250070-AS_Palm_Harbor_Parks_Rec_Building_2_Asbestos_Survey_Report.pdf

Asbestos Demolition Survey

Performed at:

Palm Harbor Parks & Recreation

Acton Building 2

Report Prepared For:

Pinellas County

Report Prepared By:

OHC Environmental Engineering, Inc.

101 South Hoover Blvd, Suite 101

Tampa, FL 33609

OHC Project #250070-AS

April 28, 2025

Palm Harbor Parks and Recreation Building 2

Asbestos NESHAP Survey

OHC Project No. 250070-AS

PROJECT INFORMATION

OHC PROJECT NO. 250070-AS

CLIENT NAME: Pinellas County

CLIENT CONTACT:

Mr. Derek Weaver

PROJECT LOCATION: Palm Harbor

Parks and Recreation Acton Building 2

SERVICES PERFORMED: Asbestos NESHAP Survey

DATES OF SERVICES: 4/15/2025 to 4/18/2025

CONSULTING FIRM: OHC Environmental Engineering, Inc.

101 South Hoover Blvd, Suite 101

Tampa, FL 33609

SURVEYOR:

Nick Foster

REPORT REVIEWED BY:

James F. Rizk, CIH, FLAC

LICENSED CONSULTANT:

James F. Rizk, CIH

FLAC #IA0000022

Asbestos NESHAP Survey

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTION

3.0 EXECUTIVE SUMMARY

4.0 ASBESTOS SURVEY

4.1 Asbestos Survey Results

4.2 Asbestos Sampling Methods

4.3 Regulatory Requirements

4.4 Statutory Requirements

5.0 OBSERVATIONS

6.0 CONCLUSIONS

7.0 LIMITATIONS

8.0 DOCUMENT CONTENT

List of Tables

Table 1 - Asbestos Containing Material

Table 2 - Materials Sampled for Asbestos

List of Appendices

APPENDIX A: Laboratory Results for Asbestos Samples

APPENDIX B: Consultant & Laboratory Credentials

Asbestos NESHAP Survey

1.0 INTRODUCTION

OHC Environmental Engineering, Inc., (OHC), was contracted by Mr. Derek Weaver of

Pinellas County Construction Services to perform an Asbestos Survey in compliance with the National Emission Standard for Hazardous Air Pollutants (NESHAP) regulation for asbestos (40 CFR 61, Subpart M). These services were conducted for the upcoming demolition of the Palm Harbor Parks and Recreation (Acton) Building 2. A representative from OHC and certified AHERA Building Inspector, Nick Foster, visited the site on April

15th through the 18th of 2025, to perform these services.

2.0 BUILDING DESCRIPTION

The building is a single-story structure with an exterior of CMU block walls and brick and mortar. The roof of the building is a sheet roofing system. The interior of the building has several types of flooring including carpet tiles, various VCT flooring with mastic, and ceramic floor tile. The walls throughout the building were a mix of GWBS and CMU block. The ceiling throughout much of the building is a drop down ceiling with insulated ductwork above.

3.0 EXECUTIVE SUMMARY

Based on the results of the Polarized Light Microscopy (PLM) laboratory analysis, asbestos-containing materials (ACM) are present, as indicated in Table 1 below.

Asbestos NESHAP Survey

TABLE 1: ASBESTOS CONTAINING MATERIALS

HSA Material Locations Material

Description

Quantity, Condition, Friability

Results

EPA

Category

& OSHA

Class

Picture

Interior of Room

2-107

Green VCT with

Streaks and

Yellow Mastic

~2368 SF

Good

Non-

Friable

15% Chrysotile

(Flooring)

NF Cat I

Class II

Room 2-105

Flooring

Blue and Various

Patterned Carpet

Tiles with Mastic

~640 SF

Good

Non-

Friable

35% Chrysotile

(Flooring)

NF Cat II

Asbestos NESHAP Survey

19 Room 2-105 Sink

Black Sink

Condensate

Coating

TBD

Good

Non-

Friable

10% Chrysotile NF Cat II

Room 2-123

Flooring

Green Carpet with Yellow

Mastic over

White Sheet

Flooring

~456 SF

Good

Non-

Friable

10% Chrysotile

(Sheet Flooring)

4% Chrysotile

(Mastic)

NF Cat I

Asbestos NESHAP Survey

N/A

Restroom Mirrors

Room 2-112

Room 2-120

Mirror Mastic

Mirrors

Throughout

Good

Non-

Friable

PACM

NF Cat II

(No Photo Available)

Asbestos NESHAP Survey

4.0 ASBESTOS SURVEY

The Environmental Protection Agency defines asbestos-containing material (ACM) as any material or product that contains more than one percent (1%) asbestos. Based on the laboratory analysis of the samples collected, ACM does not exist within the scope of this survey.

4.1 Asbestos Survey Results

Table 2 below summarizes the samples of suspect ACM collected from the site and describes the homogenous sampling area (HSA), sample ID, sample location, material description, quantity, condition, friability, and the laboratory analytical result. Please refer to the Appendices at the end of this report for official laboratory analytical results.

LEGEND:

▪ NAD = No Asbestos Detected

▪ ### = the material contains asbestos and requires compliance with NESHAP and OSHA

▪ * = Quality Control sample to ensure the reliability of laboratory analytical procedures

Asbestos NESHAP Survey

TABLE 2: MATERIALS SAMPLED FOR ASBESTOS

HSA

Sample

ID

Sample Location

Material

Description

Quantity, Condition, Friability

Lab

Results

Picture

070-1A Exterior of Building

North

Exterior Wall

Texture

Building

Exterior

Good

Non-Friable

NAD

070-1B Exterior of Building West

070-1C Exterior of Building

Southwest Corner

070-1D Exterior of Building

South

070-1E Exterior of Building

Northeast Corner

070-2A Exterior of Building

North Windows

Exterior White

Window Caulking

Windows

Good

070-2B Exterior of Building

South Windows

Asbestos NESHAP Survey

070-3A Exterior Northside

Concrete

Foundation &

Sidewalks

TBD

Good

070-3B Exterior Westside

070-3C Exterior Southside

070-4A Exterior Concrete Walls

Concrete Walls

TBD

Good

070-4B Exterior Concrete Walls

070-4C Exterior Concrete Walls

Asbestos NESHAP Survey

5 070-5A*

Exterior Sealant around

Metal Corrugated Wrap and Awning Ceiling

White

Sealant/Caulking

TBD

Fair

070-6A Exterior Walls West

Exterior CMU

Block & Mortar

TBD

Good

070-6B Exterior Walls South

070-6C Exterior Walls North

Asbestos NESHAP Survey

070-7A Exterior Westside

Windows

Exterior Black

Window & Door

Caulking

Exterior Doors and Windows

Good

070-7B Exterior Southside Door

070-7C Exterior Door Northside

8 070-8A* Exterior Concrete South Grey Expansion

Joint Compound

TBD

Good

Asbestos NESHAP Survey

070-9A Interior North Entrance

Reception Area

Cove Base with

Brown Mastic

Throughout

Interior

Good

070-9B Interior Room 2-110

070-9C Interior Outside of Room

2-120

070-10A Interior North Reception

Area

Light Blue VCT with Blue Streaks and Yellow Mastic

~936 SF

Good

070-10B Interior Room 2-110

070-10C Hallway Outside Fire

Riser Room 106

Asbestos NESHAP Survey

070-11A Interior North Reception

Area

GWBS

Throughout

Interior

Good

070-11B Interior Room 2-110

070-11C Interior Outside of Room

2-120

070-11D Interior Fire Riser Room

2-106

070-11E Interior Room 2-124

070-12A Interior Door to Room 2-

Interior Door

Caulking

Interior Doors

Good

070-12B Interior Door to Room 2-

070-12C Interior Door to Men’s

Restroom 2-125

Asbestos NESHAP Survey

070-13A Interior North Entrance

Reception Area Ceiling

White 2’ x 2’

Wormhole Ceiling

Tiles

Throughout

Interior

Good

Friable

070-13B Interior Drop Ceiling

Outside of Room 2-105

070-13C Interior Drop Ceiling

Room 2-105

070-14A Interior Room 2-109

Storage Closet

Beige VCT with

Yellow Mastic

~650 SF

Good

070-14B Interior Fire Riser Room

2-106

070-14C Interior Room 2-108

Asbestos NESHAP Survey

070-15A Interior North Reception

Area above Drop Ceiling

Silver Backed

Insulation

Throughout

Building

Good

070-15B

Interior above Drop

Ceiling Outside of Room

2-105

070-15C Interior outside of Room

2-124

070-16A Interior Outside of Room

2-120

Green VCT with

Streaks and Yellow

Mastic

~2368 SF

Good

Non-Friable

15%

Chrysotile

(Sheet

Flooring)

070-16B Interior of Room 2-107

Asbestos NESHAP Survey

17 070-17A Interior Outside of Room

2-120

Grey Interior

Window Caulking

Interior

Good

18 070-18A Room 2-105 Flooring

Blue and Various

Patterned Carpet

Tiles with Mastic

~640 SF

Good

Non-Friable

35%

Chrysotile

(Flooring)

Asbestos NESHAP Survey

19 070-19A Room 2-105 Sink

Black Sink

Condensate

Coating

1 Sink

Good

Non-Friable

10%

070-20A Room 2-105B Floor

White Rectangular

Pattern Floor Tile with Black Grout and Grey Mastic

~420 SF

Good

070-20B Room 2-107B

070-20C Men’s Restroom 2-125

Asbestos NESHAP Survey

070-21A Room 2-105B Walls

White Rectangular

Pattern Floor Tile with Black Grout and Yellow Mastic

~121 SF

Good

070-21B Room 2-107B

070-21C Men’s Restroom 2-125

22 070-22A* Room 2-108B

White VCT with

Streaks and Yellow

Mastic

~48 SF

Good

Asbestos NESHAP Survey

070-23A Room 2-124

Blue VCT with

Yellow Mastic over

Beige VCT with

Yellow Mastic

~1608 SF

Good

070-23B Women’s Restroom 2-

070-23C Men’s Restroom 2-119

070-24A Room 2-123 Flooring

Green Carpet with

Yellow Mastic over

White Sheet

Flooring

~456 SF

Good

Non-Friable

10%

Chrysotile

(Sheet

Flooring)

4%

(Mastic)

070-24B Room 2-123 Flooring

070-24C Room 2-115 Flooring

Asbestos NESHAP Survey

25 070-25A Room 2-122A Side

Storage Room Flooring

Gren 1” x 1” Floor

Tile with Biege

Grout and Grey

Mastic

~75 SF

Good

26 070-26A Room 2-122A Side

Storage Room Walls

Pink 4” x 4” Wall

Tile with Beige

Grout and White

Mastic

~75 SF

Good

Asbestos NESHAP Survey

070-27A* Metal Ducts above

Ceiling

Grey Mastic on

Metal Ducts

Throughout

Building

Good

070-27B Metal Ducts above

Ceiling

070-27C Metal Ducts above

Ceiling

070-28A Exterior West

Black Sealant on

Backside of Metal

Sheeting

Exterior Metal

Paneling

Good

070-28B Exterior North

070-28C Exterior South

Asbestos NESHAP Survey

29 070-29A* Exterior West Plaster Soffit

Ceilings

Exterior Soffit

Good

070-30A Roof Northside

Layered Roofing

Material

Roof of

Building

Good

070-30B Roof Center

070-30C Roof Southside

070-30D Roof Westside

Asbestos NESHAP Survey

070-31A Exterior Roof South

White Flashing

Caulking

Perimeter of

Roof

Good

070-31B Exterior Roof West

Asbestos NESHAP Survey

4.2 Asbestos Sampling Methods

Asbestos sampling was conducted in accordance with NESHAP (40 CFR 61, Subpart

M) protocol for the commencement of demolition/renovation activities. The surveyor conducted a visual inspection of every safe and reasonably accessible room and space of the building. Materials sampled were grouped into Homogenous Sampling Areas

(HSA) based on the texture, color, use, age, condition, and every other visual appearance to identify suspect ACM. Materials containing asbestos are grouped into the following categories:

• Regulated ACM (RACM): Refers to friable manufactured ACM or a

Category I non-friable ACM that has become friable; or a Category I Non-

Friable ACM that will be or has been subjected to sanding, grinding, cutting or abrading; or a 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.

• Category I Non-Friable ACM: Refers to asbestos containing packing, gaskets, resilient floor coverings (including mastics), and asphalt roofing products containing more than 1% asbestos.

• Category II Non-Friable ACM: Refers to any material that is not a

Category I Non-Friable ACM that contains greater than 1% asbestos.

Bulk samples of all friable and non-friable suspect ACM were collected, as well as a representative number of samples from each homogeneous area following the EPA's simplified random sampling method (EPA560/585-030a). Good Industrial Hygiene practices were followed when collecting bulk samples to minimize fiber release.

Every precaution was taken to prevent asbestos exposure to the surveyor, the building occupants, and the public. All sample locations were logged with an appropriate description and the locations were marked on any available drawings. A unique sequential numbering system was used to identify each area. Each bulk sample was placed in a labeled bag, which was immediately marked with its sample number. Strict

Chain-of-Custody protocols were followed and signed by the receiving laboratory personnel who handled the samples. The samples were analyzed via PLM EPA-600 by an AIHA and NVLAP accredited laboratory.

4.3 Regulatory Requirements

Demolition: According to NESHAP, 40CFR61 Subpart M, demolition is defined as the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility.

The final NESHAP Rule provides classification for regulated asbestos containing material as follows:

• Friable Asbestos material

• Category I non-friable ACM that has become friable

Asbestos NESHAP Survey

• Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; or

• Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by forces expected to act upon the material during demolition or renovation operations.

If the total asbestos content is determined to be trace to 10%, the owner must either assume that the material contains greater than 1% asbestos and treat the material as regulated asbestos-containing material (RACM) or have the material verified/quantified by point counting. If after point counting, the material is quantified as 1% or less, it is not regulated by the NESHAP. The Occupational

Safety and Health Administration (OSHA) considers material that contains any amount of asbestos as asbestos-containing and requires compliance with OSHA regulations. The demolition of a structure with materials present that contain any amount of asbestos is considered by OSHA as an asbestos abatement, and all applicable OSHA rules must be complied with during the demolition.

Notification: Notification is required by the local regulatory agency:

1. Ten (10) working days prior to any demolition. Demolition means the removal of any load supporting structural member of the building.

2. Ten (10) working days prior to a renovation operation, if the amount of asbestos material removed or impacted is greater than 160 SF on all building components (i.e. floor tile, mastic, GWBS, etc.) or 260 LF on pipes.

3. One (1) day prior to demolition, if the building has been condemned and is structurally unsound as determined by the appropriate agency.

Notification must be sent by certified mail with return receipt or hand delivered to the Florida Department of Environmental Protection. The demolition contractor must wait ten (10) working days (Monday – Friday) from the postmarked date of mailing or the date of hand delivery to commencement of demolition. Any change to the start date of the demolition requires notification to the agency by phone, followed by a written revision of the Notification Form.

4.4 Statutory Requirements

The regulatory agency responsible for the oversight of the rules pertaining to asbestos-containing building materials (ACBM) is the Environmental Protection Agency

(EPA). The federal regulations state that prior to demolition or renovation a facility survey must be conducted in accordance with section 40 CFR 61-M National

Emission Standards for Hazardous Air Pollutants; Asbestos NESHAP Revisions, Final Rule.

Asbestos NESHAP Survey

Enforcement of these rules was passed on to the states. In the State of Florida, they are enforced by the Department of Environmental Protection (DEP). Some counties have developed an enforcement division to carry out the responsibilities of the DEP and have developed environmental and asbestos ordinances with which may be more stringent than federal regulations, compliance with all local ordinance is also required.

5.0 OBSERVATIONS

• The mirrors inside the building restrooms as well as rooms 2-112 and 2-120 are presumed to contain positive mastic

• No drawings were provided for markup

6.0 CONCLUSIONS

Based on the results of the PLM analysis, ACM is present as listed in Table 1.

A 10-working days notification is required prior to any demolition activity. Demolition means the removal of any load support structural member of the building.

A 10-working day notification is required prior to the removal of any regulated Asbestos containing material.

7.0 LIMITATIONS

The materials sampled in this survey were subject to accessibility. OHC warrants that the investigations and methodology reflect the prevailing standard of work practices in the environmental consulting field. If unforeseen materials are discovered during the renovation/demolition of the facility, work should stop, and the material be presumed ACM until the material can be analyzed by an accredited asbestos building inspector.

8.0 DOCUMENT CONTENT

This document had been made for exclusive use by Pinellas County. The knowledge of the consultant is based upon current information and research. If local knowledge indicates error, omissions, or inaccuracy, please notify the consultant.

Asbestos NESHAP Survey

APPENDIX A:

LABORATORY RESULTS

FOR ASBESTOS SAMPLES

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APPENDIX B:

CONSULTANT & LABORATORY

CREDENTIALS

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