ASBESTOS AND LEAD BASED PAINT SURVEY HIGH MAR PROPERTY 4990 MOORHEAD AVENUE BOULDER, COLORADO

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1 ASBESTOS AND LEAD BASED PAINT SURVEY HIGH MAR PROPERTY 4990 MOORHEAD AVENUE BOULDER, COLORADO Prepared for: Boulder Housing Partners 4800 North Broadway Boulder, Colorado Attention: Ms. Shannon Cox Baker Project No. DN44, March 17, West 12th Avenue Denver, Colorado Phone: Fax:

2 TABLE OF CONTENTS EXECUTIVE SUMMARY... i INTRODUCTION... 1 SITE OBSERVATIONS... 1 REGULATORY BACKGROUND... 1 Asbestos... 1 Lead Based Paint/Lead Containing Paint... 2 BUILDING MATERIAL SAMPLING... 3 SAMPLE ANALYSIS... 3 INSPECTION RESULTS... 4 CONCLUSIONS AND RECOMMENDATIONS... 5 Special Considerations... 6 LIMITATIONS... 8 FIG. 1 SAMPLE LOCATION MAP INTERIOR MAIN BUILDING FIG. 2 SAMPLE LOCATION MAP EXTERIOR APPENDIX A TABLES OF THE SUSPECT ACMS IDENTIFIED, SAMPLED, AND ANALYZED APPENDIX B PHOTOS SAMPLED MATERIALS APPENDIX C LABORATORY ANALYTICAL DATA SHEETS APPENDIX D SUMMARY OF ASBESTOS REGULATIONS APPENDIX E CITY OF BOULDER AND COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT INFORMATION APPENDIX F BUILDING INSPECTOR S CERTIFICATION BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

3 EXECUTIVE SUMMARY CTL Thompson Inc (CTL) was retained by Boulder Housing Partners to conduct a limited asbestos and lead sampling of the High Mar Property located at 4990 Moorhead Avenue in Boulder, Colorado. The following items were determined to contain asbestos based on our findings: Sink Undercoating. In addition, Dry Wall Joint Compound was found to contain asbestos. As such, the Drywall System as a whole is defined as OSHA Drywall (less than 1% asbestos). Based on our findings the following painted surfaces are identified as lead based paint: Light Blue Paint on Picnic Shelter; Blue Exterior Paint Main Building and Shed; Blue Interior Paint; and, White Interior Paint on wood Trim. Based on conversations with Boulder Housing Partners prior to our survey it is unclear as to the method of demolition of the site building and improvements. The City of Boulder has developed a Green Building and Green Points program, which has mandatory Green Building and Green Point requirements associated with the type and size of the project. In particular the Green Building and Green Points Application requires that applicants will demonstrate that at least 65% of material by weight from the deconstruction of the existing structure (including concrete and asphalt) will be diverted from the landfill by providing a deconstruction plan. BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc i

4 Part of this requirement of the Green Building and Green Points Application requires that applicants submit a Deconstruction Plan and Construction Waste Recycling Form, which we have included in Attachment E. As a result we recommend the following: Avoid activities that will render the asbestos friable or impact painted surfaces containing lead (i.e. sanding, scraping, grinding, etc.) Boulder Housing Partners should obtain a free deconstruction assessment with a deconstruction professional, such as ReSource. As part of the assessment Boulder Housing Partners will receive a material inventory indicating which materials, equipment and interior finishes may be utilized to attain the mandatory diversion rate. A deconstruction plan should be developed, which details the building materials that will be recycled, donated for tax deduction, and sent to the landfill. The deconstruction plan should also detail procedures for dealing with the Asbestos Containing Building Materials (ACBMs) and Lead Based Paints to prevent worker exposure and improper handling and disposal. Submit a completed demolition permit to Colorado Department of Public Health and Environment. Permit must be completed to obtain sign off by Boulder County Health Department, a requirement on the City of Boulder demolition permit. Copies of CDPHE permit and City of Boulder permit are included in Attachment E. We additionally observed items which are defined as Regulated Building Materials. These are materials that may contain mercury, such as fluorescent light bulbs, and thermostats. In addition, light ballasts may contain PCBs. In total we observed 11, two bulb fluorescent lighting fixtures, and thermostats associated with some of the pool mechanical equipment. These items should not just be disposed of as general waste. In most cases they can be recycled. It should be noted that the results of our surveys reveal materials which contain asbestos, and surfaces with lead based paint, which is common for the age of the building. It is expected that other homes and commercial buildings constructed at the same time in the surrounding area would have similar findings. Not all the details of the report are presented in the Executive Summary and the entire report should be read. BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc ii

5 INTRODUCTION CTL Thompson, Inc. (CTL) was requested by Boulder Housing Partners to conduct an asbestos and lead based paint (LBP) survey of the building to evaluate the potential hazards associated with the deconstruction of the site building and exterior features. The Asbestos and Lead Survey was conducted in general accordance with the contract signed by Boulder Housing Partners and CTL, dated February 16, SITE OBSERVATIONS The High Mar property is developed building with a one-story office. The exterior is constructed of generally brick with a composite roof. The interior contains concrete flooring covered with paint, rubber matting and ceramic tile; walls consisting of brick, ceramic block; and ceilings consisting of drywall. One wood picnic shelter, a painted shed, a kiddie pool, larger pool and tennis courts are included at the site. Samples were collected at the sites on February 19, 2010 by Colorado State Certified Building Inspector Mr. Nick Talocco (Certification No. 4173) who visually surveyed readily accessible areas within the indicated buildings. Lead certification for sampling in the State of Colorado is presently only required for residences and child-occupied facilities. Presently the facility is not being used in this manner. REGULATORY BACKGROUND Asbestos An ACM is defined as any material that contains greater than 1.0 percent asbestos as determined by laboratory analysis. The Environmental Protection Agency (EPA) and the Occupational Safety & Health Administration (OSHA) distinguish between friable and non-friable forms of ACM. Friable materials can be crumbled or reduced to powder by hand pressure when dry. Non-friable materials BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 1

6 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 ACMs is important. The EPA further distinguishes non-friable ACMs as Category I and Category II. Category I non-friable ACMs include gaskets, resilient floor coverings, and asphalt roofing products. The removal of these ACMs is generally not required prior to demolition, if they are in good condition. Category II ACMs are all other non-friable ACMs and must be removed prior to normal demolition. Whether removed or remaining in a structure during renovation and/or demolition, the confirmed or presumed ACMs are subject to USEPA National Emission Standards for Hazardous Air Pollutants (NESHAP) and OSHA regulations. NESHAP requires that each owner or operator of a demolition activity provide the administrator with written notice of intent. The administrator within the State of Colorado is the Colorado Department of Public Health and the Environment (CDPHE). A demolition permit application must be completed and submitted to CDPHE ten working days prior to demolition. In general, suspect building materials which are, by regulation, not sampled are presumed to contain asbestos. Lead Based Paint/Lead Containing Paint The U.S. Department of Housing and Urban Development (HUD) and the Environmental Protection Agency (EPA) identify lead-based paint as any paint, varnish, shellac or other coating that contains lead in concentrations that are equal to or in excess of one milligram per square centimeter (1.0 mg/cm 2 ) or 0.5% by weight (5,000 parts per million - ppm). OSHA recognizes lead containing paint (LCP) as paint that contains any detectable amount of lead. Therefore for worker exposure, lead containing paint is any paint that contains in excess of 0.0 mg/cm 2 which may exceed OSHA BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 2

7 requirements as established in 29 CFR (Interim Lead in Construction Standard) during renovation, construction, and abatement activities. A summary of regulations that govern asbestos identification, management, abatement work, or shipment and disposal of asbestos waste materials along with regulations pertaining to lead based paint are presented in Appendix D. BUILDING MATERIAL SAMPLING Homogeneous building materials suspected of containing asbestos were identified and bulk samples of the materials were collected in a random and representative manner, as deemed appropriate by our representative. The samples were collected with the aid of hand tools, placed in individual sealed containers, and labeled with a unique identification number. The sampling was performed utilizing generally accepted asbestos practices and procedures. Exterior pavements, structural concrete, underground utilities, electrical wiring, and roofing materials were not included in the scope of the survey. Furthermore, the survey did not include the demolition of wall, ceiling, or floor systems in order to observe hidden conditions or materials. Painted surfaces were identified. Surfaces which appeared to be similar in color and application date where considered to be homogenous. The paint chip samples were collected in accordance with the HUD 1998 Inspection Protocol and in a random and representative manner, as deemed appropriate. The paint chip samples were collected with the aid of hand tools, and placed in individual sealed containers, and labeled with a unique identification number. SAMPLE ANALYSIS The bulk asbestos samples were delivered, using proper chain of custody procedures, to Reservoirs Environmental for analysis. Reservoirs Environmental is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP). BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 3

8 The samples were analyzed by Polarized Light Microscopy (PLM) to evaluate the asbestos content. Using the PLM method, the percentage of asbestos is determined by visual estimation. The samples were analyzed by individual layer. Unused portions of samples are archived for sixty days, unless the client requests special handling. Each surfacing homogeneous material generally requires a minimum of 3, 5, or 7 samples be collected per set (depending on the type and/or square footage of the material). Number of samples collected from homogenous miscellaneous building materials is left to the building inspector s discretion. Tables of the suspect ACMs identified, sampled, and analyzed during the survey and figures showing the approximate sample locations are presented in Appendix A. The laboratory analytical reports and chain-of-custody documentation are included in Appendix C. The paint chip samples were delivered, using proper chain of custody procedures to Reservoirs Environmental for analysis. Reservoirs Environmental is accredited laboratory by American Industrial Hygiene Association (AIHA). The samples were analyzed by flame automatic absorption (FAA) according to EPA SW846 method INSPECTION RESULTS The location and approximate quantity of the ACMs identified during this limited survey are presented below. General Area: Ceiling Building Material: Tan Drywall Joint Compound Material Type: Miscellaneous Material Condition: Friable / Not Damaged with Potential for Damage Approximate Material Quantity: Total Ceiling area 1,400 sf, Joint Compound 15 sf Asbestos Content: 3% Point Count 1.25 to 1.5 BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 4

9 General Area: Underside of metal sink Office Building Material: Black Sink Under Coating Material Type: Miscellaneous Material Condition: Non-Friable / Not Damaged with Potential for Damage Approximate Quantity: ~ 1 EA Asbestos Content: 6% The results of the paint chip sampling, and general location of the lead paint is presented in Table I below. Table I Paint Chip Sampling Results Sample ID Paint Description and General Location Lead Concentrations (mg/cm 2 ) LBP Light Blue Paint on Picnic Shelter LBP Blue Paint Exterior Main building and Shed 2505 LBP Red Paint Pool BRL LBP White Paint Pool BRL LBP Interior White Paint BRL LBP Gray Paint on Interior Concrete Floor BRL LBP Blue Interior Paint 2575 LBP White Interior Paint on Wood LBP Orange Exterior Paint on Brick BRL Notes: BRL Below Regulated Limit Bold Indicates Lead Containing Paint CONCLUSIONS AND RECOMMENDATIONS The following items were determined to contain asbestos based on our findings: Steel Sink Undercoating. In addition, Dry Wall Joint Compound was found to contain asbestos. As such, the Drywall System as a whole is defined as OSHA Drywall (less than 1% asbestos). Based on our findings the following painted surfaces are identified as lead based paint: BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 5

10 Light Blue Paint on Picnic Shelter; Blue Exterior Paint Main Building and Shed; Blue Interior Paint; and, White Interior Paint on Wood. The following recommendations apply based on our understanding that the site is planned for deconstruction, so to meet the requirements of the City of Boulder Green Building and Green Points Application. Avoid activities that will render the asbestos friable or impact painted surfaces containing lead (i.e. sanding, scraping, grinding, etc.) Boulder Housing Partners should obtain a free deconstruction assessment with a deconstruction professional such as ReSource. As part of the assessment Boulder Housing Partners will receive a material inventory indicating which materials, equipment and interior finishes may be utilized to attain the mandatory diversion rate. A deconstruction plan should be developed, which details the building materials that will be recycled, donated for tax deduction, and sent to the landfill. The deconstruction plan should also detail procedures for dealing with the Asbestos Containing Building Materials (ACBMs) and Lead Based Paints to prevent worker exposure and improper handling and disposal. Submit a completed demolition permit to Colorado Department of Public Health and Environment. Permit must be completed to obtain sign off by Boulder County Health Department. A requirement on the City of Boulder demolition permit. Copies of CDPHE permit and City of Boulder permit are included in Attachment E. We additionally observed items which are defined as Regulated Building Materials. These are materials that may contain mercury, such as fluorescent light bulbs, and thermostats. In addition, light ballasts that may contain PCBs. In total we observed 11 two bulb fluorescent lighting fixtures, and thermostats associated with some of the pool mechanical equipment. These items should not just be disposed of as general waste. Some materials can be recycled. Special Considerations It should be noted that if deconstruction will be conducted by hand methods the following OSHA requirements will apply to the project: Construction Asbestos Regulation; and, OSHA Interim Lead in Construction Standard. BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 6

11 The drywall joint compound has been found to contain asbestos greater than 1%, while the drywall it is applied does not contain asbestos, as in the case of the finished drywall in the building. The percent of asbestos contained in drywall and its associated materials, including joint compound and tape, may be determined based on a representative composite sampling program to be non-acm. This means that, as a total drywall system, the drywall system is not considered ACM, but is deemed OSHA drywall. As a result OSHA asbestos regulations apply to the wall systems since the joint compound contains asbestos. The drywall joint compound will need to be removed utilizing OSHA Class II work requirements, should the deconstruction of the building be conducted by hand (i.e. workers removing drywall from wood framing). In addition, if removal of the metal sink associated with the sink undercoating will be conducted by hand, the removal will need to be performed utilizing OSHA Class II work requirements. The sink will also need to be disposed of as asbestos containing waste. OSHA requires the employer and owner s construction contractor to conduct personal air monitoring on employees during construction work where painted surfaces that contain detectable amounts of lead are impacted. OSHA defines construction work as work for the purpose of construction, alteration and/or repair (including repainting and decorating). The purpose of the exposure monitoring is to ensure that employees are not exposed to lead at concentrations that exceed the permissible exposure level (PEL) of (50 µg/m 3 ) micrograms of lead per cubic meter of air or the action level (AL) of (30 µg/m 3 ) over an 8-hour period. If deconstruction work will be conducted by hand at the site, which will impact the lead paint, the following recommendations apply: Standard work practices should be developed for construction activities that will impact the painted surfaces identified to contain lead. The standard work practice should list engineering controls that will limit worker exposure and prevent lead paint dust from migrating to different parts of the building. Contractors familiar with the OSHA Interim Lead in Construction Standard should be used for construction activities that will impact the identified lead paint surfaces. BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 7

12 LIMITATIONS As with all site assessments, the extent of information obtained is a function of client demands, time limitations, and budgetary constraints. Samples were collected in a manner designed to create minimum disturbance of occupied areas. Our representative(s) exercised judgments and made assumptions on the similarity of material throughout the building. Our representative(s) assumed that the composition of material in concealed inaccessible spaces was the same as that found in accessible locations. CTL does not imply or guarantee that every suspect ACM or lead based paint on or in the building has been identified or sampled. Historically, asbestos and lead based paint has been used extensively in the United States. This inspection was intended to identify those components that were reasonably suspect and are most likely to have ACM in quantities subject to regulation based on existing industry and regulatory standards. We do not accept liability for additional materials or underreporting of asbestos materials that exist below floor coverings, hidden in walls, or other similar locations. If additional suspect ACMs or LBPs are discovered during renovation or demolition, the materials should be sampled and handled appropriately. All quantification of ACM is approximate; the information in this report is not intended to be used as biddable document for abatement purposes repair, encapsulation, enclosure, or Operations and Maintenance (O&M) of asbestos containing materials. This report is not represented as nor intended to be an abatement specification. We can prepare bid documents, removal and repair methods/procedures, specifications, designs and O&M plans if desired. These documents, if requested, will be prepared by EPA accredited and CDPHE certified individuals. BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc 8

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16 APPENDIX A TABLES OF THE SUSPECT ACMS IDENTIFIED, SAMPLED, AND ANALYZED BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

17 HIGH MAR PROPERTY Suspect ACMs Identified, Sampled, and Analyzed Sample ID Description Friable DW DW DW A White Tape B Tan Joint Compound C Tan Compound with White Paint D White and Tan Drywall A Tan Compound with White Paint B White and Tan Drywall A White Fibrous Woven Material B White Compound White Paint C White and Tan Drywall NO YES YES NO YES NO NO YES NO Asbestos Content ND PC 1.5 PC 1.5 ND PC 1.25 ND ND ND ND RC A Brown Caulk on Mechanical Exhaust Roof NO ND RFM RFM RFM A Tan Mastic B Black Rubber Floor Material A Tan Mastic B Black Rubber Floor Material A Tan Mastic B Black Rubber Floor Material SWCW A White Plaster Finish Material on Ceramic Block Walls YES ND SWCW A White Plaster Finish Material on Ceramic Block Walls YES ND SWCW A White Plaster Finish Material on Ceramic Block Walls YES ND SWCW A White Plaster Finish Material on Ceramic Block Walls YES ND SWCW A White Plaster Finish Material on Ceramic Block Walls YES ND CLK A Tan Caulk Between Wood and Brick NO PC 0.5 CLK A Tan Caulk Between Wood and Brick NO PC 0.5 CLK A Tan Caulk Between Wood and Brick NO PC <0.25 CLK A White Caulk Women s Shower NO ND CLK A Gray Caulk by Counter Top in Office NO ND CLK A Gray Caulk Associated with Pool NO ND CLK A Gray Caulk Associated with Pool NO ND BC BC BC A Tan Mastic B 4 Black Base Cove A Tan Mastic B 4 Black Base Cove A Tan Mastic B 4 Black Base Cove SU A Black Sink Under Coating on Steel Sink, Office NO 6% WG A White Window Glazing NO ND WP A Waterproofing Material NO ND BM A Boiler Material YES ND RM RM ND = None Detected PC = Point Count A Black Felt B Black/white Shingle A Black Tar B Black Felt NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO NO ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc A-1

18 APPENDIX B PHOTOS OF SAMPLED MATERIALS BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

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23 APPENDIX C LABORATORY ANALYTICAL DATA SHEETS BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

24 Page 1 of 4 March 2, 2010 Nick Talocco CTL/Thompson (Denver) 1971 West 12th Place Denver CO Laboratory Code: RES Subcontract Number: NA Laboratory Report: RES ,2 Project # / P.O. # Project Description: HIGH MAR 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 for Transmission Electron Microscopy (TEM) and Polarized Light Microscopy (PLM) analysis and the American Industrial Hygiene Association (AIHA), Lab ID 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. RES ,2 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 Sincerely, Jeanne Spencer Orr President Analyst(s): Paul D. LoScalzo Wenlong Liu Michael Scales Rich Wegrzyn Anita Bridges James Venendaal Adam Kinch Louis A. Church Jr. Robert R. Workman Jr. P: F: Logan Street, Suite 100 Denver, CO Page 1 of RESI-ENV

25 RESERVOIRS ENVIRONMENTAL, INC. NVLAP Lab Code TDH Licensed Laboratory # Page 2 of 4 TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Analysis Type: Turnaround: Date Analyzed: RES ,2 CTL/Thompson (Denver) HIGH MAR February 22, 2010 PLM, Short Report 3-5 Day February 27, 2010 Client Lab L Asbestos Content Non Non- Sample ID Number A Sub Asbestos Fibrous Number Y Physical Part Fibrous Components E Description (%) Mineral Visual Components (%) R. Estimate (%) (%) DW EM A White tape 3 ND 95 5 B Tan joint compound 5 Chrysotile 3 TR 97 Point Count 1.5 C Tan compound w/ white paint 7 Chrysotile 3 TR 97 Point Count 1.5 D White/tan drywall 85 ND DW EM A Tan compound w/ white paint 5 Chrysotile 3 TR 97 Point Count 1.25 B White/tan drywall 95 ND DW EM A White fibrous woven material 2 ND 98 2 B White compound w/ white paint 8 ND TR 100 C White/tan drywall 90 ND RC EM A Brown resinous material 100 ND RFM EM A Tan mastic 5 ND TR 100 B Gray/black resinous material 95 ND RFM EM A Tan mastic 5 ND TR 100 B Gray/black resinous material 95 ND RFM EM A Tan mastic 8 ND TR 100 B Gray/black resinous material 92 ND ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite Note: Further analysis by TEM is recommended for organically bound material (i.e. floor tile) if PLM results are <1%. Data QA

26 RESERVOIRS ENVIRONMENTAL, INC. NVLAP Lab Code TDH Licensed Laboratory # Page 3 of 4 TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Analysis Type: Turnaround: Date Analyzed: RES ,2 CTL/Thompson (Denver) HIGH MAR February 22, 2010 PLM, Short Report 3-5 Day February 27, 2010 Client Lab L Asbestos Content Non Non- Sample ID Number A Sub Asbestos Fibrous Number Y Physical Part Fibrous Components E Description (%) Mineral Visual Components (%) R Estimate (%) (%). SWCW EM A White plaster w/ white paint 100 ND TR 100 SWCW EM A White plaster w/ white paint 100 ND TR 100 SWCW EM A Tan granular plaster w/ white/multi-colored paint 100 ND TR 100 SWCW EM A White plaster w/ white paint 100 ND TR 100 SWCW EM A White plaster w/ white paint 100 ND TR 100 CLK EM A Tan caulk w/ gray paint 100 Chrysotile 2 TR 98 Point Count 0.5 CLK EM A Tan caulk w/ white paint 100 Chrysotile 2 TR 98 Point Count 0.5 CLK EM A Tan caulk w/ blue paint 100 Chrysotile 2 TR 98 Point Count <0.25 CLK EM A White caulk 100 ND TR 100 CLK EM A Gray caulk 100 ND TR 100 CLK EM A Gray caulk 100 ND TR 100 ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite Note: Further analysis by TEM is recommended for organically bound material (i.e. floor tile) if PLM results are <1%. Data QA

27 RESERVOIRS ENVIRONMENTAL, INC. NVLAP Lab Code TDH Licensed Laboratory # Page 4 of 4 TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Analysis Type: Turnaround: Date Analyzed: RES ,2 CTL/Thompson (Denver) HIGH MAR February 22, 2010 PLM, Short Report 3-5 Day February 27, 2010 Client Lab L Asbestos Content Non Non- Sample ID Number A Sub Asbestos Fibrous Number Y Physical Part Fibrous Components E Description (%) Mineral Visual Components (%) R Estimate (%) (%). CLK EM A Gray caulk 100 ND TR 100 BC EM A Tan mastic 3 ND TR 100 B Black cove base 97 ND BC EM A Tan mastic 2 ND TR 100 B Black cove base 98 ND BC EM A Tan mastic 2 ND TR 100 B Black cove base 98 ND SU EM A Black resinous material 100 Chrysotile 6 TR 94 WG EM A White resinous material 100 ND TR 100 WP EM A Tan/multi-colored plaster 100 ND TR 100 BM EM A White/tan fibrous material 100 ND 98 2 RM EM A Black felt 20 ND B Black/white shingle 80 ND RM EM A Black tar 10 ND TR 100 B Black felt 90 ND ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite Note: Further analysis by TEM is recommended for organically bound material (i.e. floor tile) if PLM results are <1%. Data QA

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30 February 25, 2010 Laboratory Code: RES Subcontract Number: NA Laboratory Report: RES Project # / PO #: Project Description: High Mar Nick Talocco CTL/Thompson (Denver) 1971 West 12th Place Denver CO Dear Customer, Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and Environmental matrices by the American Industrial Hygiene Association, Lab ID Accreditation Certificate #480. The laboratory is currently proficient in both PAT & ELPAT programs respectively. Reservoirs has analyzed the following sample(s) using Atomic Absorption Spectroscopy (AAS) / Atomic Emission Spectroscopy - Inductively Coupled Plasma (AES-ICP) per your request. Reported sample results were not blank corrected. The analysis has been completed in general accordance with the appropriate methodology as stated in the analysis table. Results have been sent to your office. RES 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 authorized by the client. The results described in this report only apply to the samples analyzed. 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 should have any questions about this report, please feel free to call me at Sincerely, Jeanne Spencer Orr President P: F: Logan Street, Suite 100 Denver, CO Page 1 of RESI-ENV

31 RESERVOIRS ENVIRONMENTAL, INC Logan St., Suite 100 Denver CO TABLE ANALYSIS: LEAD IN PAINT RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Analysis Type: Turnaround: Date Samples Analyzed: RES CTL/Thompson (Denver) High Mar February 22, 2010 USEPA SW B / AA (7420) 3-5 Day February 24, 2010 Client Lab Reporting LEAD ID Number ID Number Limit CONCENTRATION (mg/cm2) (mg/cm2) LBP EM LBP EM ,505 LBP EM BRL LBP EM BRL LBP EM BRL LBP EM BRL LBP EM ,575 LBP EM LBP EM BRL * Unless otherwise noted all quality control samples performed within specifications established by the laboratory. BRL = Below Reporting Limit Page 2 of 2 Data Qa

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34 APPENDIX D SUMMARY OF ASBESTOS REGULATIONS BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

35 SUMMARY OF ASBESTOS REGULATIONS Requirements that govern asbestos identification, management, abatement work, or shipment and disposal of asbestos waste materials, include the following: Occupational Safety and Health Administration (OSHA), including but not limited to: Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite; Final Rules Title 29, Part 1910, Section 1001 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; Specifications for Accident Prevention Signs and Tags Title 29, Part 1910, Section 145 of the Code of Federal Regulations; and, Interim Lead in Construction Standard 29 CFR U.S. Department of Transportation (DOT), including but not limited to: Hazardous Substances Title 29, Part 171 and 172 of the Code of Federal Regulations. U.S. Environmental Protection Agency (EPA), including but not limited to: Asbestos Hazard Emergency Response Act (AHERA) Regulation; Asbestos Containing Materials in Schools Final Rule & Notice Title 40, Part 763 Subpart E of the Code of Federal Regulations; Training Requirements of (AHERA) and Asbestos in Schools Hazard Abatement Reauthorization Act (ASHARA) Regulations; Asbestos Containing Materials in Schools Final Rule & Notice Title 40, Part 763, Subpart E, Appendix C of the Code of Federal Regulations; National Emission Standard for Hazardous Air Pollutants (NESHAP); and, BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc D-1

36 National Emission Standard for Asbestos Title 40, Part 61, Subpart A, Subpart M (Revised Subpart B) of the Code of Federal Regulations. Colorado Department of Public Health and Environment (CDPHE), including but not limited to: Air Quality Control Commission, Regulation No. 8 (5CCR , Part B). Hazardous Materials and Waste Management Division, Section 5.5 of the Regulations Pertaining to Solid Waste Disposal Sites and Facilities (6 CCR ) BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc D-2

37 APPENDIX E CITY OF BOULDER AND COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT INFORMATION BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

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58 APPENDIX F BUILDING INSPECTOR S CERTIFICATION BOULDER HOUSING PARTNERS HIGH MAR PROPERTY 4990 MOORHEAD AVENUE CTL І T PROJECT NO. DN44, S:\PROJECTS\44700\DN \221\2. Reports\R1\DN R1.doc

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