbestos fibers may have been potentially milled into the non-organic binder matrix, when the amount of asbestos in the sample material is reported as Non-Detected by PLM analysis, due to the difficulty in analyzing such small, thin asbestos fibers in resinously bound materials by PLM analysis, EPA recommends that these types of materials, which were reported as non-acbms by PLM, be further analyzed using TEM Chatfield Method. ATC was not authorized to conduct such analysis. Copies of the laboratory analytical report and corresponding chain-of-custody documents are included in Appendix A. Results are reported in percent asbestos by volume and 8

12 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY indicate the types of asbestos. Other common non-asbestos components may also be noted on the analytical reports. A site drawing showing sample locations is provided in Appendix B, and a photo log is provided in Appendix C. Inspector and laboratory accreditations are provided in Appendix D. 5.0 RECOMMENDATIONS AND CONCLUSIONS The results of the asbestos survey conducted of the site building located at the Wal-Mart #0097 in Ripley, Tennessee indicate that none of the accessible suspect building materials sampled were found to contain more than 1% asbestos. As a result, no recommendations are warranted at this time. Contractors and employees working in this building should be made aware of the possibility that concealed ACBMs may be found during demolition/renovation. They should be advised not to disturb known or suspect ACBMs without owner approval. Any concealed building materials discovered during maintenance or renovation activities, which are suspected to contain asbestos, should be sampled and analyzed to confirm the presence of asbestos prior to disturbing. The EPA has not prohibited the manufacture and import of miscellaneous materials, such as vinyl floorings, mastics, roofing materials, etc. As a result, any future replacement materials should be checked for the presence of asbestos prior to installation. 6.0 ASSUMPTIONS AND LIMITATIONS The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during ATC s inspection of the Wal-Mart #0097 building located at 628 Highway 51 North, Ripley, Tennessee. 9

13 Wal-Mart #0097 Ripley, TN LIMITED ASBESTOS-CONTAINING BUILDING MATERIALS SURVEY Please note that only interior finishes were sampled for the purposes of this report. The selection of sample locations and frequency of sampling was based on ATC s observations and the assumption that like materials in the same area are homogeneous in content. Destructive investigation was not conducted as proposed. Concealed ACBMs may exist in concealed areas not investigated or identified. The report is designed to aid the client in understanding the extent of ACBM issues as they pertain to the planned renovation/demolition areas of the site building areas. Under no circumstances is the report to be utilized as a bidding document or as a project specification document since it does not have all the components required to serve as an Asbestos Abatement Project Design document or an Abatement Workplan. Our professional services have been performed, our findings obtained, and our conclusions and recommendations prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated. 10

14 APPENDIX A ACM LABORATORY ANALYTICAL RESULTS

15 ANALYTICAL REPORT Prepared for: ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis, MO Project: Order#: Report Date: Wal-Mart Stores, Inc./Wal-Mart Store # /21/2006 ATC ASSOCIATES, INC E. Nichols Avenue, Suite 350, Centennial, CO Ph:

16 Client: PLM REPORT SUMMARY 8985 E. Nichols Avenue, Suite 350 Centennial, CO Fax NVLAP Lab Code AIHA Lab Code Rod Cooper ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis MO Project: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Client Project No.: Identification: N/A Test Method: EPA Method 600/M ; 600/R-93/116 ATC Job No.: S Batch No.: Report Date: 07/21/2006 Sample Date: 07/19/2006 Date Analyzed: 07/21/2006 Page 1 of 3 Client No. Lab No. Sample Description / Location Asbestos Content FT/M-1A LAYER 1 12"x12" Floor Tile, White Emergency Exit Hardware FT/M-1A LAYER 2 12"x12" Floor Tile Mastic, Yellow Emergency Exit Hardware FT/M-1B LAYER 1 12"x12" Floor Tile, White Personnel/Training Office FT/M-1B LAYER 2 12"x12" Floor Tile Mastic, Yellow Personnel/Training Office FT/M-1C LAYER 1 12"x12" Floor Tile, Doors to Stockroom Between Grocery & GM FT/M-1C LAYER 2 12"x12" Floor Tile Mastic, Doors to Stockroom Between Grocery & GM CB/A-2A Vinyl Cove Base Adhesive, Tan/ Yellow Emergency Exit Hardware CB/A-2B Vinyl Cove Base Adhesive, Tan/ Yellow Personnel/Training Office These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested. The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

17 Client: PLM REPORT SUMMARY 8985 E. Nichols Avenue, Suite 350 Centennial, CO Fax NVLAP Lab Code AIHA Lab Code Rod Cooper ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis MO Project: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Client Project No.: Identification: N/A Test Method: EPA Method 600/M ; 600/R-93/116 ATC Job No.: S Batch No.: Report Date: 07/21/2006 Sample Date: 07/19/2006 Date Analyzed: 07/21/2006 Page 2 of 3 Client No. Lab No. Sample Description / Location Asbestos Content CB/A-2C Vinyl Cove Base Adhesive, Tan/ Doors to Stockroom Between Grocery & GM DW/JC-3A LAYER 1 Mastic, Yellow Personnel/Training Office DW/JC-3A LAYER 2 Joint Compound, White Personnel/Training Office DW/JC-3A LAYER 3 Drywall, White/ Tan Personnel/Training Office DW/JC-3B LAYER 1 Joint Compound, White Storage Room Wall of GM DW/JC-3B LAYER 2 Drywall, White/ Tan Storage Room Wall of GM DW/JC-3C LAYER 1 Joint Compound, White Stockroom Wall Between Dairy & Meat These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested. The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

18 Client: PLM REPORT SUMMARY 8985 E. Nichols Avenue, Suite 350 Centennial, CO Fax NVLAP Lab Code AIHA Lab Code Rod Cooper ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis MO Project: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Client Project No.: Identification: N/A Test Method: EPA Method 600/M ; 600/R-93/116 ATC Job No.: S Batch No.: Report Date: 07/21/2006 Sample Date: 07/19/2006 Date Analyzed: 07/21/2006 Page 3 of 3 Client No. Lab No. Sample Description / Location Asbestos Content DW/JC-3C LAYER 2 Drywall, White/ Tan Stockroom Wall Between Dairy & Meat FT/M-4A /32" Seamless Flooring, Gray/ Multi-colored Note: No Mastic Meat Prep Room FT/M-4B /32" Seamless Flooring, Gray/ Multi-colored Note: No Mastic Dry Produce Prep Area These samples were analyzed by layers. Specific layer or component asbestos content is indicated when relevant. The EPA considers a material to be asbestos containing only if it contains more than one percent asbestos by Calibrated Visual Area Estimation (CVAE). EPA regulations also indicate that Regulated Asbestos Containing Materials (RACM) -- materials which are friable or may become friable -- be further analyzed by point counting when the results indicate less than ten percent asbestos by CVAE. Our laboratory utilizes CVAE on a routine basis and does not include point counting unless specifically requested. The results may not be reproduced except in full, and should not be used as a scope of work for abatement without consulting with ATC.

19 BATCH NO NVLAP Lab Code AIHA Lab Code Rod Cooper ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis MO Collected: 07/19/2006 Collected By: Rod Cooper Collection Address: 628 Hwy 51 N. Ripley, TN Client Project No.: Description: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Date Received: 07/20/2006 Date Analyzed: 07/21/2006 Date Reported: Comments: /21/2006 Lab ID Sample # Sample Location / Sample Description Asbestos Constituents (%) Non-Asbestos Constituents (%) FT/M-1A Emergency Exit Hardware LAYER 1 12"x12" Floor Tile, White Carbonates Binder/Filler 60% 40% LAYER 2 12"x12" Floor Tile Mastic, Yellow Binder/Filler 100% FT/M-1B Personnel/Training Office LAYER 1 12"x12" Floor Tile, White Carbonates Binder/Filler 60% 40% LAYER 2 12"x12" Floor Tile Mastic, Yellow Binder/Filler 100% Doors to Stockroom Between Grocery & GM LAYER 1 12"x12" Floor Tile, White Carbonates Binder/Filler 60% 40% LAYER 2 12"x12" Floor Tile Mastic, Yellow Cellulose Fiber (Incom) 5% Binder/Filler 95% Emergency Exit Hardware CB/A-2A Vinyl Cove Base Adhesive, Tan/ Yellow Binder/Filler 100% CB/A-2B Personnel/Training Office Vinyl Cove Base Adhesive, Tan/ Yellow Cellulose Fiber (Incom) 10% Binder/Filler 90% Doors to Stockroom Between Grocery & GM Vinyl Cove Base Adhesive, Tan/ Yellow Cellulose Fiber (Incom) 5% Binder/Filler 95% Analyzed by: Reviewed by: Page 1 of 2

20 BATCH NO NVLAP Lab Code AIHA Lab Code Rod Cooper ATC Associates Inc.-St. Louis 8233 Brentwood Industrial Drive St. Louis MO Collected: 07/19/2006 Collected By: Rod Cooper Collection Address: 628 Hwy 51 N. Ripley, TN Client Project No.: Description: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Date Received: 07/20/2006 Date Analyzed: 07/21/2006 Date Reported: Comments: /21/2006 Lab ID Sample # Sample Location / Sample Description Asbestos Constituents (%) Non-Asbestos Constituents (%) Personnel/Training Office DW/JC-3A LAYER 1 Mastic, Yellow Binder/Filler 100% LAYER 2 Joint Compound, White Carbonates Binder/Filler 65% 35% LAYER 3 Drywall, White/ Tan Cellulose Fiber (Incom) 30% Gypsum 70% DW/JC-3B Storage Room Wall of GM LAYER 1 Joint Compound, White Carbonates Binder/Filler 65% 35% LAYER 2 Drywall, White/ Tan Cellulose Fiber (Incom) 25% Gypsum 75% DW/JC-3C Stockroom Wall Between Dairy & Meat LAYER 1 Joint Compound, White Carbonates Binder/Filler 65% 35% LAYER 2 Drywall, White/ Tan Cellulose Fiber (Incom) 40% Gypsum 60% FT/M-4A Meat Prep Room 3/32" Seamless Flooring, Gray/ Multi-colored Note: No Mastic Aggregate Non-Fibrous Material 35% 65% FT/M-4B Dry Produce Prep Area 3/32" Seamless Flooring, Gray/ Multi-colored Note: No Mastic Aggregate Non-Fibrous Material 35% 65% Analyzed by: Reviewed by: Page 2 of 2

21 8985 E. Nichols Avenue, Suite 350 Centennial, CO Fax Client: PLM REPORT SUMMARY Rod Cooper ATC Job No.: S ATC Associates Inc.-St. Louis Batch No.: Brentwood Industrial Drive Report Date: 07/21/2006 St. Louis MO Sample Date: 07/19/2006 Project: Wal-Mart Stores, Inc./Wal-Mart Store #0097 Date Analyzed: 07/21/2006 Client Project No.: Identification: N/A Test Method: EPA Method 600/M ; 600/R-93/116 NVLAP Lab Code AIHA Lab Code Page 1 of 1 PLM Analysis Methodology PLM samples were analyzed utilizing the Environmental Protection Agency's Test Method: Method for the Determination of Asbestos in Building Materials (EPA 600/R-93/116. July, 1993). Reporting Limit <1% Asbestos. Additional treatment and tests may be required to accurately define composition (i.e. ashing, extractions, acetone treatment, andtem). Unused portions of samples are archived for one year unless client requests special handling. Asbestos content of mastic/adhesive is separated from total percent asbestos and other materials. Laboratory Equipment Laboratory analysis was accomplished utilizing an Olympus BH-2 polarized light microscope. The microscope is equipped with dispersion staining lenses. Quality Control ATC Associates, Inc. is accredited by NVLAP Bulk Asbestos Sample Quality Assurance Program (Lab Code ) and AIHA (Lab Code ). ATC participates in the NVLAP and AIHA Bulk Asbestos Sample Quality Assurance Programs and maintains an in-house QC/QA program for bulk samples whereby 10% of all submitted samples are reanalyzed and documented in a Quality Control Manual. ATC also participates in a quarterly round robin QC/QA program for bulk samples with several accredited laboratories throughout the United States. Current and past QC/QA program results are available in the laboratory for inspection. Laboratory Personnel Samples were analyzed by Jeff Lomme, Laboratory Director. Mr. Lomme is a professional geologist who has successfully completed the McCrone Institutes's "Advanced Asbestos Identification" Course. Approved Signatory : Jeff Lomme NVLAP LAB CODE The non-detection of asbestos fibers in floor tile by PLM is of itself inconclusive. Confirmation by Transmission Electron Microscope (TEM) is recommended for negative floor tile samples. This report must not be used by the client to claim product endorsements by NVLAP or an agency of the U.S. government. This test reports only to the items stated.

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23 APPENDIX B SAMPLE LOCATION DRAWING

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25 APPENDIX C PHOTO LOG

26 Wal-Mart Store, Inc. Store #0097 Ripley, Tennessee Pictures Taken: July 19, 2006 Photo 1: Front Exterior of Wal-Mart Store Photo 2: Sample FT/M-1A 12 x 12 White Floor Tile and Mastic at Emergency Exit Doors in Hardware Photo 3: Sample CB/A-2A 4 Vinyl Cove Base Adhesive at Emergency Exit Doors in Hardware Photo 4: Sample FT/M-1B 12 x 12 White Floor Tile and Mastic at Personnel/Training Office Photo 5: Sample CB/A-2B 4 Vinyl Cove Base Adhesive at Personnel/Training Office Photo 6: Sample DW/JC-3A Drywall/Joint Compound at Personnel/Training Office Project No ATC Associates Inc.

27 Wal-Mart Store, Inc. Store #0097 Ripley, Tennessee Pictures Taken: July 19, 2006 Photo 7: Sample DW/JC-3B Drywall/Joint Compound of Storage Room Wall Photo 8: Sample FT/M-1C 12 x 12 White Floor Tile and Mastic at Doors to Stockroom Photo 9: Sample CB/A-2C 4 Vinyl Cove Base Adhesive at Doors to Stockroom Photo 10: Sample DW/JC-3C Drywall/Joint Compound of Stockroom Wall between Dairy and Meat Coolers Photo 11: Sample FT/M-4A Gray 3/32 Seamless Flooring in Meat Prep Room Photo 12: Sample FT/M-4B Gray 3/32 Seamless Flooring in Dry Produce Prep Area Project No ATC Associates Inc.

28 APPENDIX D INSPECTOR AND LABORATORY ACCREDITATIONS

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