Enclosure_4_-_Hazardous_Materials_Assessment.pdf

ENCLOSURE 4

HAZARDOUS MATERIALS ASSESSMENT

Residential Structures

12940 US Highway 441 North

Canal Point

Palm Beach County, Florida

Contract Number: GS-10F-181BA

Order Number: AG-32SC-D-15-0188

Requisition Number: 765619

September 30, 2015

Prepared for:

United States Department of Agriculture (USDA/ARS)

1815 N University Street

Peoria, Illinois 61604

EAC Project Number: 15-2674

Prepared by:

Environmental Assessments & Consulting

1500 NW 3 Street, Suite 104rd

Deerfield Beach, Florida 33442

1500 NW 3rd Street, Suite 104 #105

Deerfield Beach, Florida 33442 www.eacusa.com

S Sarasota t. Petersburg Ft. Lauderdale Atlanta Charlotte

September 30, 2015 EAC Project No.: 15-2674

United States Department of Agriculture Mr. Joshua Dobereiner 1815 N University Street Peoria, Illinois 61604

RE: HAZARDOUS MATERIALS ASSESSMENT - Residential Structures - 12940 US Highway 441 North - Canal Point - Palm Beach County - Florida

Dear Mr. Dobereiner:

Environmental Assessments & Consulting (EAC) has completed a Hazardous Materials Assessment for the facility mentioned above. The purpose of this project was to identify the existence, extent and condition of asbestos containing materials (ACM), lead-based paint (LBP) and / or other hazardous materials within the on-site structures. This project was completed according to the Scope of Work as specified in GSA eBuy RFQ995693 and as awarded in Contract Number GS-10F-181BA, dated August 19, 2015.

This report details the results of these activities performed under the above contract and with the specified scope of work. No warranty is provided with this report, expressed or implied. This report was prepared for the exclusive use of United States Department of Agriculture (USDA) and General Services Administration (GSA). This report is the property of EAC. The unauthorized use of this report by third parties will be at the user's own risk.

We appreciate the opportunity to be of service to you on this project. Should you have any questions regarding this report, please feel free to call us at (954) 353-7442.

Respectfully submitted, Environmental Assessments & Consulting

D.S. Monty Watson EPA Accredited Surveyor / Project Manager

TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 FACILITY DESCRIPTION

3.0 ASBESTOS SURVEY

3.1 Introduction

3.2 Survey Procedures

3.3 Laboratory Analytical Results

3.3.1 Results

3.4 Recommendations - Asbestos Containing Materials

3.4.1 Resilient Floor Covering Exemption

3.5 Asbestos - General Recommendations / Discussion

4.0 LEAD-BASED PAINT INVESTIGATION

4.1 Introduction

4.2 Survey Procedures

4.2.1 Results

4.3 Recommendations - Lead Based Paint

5.0 HAZARDOUS MATERIALS SURVEY

6.0 LIMITATIONS AND EXCLUSIONS OF WARRANTY

7.0 DEFINITIONS

LIST OF APPENDICES

APPENDIX I - ANALYSIS SUMMARY

APPENDIX II - LABORATORY RESULTS & CHAIN-OF-CUSTODY FORMS

APPENDIX III - ACCREDITATIONS

APPENDIX IV - SITE PLAN

APPENDIX V - PHOTOGRAPHS

APPENDIX VI - FDEP MEMORANDUM

United States Department of Agriculture / GSA Contract GS-10F-181BA EAC Project No. 15-2674 Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 1

1.0 INTRODUCTION

EAC was engaged by the United States General Services Administration (GSA) on behalf of Mr.

Joshua Dobereiner of United States Department of Agriculture (USDA) to perform a Hazardous

Materials Assessment of two (2) former residential structures located at 12940 US Highway 441

North in Canal Point, Palm Beach County, Florida.

The purpose of this project was to identify the existence, extent and condition of asbestos containing materials (ACM), lead-based paint (LBP) and hazardous materials within the on-site structures. This project was completed according to the Scope of Work specified in GSA eBuy

RFQ995693 and as awarded in Contract Number GS-10F-181BA, dated August 19, 2015.

This limited sampling event was not meant to fully satisfy regulatory requirements for an asbestos or lead survey for a renovation or demolition according to the US Environmental Protection Agency

(EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP), Occupational Safety and Health Administration (OSHA), and / or State of Florida regulations. The client fully understood this limitation prior to work commencing on this project.

Environmental Assessments & Consulting

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 2

2.0 FACILITY DESCRIPTION

The subject facility is located at 12940 US Highway 441 North in Canal Point, Palm Beach County, Florida. According to Palm Beach County Property Appraiser records, the two (2) structures were constructed in 1934 and 1938, respectively. The client provided the following description of the site:

“The house, constructed in 1934, is a 3,122 square foot 2-story neoclassical house with a wood balloon frame. The 2-story apartment structure, constructed in 1938, is 1,100 square feet with a wood siding exterior. The existing structures are dilapidated and have reached or exceeded their economic life. The house leans to the west, the pilings are not in good condition, the roof has holes in multiple places, floors are rotted, drywall was removed, and numerous windows are damaged or missing, and has been condemned by the county. The main structure has been emptied and gutted.” See Appendix IV for a Site Plan.

EAC observed both structures to be wood frame and two-story. The main (larger, western structure) house is set on concrete pilings, and the back (smaller, eastern structure) house was observed to be slab-on-grade concrete. Exterior siding and finish materials consist of transite

(asbestos) siding tiles on both structures. The interior structural framework of both consists of what appears to be pine wood frame covered with local pulp fiber board (mostly removed in the main house and heavily damaged but extant in the apartment structure “back house”) and known as

“bagass”, with plywood and wood paneling. Ceilings consist of similar materials, with an acoustic drop ceiling tile system in the northern (1 floor) room of the back house. Flooring consistsst primarily of hardwood, likely original cypress, throughout the main house and the 2 floor of thend back house. No HVAC systems were observed on site. Roofing consists of asphalt and/or composite shingles. The facility is currently unoccupied and would be considered uninhabitable in its present condition (see Photographs in Appendix V).

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 3

3.0 ASBESTOS SURVEY

3.1 Introduction

EAC conducted an asbestos survey of the residential structures located at 12940 US Highway 441

North in Canal Point, Palm Beach County, Florida.

The purpose of the asbestos sampling protocol was to identify the existence, extent and condition of asbestos containing materials (ACM) within the on-site structures. This sampling event was not meant to fully satisfy regulatory requirements for an asbestos survey for a demolition according to the US Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air

Pollutants (NESHAP), Occupational Safety and Health Administration (OSHA), and / or State of

Florida regulations. The client fully understood this limitation prior to work commencing on this project.

3.2 Survey Procedures

All accessible areas of the facility were visually inspected on September 6, 2015 by an EPA-accredited surveyor to identify suspect ACM. Bulk sampling was performed by D.S. Monty Watson.

Mr. Watson has completed the AHERA-inspector course for Facility Survey and Building Systems and has personally conducted asbestos surveys since 2005.

A total of 28 bulk samples (39 layers) of suspect asbestos containing materials were collected. A visual walkthrough was first conducted in order to identify homogeneous areas (HA) of suspect

Asbestos Containing Materials (ACM) that would be disturbed, and to develop a scheme for obtaining representative bulk samples. Homogeneous areas are like in color, size, texture, use, function, and date of application. Please note that apart from general use (residential), HAs were indistinct due to deterioration and/or removal of materials. The suspect materials were also assessed for their physical condition and potential for future disturbance. The number of samples collected from each homogeneous area generally followed the EPA AHERA regulations (40 CFR

763.86). A summary of the materials sampled during the asbestos survey can be found in

Appendix I.

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3.3 Laboratory Analytical Results

EAC forwarded the representative bulk samples of the suspect asbestos containing materials collected during this demolition asbestos survey to EMSL Analytical Inc in Orlando, Florida (EMSL).

EMSL is recognized under the National Voluntary Laboratory Accreditation Program (NVLAP) for satisfactory compliance with criteria established in Title 15, Part 7 Code of Federal Regulations for

Bulk Asbestos Fiber Analysis. Samples were analyzed by Polarized Light Microscopy (PLM) as recommended by the EPA for asbestos identification by Method 600/R-93-116. PLM is an analytical method recommended by the EPA for asbestos identification based on the unique optical properties of mineral forms in a material. During analysis, identification of asbestos is accomplished by a process of applying dispersion staining to the suspect material, and then observing the material under polarized light. This method of analysis allows asbestos fiber characteristics to colorize, which enables the microscopist to verify the presence or absence of asbestos, to estimate the relative quantity of asbestos, and to identify varieties of asbestos.

3.3.1 Results

The EPA’s NESHAP and AHERA regulations as well as OSHA define an ACM as one that contains more than one percent (>1%) by weight asbestos fibers when analyzed by PLM. The complete laboratory results and chain-of-custody forms have been included in Appendix II.

Based on the results of the laboratory analysis of the samples by PLM, the following samples from suspect materials contain asbestos:

Material: Transite Siding

Sample No. A-4, A-5, A-6, A-20, A-21, A-22

Location: Both structures

Type: Chrysotile, 15%, Category II Nonfriable

Quantity: 5,000 SF *

Condition: Good

Classification: Miscellaneous Finishing

Potential for Disturbance: High

The cementitious “transite” siding was observed to be in generally good condition considering the overall deterioration of the structures, but the potential for disturbance is High, given the planned demolition of the structures.

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 5

Material: Resilient Flooring

Sample No. A-13, A-14 & A-15 (Flooring 1)

Location: Main house - kitchen

Type: Chrysotile, 15-20%, Category I Nonfriable

Quantity: 150 SF *

Condition: Damaged

Classification: Surfacing

Potential for Disturbance: High

The top layer of resilient flooring (red-black) was not found to contain asbestos; however, the layer immediately below and/or mastic (backing layers could not be separated in the laboratory) was found to be ACM. This flooring is in a poor condition and is brittle in several places. The potential for disturbance is High, given the planned demolition of the structures.

Material: 9"x9" Vinyl Floor Tile

Sample No. A-26, A-27 & A-28 (tile)

Location: Back house - kitchen/living room

Type: Chrysotile, 10%, Category I Nonfriable

Quantity: 100 SF *

Condition: Damaged

Classification: Surfacing

Potential for Disturbance: High

Material: Vinyl Floor Tile Mastic

Sample No. A-26, A-27 & A-28 (mastic)

Location: Back house - kitchen/living room

Type: Chrysotile, 3-5%, Category I Nonfriable

Quantity: 100 SF *

Condition: Good

Classification: Surfacing

Potential for Disturbance: High

The 9"x9" vinyl floor tile & mastic was observed to be in generally good condition considering the overall deterioration of the structures, but the potential for disturbance is High, given the planned demolition of the structures.

Material: Acoustic Ceiling Tiles (ACT)

Sample No. N/A

Location: Back house - northern single-story addition

Type: Presumed ACM, Category I Nonfriable

Quantity: 375 SF *

Condition: Damaged

Classification: Miscellaneous

Potential for Disturbance: High

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 6

This material (ACT) was observed in the northern room of the back house. It is a single-story, single-room addition to the earlier structure, and is not delineated as such in the Palm Beach County Property Appraiser records. It appears to be consistent with 1970s or early 1980s materials (wood paneling on walls, carpet, hanging lamp fixtures). Due to the heavy presence of wasps in and around the entryway and/or infesting the room, access was not possible. This material should be considered likely to be ACM, until sampling is possible.

* The quantities given are an approximation only, and we strongly recommend that this be verified with a written proposal by an abatement contractor for purposes of removal, lease or purchase negotiations, etc.

3.4 Recommendations - Asbestos Containing Materials

As the facility is most likely scheduled for demolition, the EPA requires (in the National Emission

Standard for Hazardous Air Pollutants, NESHAP, 40 CFR 61M), the removal of all regulated asbestos containing materials (RACM) that are, or might become, friable prior to the demolition.

RACM is defined in the NESHAP as (1) Friable asbestos material, (2) Category I nonfriable ACM that has become friable, (3) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (4) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to a powder by the forces expected to act on the material in the course of demolition operations.

According to EPA NESHAP regulations, a ten-day notice is required to be submitted to the EPA-enforcement proponent prior to the commencement of the asbestos removal and demolition. Since asbestos removal is required prior to a demolition, a separate notice is required for the removal and an additional notice is required for the demolition. The ten-day notice requirements should be considered in your schedule. The notice should be sent to Palm Beach County. Any changes in any of the information submitted on the original notification form should be corrected, and sent to the appropriate agencies within the time limits set forth by the NESHAP and Palm Beach County.

In addition, all other provisions of the NESHAP and Palm Beach County should be followed.

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3.4.1 Resilient Floor Covering Exemption

According to Chapter 94-469, licensure as an asbestos contractor is not required for moving, removal, or disposal of asbestos-containing resilient floor covering or its adhesive, provided the resilient floor covering is a Category I nonfriable material as defined by the NESHAP and remains a Category I nonfriable material during removal activity. Since the asbestos containing vinyl floor tile is considered Category I nonfriable, removal may be performed by a general contractor, demolition contractor, or state-licensed asbestos abatement contractor who use adequate engineering controls to prevent contamination outside of the work area and who are in accordance with Federal and the following State Regulations:

State Regulations have made stipulations allowing a contractor (whether a general, demolition contractor) that has met the requirements for licensure to remove the resilient floor covering and its adhesive. These stipulations are as follows:

1. "All such activities are performed in accordance with all applicable asbestos standards of the United

States Occupational Safety and Health Administration (OSHA) under 29 C.F.R. part 1926." This includes, but is not limited to, stringent training requirements for the on-site supervisor and workers on the project. Compliance with OSHA requirements is mandatory before attempting to remove asbestos containing resilient flooring and its adhesive without a State-Licensed Asbestos Abatement

Contractor.

2. "The removal is not subject to asbestos licensing or accreditation requirements pursuant to federal asbestos NESHAP regulations as promulgated by the United States Environmental Protection

Agency."

3. "W ritten notice of the time, place, and company performing the removal and certification that all conditions required under this subsection are met are provided to the Department of Business and

Professional Regulation at least 3 days prior to such removal. The contractor removing such flooring materials is responsible for maintaining proof that all the conditions required under this subsection paragraph are met. The department may inspect removal sites to determine compliance with this subsection, and shall adopt rules governing inspections." (Florida Statute 94-469) W ritten notice may be made on a form provided by the State of Florida and available from EAC.

If these State regulations imposed for the removal are not met by the contractor, a State-Licensed

Asbestos Abatement Contractor should be retained to remove the resilient floor covering.

The EPA further states (in the NESHAP, 40 CFR 61M), that Category I Nonfriable materials that are in good condition that contain asbestos may remain in place during demolition provided the

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 8 demolition is supervised by a person knowledgeable of the provisions of the NESHAP and OSHA and as long as normal, intact removal and "Wet" demolition techniques are employed that preclude the crumbling, pulverization or powdering of the asbestos containing material. In addition, the material must remain a Category I Nonfriable material throughout the process of removal including disposal. If any action on the material occurs that would cause it to become non-intact such as sawing, sanding, abrading, grinding making it a non-Category I Nonfriable material, then the material must be removed prior to demolition.

Since recycling materials generated from a demolition such as Category I Nonfriable ACM roofing and concrete with Category I Nonfriable ACM materials adhered to it (typically floor tile/mastic) is common and may be employed in this project, compliance with EPA NESHAP and OSHA regulations may only be met if the roofing or flooring is removed prior to the demolition. Recycling would typically mean crumbling, pulverization, powdering, sawing, sanding, cutting, or abrading of materials. Recycling Category I Nonfriable ACM materials in this manner would be in violation of the NESHAP and may cause worker exposure over OSHA Permissible Exposure Limits.

Consideration should be given to whether compliance with NESHAP and OSHA is possible if recycling will occur during the project. The costs of removal of Category I Nonfriable ACM's prior to demolition, in some cases, may be offset by the financial gain of recycling; in these cases, removal prior to demolition is favorable.

According to the Florida Department of health (DOH) in Palm Beach County, a copy of the asbestos survey shall be kept on site where the demolition is taking place until the demolition is complete (per NESHAP, 40 CFR Part 61, Subpart M).

3.5 Asbestos - General Recommendations / Discussion

Asbestos containing materials or presumed asbestos containing materials not disturbed or removed as a part of the demolition may be managed in-place by implementing an Operations and

Maintenance (O&M) Program designed to maintain the materials in good condition and limit their disturbance. As a part of the O&M Program and OSHA's "Right-to-Know" laws, custodial or maintenance personnel who may be required to work on or around the asbestos containing materials should be informed of the presence of asbestos in these materials and to not perform any

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 9 activity that might result in release of asbestos fibers, i.e., scraping, sanding, cleaning with abrasive materials. The EPA has stated that the minimum response for asbestos containing materials found in a facility is to implement an O&M Program. The O&M program may address the following response actions for asbestos containing materials or presumed asbestos containing materials identified in a facility:

1. Repair - to minimize fiber release

2. Encapsulation - typically a penetrating surface coating applied stabilize and to minimize fiber release

3. Enclosure - typically an air-tight barrier to isolate the ACM and to minimize fiber release

4. Removal - to remove the ACM from the facility

Although all readily visible suspect asbestos containing materials were sampled during this survey, it is conceivable that concealed suspect materials may be present. Due to the destructive nature of removing surfacing materials that could expose underlying materials, structural members, and concealed/hidden materials, sampling of suspect materials not readily accessible was not performed. If concealed materials are encountered during demolition or renovation procedures, work in the area should cease, employees should be removed from the area, and sampling and analysis should be performed. Materials completely identifiable and non-asbestos like fiberglass, foam, rubber, wood, metal, glass, etc. were not sampled. No warranty is made concerning past or future occurrences at the site concerning materials at the site.

Because of the limitations imposed by the client concerning the scope of work of the sampling and laboratory analysis in the facility for this demolition asbestos survey, all regulations imposed by

OSHA, the State of Florida, and the EPA may not have been addressed. Additional sampling and laboratory analysis may be required in order to adequately satisfy EPA, OSHA and the State of

Florida regulations.

All identified ACMs at the subject site are non-friable in their current states, but may become friable as a result of demolition and removal activities. As such, "wet" methodology should be employed, in particular for flooring materials that have underlying mastic that is more brittle than the tile itself, and more likely to become friable during removal. In addition, transite paneling should be removed intact first. No mastic was observed underlying this material, and each panel appeared to be held in place by nails.

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Although Palm Beach County does not require the submission of a Demolition Asbestos Survey as part of the permitting process for demolition, the State of Florida Department of Environmental

Protection (DEP) requires a written notice of intent to be submitted ten (10) working days prior to the start of any regulated project. Additionally, ACMs are regulated as solid waste, and must be disposed in an a Class III landfill, specifically permitted to receive asbestos waste. The closest such landfill to the subject site is Waste Management's Okeechobee Landfill, whose address is

10800 N.E. 128th Avenue, Okeechobee, FL 34973. The phone number for the landfill is

800-963-4776. It is approved for both friable and non-friable asbestos waste.

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4.0 LEAD-BASED PAINT INVESTIGATION

4.1 Introduction

Lead-based paint (LBP) sampling was conducted within the on-site structures. The purpose of the survey was to identify lead in paint on interior and exterior surfaces (where applicable) of the building. Measurements for lead in paint were made using laboratory analysis os suspected lead based paint chips.

The U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and

Control of Lead-Based Paint Hazards in housing (HUD Guidelines),Chapter 7: Lead-based Paint

Inspection, 1997 Revision, were generally followed for this survey.

HUD defines “lead-based paint” as any coating that has a lead concentration of 1.0 milligram of lead per square centimeter (mg/cm ) or greater, or if the lead concentration is greater than 0.5%2 by weight. The Consumer Product Safety Commission (CPSC) currently considers paint to be lead-containing if the concentration of lead exceeds 600ppm (0.06% by weight). In 1978, the

CPSC banned the sale of lead-based paint to consumers, and banned its application in areas where consumers have direct access to painted surfaces. Both the CPSC and HUD definitions of lead-containing paint are aimed at protecting the general population from exposure to lead in the residential setting. By contrast, the mission of the Occupational Safety and Health Administration

(OSHA) with respect to lead-containing paint, is to protect workers during construction activities that may generate elevated airborne lead concentrations. OSHA states that construction work

(including renovation, maintenance, and demolition) carried-out on structures coated with paint have lead concentrations lower than the HUD or CPSC standards can still result in airborne lead concentrations in excess of regulatory limits. For this reason, OSHA has not defined lead-containing paint, but states that paint having any measurable level of lead may pose a substantial exposure hazard during construction work, depending upon the work performed.

4.2 Survey Procedures

The on-site structures were constructed in 1934 and 1938, and therefore the potential for Lead-based paint to be present is higher than buildings constructed at a later time. During the site

Residential Structures (12940 US Highway 441 North, Canal Point, Palm Beach County, Florida) Page 12 inspection, an EAC representative observed the physical condition of the paint on the surface walls inside and outside the structure. The painted surfaces of the building were generally in good condition, however, a few localized areas were observed to be in poor condition (peeling / cracking). Six (6) samples of deteriorated paint were collected and sent to EMSL Analytical, Inc.

located in Orlando, Florida (EMSL) for analysis of Lead in paint by EPA Method SW846/7420.

Samples were analyzed by Flame Atomic Absorption Spectrometry (FAA). Flame Atomic

Absorption Spectrometry measures the ratio of light absorbed without a sample to the amount of light absorbed with a sample. A copy of the results and chain of custody can be found in Appendix

II.

4.2.1 Results

Lead-Based Paint Sample Results

Sample

No.

Color of Paint Location

% Lead by

Weight

Above HUD

Standard (0.5%)

L-1 White Main House 0.11% No

L-2 White Main House 0.098% No

L-3 White Main House 0.11% No

L-4 White Back House 0.016% No

L-5 White Back House 0.11% No

L-6 White Back House 0.038% No

Housing and Urban Development (HUD) considers a paint to be Lead-containing if Lead content is greater than 0.50 percent. Based on these results, none the samples exceed HUD standards.

However, OSHA’s definition of a Lead-containing material is any material which contains measurable amounts of Lead.

4.3 Recommendations - Lead Based Paint

Prior to renovation / demolition, in accordance with OSHA 29 CFR 1926.62, employee protection requirements for workers exposed to Lead or Lead-based products should be followed. Prior to the renovation / demolition, the contractor should perform an exposure assessment for employees involved in the renovation in accordance with 29 CFR 1926.62.

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No sanding, scraping, or removing of the painted surfaces should be permitted without implementing engineering controls and worker protection measures described in OSHA Subpart

D, 29 CFR 1929.62 to reduce Lead dust emissions.

In addition, typically Toxic Characteristic Leaching Profile (TCLP) analysis is performed on the anticipated building debris prior to the renovation / demolition of the building to classify the debris as hazardous or non-hazardous in compliance with EPA regulatory requirements for Lead leaching.

In those cases, if TCLP analysis indicated that Lead leaching will take place above the regulatory level, then the painted surfaces must be removed prior to the disposal of the building debris.

However, according to the Florida Department of Environmental Protection (FDEP) memorandum to County Solid Waste Directors dated February 13, 2002 (see Appendix VI), Lead Based Paint debris from residences is considered “household waste” and is thus exempt from regulation as a hazardous waste under the Resource Conservation and Recovery Act (RCRA). As such, this material can be disposed of as household waste in a Municipal Solid Waste (MSW) landfill. Note:

Since this project may involve the disposal of building materials that are asbestos containing, the disposal requirements in regard to asbestos containing materials would take precedence.

Although Palm Beach County does not require the submission of a Lead Based Paint Survey as part of the permitting process for demolition, the aforementioned OSHA regulations would be the responsibility of the contractor and the USDA.

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5.0 HAZARDOUS MATERIALS SURVEY

EAC conducted a reconnaissance of the subject site and interior inspection of structures to identify the presence of any hazardous materials beyond Asbestos and Lead-Based Paint. No other hazardous materials were identified within the structure or observed on the property as of the date of EAC’s inspection. Nearly all materials had previously been removed from the main house, and only extant building materials and small animal bones as a result of usage by owls was observed.

The back house contained household debris and garbage, but no chemicals or other materials were observed.

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6.0 LIMITATIONS AND EXCLUSIONS OF WARRANTY

The assessments were performed using procedures and a level of diligence typically exercised by professional consultants performing similar services. However, asbestos, lead-based pant and other hazardous materials can be present in a structure, but not identified using ordinary investigative procedures.

No survey can completely eliminate uncertainty regarding the presence of asbestos, lead-based paint and other hazardous materials. EAC’s level of diligence and investigative procedures are intended to reduce, but not eliminate, potential uncertainty regarding the presence of these materials. Therefore, the determinations within this report should not be construed as a guarantee that all asbestos, lead-based paint and other hazardous materials present in the subject property has been included in this report.

This report presents EAC’s professional determinations, which are dependent upon information obtained during performance of consulting services. EAC assumes no responsibility for omissions and errors resulting from inaccurate information provided by sources outside of EAC.

The County may also have permit requirements regarding trees at the subject site. Cypress in particular are a protected species in Florida, and certain trees, based on trunk diameter, may also be subject to permitting requirements if they are to be removed or may be damaged during demolition activities. A survey of flora and fauna was not conducted as part of this Hazardous

Materials Assessment, as the client (USDA) is considered the expert in these matters.

7.0 DEFINITIONS

- Abatement means asbestos control beyond a special operations and maintenance program; means removal, repair, encapsulation, or enclosure of an asbestos-containing material to prevent fiber release.

- Asbestos means the asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), cummingtonite-grunertie, anthophyllite, and actinolite-tremolite. (EPA 40 CFR 61 Subpart M)

- BPR means the State of Florida Department of Business and Professional Regulation

- Category I Non-Friable Asbestos-Containing Material means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than one percent asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR 763, Section 1, Polarized Light Microscopy. (EPA 40 CFR

61, Subpart M)

- Category II Non-Friable Asbestos-Containing Material means any material, excluding Category I non-friable asbestos-containing material, containing more than one percent asbestos as determined using the methods specified in Appendix A, Subpart F, 40 CFR 763, Section 1, Polarized Light Microscopy that, when dry cannot be crumbled, pulverized, or reduced to powder by hand pressure. (EPA 40 CFR 61, Subpart M)

- Demolition means 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 (or sinking of a ship). (EPA 40 CFR 61, Subpart M)

- EPA means the Environmental Protection Agency

- Encapsulation means the application of a coating to asbestos-containing material to prevent fiber release.

- Enclosure means the construction of an air-tight barrier around asbestos-containing material to prevent fiber release.

- Exposure means the presence of people in an area where levels of an airborne contaminant is elevated; the total amount of a airborne contaminant inhaled by a person, typically approximated by the product of concentration and duration.

- FDEP means the Florida Department of Environmental Protection

- Facility means any institutional, commercial, public, industrial, or residential structure, installation, or building

(including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site. For purposes of this definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential structure, installation, or building. Any structure, installation or building that was previously subject to less of its current use or function. (EPA 40 CFR

61, Subpart M)

- Facility Component means part of a facility including equipment. (EPA 40 CFR 61, Subpart M)

- Fibrous means spongy, fluffy, composed of long strands of fiber.

- Friable Asbestos Material - means any material contain more than one percent asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR 763 Section 1, Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the asbestos content is less than ten percent as determined by a method other than point counting PLM, verify the asbestos content by point counting using PLM. This may include previously non-friable material which becomes broken or damaged by mechanical force. (EPA 40 CFR 61, Subpart M)

- Homogeneous Material means a material which may or may not extend through many functional spaces, and is uniform in color, size, texture, and relative date of installation or application, and appears to be the same identical material.

- Miscellaneous Materials means interior or exterior material components such as wallboard, linoleum, floor and ceiling tiles, fire doors, roofing, siding, and other materials not an integral component of the building such as stage curtains, protective clothing, laboratory apparatus and equipment, and other materials considered to be part of the real estate.

- NESHAP means the National Emission Standard for Hazardous Air Pollutants - EPA Rules under the Clean Air

Act.

- Non-Friable Asbestos-Containing Material means any material containing more than one percent asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR 763, Section 1, Polarized Light

Microscopy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (EPA 40

CFR 61, Subpart M)

- Operations & Maintenance (O&M) Program means a formulated plan of training, cleaning, work practices, and surveillance to maintain asbestos-containing materials in good condition. The principle objective of an O&M program is to minimize exposure of all building occupants to asbestos fibers.

- Polarized Light Microscopy means an analytical method (600/M4-82-010) recommended by the EPA for asbestos identification based on analysis of the unique optical properties of mineral forms in the bulk samples.

- Regulated Asbestos Containing Material (RACM) means (a) Friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subject to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to a powder by forces expected to act on the material in the course of demolition or renovation operations regulated by the NESHAP. (EPA 40 CFR 61, Subpart M)

- Renovation means altering a facility or one or more facility components in any way, including the stripping or removal of Regulated ACM from a facility component. Operations in which load-supporting structural members are wrecked or taken out are demolitions, and are excluded from this definition.

- Resilient Floor Covering means asbestos-containing floor tile, including asphalt and vinyl floor tile, and sheet vinyl floor covering containing more than one percent asbestos as determined using Polarized Light Microscopy according to the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light

Microscopy.

- Structural Member means any load-supporting member of a facility, such as beams and load supporting walls;

or any nonload-supporting member such as ceilings and nonload-supporting walls.

- Surfacing Materials means materials which are sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

- Thermal System Insulation means materials in a building distribution system applied to pipes, fittings, boilers, breaching, tanks, ducts, or other system components to prevent heat loss or gain, water condensation, or for other purposes.