DEMOLITION INSPECTION REPORT ASBESTOS CONTAINING MATERIALS

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1 DEMOLITION INSPECTION REPORT ASBESTOS CONTAINING MATERIALS Property Address: The Rocky Ridge 3741 Chesnut Ridge Inspection ordered by: Cotton Commercial USA 5443 Katy Hockley Cutoff Rd. Katy, TX PH: (205) (866) FAX: (205) Southland Drive, Ste. 134, Hoover, AL Produced Using ReportMakerPro Copyright

2 Building Detail Photos Front elevation. Front elevation. Left elevation. Right elevation. Rear elevation. Rear elevation. Rear elevation. Interior detail photo

3 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane TABLE OF CONTENTS: 1.0 PURPOSE AND SCOPE OF SERVICES REGULATIONS, STANDARDS & GUIDELINES PROJECT AREA DESCRIPTION INSPECTION METHODOLOGY ANALYTICAL METHODOLOGY SUSPECT MATERIALS ASBESTOS INSPECTION AND SAMPLING RESULTS FRIABLE ACM NON-FRIABLE ACM CONCLUSIONS AND RECOMMENDATIONS ASSUMPTIONS AND LIMITATIONS 7 APPENDICES: Appendix A: Report of Laboratory Analysis for Asbestos Appendix B: Sample Location Drawings Appendix C: Inspector and Laboratory Certifications SBC Project No Page 1

4 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane 1.0 PURPOSE AND SCOPE OF SERVICES The purpose of this Demolition Inspection" was to identify asbestos containing materials (ACM) likely to be impacted by the proposed demolition of The Verandas at Rocky Ridge located at 3741 Chestnut Ridge Lane,. This inspection was limited due to the dangerous conditions of the building resulting from a catastrophic fire. The heating, ventilation, and air condition (HVAC) system was not included in the scope of the demolition inspection and therefore no testing was conducted. A summary of the services to be provided by Specialty Building Consultants, (SBC) is presented below: Perform a visual inspection of the interior of the subject structure to identify building materials suspected to potentially contain asbestos. Collect information on conditions, quantities, and locations of those materials suspected to potentially be ACM. Collect bulk samples representative of the suspect materials and analyze those samples for asbestos content utilizing Polarized Light Microscopy and Dispersion Staining Techniques performed in accordance with EPA Bulk Analysis Method EPA/600/R93/116 July Compilation of a report (contained herein) which describes the inspection process, presents all sampling and analytical results, and generally identifies ACM locations and approximate quantities in accordance with Communication of Hazards requirements pursuant to 29 CFR (k). This report includes several appendices which contain important information that may be essential to proper understanding of the data summarized in the narrative sections. 2.0 REGULATIONS, STANDARDS & GUIDELINES This section of the report provides basic information on some of the key criteria applicable to the inspection performed by SBC; as well as regulatory obligations applicable to building owners and contractors involved in operations impacting ACM. The information below is presented in a very general nature and is not a complete representation of regulatory requirements. Any key parties, that will be involved in the demolition and/or renovation projects, and whom are not knowledgeable of the associated asbestos regulatory requirements, should consult with the regulatory authorities mentioned herein and/or an asbestos abatement professional such as a certified asbestos project designer, before proceeding with any renovation, salvage, or demolition operations that might disturb the ACM. The National Emissions Standards for Hazardous Air Pollutants (NESHAP) requires the Owner or Operator of a facility to determine the presence or non-presence of asbestos containing materials via a thorough inspection prior to conducting renovation or demolition activities. The NESHAP Standard for asbestos (40 CFR Part 61 Sub-part M) is applicable to all types of facilities, regardless of construction date, except single family dwellings or multi-family dwellings with four or fewer units, unless those dwellings are being renovated or demolished for commercial purposes. NESHAP requires the use of controlled wet procedures for removal of asbestos materials that are or will become friable during renovation or demolition. The removal procedure must prevent visible emissions and must occur before renovation or demolition activities impact those materials. This report and the associated inspections and testing satisfy SBC Project No Page 2

5 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane the initial NESHAP requirements. Presentation of this report and/or a pertinent summary thereof to all parties potentially performing activities that will disturb ACM at the subject facility will complete the Owner/Operator discovery and communication requirements pursuant to NESHAP. Removal, handling and disposal of certain ACM (if identified herein) must be provided in accordance with NESHAP as locally administrated and enforced by the Alabama Department of Environmental Management (ADEM) c/o the Jefferson County Department of Health (JCDH). Renovation projects involving ACM and all demolition projects, regardless of ACM, require advance notification to ADEM. Alabama s asbestos regulations that are relevant to renovation and demolition are essentially the same as the federal NESHAP. On October 11, 1994, OSHA s current construction industry regulation (29 CFR Part ) for asbestos became effective. That regulation known as the Asbestos Construction Standard is related to asbestos exposure in construction, renovation, demolition, and building repair work places. Building owners are required, pursuant to section (k) Communication of Hazards of the Standard, to notify employees, tenants and prospective employers (e.g. construction bidders) of the description, locations and quantities of ACM in their buildings. Suspect materials installed no later than 1980 must be assumed to contain asbestos unless inspected and analyzed using AHERA protocol. The OSHA Standard applies by law to work performed by private sector employers / contractors, regardless of the type of facility or building owner. The OSHA Asbestos Standard does not directly apply to work performed by employees of state, county and municipal agencies in states without state-run OSHA programs (e.g. Alabama); however, since December 2000 the provisions of the Standard were made binding on state and local entities, via the EPA s Asbestos Worker Protection Rule (40 CFR 763 Subpart G). Also most federal agencies have adopted the OSHA Standard for operations performed by their employees. Presentation of this report or pertinent information derived from it, to all parties that will potentially work in contact with the ACM described herein, if any, will complete the Owner/Operator s initial discovery and communications requirements pursuant to the OSHA Standard. Removal, handling and disposal of ACM (if identified herein) must be provided in accordance with the OSHA Standard, which is enforced by the Birmingham branch office of OSHA. On November 28, 1992, a law became effective which extended to EPA s Model Accreditation Plan (MAP), originally applicable only to schools, to all public and commercial buildings. Currently the rule extends the accreditation requirements of MAP to persons performing asbestos work (inspectors, project designers, abatement supervisors and workers) in public and commercial buildings, but does not extend the other aspects of the AHERA asbestos rules for schools. This inspection was conducted using EPA/MAP accredited personnel. Accreditation in Alabama is provided by the University of Alabama s Safe State Environmental Program. Refer to Appendix D for copies of the inspector s Safe State accreditation certificate. 3.0 PROJECT AREA DESCRIPTION The apartment building is a two story, 20 unit, structure on slab construction built in the 1970/80 s. The building utilizes wood frame construction. The exterior walls are brick and wood siding with interior walls being gypsum. Floors are typically covered by some type of sheet vinyl flooring in the bathrooms and kitchens and carpet in the remaining areas. The building s HVAC system is located in individual vented closets and ductwork is wrapped in a fiberglass with aluminum backed wrap with tape holding the seams together. Condensing SBC Project No Page 3

6 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane units are located on the exterior of the building. No suspect mastic was observed on any HVAC components. In addition, the water piping in utility closets is copper and PVC piping. 4.0 INSPECTION METHODOLOGY The inspection was conducted on March 12, 2014 by Chuck Marion, a University of Alabama Safe State Environmental Program certified asbestos inspector. See Appendix D for the inspector's accreditation certificate. SBC s investigation produced an Inspection that meets the requirements of the aforementioned standards (NESHAP & OSHA). SBC s first step in the overall survey/inspection process was to collect and review records (if available) of previous material testing, asbestos surveys and abatement activities. No asbestos related records were provided to SBC. Building components/systems were then evaluated for the presence of material suspected to contain asbestos. After those suspect materials were identified, sample collection locations were randomly selected. Then bulk samples were obtained and placed into individual containers for transportation to the laboratory. Each sample was assigned a unique number and each sample description was recorded on a Chain-Of-Custody / Analysis Request Form. Those numbers directly correspond with the numbers listed on the laboratory reports in Appendix B. Sample collection locations were recorded on a building sketch as indicated in Appendix C. Each time suspect ACM was sampled; it was classified as either a friable or a non-friable material. Friable materials, when dry, may be crumbled, pulverized or reduced to powder by hand pressure. Friable ACM is potentially more hazardous than non-friable ACM because friable material can release airborne asbestos fibers more easily. 5.0 ANALYTICAL METHODOLOGY All bulk samples were analyzed at Hayes Microbial Consulting (HMC) by polarized light microscopy (PLM) utilizing dispersion staining techniques in accordance with EPA method EPA/600/R-93/116 July This type of analysis requires the analyst to take a portion of the bulk sample and treat it with an oil of specific refractive index. The prepared slide is then subjected to a variety of optical tests. Percentages of the identified types of asbestos are determined by visual estimation. Even though this is a process of estimation, any material that contains greater than one percent of any type of fibrous asbestos is considered ACM and must be handled in accordance with applicable provisions of EPA, OSHA and state regulations if likely to be disturbed during maintenance, repair, renovation, or demolition operations. HMC operates a laboratory, located at 3005 East Boundary Terrace, Ste. F, Midlothian, VA, that participates in the U.S. EPA approved National Voluntary Laboratory Accreditation Program (NVLAP) for asbestos identification by polarized light microscopy. HMC s NVLAP s Laboratory Code is # Please see appropriate Certificates in Appendix D. 6.0 SUSPECT MATERIALS A table listing all suspect homogeneous materials identified during this inspection is presented in Appendix A. That table presents detailed descriptions of the materials along with the general locations of each suspect material; the sample numbers corresponding to each homogeneous material; the sample analysis results; and a listing of sample collection sites (rooms/areas). The following is a more general list of basic types of building materials that were suspected to potentially contain asbestos. The materials are grouped into categories according to general types as set forth in AHERA, 40 CFR 763. SBC Project No Page 4

7 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane Surfacing Materials (decorative, acoustical, thermal, or fire resistant products that are typically site batched and sprayed or troweled onto a building component) None Thermal System Insulation (HVAC & plumbing system insulations) None Miscellaneous Material Asphalt shingles Roofing material Vinyl floor mastic Drywall materials Joint compound Non-AHERA Exterior Material None 7.0 ASBESTOS INSPECTION AND SAMPLING RESULTS SBC collected a total of 13 samples representing materials found in/on the subject building system components. All samples were analyzed per the EPA s standard PLM method. The PLM report can be found in Appendix A. A narrative description of all "Friable ACM" and "Non- Friable ACM" identified during this inspection is given below, if applicable. Additional information about each ACM, including the estimated quantities, is presented in Appendix A. 7.1 FRIABLE ACM Any ACM identified during this Demolition Inspection were classified as either friable or non-friable based upon their potential to be crumbled, pulverized or reduced to powder by hand pressure when dry. The following is a list of those ACM, if applicable, that can be crumbled, pulverized or reduced to powder by hand pressure when dry (i.e. friable): NONE 7.2 NON FRIABLE ACM Based upon physical inspections the following identified ACM were classified as non-friable: Sheet vinyl flooring and mastic. SBC Project No Page 5

8 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane 3-tab asphalt shingles. No Carpet mastic used to secure carpet. (Padding and tack strips). NOTE #1: Where multiple layers of flooring products are present and only one contains asbestos, all adhered layers of the flooring, specifically the carpet over tile in the classrooms, should be treated as ACM due to the fact that adhered layers of flooring normally cannot be properly separated prior to removal and/or disposal. In summary, all floor covering materials, are considered to be positive for asbestos and therefore must be removed in accordance to regulatory guidelines. 8.0 CONCLUSIONS AND RECOMMENDATIONS SBC's demolition inspection services were conducted to fulfill the NESHAP requirement for a "thorough" inspection per 40 CFR 61 Subpart M, and OSHA s requirements per 29 CFR Part Section k. The inspection at The Verandas at Rocky Ridge, Birmingham, Alabama, determined that none of the building materials were found to contain ACM The EPA and OSHA regulations address various types of ACM differently and all of the associated regulatory issues including disposal for each type are too complex to effectively discuss in this report format. However, the basic EPA and OSHA classifications for each homogeneous ACM identified during this inspection are presented in Appendix A. Certain types of ACM must be removed by ADEM/EPA certified abatement personnel prior to renovation or demolition operations that will disturb them. That includes all friable ACM which generally includes ACM insulation products. However, other types of ACM can remain in place during renovation or demolition, depending upon the condition of the ACM and the nature of the construction activities, more specifically, the forces that will act upon the ACM. Regardless, all waste that contains ACM should be disposed of in a landfill that is permitted by ADEM to receive ACM. As such, SBC often recommends the complete removal and disposal of all ACM from buildings prior to any renovation or demolition operations. However, it is important to note that this is not necessarily required and cost savings may potentially be achieved by other approaches, particularly with respect to the ACM roof cement applied to various items on the roof that may not be demolished or otherwise disturbed by sawing, grinding, torching, or welding (e.g. brick & concrete bases and parapets). Guidance on various options can be obtained from the aforementioned regulatory agencies and/or qualified abatement professionals such as a certified asbestos project designer employed by SBC or another qualified firm. Renovation projects at regulated facilities, involving at least 160 square feet or 260 linear feet of regulated ACM (RACM), and all demolition projects (regardless of ACM presence), require NESHAP notification, which given this project's location must be filed with the Jefferson County Department of Health, at least ten working days prior to activities that would disturb the ACM. Removal of NESHAP regulated ACM must be performed by Alabama Safe State accredited asbestos abatement personnel employed by an ADEM licensed asbestos abatement contractor. The foregoing paragraph relates primarily to the EPA s NESHAP asbestos standard 40 CFR 61 Subpart M, which is also the basis of Alabama regulations. ACM handling is also regulated by OSHA which has a much more complex regulation that is too involved to summarize herein. Any SBC Project No Page 6

9 Demolition Asbestos Inspection Report March 12, Chestnut Ridge Lane handling of any type of ACM must be conducted in accordance with the OSHA standard by persons trained for the appropriate class of work as outlined by the standard. It is important to note that OSHA regulates all types of ACM handling activities, regardless of the NESHAP status, and all firms and their employees working on project sites where they will come into contact with ACM must comply with the OSHA Asbestos Standard 29 CFR , which will at a minimum involve specific training and worker protection procedures. Furthermore, owners of buildings that contain ACM, must inform all prospective contractors/employers about the ACM descriptions, locations, and quantities, before those firms bid on or conduct repair, renovation, or demolition work. A copy of this report should be provided to the building owner/operator and any firms that may have employees performing work which would impact the ACM at the subject building. If any of the ACM identified herein will remain in the building after renovations or demolition work has been performed; an asbestos operations and maintenance (O&M) program should then be developed and implemented to effectively manage the ACM in a good/safe condition, as long as the ACM remains in the building. 9.0 ASSUMPTIONS AND LIMITATIONS The results, findings, conclusions & recommendations expressed in this report are based only on conditions that were observed during the inspection performed by SBC on March 12, 2014, and the assumption that the suspect materials will be significantly impacted by the proposed demolition activities. It should be noted that materials within one portion of the structure that appear alike to materials in other parts of the structure were assumed to be homogeneous and therefore were not necessarily tested at each location, which is consistent with EPA approved procedures. This report is designed to provide the building owner, architect, engineer, construction manager, and contractors, with documentation that a regulatory compliant investigation for ACM has been conducted, and to aid their ability to identify the ACM. This report was developed to be used intact with all appendices listed in the table of contents. Anyone using only a portion of this report assumes the risk of potential misinterpretation of the data. This report is not intended to be a stand-alone bidding/contract document. It was not within the scope of services of this inspection for SBC to provide asbestos abatement guidance. For advice on abatement contract matters please consult with a certified asbestos abatement professional employed by SBC or other qualified firm. SBC Project No Page 7

10 Appendix A Report of Laboratory Analysis for Asbestos

11 HMC # Analysis Report prepared for Specialty Building Consultants 500 Southland Drive 134 Hoover, AL Ph.: Job Number: Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane Date Sampled: Date Analyzed: Report Date: AIHA EMPAT Laboratory ID# EPA Laboratory ID# VA01419 NVLAP Laboratory Code: AIHA Accredited Environmental Microbiology Certified Clinical Microbiologist Page 1 of 6

12 HMC # Specialty Building Consultants 500 Southland Drive 134 Hoover, AL March 14, 2014 Client Job Number: Client Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane Dear Specialty Building Consultants, We would like to thank you for trusting Hayes Microbial for your analytical needs. On March 13, 2014 we received 13 samples by FedEx for the job referenced above. The results in this analysis pertain only to this job, collected on the stated date and should not be used in the interpretation of any other job. This report may not be duplicated, except in full, without the written consent of Hayes Microbial Consulting, LLC. This laboratory bears no responsibility for sample collection activities, analytical method limitations, or your use of the test results. Interpretation and use of test results are your responsibility. Any reference to health effects or interpretation of mold levels is strictly the opinion of Hayes Microbial Consulting. In no event, shall Hayes Microbial Consulting or any of its employees be liable for lost profits or any special, incidental or consequential damages arising out of your use of the test results. Steve Hayes, BSMT(ASCP) Laboratory Director Hayes Microbial Consulting, LLC Page 2 of 6

13 Specialty Building Consultants 500 Southland Drive, 134 Hoover, AL Ph.: Asbestos PLM Analysis HMC # Job Number: Collected by: Chuck Marion Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 1 Sample Name: Asphalt Shingle Morphology/Macro Desc.: Asphaltic / Asphaltic (None Detected) 30 % Fiberglass 70 % Date Collected: Date Received: Date Reported: 03/12/ /13/ /14/2014 HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 2 Sample Name: Sheetrock Morphology/Macro Desc.: Powdery / Mastic/Adhesive (None Detected) 5 % Fiberglass 20 % Cellulose fibers 75 % HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 3 Sample Name: Insulation Morphology/Macro Desc.: Fibrous / Powdery (None Detected) 95 % Fiberglass 5 % HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 4 Sample Name: Asphalt Shingle Morphology/Macro Desc.: Asphaltic / Asphaltic (None Detected) 35 % Fiberglass 65 % Signature: Date: 03/14/2014 Reviewed by: Date: 03/14/2014 Page 3 of 6

14 Specialty Building Consultants 500 Southland Drive, 134 Hoover, AL Ph.: Asbestos PLM Analysis HMC # Job Number: Collected by: Chuck Marion specialtybuilding@gmail.com Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 5 Sample Name: Vinyl Flooring Morphology/Macro Desc.: Vinyl Tile / Long Fibers (None Detected) 5 % Fiberglass 25 % Cellulose fibers 70 % Date Collected: Date Received: Date Reported: 03/12/ /13/ /14/2014 HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 6 Sample Name: Carpet Morphology/Macro Desc.: Fibrous / Ceramic (None Detected) (None Detected) 100 % synthetic fibers HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 7 Sample Name: Roofing Material Morphology/Macro Desc.: Fibrous / Asphaltic (None Detected) 70 % Fiberglass 30 % HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 8 Sample Name: Wood Siding Morphology/Macro Desc.: Debris / Asphaltic (None Detected) 90 % Wood Pulp 10 % Signature: Date: 03/14/2014 Reviewed by: Date: 03/14/2014 Page 4 of 6

15 Specialty Building Consultants 500 Southland Drive, 134 Hoover, AL Ph.: Asbestos PLM Analysis HMC # Job Number: Collected by: Chuck Marion specialtybuilding@gmail.com Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 9 Sample Name: Insulation Morphology/Macro Desc.: Fibrous / Powdery (None Detected) 98 % Fiberglass 2 % Date Collected: Date Received: Date Reported: 03/12/ /13/ /14/2014 HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 10 Sample Name: Electrical Wire Casing Morphology/Macro Desc.: Shiny / Mastic/Adhesive (None Detected) 10 % Cellulose fibers 90 % HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 11 Sample Name: Asphalt Shingle Morphology/Macro Desc.: Asphaltic / Asphaltic (None Detected) 25 % Fiberglass 75 % HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 12 Sample Name: Asphalt Shingle Morphology/Macro Desc.: Asphaltic / Asphaltic (None Detected) 20 % Fiberglass 80 % Signature: Date: 03/14/2014 Reviewed by: Date: 03/14/2014 Page 5 of 6

16 Specialty Building Consultants 500 Southland Drive, 134 Hoover, AL Ph.: Asbestos PLM Analysis HMC # Job Number: Collected by: Chuck Marion specialtybuilding@gmail.com Job Name: The Rocky Ridge 3741 Chesnut Ridge Lane HMC ID Number: L1 Analysis Type: EPA 600/R-93, M-4/ Sample Number: 13 Sample Name: Vinyl Flooring Morphology/Macro Desc.: Vinyl Tile / Long Fibers (None Detected) 15 % Cellulose fibers 85 % Date Collected: Date Received: Date Reported: 03/12/ /13/ /14/2014 Signature: Date: 03/14/2014 Reviewed by: Date: 03/14/2014 Page 6 of 6

17 Appendix B Sample Location Drawings

18 SAMPLE LAYOUT Grid Location Type of Sample Estimate % Asbestos Non-asbestos % Fibers % Non-fibrous B1 Asphalt shingle None 30 Fiberglass 70 D2 C2 Sheetrock Insulation None 5 Fibrous 20 Cellulose 75 None 95 Fiberglass 5 G2 Asphalt shingle None 35 Fiberglass 65 I2 I2 Vinyl flooring Carpet None 5 Fiberglass 25 Cellulose 70 None None 100 E1 Roofing material None 70 Fiberglass 30

19 SAMPLE LAYOUT Grid Location Type of Sample Estimate % Asbestos Non-asbestos % Fibers Non-Fibrous C7 Exterior siding None 90 Pulp 10 D1 Insulation None 98 Fiberglass 2 D1 Electrical wire casing None 10 Cellulose 90 F7 Asphalt shingle None 25 Fiberglass 75 I7 Asphalt shingle None 20 Fiberglass 80 I2 Vinyl flooring None 15 Cellulose 85

20 Appendix C Inspector and Laboratory Certifications

21

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