DOMINION

December 3, 2018

Dr. Dennis Goodwin

Murphy School District
2615 West Buckeye Road
Phoenix, AZ 85009

RE: Limited Fungal and Lead Paint Inspection

Alfred F. Garcia Elementary School
1441 South 27th Avenue
Phoenix, AZ 85009

Dominion Project Number: AZ0946.32

Dear Dr. Goodwin,

Pursuant to your request, Dominion Environmental Consultants, Inc. (Dominion) conducted a

limited fungal and lead paint inspection at Alfred F. Garcia Elementary School on September 13,
October 17, October 23 and November 13, 2018.

BACKGROUND

Dominion was informed by Murphy Elementary School District (MESD) personnel that concerns
over the air quality inside Alfred F. Garcia Elementary School had been raised by several staff members.
Dominion was directed to perform an initial visual inspection inside Alfred F. Garcia Elementary School
for any signs of water damage or suspect fungal growth and to collect one (1) lead paint chip sample
from the plaster walls in the affected areas on September 13, 2018. Based on the findings of the visual
inspection and the results of the lead paint chip sampling, Dominion was then directed to perform fungal
spore trap air sampling and lead wipe sampling in the affected areas on October 17, October 23 and
November 13, 2018.

RELEVANT OBSERVATIONS

*Note: Only rooms within the affected areas are included in these observations. All other rooms
showed no signs of water damage or suspect fungal growth. Listed below, separated by room, are the
specific visual observations:

DOMINION ENVIRONMENTAL CONSULTANTS, INC.

20045 North 19th Avenue, Building 7, Phoenix, Arizona 85027
Tel: (623) 516-1415 Fax: (623) 516-0017
www.dominion-env.com
 Office and Workroom – Visible water damage and suspect fungal growth was observed on the
drywall ceiling in the Front Office, Storage Room and Teacher Workroom.
 Room 2 - Water damage and suspect fungal growth was observed beneath the sink in the
southwest corner of the room.
 Room 4 - Water damage and suspect fungal growth was observed beneath the sink in the
southwest corner of the room.
 Room 5 - Water damage and suspect fungal growth was observed beneath the sink in the
southeast corner of the room.
 Room 6 – Water damaged ceiling tiles, water damage above the ceiling grid and suspect fungal
growth was observed on the north side of the room.
 Room 10/Lounge - Water damaged ceiling tiles, water damage above the ceiling and suspect
fungal growth grid was observed in the Lounge and in the Bilingual Room.
 Room 11 – Water damage and suspect fungal growth was observed on the plaster and skim coat
beneath the paint along the north exterior wall of the room.
 Room 13 - Water damage and suspect fungal growth was observed beneath the sink in the
northwest corner of the room. Water damaged ceiling tiles and water damage and suspect fungal
growth above the ceiling grid was observed.
 Room 22 - Water damage and suspect fungal growth was observed beneath the sink in the
northeast corner of the room.
 Room 24 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth was observed on the plaster
and skim coat beneath the paint along the south exterior wall of the room.
 Room 25 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth was observed on the plaster
and skim coat beneath the paint along the south exterior wall of the room.
 Room 26 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed throughout the room.
 Room 27 - Water damaged ceiling tiles and water damage above the ceiling grid and suspect
fungal growth was observed. Water damage and suspect fungal growth was observed beneath the
sink in the southeast corner of the room. Water damage and suspect fungal growth on the plaster
and skim coat beneath the paint along the south exterior wall of the room was observed.
 Room 28 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed throughout the room.
 Room 29 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed throughout the room.
 Room 30 - Water damage and suspect fungal growth was observed beneath the sink in the
northeast corner of the room. Water damaged ceiling tiles and water damage and suspect fungal
growth above the ceiling grid was observed on the west side of the room.
 Room 31 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed on the west side of the room.
 Room 32 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.
 Room 33 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.

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  Room 34 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.
 Room 35 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.
 Room 36 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.
 Room 37 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed. Water damage and suspect fungal growth on the plaster and skim coat
beneath the paint along the north exterior wall of the room was observed.
 Room 43 - Water damaged ceiling tiles and water damage and suspect fungal growth above the
ceiling grid was observed.
 Storage Rooms – Water damage and suspect fungal growth on the drywall ceiling in the Storage
Rooms adjacent to Rooms 29 and 32 was observed.

See Exhibit 1-“Photo Log – Water Damage” and Exhibit 2-“Water Damage Location Map” for more
detailed observations.

FUNGAL SAMPLING

Sampling Techniques - Spore Trap Ambient Air Sampling

A Buck BioAire sampling pump and Zefon Air-O-Cell cassettes were utilized to collect spore trap
air samples from the indoor and outdoor ambient air. Spore trap samples determine total fungal spore
counts (both viable and non-viable) in the air. The air sampling technique is performed by drawing the
air through the Zefon cassette. The air impacts an adhesive surface within the sealed cassette housing
and airborne particulate is trapped onto the surface by adhesion. The samples are examined
microscopically to quantify and identify the fungal spores present in the air.

The intake air flow to the sampler is calibrated at 15 L per minute. All ambient air cassette samples,
both indoor and outdoor, were collected at 15 L per minute for five minutes. After sample collection, the
cassettes were transported under chain of custody to the laboratory for analysis. The analytical results
are expressed as total spore counts per cubic meter of air.

ANALYTICAL RESULTS

Spore Trap Ambient Air Sample Analysis

On October 17, 2018, Dominion collected twenty-two (22) spore trap air samples from inside the
affected areas at Alfred F. Garcia Elementary School. Two (2) additional ambient spore trap air samples
were collected from the outdoor air for use as comparison control samples. Below is a list of the sample
locations. (See Exhibit 3-“Spore Trap Air Sample Location Map-10/17/18” for detailed locations.)

 AZ0946.32-AC-1 Outdoors - Northwest

 AZ0946.32-AC-2 Outdoors – Southwest
 AZ0946.32-AC-3 Room 37
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  AZ0946.32-AC-4 Room 36
 AZ0946.32-AC-5 Room 35
 AZ0946.32-AC-6 Room 34
 AZ0946.32-AC-7 Room 33
 AZ0946.32-AC-8 Room 32
 AZ0946.32-AC-9 Room 31
 AZ0946.32-AC-10 Room 30
 AZ0946.32-AC-11 Room 29
 AZ0946.32-AC-12 Room 28
 AZ0946.32-AC-13 Room 27
 AZ0946.32-AC-14 Room 26
 AZ0946.32-AC-15 Room 25
 AZ0946.32-AC-16 Room 24
 AZ0946.32-AC-17 Room 23
 AZ0946.32-AC-18 Room 22
 AZ0946.32-AC-19 Room 13
 AZ0946.32-AC-20 Room 12
 AZ0946.32-AC-21 Room 11
 AZ0946.32-AC-22 Room 10 (Lounge)
 AZ0946.32-AC-23 Room 9
 AZ0946.32-AC-24 Front Office

The laboratory analytical data indicated slightly elevated airborne fungal spore counts in one (1) of
the spore trap air samples collected from Room 13, when compared to the analytical data from the
outdoor air samples (see Exhibit 4-“Spore Trap Air Sample Analysis Report-10/17/18”). Dominion
recommended that Room 13 be re-sampled on October 23, 2018.

On October 23, 2018, Dominion collected one (1) spore trap air re-sample from inside Room 113 at
Alfred F. Garcia Elementary School. Two (2) additional ambient spore trap air samples were collected
from the outdoor air for use as comparison control samples. Below is a list of the sample locations. (See
Exhibit 5-“Spore Trap Air Sample Location Map-10/23/18” for detailed locations.)

 AZ0946.32-AC-1 Outdoors - Northwest

 AZ0946.32-AC-2 Outdoors – Northeast
 AZ0946.32-AC-3 Room 13

The laboratory analytical data did not indicate an elevated airborne fungal spore count in the spore
trap air re-sample collected from Room 13, when compared to the analytical data from the outdoor air
samples (see Exhibit 6-“Spore Trap Air Sample Analysis Report – 10/23/18”).

LEAD SAMPLING

Lead Paint Chip Sampling

On September 13, 2018, one (1) paint chip sample was collected from one (1) suspect painted
substrate at Alfred F. Garcia Elementary School. The paint chip sample was submitted to EMLab P&K
(EMLab) for analysis using Flame Atomic Absorption Spectrometer method. EMLab is accredited by
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the American Industrial Hygiene Association for the analysis of lead in paint and soil (Laboratory ID:
178697). The sample was collected and submitted to the laboratory using established chain-of-custody
procedures.

The following suspect painted substrate was sampled during the limited lead paint inspection (see
Exhibit 7-“Lead Paint Chip Sample Location Map-9/13/18”.):

 AZ0946.32-LPC-1 White Plaster Paint

As seen in Table 1, the one (1) of the paint chip sample collected was reported by the laboratory to
contain lead above the laboratory limit of detection (see Exhibit 8-“Lead Paint Chip Sample Analysis
Report-9/13/18”).

Table 1 - Paint Chip Sample Results

Lead-Containing Estimated Quantity Reading Detection Lead Concentration

Location
Paint of Material Limit (ppm) (ppm)

Exterior Walls throughout E,

White Plaster Paint To be determined 40 2,500
F, G and H Buildings

See Exhibit 9-“Photo Log – Lead-Containing Paint Damage” and Exhibit 10-“Lead Paint Damage
Location Map” for further details.

Lead Wipe Sampling

The lead wipe sampling of Alfred F. Garcia Elementary School was performed by Mr. Matthew
Janoski an EPA-accredited Risk Assessor on October 17 and November 13, 2018.

On October 17, 2018, Dominion collected a total of twenty-two (22) lead wipe samples from
horizontal surfaces in the areas where peeling paint was observed. Below is a list of the sample
locations. (See Exhibit 11-“Lead Wipe Sample Location Map-10/17/18” for detailed locations.)

 AZ0946.32-LW-1 Room 37
 AZ0946.32-LW-2 Room 36
 AZ0946.32-LW-3 Room 35
 AZ0946.32-LW-4 Room 34
 AZ0946.32-LW-5 Room 33
 AZ0946.32-LW-6 Room 32
 AZ0946.32-LW-7 Room 31
 AZ0946.32-LW-8 Room 30
 AZ0946.32-LW-9 Room 29
 AZ0946.32-LW-10 Room 28
 AZ0946.32-LW-11 Room 27
 AZ0946.32-LW-12 Room 26
 AZ0946.32-LW-13 Room 25
 AZ0946.32-LW-14 Room 24
 AZ0946.32-LW-15 Room 23

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  AZ0946.32-LW-16 Room 22
 AZ0946.32-LW-17 Room 13
 AZ0946.32-LW-18 Room 12
 AZ0946.32-LW-19 Room 11
 AZ0946.32-LW-20 Room 10
 AZ0946.32-LW-21 Room 9
 AZ0946.32-LW-22 Front Office

Based on these results, Dominion was directed to collect an additional four (4) lead wipe samples on
November 13, 2018 from the floor in randomly selected rooms where peeling paint was observed. (See
Exhibit 12-“Lead Wipe Sample Location Map-11/13/18” for detailed locations.)

 AZ0946.32-LW-1 Room 11-Floor

 AZ0946.32-LW-2 Room-Floor
 AZ0946.32-LW-3 Room 32-Floor
 AZ0946.32-LW-4 Room 36-Floor

The lead wipe samples from 10/17/18 & 11/13/18 were submitted to EMLab P&K (EMLab) for
analysis using the Flame Atomic Absorption Spectrometer method. EMLab is certified by the United
States Environmental Protection Agency for the analysis of lead in paint and soil (Certification Number:
178697). The samples were collected and submitted to the laboratory using established chain-of-custody
procedures.

Twenty (20) of the lead wipes sampled, were reported by the laboratory to be below the laboratory
limit of detection.

As seen in the following chart, six (6) of the lead wipes collected were reported by the laboratory to
contain lead above the laboratory limit of detection. See Exhibit 13-“Lead Wipe Sample Analysis
Report-10/17/18” and Exhibit 14-“Lead Wipe Sample Analysis Report-11/13/18” for detailed results.
Lead Wipes Identified to Contain Lead
Lead Wipe Reading
Lead Concentration
Sample Location Detection Limit
10/17/18-LW-5 - Room 33 – NE Corner-Bookcase 10 ug/ft2 76 ug/ft2
10/17/18-LW-13 - Room 25 – SE Corner–Sink Counter 10 ug/ft2 70 ug/ft2
10/17/18-LW-14 - Room 24 – SW Corner–Bookshelf 10 ug/ft2 30 ug/ft2
10/17/18-LW-21 - Room 9 – North Wall–Top of Shelf 10 ug/ft2 22 ug/ft2
11/13/18-LW-2 - Room 26 – South Wall - Floor 10 ug/ft2 31 ug/ft2
11/13/18-LW-4 - Room 36 – North Wall - Floor 10 ug/ft2 81 ug/ft2

*The current U.S. Department of Housing and Urban Development (HUD) action levels for lead dust is 10 g/ft2
(January 31, 2017). Clearance levels for lead dust on floors is <10 g/ft2.

CONCLUSIONS

Based on the laboratory analytical data for the air samples contained herein, no elevated airborne
fungal spore counts were identified at the time and place of sampling, when compared to the outdoor
samples.

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 Visual inspection indicated that water damage was observed on the drywall ceiling, ceiling tiles and
above the ceiling grid in various locations throughout Alfred F. Garcia Elementary School.

Lead-containing paint was observed to be damaged and flaking from the exterior plaster walls in
various locations throughout Alfred F. Garcia Elementary School.

Lead wipe samples collected from six (6) locations within Alfred F. Garcia Elementary School were
reported by the laboratory to be above the level of detection.

RECOMMENDATIONS

 The damaged lead-containing paint observed on the plaster walls in the classrooms should be
stabilized or abated.

 The flooring and horizontal surfaces in the rooms where peeling paint was observed should be
HEPA vacuumed.

 Final lead wipe sampling should be conducted prior to re-occupancy of the room.

 The source(s) of moisture in the building should be identified and repaired.

 All water damaged ceiling tiles should be removed and replaced.

 All remaining water damaged building materials should be repaired.

LEAD REGULATIONS AND GUIDELINES

The following are the regulations, rulings and guidelines concerning lead-containing paint. Some of
the regulations are triggered by threshold amounts, therefore not all the regulations apply to the lead-
containing paint identified above.

1980-40 CFR Part 260. EPA/Resource Conservation and Recovery Act (RCRA) states that all
potentially hazardous waste must be categorized before it is land filled. The waste categorization
procedure for lead-containing materials is the Toxic Characterization Leaching Procedure (TCLP) that
characterizes a lead-containing material that shows more than 5 parts per million (ppm) lead (Pb) in its
Leachate as a RCRA lead-containing hazardous waste. The regulation also states there is no relationship
between total lead in a material as determined by XRF or Atomic Absorption (AA) and leachable lead
compounds; therefore, total lead content is no predictor of the probability of passing or failing the
TCLP.

1993-29 CFR Part 1926.62. OSHA states that the presence of lead, regardless of amount, in paint
makes it lead-containing material and subjects workers disturbing this material to OSHA prescribed
work procedures.

2012 Department of Housing and Urban Development (HUD). Current lead-based paint hazard
guidelines state that paint films that contain greater than 5,000 ppm lead must be classified as lead-based
paint for inspection and hazard assessment purposes. These guidelines incorporate OSHA’s
(29CFR1926.62) rules when considering any lead removal activities, and RCRA’s (29CFR 261.24)
requirements pertaining to disposal of generated lead-containing wastes.
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1996-40 CFR Part 745. EPA states that for lead-containing paint activities including inspection,
sampling, risk assessment and abatement, appropriate work practices are contained in various approved
“Guidance Documents”. Therefore, the work practices presented in the HUD 95 Guidelines for these
activities can in general be followed in any type of building structure until they are superseded by future
EPA regulations. This inclusion in 40 CFR, Part 745 by reference makes these guidelines regulatory in
nature. This regulation also informs the party conducting lead paint removal activities that they are
subject to the requirements of 40 CFR, Part 261.24 pertaining to the management of waste from lead
abatement activity.

2010-40 CFR Part 745 Revised US EPA Renovation, Repair, and Painting Rule. All contractors
working in homes, housing units, child care facilities (defined as a residential, public, or commercial
building where children under age six are present on a regular basis), and schools built before 1978 must
be USEPA certified and follow specific work practices to prevent lead contamination when working in
such facilities. Project clearance testing by a third party is required by contractors to confirm that no
dangerous levels of lead were released by the renovation, repair, or painting work.

Dominion recommends that the regulatory guidelines listed above are followed during any
disturbance of the paint identified to contain lead. Any building materials identified with lead-containing
and lead-based paint that will be impacted during the demolition should be removed by a qualified lead-
containing paint abatement contractor (see Lead-Containing Paint Damage Location Map).

Dominion also recommends that the non-lead-containing paint building materials that are attached to
a building material with lead-containing and lead-based paint be removed by a qualified lead-containing
paint abatement contractor to avoid any possible disturbance. The contractor should comply with all
governing regulatory agencies having jurisdiction over lead-containing paint removal projects.

The MESD should retain the services of an independent lead-containing paint consulting firm to
monitor the performance of the abatement contractor. The consulting firm should oversee the
completeness of the lead-containing paint removal and verify the quality of the air during the removal
work. The consultant should also document that the work was performed in compliance with the
respective regulatory guidelines.

LIMITATIONS

The conclusions and results contained herein are based solely on the information presented in this
report. The sampling, testing, and observations described in the report represent conditions only at the
specified times and locations. Additional information or contamination which were hidden,
undiscovered, inaccessible, or not a part of the findings presented herein, would result in the
modification of the conclusions and recommendations made herein.

The sampling methods, techniques, and scope of services were not comprehensive or to be
considered all inclusive. Any remediation guidelines are minimum general guidelines, based solely on
the findings presented herein. They are presented as a courtesy and are not to be considered a complete
or detailed set of specifications. Dominion performed its investigation in a specific area, as directed by
the client.

Dominion’s specific scope of service for this report did not include the inspection for, or
identification of, asbestos, or any other hazardous or controlled substances not specifically identified
herein.
8 DOMINION
 Dominion is not responsible for the accuracy of information provided by others, or for conditions or
consequences arising from relevant facts that were withheld, concealed, undiscovered, or not fully
disclosed.

Dominion is not a law firm and therefore, makes no representations regarding any potential liability
of any person or entity for site conditions. Further, Dominion is not qualified to present medical advice.
If any present or future health issues are in question, it is recommended that the findings in this report be
presented to a qualified medical professional for evaluation.

If you should have any questions or would like to discuss the contents of this report, please do not
hesitate to contact Dominion at any time.

Sincerely,

Dominion Environmental Consultants, Inc.

Matthew Janoski
Industrial Hygienist/EPA Lead Risk Assessor
U.S. EPA Certificate No. LBP-R-18931-1
Expires: August 22, 2019

Enclosures -
Exhibit 1 – Photo Log - Water Damage
Exhibit 2 –Water Damage Location Map
Exhibit 3 – Spore Trap Air Sample Location Map - 10/17/18
Exhibit 4 – Spore Trap Air Sample Analysis Report - 10/17/18
Exhibit 5 – Spore Trap Air Sample Location Map - 10/23/18
Exhibit 6 – Spore Trap Air Sample Analysis Report - 10/23/18
Exhibit 7 – Lead Paint Chip Sample Location Map - 9/13/18
Exhibit 8 – Lead Paint Chip Sample Analysis Report – 9/13/18
Exhibit 9 – Photo Log - Lead Paint Damage
Exhibit 10 –Lead Paint Damage Location Map
Exhibit 11 – Lead Wipe Sample Location Map - 10/17/18
Exhibit 12 – Lead Wipe Sample Location Map - 11/13/18
Exhibit 13 – Lead Wipe Sample Analysis Report - 10/17/18
Exhibit 14 – Lead Wipe Sample Analysis Report - 11/13/18
Exhibit 15 – Inspector Certification - Lead
Exhibit 16 – Laboratory Certification - Lead

9 DOMINION
EXHIBIT 1
 SITE PHOTOGRAPHS – ALFRED F. GARCIA SCHOOL – EXAMPLES OF WATER DAMAGE

1. Room 2 – Water Damage Beneath Sink 2. Room 2 – Water Damage Beneath Sink

3. Room 2 – Water Damage Beneath Sink 4. Room 6 – Water Damage Above Ceiling Grid

5. Room 6 – Water Damage Above Ceiling Grid 6. Room 6 – Water Damage Above Ceiling Grid

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AZ0946.32 DOMINION
 7. Front Office – Water Damage to Ceiling 8. Front Office – Water Damage to Ceiling

9. Front Office – Water Damage to Ceiling 10. Room 30 – Water Damage Above Ceiling Grid

11. Room 6 – Water Damage Above Ceiling Grid 12. Room 6 – Water Damage Above Ceiling Grid

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 13. Room 27 – Water Damage Above Ceiling Grid 14. Room 27 – Water Damage Above Ceiling Grid

15. Room 27 – Water Damage Above Ceiling Grid 16. Room 32 – Water Damage Above Ceiling Grid

17. Room 32 – Water Damage Above Ceiling Grid 18. Room 34 – Water Damage Above Ceiling Grid

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 19. Room 34 – Water Damage Above Ceiling Grid 20. Room 34 – Water Damage Above Ceiling Grid

21. Room 34 – Water Damage Above Ceiling Grid 22. Room 35 – Water Damage Above Ceiling Grid

23. Room 35 – Water Damage Above Ceiling Grid 24. Room 35 – Water Damage Above Ceiling Grid

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EXHIBIT 2
EXHIBIT 3
EXHIBIT 4
EXHIBIT 5
EXHIBIT 6
EXHIBIT 7
EXHIBIT 8
EXHIBIT 9
 SITE PHOTOGRAPHS – ALFRED F. GARCIA SCHOOL – EXAMPLES OF LEAD-CONTAINING PAINT DAMAGE

1. Room 25 – Lead-Containing Paint Damage 2. Room 25 – Lead-Containing Paint Damage

3. Room 25 – Lead-Containing Paint Damage 4. Room 27 – Lead-Containing Paint Damage

5. Room 27 – Lead-Containing Paint Damage 6. Room 33 – Lead-Containing Paint Damage

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 7. Room 33 – Lead-Containing Paint Damage 8. Room 33 – Lead-Containing Paint Damage

9. Room 33 – Lead-Containing Paint Damage 10. Room 33 – Lead-Containing Paint Damage

11. Room 33 – Lead-Containing Paint Damage 12. Room 33 – Lead-Containing Paint Damage

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 13. Room 34 – Lead-Containing Paint Damage 14. Room 34 – Lead-Containing Paint Damage

15. Room 34 – Lead-Containing Paint Damage 16. Room 35 – Lead-Containing Paint Damage

17. Room 35 – Lead-Containing Paint Damage 18. Room 35 – Lead-Containing Paint Damage

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 19. Room 35 – Lead-Containing Paint Damage 20. Room 36 – Lead-Containing Paint Damage

21. Room 36 – Lead-Containing Paint Damage 22. Room 36 – Lead-Containing Paint Damage

23. Room 36 – Lead-Containing Paint Damage 24. Room 36 – Lead-Containing Paint Damage

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EXHIBIT 10
EXHIBIT 11
EXHIBIT 12
EXHIBIT 13
EXHIBIT 14