18. Attachment C - Environmental Building Inspection.pdf

5 December 2019

Attachment C

Environmental Building Inspection

89503221QWA000348

ENVIRONMENTAL BUILDING INSPECTION for the SHIPROCK GARAGE, CONTROL, and STORAGE

BUILDINGS

Prepared for:

United States Department of Energy Western Area Power Administration

Rocky Mountain Regional Office 5555 East Crossroads Boulevard

Loveland, Colorado 80537

Prepared by:

Foothills Environmental, Inc.

11099 West 8th Avenue Lakewood, CO 80215

December 5, 2019

FEI Project # AS19084 DOE Order# 89503219FWA400091

ACRONYMS

ACM Asbestos Containing Material

ACBM Asbestos Containing Building Material

AIHA American Industrial Hygiene Association

BDL Below Detection Limit

CDPHE Colorado Department of Public Health and Environment

EPA United States Environmental Protection Agency

OSHA Occupational Safety and Health Administration

LBP Lead Based Paint mg/cm2 milligram per square centimeter mg/kg milligram per kilogram

NVLP National Voluntary Laboratory Accreditation Program

PACM Presumed Asbestos Containing Material

PCB Polychlorinated Biphenyls

PLM Polarized Light Microscopy ppm parts per million

TEM Transmission Electron Microscopy

XRF X-ray florescence

TABLE OF CONTENTS

1.0 EXECUTIVE SUMMARY

1.1 INTRODUCTION

1.2 SCOPE OF WORK

1.3 STANDARD BULK SAMPLING AND ANALYTICAL PROCEDURES

1.3.1 Asbestos

1.3.2 Lead Paint

1.3.3 PCBs

1.4 BUILDING DESCRIPTIONS

1.5 STATEMENT OF INACCESSIBILITY

2.0 ASBESTOS-CONTAINING MATERIAL (ACM) LOCATION SUMMARY

2.1 EQUIPMENT STORAGE BUILDING 0002 BULK SAMPLE INSPECTION SUMMARY

2.1.1 Building 0002 Suspect Surfacing Materials

2.1.2 Building 0002 Suspect Thermal System Insulation Materials

2.1.3 Building 0002 Suspect Miscellaneous Materials

2.2 BUILDING 0010 BULK SAMPLE INSPECTION SUMMARY

2.2.1 Building 0010 Suspect Surfacing Materials

2.2.2 Building 0010 Suspect Thermal System Insulation Materials

2.2.3 Building 0010 Suspect Miscellaneous Materials

2.3 BUILDING 0011 BULK SAMPLE INSPECTION SUMMARY

2.3.1 Building 0011 Suspect Surfacing Materials

2.3.2 Building 0011 Suspect Thermal System Insulation Materials

2.3.3 Building 0011 Suspect Miscellaneous Materials

3.0 ASBESTOS SAMPLE RESULTS TABLE

4.0 SUMMARY OF XRF RESULTS TABLE

5.0 SUMMARY OF PCB RESULTS

6.0 CONCLUSIONS AND RECOMMENDED ACTIONS

6.1 ASBESTOS

6.1.1 Friable ACM

6.1.2 Non-friable ACM

6.1.3 Materials Containing 1% or Less Asbestos (Trace)

6.1.4 Materials Assumes to Contain 1% or Greater Asbestos

6.1.5 RACM vs NON-RACM

6.1.6 Other Regulations

6.2 LEAD

6.3 PCBS

7.0 LIMITATIONS

APPENDIX A - PLM LAB RESULTS

APPENDIX B – ASBESTOS SAMPLE AND MATERIAL LOCATIONS DRAWINGS

APPENDIX C - PCB LAB RESULTS

APPENDIX D - PHOTOGRAPHS

APPENDIX E – CERTIFICATES

Foothills Environmental, Inc. 11099 W. 8th Ave. Lakewood, CO 80215 (303) 232-2660

1.0 EXECUTIVE SUMMARY

On October 8th and 9th, 2019, Foothills Environmental, Inc. (FEI) performed an environmental building inspection on the interior and exterior of the Garage Building 0011, Control Building 0010, and Equipment Storage Building 0002 located at the Western Area Power Authority (WAPA) location near Shiprock, New Mexico. The environmental building inspection included an asbestos inspection for demolition, lead based pant testing, and paint/caulk polychlorinated biphenyl (PCB) sampling. Jason Martin, an EPA certified asbestos inspector and Certified Industrial Hygienist (CIH) conducted the inspection

1.1 Materials Requiring Removal Prior to Demolition

Regulated Asbestos-Containing Material (RACM) means (a) friable asbestos-containing material, (b) Category I non-friable ACM that has become friable, (c) Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

Non-RACMs are those non-friable materials not likely to be rendered friable during the normal demolition process, therefore are less likely to release airborne asbestos. Under normal demolition activities, non- RACMs that are non-friable Category I materials (gaskets, resilient flooring, adhesives, and asphalt roofing) and similar non-friable Category II are allowed by EPA regulations to remain during normal building demolition, and can be disposed of as normal demolition debris, provided these materials remain non-friable during demolition activities and the landfill will accept the waste as solid waste.

Table 1 - RACM

Homogeneous Area/ Description

Condition Type / Friable or Non-Friable

Analytical Result

Approx.

Quantity Material Location(s)

None - - - - -

Table 2 – Non-RACM >1% Homogeneous Area/

Description Condition

Type / Friable or Non-Friable

Analytical Result Approx.

Quantity

Material Locations

Transite panel remnant debris Significantly

Damaged Misc./Non-Friable 15-20% Chrysotile 2 square feet

Building 0010, Control Room northwest wire trench 12”x12” upper vinyl floor tile (white with black dots) with mastic (yellow) over lower vinyl floor tile

(off-white) with mastic (black)

Good Misc./Non-Friable 6% Chrysotile in lower tile 180 square feet

Building 0011, Printer Room

Window glazing Good Misc./Non-Friable 2-3% Chrysotile 48 square feet (4 windows)

Building 0011, East Garage north windows

Built-up tar/foam roofing with silver paint

Good Misc./Non-Friable 2% Chrysotile in black tar/silver paint 4,032 square feet Building 0011, East Garage old flat roof in attic space

Table 3 – Trace Materials <1%

Homogeneous Area/ Description

Condition Type / Friable or Non-Friable

Analytical Result Approx.

Quantity

Material Location(s)

Composite drywall and joint compound

Good Misc./Non- Friable

2-3% Chrysotile in joint compound

(0.31-0.39% chrysotile as composite)

720 square feet Ceilings in Printer Room, Kitchen, Restroom and Northeast Office

The following paint coatings contain greater than 1.0 mg/cm2 of lead:

Control Building 0010 – Cream/Red paint on the interior and exterior surfaces of the metal north exterior door.

Control Building 0010 – Cream/Red paint on the concrete north door threshold, and east door threshold.

Garage Building 0011 – Off-white/Red paint on the exterior surfaces of the roll-up garage doors, man doors and north windows associated with the East Garage (original build).

The following paint/caulk/wipe materials contain greater than 50 ppm of PCB:

None.

1.1 Introduction

Foothills Environmental Inc. (FEI) was contracted by Western Area Power Authority (WAPA) to conduct asbestos, lead paint, and PCB materials surveys of the Garage Building 0011, Control Building 0010, and Equipment Storage Building 0002 at the substation location in Shiprock, New Mexico. Jason Martin, an Asbestos Inspector certified by the Environmental Protection Agency (EPA) conducted the inspections on October 8th and 9th, 2019. Reservoirs Environmental Inc., an independent laboratory accredited by the National Voluntary Accreditation Program (NVLAP) and the American Industrial Hygiene Association (AIHA), analyzed the bulk samples for asbestos utilizing Polarized Light Microscopy (PLM). ALS Group USA, Corp., an independent laboratory accredited by the American Industrial Hygiene Association (AIHA), analyzed the bulk and wipe samples for PCBs utilizing Gas Chromatography / Electron Capture Detectors (GC/ECD) according to the current revision of SOP 409 based on EPA SW-846 test method 8082.

1.2 Scope of Work

The scope of the evaluation the evaluation included the Garage Building 0011, Control Building 0010, and Equipment Storage Building 0002. The combined goals of this inspection were to:

1. Identify asbestos-containing material (ACM) throughout the buildings and to document the location, condition, friability and quantity of each identified material.

2. Identify lead-based paint (LBP) throughout the buildings and to document the component, substrate, color, location, and concentration of lead in each paint analyzed.

3. Identify PCB containing paints and caulks, as well as PCB contamination where oil staining is evident and to document the location and color of each identified PCB containing material or contaminated area.

4. Make appropriate recommendations on how to approach each material identified as an ACM, LBP, or PCB containing prior to demolition or renovation.

5. Compile sample data information, observations obtained from the site visits, conclusions and recommendations into a report form.

1.3 Standard Bulk Sampling and Analytical Procedures

1.3.1 Asbestos

This asbestos inspection was completed in general accordance with the Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) regulation using bulk sampling techniques referenced in OSHA 29 CFR 1910.1001, which in turn, references U.S. EPA Asbestos Hazard Emergency Response Act (AHERA) protocol.

The inspection was completed by separating materials into Homogeneous Areas. A homogeneous area (material) is defined as an area containing a material that appears similar throughout with regard to color, texture, and date of application. Individual systems that were inspected, but not suspected to contain asbestos, are not included in this report. Such systems include concrete, carpet, fiberglass, plastic, and wood products. From the list of suspect homogeneous areas, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, friability, and amount of damage of each material. 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: Refers to spray or troweled applied surfaces such as plaster ceilings and walls, fireproofing, textured paints, textured plasters, and spray-applied acoustical surfaces.

Thermal System Insulation: Refers to insulation used to inhibit heat gain or loss on pipes, boilers, tanks, ducts, and various other building components.

Miscellaneous Materials: Refers to friable and non-friable products and materials that do not fit in any of the above two (2) categories such as resilient floor covering, baseboards, mastics, adhesives, roofing material, caulking, glazing, and siding. This category also contains wallboard, joint compound, and ceiling tiles.

The condition of suspect materials was evaluated as “good”, “damaged”, or “significantly damaged” using the following parameters:

Good - material with no visible damage or deterioration or showing only very limited damage or deterioration.

Damaged - material which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that the bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Damaged material are those that are <10% scattered or <25% localized.

Significantly Damaged - material which has extensive and severe damage. Significantly damaged materials are those that are >10% scattered or > 25% localized.

Each suspect material was also classified as friable (F), Category I non-friable (Cat. I), or Category II non-friable (Cat. II), according to the U.S. EPA National Emissions Standard for Hazardous Air Pollutants (NESHAP) definitions.

The sampled materials were wetted with an amended water solution to minimize the release of airborne fibers during sample collection. A sample collection hand tool, cleaned after the collection of each sample, was used to remove a small sample of suspect material. Each suspect material was placed into a small plastic bag, labeled, and sealed. Upon completion of sampling activities, samples were placed into a sealed container along with chain of custody forms and delivered for analysis to Reservoirs Environmental, Inc.

in Denver, Colorado. Reservoirs Environmental, Inc. is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for conducting bulk and air sample analyses for asbestos.

As specified in 40 CFR Part 763, Subpart F, Appendix A, each sample was analyzed using Polarized Light Microscopy (PLM) in accordance with U.S. EPA Method 600/R-93/116, June, 1993. Some samples will contain numerous “layers”. The laboratory will classify and report each layer found with a corresponding asbestos content. In some instances, bulk samples of similar materials (HAs) are reported as having a different number of layers. Percent asbestos for separate layers and total for the sample are delineated in the laboratory report. Unused portions of samples are archived for six months unless the client requests special handling.

The Environmental Protection Agency (EPA) defines ACM as a material containing greater than 1.0 percent (%) asbestos. Both friable and non-friable materials were sampled. A friable material is a material that when dry may be crumbled, pulverized, or reduced to powder by hand pressure. Because friable materials are more easily damaged and more likely to release fibers into the air, they are of greater concern than non-friable ACM.

Materials containing 1% or less asbestos are considered Trace by EPA. The Occupational Safety and Health Administration (OSHA) Construction Asbestos Standard 29 CFR 1926.1101 contains work practice and engineering control requirements and prohibitions that must be observed regardless of the percentage of asbestos in installed construction materials. Even though these materials are not regulated under the NESHAP for demolition, consideration must be given for worker exposure during any activities that may disturb them.

1.3.2 Lead Paint

The intent of this study was to identify the presence of lead-based paint above HUD specified regulatory action levels. The U.S. Department of Housing and Urban Development (HUD) and the U.S.

Environmental Protection Agency (EPA) define an inspection as a surface-by surface investigation to determine the presence of lead-based paint (see 40 CFR part 745 and Title X of the 1992 Housing and Community Development Act). XRF readings were taken on representative painted surfaces on each building component in each area equivalent. HUD defines lead-based paint as lead equal to or greater than

1.0 mg/cm2. All XRF readings below the HUD regulatory definition are considered negative and all readings at and above this level are considered positive. If lead-based paint was found, the inspection would identify the architectural components and their respective lead concentrations in such a manner that this report could be used as a basis for subsequent abatement activity. FEI understands that the subject property does not meet the definition of a child-occupied facility. This assessment is not a comprehensive survey and is not compliant with all of the EPA and HUD sampling requirements with regard to child occupied facilities.

The XRF utilized for this project was a Heuresis Pb200i Lead Paint spectrum analyzer instrument. The instrument was calibrated to the manufacturer's specifications and was also periodically verified against the National Institute of Standards and Testing (NIST) Standard Reference Materials (SRM) 2570 lead film (0.0 mg/cm2), (SRM) 2571 lead film (3.58 mg/cm2), (SRM) 2572 lead film (1.53 mg/cm2), (SRM) 2573 lead film (1.04 mg/cm2). Each XRF reading taken during the survey is logged in the internal memory of the instrument and downloaded for reporting purposes at the conclusion of the survey. Foothills Environmental, Inc. is a state of Colorado Lead Evaluation Firm #14927.

1.3.3 PCBs

The PCB sampling is necessary to determine if there are PCBs in the building matrix. One sample from each paint type throughout each building should provide a representative understanding of the PCB levels in paint. Wipe samples were collected where staining from oils is evident to determine if the oil stain contained PCBs. One caulk sample was collected from each location where caulk is used within the building. ALS Group USA, Corp., an independent laboratory accredited by the American Industrial Hygiene Association (AIHA), analyzed the bulk and wipe samples for PCBs utilizing Gas Chromatography / Electron Capture Detectors (GC/ECD) according to the current revision of SOP 409 based on EPA SW- 846 test method 8082.

Disposal of PCB containing building material usually falls under 40 CFR 761.62 - PCB Bulk Product Waste (paints or caulking manufactured with PCBs). Materials containing PCBs in a non-liquid state at the time of disposal greater than or equal to 50 ppm are regulated.

1.4 Building Descriptions

The Equipment Storage Building 0002 is an approximately 5,380 square foot metal warehouse structure on with metal siding and roof originally constructed in 1986. The Control Building 0010 is an approximately 2,588 square foot concrete masonry unit structure on concrete slab with a metal roof originally constructed in 1964. The Garage Building 0011 is an approximately 6,500 square foot concrete masonry unit structure on concrete slab with metal roof, originally constructed in 1964 with an addition completed on the west end of the building at a later time. The interior of the Garage Building 0011 is partially finished with vinyl floor tile and drywall walls/ceilings in the office areas. An original built-up flat roof is still present above the original east end of the building beneath the metal roof.

1.5 Statement of Inaccessibility

Accessible areas of the structure were inspected for ACM, LBP, and PCBs within the described scope of work. Underground conduit, roofing materials, electrical panels, instruments or other appurtenances were not inspected. Attempts were made to identify and access suspect materials; however, the potential for additional unidentified materials may exist within inaccessible areas, such as in machinery, in equipment, underground, etc. Any suspect materials located in these areas should be assumed asbestos-containing until sample collection can be performed and subsequent analyses prove otherwise.

Conclusions of the report are professional opinions based solely upon site observations and interpretations of analyses as described in our report. The opinions presented herein apply to site conditions at the time of our investigation, and interpretation of current regulations pertaining to regulated materials. Therefore, our opinions and recommendations may not apply to future conditions that may exist at the building, which we have not had the opportunity to evaluate. The regulations should always be verified prior to any work involving regulated materials.

Within the limitations of scope, schedule, and budget, our services have been executed in accordance with generally accepted practices in this area at the time this report was prepared. No other hazardous materials/wastes were investigated. No other conditions, expressed or implied, should be assumed.

2.0 ASBESTOS-CONTAINING MATERIAL (ACM) LOCATION SUMMARY

The following sections summarize the survey findings and analytical results for suspect ACM sampled at the subject site. ACM summary tables shown have been prepared for each general sample location: floors, walls, ceilings, etc. These tables are organized to show each material analyzed, its asbestos content, and sample location. Representative samples of suspect materials were sent to an accredited laboratory for analysis.

2.1 Equipment Storage Building 0002 Bulk Sample Inspection Summary

The following suspect materials were identified and sampled at Building 0002 during this inspection.

The material identification is listed by Homogeneous Area designation and description following:

2.1.1 Building 0002 Suspect Surfacing Materials

None

2.1.2 Building 0002 Suspect Thermal System Insulation Materials

None

2.1.3 Building 0002 Suspect Miscellaneous Materials

Siding panel screw gasket, black – exterior siding Expansion joint material – cage area concrete slab seams Roof vent caulk, white

2.2 Building 0010 Bulk Sample Inspection Summary

The following suspect materials were identified and sampled at Building 0010 during this inspection.

The material identification is listed by Homogeneous Area designation and description following:

2.2.1 Building 0010 Suspect Surfacing Materials

Interior CMU block filler Exterior CMU block filler

2.2.2 Building 0010 Suspect Thermal System Insulation Materials

None

2.2.3 Building 0010 Suspect Miscellaneous Materials

12” x 12” Vinyl floor tile (white with gray streaks) and mastic (yellow) Cove base mastic (brown/white) associated with 4” cove base (gray) Transite panel remnant debris Door frame caulk (white) Roof caulk (tan) Duct mastic (gray) Built-up tar/foam roofing, original flat roof under metal roof – Assumed to be same as B0011 CMU block vermiculite wall insulation – Assumed HVAC system vibration dampeners – Assumed

2.3 Building 0011 Bulk Sample Inspection Summary

The following suspect materials were identified and sampled at Building 0011 during this inspection.

The material identification is listed by Homogeneous Area designation and description following:

2.3.1 Building 0011 Suspect Surfacing Materials

Interior/exterior CMU block filler – east original build Interior/exterior CMU block filler – west addition

2.3.2 Building 0011 Suspect Thermal System Insulation Materials

None

2.3.3 Building 0011 Suspect Miscellaneous Materials

12” x 12” Vinyl floor tile (white with blue/red streaks) and mastic (tan) 12” x 12” upper vinyl floor tile (white with black dots) and mastic (clear) over lower vinyl floor tile (off-white) and mastic (black) Cove base mastic (tan/yellow) associated with 4” cove base (gray) Cove base mastic (yellow) associated with 4” cove base (tan) Composite drywall and joint compound 2’x4’ ceiling tile (fissures and pin holes pattern) Exterior caulk (white) Exterior caulk (black) Window glazing Wall tile adhesive (white) Duct mastic (white) Duct mastic (gray) Roof caulk (white) Roof mastic (black) Built-up tar/foam roofing, original flat roof under metal roof, in attic space CMU block vermiculite wall insulation – Assumed HVAC system vibration dampeners – Assumed

3.0 ASBESTOS SAMPLE RESULTS TABLE

The following tables summarize asbestos sample results collected for this project. A copy of analytical results is attached in Appendix B to this report for your reference. Sample location are described on Figures attached in Appendix A.

The following table summarizes the sample results collected at the Shiprock Equipment Storage Building 0002:

Sample Number

Material Description Sample Location Condition Approx.

Quantity

Analytical Result

0002-ACM-001

Siding panel screw gasket, black

Exterior siding, south side, east end G / NF All screws

ND

0002-ACM-002 Exterior siding, south side, middle G / NF ND

0002-ACM-003

Expansion joint material

Cage area, floor, northeast corner G / NF

5 SF

ND

0002-ACM-004 Cage area, floor, northwest corner G / NF ND

0002-ACM-005

Roof vent caulk, white

Roof, middle roof vent G / NF

4 SF

ND

0002-ACM-006 Roof, west roof vent G / NF ND

0002-ACM-007 Roof, west roof vent G / NF ND

F= friable NF=non-friable

G=good D=damaged SD=severely damaged SF=square feet LF=linear feet

ND=none detected *= multiple layers

The following table summarizes the sample results collected at the Shiprock Control Building 0010:

Number

Material Description Sample Location Condition Approx.

Quantity

Analytical Result

0010-ACM-001

Interior CMU block filler

Control Room, west wall G / NF

2,424 SF

ND*

0010-ACM-002 Control Room, north wall, at wire hole G / NF ND*

0010-ACM-003 Control Room, north wall, right of door G / NF ND*

0010-ACM-004 Control Room, east wall, upper at beam hole G / NF ND*

0010-ACM-005 Control Room, west wall, upper at beam hole G / NF ND*

0010-ACM-006

Exterior CMU block filler

Exterior, north, debris on ground G / NF

2,424 SF

ND*

0010-ACM-007 Exterior, northwest corner G / NF ND*

0010-ACM-008 Exterior, southwest corner G / F ND

0010-ACM-009 Exterior, southeast corner G / F ND

0010-ACM-010 Exterior, northeast corner G / NF ND*

0010-ACM-011 12”x12” Vinyl floor tile (white with gray streaks) and mastic (yellow)

Control Room, south floor at cut G / NF

2,520 SF

ND*

0010-ACM-012 South Exterior, northeast floor, next to HVAC G / NF ND*

0010-ACM-013 Cove base mastic (brown/white) associated with 4” cove base (gray)

Control Room, west wall G / NF

70 SF

ND*

0010-ACM-014 Control Room, north wall G / NF ND*

0010-ACM-015

Transite panel remnant debris

Control Room, northwest wire trench D / NF

2 SF

20% chrysotile

0010-ACM-016 Exterior, in wire trench at northwest corner D / NF 15% chrysotile

0010-ACM-017

Door frame caulk (white)

Exterior, at north door G / NF

120 SF

ND*

0010-ACM-018 Control Room, at north door G / NF ND*

0010-ACM-019

Roof caulk (tan)

Roof, upper peak G / NF

5 SF

ND

0010-ACM-020 Roof, southwest peak G / NF ND

0010-ACM-021 Roof, southwest peak G / NF ND

0010-ACM-022

Duct Mastic (gray)

Control Room, duct, east end G / NF

10 SF

ND

0010-ACM-023 Control Room, duct, west end G / NF ND*

0010-ACM-024 Control Room, duct, west end G / NF ND*

G=good D=damaged SD=severely damaged

The following table summarizes the sample results collected at the Shiprock Garage Building 0011:

Number

Material Description Sample Location Condition Approx.

Quantity

Analytical Result

0011-ACM-001

Interior/exterior CMU block filler

East Garage, west wall G / NF

>9,000 SF

ND*

0011-ACM-002 East Garage, north wall at window G / NF ND*

0011-ACM-003 East Garage, east wall at Printer Room door G / NF ND*

0011-ACM-004 Printer Room, east wall at door G / NF ND*

0011-ACM-005 Northeast Office, east wall at door G / NF ND*

0011-ACM-006 Exterior, southwest corner G / NF ND*

0011-ACM-007 Exterior, northwest corner G / NF ND*

0011-ACM-008 Exterior, northeast corner G / NF ND*

0011-ACM-009 Exterior, southeast corner G / NF ND*

0011-ACM-010 12”x12” Vinyl floor tile (white with blue/red streaks) and mastic (yellow)

Middle West Office, west floor at door G / NF

768 SF

ND*

0011-ACM-011 Southwest Office, northwest corner floor G / NF ND*

0011-ACM-012 12”x12” upper vinyl floor tile (white with black dots) with mastic (yellow) over lower vinyl floor tile (off-white) with mastic (black)

Southeast Office, northwest corner floor G / NF

180 SF

6% chrysotile in lower tile

0011-ACM-013 Southeast Office, east floor G / NF 6% chrysotile in lower tile

0011-ACM-014 Cove base mastic (tan/yellow) associated with 4” cove base (gray)

Southwest Office, southeast corner G / NF

70 SF

ND*

0011-ACM-015 Middle West Office, stair landing, south wall G / NF ND*

0011-ACM-016

Cove base mastic (yellow) associated with 4” cove base (tan)

Southeast Office, northwest corner G / NF

18 SF

ND*

0011-ACM-017 Southeast Office, northeast corner G / NF ND*

0011-ACM-018

Composite drywall and joint compound

Kitchen, ceiling G / NF

720 SF

3% chrysotile in joint compound (0.31% chrysotile as composite)

0011-ACM-019 Northeast Office, ceiling G / NF 2-3% chrysotile in joint compound

(0.39% chrysotile as composite)

0011-ACM-020

2’x4’ Ceiling tile (fissures and pin holes pattern)

Southwest Office, ceiling G / NF

768 SF

ND

0011-ACM-021 Southwest Office, ceiling G / NF ND

0011-ACM-022 Middle West Office, ceiling G / NF ND

0011-ACM-023

Exterior caulk (white)

West Office, west door, south side G / NF 342 SF (14 doors and 4 windows)

ND

0011-ACM-024 East Garage, west window, west side G / NF ND

G=good D=damaged SD=severely damaged

The following table summarizes the sample results collected at the Shiprock Garage Building 0011:

Number

Material Description Sample Location Condition Approx.

Quantity

Analytical Result

0011-ACM-025

Exterior caulk (black)

Southwest Office, south window G / NF 120 SF (10 windows)

ND

0011-ACM-026 Northeast Office, east window G / NF ND

0011-ACM-027

Interior/exterior CMU block filler (smooth and shiny)

Southwest Office, east wall G / NF

6,000 SF

ND*

0011-ACM-028 Middle West Office, south wall G / NF ND*

0011-ACM-029 Southwest Garage, west wall G / NF ND*

0011-ACM-030 West Loft Stairwell, at window G / NF ND*

0011-ACM-031 West Loft, east wall G / NF ND*

0011-ACM-032 Northwest Garage, east wall G / NF ND*

0011-ACM-033 Northwest Garage, west wall G / NF ND*

0011-ACM-034

Window glazing

East Garage, west window G / NF 48 SF (4 windows)

2% chrysotile

0011-ACM-035 East Garage, east window G / NF 3% chrysotile

0011-ACM-036

Wall tile adhesive (white)

Bathroom, east wall G / NF

200 SF

ND*

0011-ACM-037 Bathroom, west wall G / NF ND*

0011-ACM-038

Duct mastic (white)

West Loft, lower duct, south end G / NF

10 SF

ND

0011-ACM-039 West Loft, upper duct, middle G / NF ND

0011-ACM-040

Duct mastic (gray)

West Loft, lower duct, south end G / NF

10 SF

ND

0011-ACM-041 West Loft, lower duct, north end G / NF ND

0011-ACM-042 West Loft, lower duct, north end G / NF ND

0011-ACM-043

Roof caulk (white)

Roof, middle peak G / NF

5 SF

ND

0011-ACM-044 Roof, west peak G / NF ND

0011-ACM-045

Roof mastic (black)

Roof, north vent G / NF

2 SF

ND

0011-ACM-046 Roof, north vent G / NF ND

0011-ACM-047

Built-up tar/foam roofing

East Garage, attic space, east floor (old roof) G / NF

4,032 SF

2% chrysotile in tar/silver paint

0011-ACM-048 East Garage, attic space, west floor (old roof) G / NF ND* (see 0011-ACM048)

0011-ACM-049 East Garage, attic space, west floor (old roof) G / NF ND* (see 0011-ACM048)

G=good D=damaged SD=severely damaged

4.0 SUMMARY OF XRF RESULTS TABLE

The following table summarizes the XRF results for the Equipment Storage Building 0002:

Shot Building Room Object Substrate Color Location Condition Pb

(mg/cm2) LBP Result

1 N/A N/A Blank N/A N/A N/A N/A 0.1 Negative

2 N/A N/A Positive Baseline N/A N/A N/A N/A 1.1 Positive

3 0002 Main Bay Support Beam Metal Red North Good 0.1 Negative

4 0002 Main Bay Frame Beam Metal Red East Good 0.0 Negative

5 0002 Main Bay Man Door Metal White East Good 0.0 Negative

6 0002 Main Bay Wall (siding) Metal White South Good 0.1 Negative

7 0002 Cage Bay Door Metal White West Good ‐0.2 Negative

8 0002 Cage Bay Door Frame Metal White West Good 0.1 Negative

9 0002 Cage Bay Wall (siding) Metal White East Good 0.1 Negative

10 0002 Exterior Siding Metal Off‐White East Good ‐0.1 Negative

11 0002 Exterior Siding Metal Off‐White South Good 0.1 Negative

13 N/A N/A Positive Baseline N/A N/A N/A N/A 1.0 Positive

14 N/A N/A Blank N/A N/A N/A N/A 0.0 Negative

The following table summarizes the XRF results for the Control Building 0010:

Shot Building Room Object Substrate Color Location Condition Pb

(mg/cm2) LBP Result

1 N/A N/A Blank N/A N/A N/A N/A 0.1 Negative

2 N/A N/A Positive Baseline N/A N/A N/A N/A 1.1 Positive

3 0010 Roof Roof Metal Tan West Good 0.0 Negative

4 0010 Exterior Gutter Metal Brown West Good 0.1 Negative

5 0010 Exterior Wall CMU White North Fair 0.4 Negative

6 0010 Exterior Door Metal Cream/Red North Good 4.9 Positive

7 0010 Exterior Door Metal Cream/Red East Good 0.1 Negative

8 0010 Exterior Door Metal Cream/Red East Good 0.0 Negative

9 0010 Exterior Door Frame Metal Cream/Red East Good 0.0 Negative

10 0010 Exterior Door Threshold Concrete Red East Fair 1.2 Positive

11 0010 Exterior Wall CMU White East Good 0.5 Negative

12 0010 Control Room Cabinet Metal Gray North Good 0.0 Negative

13 0010 Exterior Door Threshold Concrete Red North Fair 1.4 Positive

14 0010 Control Room Door Interior Metal Cream/Red North Good 2.5 Positive

15 0010 Control Room Wall CMU White West Good 0.4 Negative

16 0010 Control Room Wall CMU White East Good 0.2 Negative

17 0010 Control Room Metal Trim Metal Gray East Good 0.0 Negative

18 0010 Control Room Floor Concrete Gray East Good 0.1 Negative

19 0010 Control Room Door Metal Cream/Red East Good 0.1 Negative

20 0010 Control Room Door Frame Metal Cream/Red East Good 0.0 Negative

21 0010 Control Room Roof Truss Metal Red West Good 0.2 Negative

22 N/A N/A Positive Baseline N/A N/A N/A N/A 1.1 Positive

23 N/A N/A Blank N/A N/A N/A N/A 0.1 Negative

The following table summarizes the XRF results for the Garage Building 0011:

Shot Building Room Object Substrate Color Location Condition Pb

(mg/cm2) LBP Result

1 N/A N/A Blank N/A N/A N/A N/A 0.0 Negative

2 N/A N/A Positive Baseline N/A N/A N/A N/A 1.1 Positive

3 0011 Roof Roof Metal Tan South Good 0.1 Negative

4 0011 Roof Sofit Metal White South Good 0.1 Negative

5 0011 SW Office Wall Wood Light Yellow West Good 0.0 Negative

6 0011 SW Office Door Frame Metal Cream East Good 0.5 Negative

7 0011 SW Office Door Metal Cream East Good 0.1 Negative

8 0011 West Stairs Stair Rail Metal Dark Yellow Floor Good 0.3 Negative

9 0011 West Loft Floor CMU Gray Floor Good 0.1 Negative

10 0011 West Loft Roof Truss Metal Red Ceiling Good 0.1 Negative

11 0011 SW Garage Garage Door Metal White South Good 0.0 Negative

12 0011 SW Garage Garage Door Frame Metal White/Red East Good 0.1 Negative

13 0011 East Garage Wall CMU White North Good 0.4 Negative

14 0011 NE Office Wall CMU Light Yellow South Good 0.4 Negative

15 0011 NE Office Door Frame Metal White West Good 0.6 Negative

16 0011 Kitchen Floor Concrete Blue Floor Good 0.1 Negative

17 0011 Print Room Ceiling Drywall White Ceiling Good 0.1 Negative

18 0011 Print Room Door Frame Metal Black West Good 0.8 Negative

19 0011 Exterior Wall CMU Off‐White East Fair 0.4 Negative

20 0011 Exterior Garage Door Metal Off‐White/red South Fair 4.3 Positive

21 0011 Exterior Garage Door Metal Red South Fair 5.0 Positive

22 0011 Exterior Wall CMU Off‐White South Fair 0.4 Negative

23 0011 Exterior Garage Door Metal Off‐White/red South Fair 0.1 Negative

24 0011 Exterior Garage Door Metal Off‐White/red South Fair 0.0 Negative

25 0011 Exterior Door East Garage Door Metal Off‐White/red North Good 2.5 Positive

26 0011 Interior Door East Garage Door Metal White North Good 0.2 Negative

27 0011 Exterior East Garage Window Metal Off‐White/red North Good 2.5 Positive

28 0011 Exterior NW Garage Door Metal Off‐White/red North Good ‐0.1 Negative

29 0011 Exterior NW Garage Door Frame Metal Off‐White/red North Good 0.1 Negative

30 0011 Exterior NW Office Door Metal Off‐White/red North Good 0.0 Negative

31 0011 Exterior MidWest Office Door Metal Off‐White/red West Good 0.1 Negative

32 0011 Exterior Window Metal Brown South Good 0.4 Negative

33 0011 Exterior SW Office Door Metal Off‐White South Good ‐0.1 Negative

34 N/A N/A Positive Baseline N/A N/A N/A N/A 1.1 Positive

35 N/A N/A Blank N/A N/A N/A N/A 0.1 Negative

For the purposes of this report, LBP has been classified as being either in Intact, Fair, or Poor condition.

The following are the general definitions of each condition category.

Intact (Good) Condition Paint is intact with no sign of peeling or damage over the component system

Fair Condition Paint shows signs of wear (chalking, peeling, chipping, abrasion, or minimal delamination less than 10% of a component surface, due to age or other factors such as moisture or physical contact.

Poor condition Paint is substantially delaminating or peeling greater than 10% of a component surface or 25% in a focused area of the component system.

5.0 SUMMARY OF PCB RESULTS

Sample ID – 0002-PCB-001 Exterior siding paint (off-white) Parameter Result Det. Limit

PCB 1016 Not detected 10 mg/kg PCB 1221 Not detected 10 mg/kg PCB 1232 Not detected 10 mg/kg PCB 1242 Not detected 10 mg/kg PCB 1248 Not detected 10 mg/kg PCB 1254 Not detected 10 mg/kg PCB 1260 Not detected 10 mg/kg

Sample ID – 0002-PCB-002 Support beam/truss paint (red) Parameter Result Det. Limit PCB 1016 Not detected 4.2 mg/kg PCB 1221 Not detected 4.2 mg/kg PCB 1232 Not detected 4.2 mg/kg PCB 1242 Not detected 4.2 mg/kg PCB 1248 Not detected 4.2 mg/kg PCB 1254 Not detected 4.2 mg/kg PCB 1260 Not detected 4.2 mg/kg

Sample ID – 0002-PCB-003 Interior siding paint (white) Parameter Result Det. Limit PCB 1016 Not detected 8.3 mg/kg PCB 1221 Not detected 8.3 mg/kg PCB 1232 Not detected 8.3 mg/kg PCB 1242 Not detected 8.3 mg/kg PCB 1248 Not detected 8.3 mg/kg PCB 1254 Not detected 8.3 mg/kg PCB 1260 Not detected 8.3 mg/kg

Sample ID – 0002-PCB-004 Roof vent caulk (clear/white) Parameter Result Det. Limit PCB 1016 Not detected 2.7 mg/kg PCB 1221 Not detected 2.7 mg/kg PCB 1232 Not detected 2.7 mg/kg PCB 1242 Not detected 2.7 mg/kg PCB 1248 Not detected 2.7 mg/kg PCB 1254 Not detected 2.7 mg/kg PCB 1260 Not detected 2.7 mg/kg

Sample ID – 0010-PCB-001

Interior wall/ceiling paint (white) Parameter Result Det. Limit PCB 1016 Not detected 0.98 mg/kg PCB 1221 Not detected 0.98 mg/kg PCB 1232 Not detected 0.98 mg/kg PCB 1242 Not detected 0.98 mg/kg PCB 1248 Not detected 0.98 mg/kg PCB 1254 9.4 mg/kg 0.98 mg/kg PCB 1260 Not detected 0.98 mg/kg

Sample ID – 0010-PCB-002 Roof truss paint (red) Parameter Result Det. Limit PCB 1016 Not detected 6.2 mg/kg PCB 1221 Not detected 6.2 mg/kg PCB 1232 Not detected 6.2 mg/kg PCB 1242 Not detected 6.2 mg/kg PCB 1248 Not detected 6.2 mg/kg PCB 1254 20 mg/kg 6.2 mg/kg PCB 1260 Not detected 6.2 mg/kg

Sample ID – 0010-PCB-003

Interior door paint (cream) Parameter Result Det. Limit PCB 1016 Not detected 12 mg/kg PCB 1221 Not detected 12 mg/kg PCB 1232 Not detected 12 mg/kg PCB 1242 Not detected 12 mg/kg PCB 1248 Not detected 12 mg/kg PCB 1254 5.3 mg/kg 12 mg/kg PCB 1260 Not detected 12 mg/kg

Sample ID – 0010-PCB-004 Metal roof paint (tan) Parameter Result Det. Limit PCB 1016 Not detected 10 mg/kg PCB 1221 Not detected 10 mg/kg PCB 1232 Not detected 10 mg/kg PCB 1242 Not detected 10 mg/kg PCB 1248 Not detected 10 mg/kg PCB 1254 Not detected 10 mg/kg PCB 1260 Not detected 10 mg/kg

Sample ID – 0010-PCB-005 Metal roof gutter paint (brown) Parameter Result Det. Limit PCB 1016 Not detected 17 mg/kg PCB 1221 Not detected 17 mg/kg PCB 1232 Not detected 17 mg/kg PCB 1242 Not detected 17 mg/kg PCB 1248 Not detected 17 mg/kg PCB 1254 Not detected 17 mg/kg PCB 1260 Not detected 17 mg/kg

Sample ID – 0010-PCB-006 Caulk (white) Parameter Result Det. Limit PCB 1016 Not detected 2.6 mg/kg PCB 1221 Not detected 2.6 mg/kg PCB 1232 Not detected 2.6 mg/kg PCB 1242 Not detected 2.6 mg/kg PCB 1248 Not detected 2.6 mg/kg PCB 1254 Not detected 2.6 mg/kg PCB 1260 Not detected 2.6 mg/kg

Sample ID – 0010-PCB-007 Caulk (pink) Parameter Result Det. Limit PCB 1016 Not detected 3.7 mg/kg PCB 1221 Not detected 3.7 mg/kg PCB 1232 Not detected 3.7 mg/kg PCB 1242 Not detected 3.7 mg/kg PCB 1248 Not detected 3.7 mg/kg PCB 1254 Not detected 3.7 mg/kg PCB 1260 Not detected 3.7 mg/kg

Sample ID – 0010-PCB-008 Exterior caulk (white) Parameter Result Det. Limit PCB 1016 Not detected 2.5 mg/kg PCB 1221 Not detected 2.5 mg/kg PCB 1232 Not detected 2.5 mg/kg PCB 1242 Not detected 2.5 mg/kg PCB 1248 Not detected 2.5 mg/kg PCB 1254 Not detected 2.5 mg/kg PCB 1260 Not detected 2.5 mg/kg

Sample ID – 0010-PCB-009 Roof caulk (tan) Parameter Result Det. Limit PCB 1016 Not detected 4.7 mg/kg PCB 1221 Not detected 4.7 mg/kg PCB 1232 Not detected 4.7 mg/kg PCB 1242 Not detected 4.7 mg/kg PCB 1248 Not detected 4.7 mg/kg PCB 1254 Not detected 4.7 mg/kg PCB 1260 Not detected 4.7 mg/kg

Sample ID – 0010-PCB-010 Concrete door threshold paint (red) Parameter Result Det. Limit PCB 1016 Not detected 3.7 mg/kg PCB 1221 Not detected 3.7 mg/kg PCB 1232 Not detected 3.7 mg/kg PCB 1242 Not detected 3.7 mg/kg PCB 1248 Not detected 3.7 mg/kg

Sample ID – 0011-PCB-001 West Garage CMU paint (light yellow) Parameter Result Det. Limit PCB 1016 Not detected 1.9 mg/kg PCB 1221 Not detected 1.9 mg/kg PCB 1232 Not detected 1.9 mg/kg PCB 1242 Not detected 1.9 mg/kg PCB 1248 Not detected 1.9 mg/kg PCB 1254 Not detected 1.9 mg/kg PCB 1260 Not detected 1.9 mg/kg

Sample ID – 0011-PCB-002 East Garage metal rail paint (dark yellow) Parameter Result Det. Limit PCB 1016 Not detected 12 mg/kg PCB 1221 Not detected 12 mg/kg PCB 1232 Not detected 12 mg/kg PCB 1242 Not detected 12 mg/kg PCB 1248 Not detected 12 mg/kg PCB 1254 Not detected 12 mg/kg

Sample ID – 0011-PCB-003 West Garage metal door/frame paint (cream) Parameter Result Det. Limit PCB 1016 Not detected 12 mg/kg PCB 1221 Not detected 12 mg/kg PCB 1232 Not detected 12 mg/kg PCB 1242 Not detected 12 mg/kg PCB 1248 Not detected 12 mg/kg PCB 1254 Not detected 12 mg/kg

Sample ID – 0011-PCB-004 Roof truss paint (red) Parameter Result Det. Limit PCB 1016 Not detected 17 mg/kg PCB 1221 Not detected 17 mg/kg PCB 1232 Not detected 17 mg/kg PCB 1242 Not detected 17 mg/kg PCB 1248 Not detected 17 mg/kg

Sample ID – 0011-PCB-005 East Garage wall/ceiling paint (white) Parameter Result Det. Limit PCB 1016 Not detected 3.1 mg/kg PCB 1221 Not detected 3.1 mg/kg PCB 1232 Not detected 3.1 mg/kg PCB 1242 Not detected 3.1 mg/kg PCB 1248 Not detected 3.1 mg/kg PCB 1254 Not detected 3.1 mg/kg PCB 1260 Not detected 3.1 mg/kg

Sample ID – 0011-PCB-006 Kitchen floor paint (blue) Parameter Result Det. Limit PCB 1016 Not detected 4.1 mg/kg PCB 1221 Not detected 4.1 mg/kg PCB 1232 Not detected 4.1 mg/kg PCB 1242 Not detected 4.1 mg/kg PCB 1248 Not detected 4.1 mg/kg PCB 1254 3.7 mg/kg 4.1 mg/kg PCB 1260 Not detected 4.1 mg/kg

Sample ID – 0011-PCB-007 Exterior paint (off-white/white) Parameter Result Det. Limit PCB 1016 Not detected 2.5 mg/kg PCB 1221 Not detected 2.5 mg/kg PCB 1232 Not detected 2.5 mg/kg PCB 1242 Not detected 2.5 mg/kg PCB 1248 Not detected 2.5 mg/kg PCB 1254 Not detected 2.5 mg/kg PCB 1260 Not detected 2.5 mg/kg

Sample ID – 0011-PCB-008 Exterior garage door paint (off-white/red) Parameter Result Det. Limit PCB 1016 Not detected 2.9 mg/kg PCB 1221 Not detected 2.9 mg/kg PCB 1232 Not detected 2.9 mg/kg PCB 1242 Not detected 2.9 mg/kg PCB 1248 Not detected 2.9 mg/kg PCB 1254 Not detected 2.9 mg/kg PCB 1260 Not detected 2.9 mg/kg

Sample ID – 0011-PCB-009 Exterior caulk (white) Parameter Result Det. Limit PCB 1016 Not detected 3.7 mg/kg PCB 1221 Not detected 3.7 mg/kg PCB 1232 Not detected 3.7 mg/kg PCB 1242 Not detected 3.7 mg/kg PCB 1248 Not detected 3.7 mg/kg

Sample ID – 0011-PCB-010 Exterior caulk (black) Parameter Result Det. Limit PCB 1016 Not detected 3.4 mg/kg PCB 1221 Not detected 3.4 mg/kg PCB 1232 Not detected 3.4 mg/kg PCB 1242 Not detected 3.4 mg/kg PCB 1248 Not detected 3.4 mg/kg PCB 1254 Not detected 3.4 mg/kg PCB 1260 Not detected 3.4 mg/kg

Sample ID – 0011-PCB-011 West Loft floor paint (gray) Parameter Result Det. Limit PCB 1016 Not detected 4.2 mg/kg PCB 1221 Not detected 4.2 mg/kg PCB 1232 Not detected 4.2 mg/kg PCB 1242 Not detected 4.2 mg/kg PCB 1248 Not detected 4.2 mg/kg PCB 1254 Not detected 4.2 mg/kg PCB 1260 Not detected 4.2 mg/kg

Sample ID – 0011-PCB-012 Metal roof paint (tan) Parameter Result Det. Limit PCB 1016 Not detected 17 mg/kg PCB 1221 Not detected 17 mg/kg PCB 1232 Not detected 17 mg/kg PCB 1242 Not detected 17 mg/kg PCB 1248 Not detected 17 mg/kg

Sample ID – 0011-PCB-013 Roof peak seam caulk (white) Parameter Result Det. Limit PCB 1016 Not detected 3.2 mg/kg PCB 1221 Not detected 3.2 mg/kg PCB 1232 Not detected 3.2 mg/kg PCB 1242 Not detected 3.2 mg/kg PCB 1248 Not detected 3.2 mg/kg PCB 1254 Not detected 3.2 mg/kg PCB 1260 Not detected 3.2 mg/kg

Sample ID – 0011-PCB-014 Metal window paint (brown) Parameter Result Det. Limit PCB 1016 Not detected 17 mg/kg PCB 1221 Not detected 17 mg/kg PCB 1232 Not detected 17 mg/kg PCB 1242 Not detected 17 mg/kg PCB 1248 Not detected 17 mg/kg

Sample ID – 0011-WS-001 East garage floor oil stain Parameter Result Det. Limit PCB 1016 Not detected 1 mg/kg PCB 1221 Not detected 2 mg/kg PCB 1232 Not detected 1 mg/kg PCB 1242 Not detected 1 mg/kg PCB 1248 Not detected 1 mg/kg PCB 1254 Not detected 1 mg/kg PCB 1260 Not detected 1 mg/kg

Sample ID – 0011-WS-002 East garage floor oil stain

Parameter Result Det. Limit PCB 1016 Not detected 1 mg/kg PCB 1221 Not detected 2 mg/kg PCB 1232 Not detected 1 mg/kg PCB 1242 Not detected 1 mg/kg PCB 1248 Not detected 1 mg/kg PCB 1254 Not detected 1 mg/kg PCB 1260 Not detected 1 mg/kg

6.0 CONCLUSIONS and RECOMMENDED ACTIONS

6.1 Asbestos

Asbestos-Containing Materials – General

Removal, in accordance with the EPA NESHAP, is required of materials with an asbestos content greater than one percent (1%) that are friable or will be made friable during renovation or demolition activities.

Friable means that the material, when dry may be crumbled, pulverized, or reduced to powder by hand pressure.

The National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations set forth by the U.S.

Environmental Protection Agency control asbestos emissions from renovation and demolition activities.

The following sections describe materials that were identified during this inspection and recommended actions prior to renovation or demolition.

6.1.1 Friable ACM

No materials were identified as friable ACM during the inspection.

6.1.2 Non-friable ACM

The following materials were identified as, or assumed to be, non-friable ACM during the inspection:

The approximately 2 square feet of significantly damaged non-friable Transite panel and remnant debris present in the Control Building 0010 northwest wire trench on the interior and exterior of the building contained 15-20% chrysotile asbestos.

The approximately 180 square feet of non-friable lower vinyl floor tile layer (off-white) with black mastic (black) present throughout the Garage Building 0011 East Garage Printer Room contained 6% chrysotile asbestos in the tile. The black mastic, upper vinyl floor tile layer and clear adhesive associated with the Printer Room flooring do not contain asbestos.

The non-friable window glazing associated with the approximately 48 square feet of window surface area associated with the four (4) windows along the Garage Building 0011 south exterior wall contained 2-3% chrysotile asbestos.

The black tar with silver paint associated with the approximately 4,032 square feet of non-friable flat built-up tar/foam roofing located on the floor of the attic space of the Garage Building 0011 East Garage contained 2% chrysotile asbestos.

The CMU block structural walls throughout the building are assumed to contain insulation on the interior hollow cavities within the CMU blocks. CMU block insulation must be assumed to be asbestos containing until inspection and sampling proves otherwise.

The approximately (3) vibration dampeners associated with the HVAC system ductwork located in the Garage Building 0011 West Loft must be assumed to be asbestos containing until inspection and sampling proves otherwise

Cementitious (Transite) Panels are classified as non-friable materials. These materials can become friable if aging and corrosion causes deterioration of the panels. Abrasive actions such as drilling, hammering, cutting, grinding, etc. will also cause the materials to become friable and should not be performed during maintenance activities without following proper precautions. Any removal of or alteration to asbestos-containing cementitious panels requires adherence to all applicable local, state, and federal regulations concerning removal and disposal of asbestos materials. Periodic condition inspections are recommended until the materials are removed.

Floor tile is a Category I non-friable ACM. Category I material is defined as asbestos-containing resilient floor covering, asphalt roofing products, packings and gaskets. Asbestos-containing mastic is also considered a Category I material. Category I non-friable ACM that has a high probability of becoming crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations are considered a regulated asbestos-containing material and must comply with NESHAP regulations. Care should be exercised when cleaning floor tile surfaces. Loose and damaged floor tiles should be repaired or removed using trained personnel, wearing proper personal protective equipment (PPE), and following proper O&M procedures. A wet cleaning or polishing agent should always be used when buffing is performed. Abrasive actions such as dry buffing, drilling, grinding, hammering, sawing, etc. should not be performed unless proper precautions are followed. Alterations to or the removal of these materials requires adherence to all applicable local, state, and federal regulations concerning asbestos removal and disposal. Periodic condition inspections are recommended until the materials are removed.

Roofing Materials are classified as non-friable material unless severely damaged by heat, air, or water erosion. Generally, if roofing materials are damaged to the extent where the materials are classified as friable, the roofing system will fail and replacement will be necessary. If a roofing system needs to be replaced due to failure or for renovations, all applicable local, state, and federal regulations concerning asbestos removal and disposal must be followed. Abrasive actions such as cutting, drilling, grinding, etc.

should not be performed on asbestos-containing roofing materials. Periodic condition inspections are recommended until the materials are removed.

Window Glazing compounds are classified as non-friable materials when intact and in good condition.

These materials can become friable if aging and exposure to the weather causes deterioration of the compounds. Abrasive actions such as drilling, hammering, cutting, grinding, etc… will also cause the materials to become friable and should not be performed during maintenance activities without following proper precautions. Any removal of or alteration to asbestos- containing window glazing compounds requires adherence to all applicable local, state, and federal regulations concerning removal and disposal of asbestos materials. Periodic condition inspections are recommended until the materials are removed.

6.1.3 Materials Containing 1% or Less Asbestos (Trace)

Materials that do not contain asbestos greater than 1% by point-count analysis are allowed to remain during demolition and can be disposed as non-ACM waste. Removal, in accordance with the NESHAP regulations is not required.

The Occupational Safety and Health Administration (OSHA) Construction Asbestos Standard 29 CFR

1926.1101 contains work practice and engineering control requirements and prohibitions that must be observed regardless of the percentage of asbestos in the installed construction materials. The employer still must follow the requirements in paragraphs (g)(1) [except (g)(1)(i)], (g)(2) and (g)(3) that describe engineering and work practice controls operation as well as prohibitions that must be observed regardless of the percentage of asbestos in construction materials.