Attachment_C.pdf

371 Crest View Drive Black Hawk, Colorado 80422

Phone: 720-209-5282 www.sunrise-enviro.com

Asbestos Consulting Services

PRE-DEMOLITION

ASBESTOS INSPECTION

BROWNSVILLE #1 LODE CLAIM

DRAPER CABIN

TOWNSHIP 10 SOUTH, RANGE 85 WEST,

SECTION 18 NORTHEAST, 6th PM

WHITE RIVER NATIONAL FOREST

PITKIN COUNTY, COLORADO

PREPARED FOR:

White River National Forest Supervisor Office West

120 Midland Avenue Suite 140

Glenwood Springs, Colorado 81601

PROJECT: SEI14-P130

PREPARED: September 2, 2014

TABLE OF CONTENTS

SECTION DESCRIPTION PAGE

CERTIFICATION OF RESULTS 3

1.0 EXECUTIVE SUMMARY 4

2.0 SCOPE AND FACILITY INFORMATION 5

2.1 Inspection Objectives and Scope 5

2.2 Building Description 5

2.3 Review of Existing Information 5

3.0 METHODS AND TECHNIQUES 6

3.1 Inspection 6

3.2 Bulk Sampling 6

3.3 Sample Analysis 7

4.0 ASBESTOS-CONTAINING MATERIAL DESCRIPTIONS

AND RECOMMENDATIONS 7

5.0 PRESUMED ASBESTOS CONTAINING MATERIAL

DESCRIPTIONS AND RECOMMENDATIONS 10

6.0 NON-ASBESTOS CONTAINING MATERIAL DESCRIPTIONS 10

7.0 INSPECTOR COMMENTS 11

8.0 CONCLUSIONS AND RECOMMENDATIONS 11

9.0 LIMITATIONS 12

Appendices

Appendix A-Laboratory Results Appendix B-Certifications

CERTIFICATION OF RESULTS

This Pre-Demolition Asbestos Inspection was performed on behalf of the White River National Forest, (hereafter referred to as “Client”), subsidiaries, partners, directors and officers, and all its successors and assigns, solely for use in evaluation of the presence of asbestos-containing building materials sampled at the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado (hereafter referred to as the “Site”). The information herein is only for the specific use of White River National Forest and Sunrise Environmental, Inc. Use by any other parties is unauthorized. Sunrise Environmental, Inc accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless written authorization is obtained by Sunrise Environmental, Inc.

Sunrise Environmental, Inc.

Scott D. Sanders President CDPHE Building Inspector Certificate #633

1.0 EXECUTIVE SUMMARY

Sunrise Environmental, Inc. has completed a Pre-Demolition Asbestos Inspection of the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado. The inspection was performed by Mr. Scott D. Sanders of Sunrise Environmental, Inc. August 25, 2014. After identifying homogeneous areas of suspect Asbestos Containing Building Materials (ACBM), the inspector(s) collected samples from each homogeneous area, which were analyzed by polarized light microscopy.

Sunrise Environmental, Inc. collected and analyzed a total of three (3) samples from two (2) homogeneous areas for asbestos content, one (1) of which was found to contain greater than 1% asbestos. Sunrise Environmental, Inc. did not presume any additional Homogeneous Areas as asbestos containing.

The material found to contain greater than 1% asbestos at the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado Cabin is listed below:

Black roofing tar (Homogeneous Area #2)

2.0 SCOPE AND FACILITY INFORMATION

2.1 Inspection Objectives and Scope

White River National Forest requested Sunrise Environmental, Inc. inspect the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado for the presence of asbestos containing building materials (ACBM). Sunrise Environmental, Inc. performed a Pre-Demolition Asbestos Inspection in accordance with the requirements of 40 CFR 61, National Standards for Hazardous Air Pollutants (NESHAP), and Colorado Department of Public Health and Environment Air Quality Control Commission (CDPHE-AQCC) Regulation 8, which require that a structure be thoroughly inspected for the presence of asbestos-containing building materials prior to demolition.

Our scope of services included the following:

Identify suspect asbestos containing building materials (ACBM) within the structure.

Identify suspect asbestos containing materials (ACM) on the surface of the ground surrounding the structure.

Collect bulk samples of all identified suspect materials in accordance with 40 CFR

763.86 and CDPHE-AQCC Regulation # 8.

Submit the bulk samples to a NVLAP accredited asbestos laboratory for analysis;

Specify the condition of the suspect ACBM;

Compile a final report of findings.

Sunrise Environmental, Inc. made reasonable efforts to locate and identify asbestos containing building materials (ACBM) at the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado. The inspection was conducted by CDPHE Certified Asbestos Building Inspector Scott D. Sanders.

2.2 Building Description

The structure at the site was constructed primarily of rocks and wood, with metal sheet roofing.

2.3 Review of Existing Information

No previous asbestos inspection documentation was provided for review.

3.0 METHODS AND TECHNIQUES

3.1 Inspection

Sunrise Environmental, Inc. inspected the Brownsville #1 Load Claim Draper Cabin, Township 10 South, Range 85 West, Section 18 Northeast, 6th PM, White River National Forest, Pitkin County, Colorado to locate and identify friable and non-friable asbestos containing building materials. Mr. Scott D. Sanders of Sunrise Environmental, Inc. performed the inspection August 25, 2014. Mr. Scott D. Sanders is a Colorado Department of Public Health and Environment (CDPHE-AQCC) certified asbestos building inspector. The inspector visually inspected accessible portions of the structures to locate and identify suspect ACBM, touched suspect ACBM to determine friability, and determined the extent of homogeneous areas of friable and non-friable suspect ACBM.

3.2 Bulk Sampling

Random bulk samples, representative of the suspect asbestos containing building materials of each homogeneous area, were collected according to guidelines published as Environmental Protection Agency (EPA) Final Rule: Title II of the Toxic Substances Control Act (TSCA), 15 USC, Sections 2641 through 2654 and in compliance with 40 CFR, Part 763 and Colorado Department of Public Health and Environment (CDPHE), Regulation Number 8. Representative sampling is based on the following criteria:

1. The distribution of the suspect material throughout the homogeneous area.

2. The suspect materials physical characteristics and application.

3. Random sampling patterns determined for each homogeneous area.

Suspect materials sampled and analyzed should be considered representative of materials in each homogeneous area if:

1. They exhibit similar physical characteristics.

2. The application of the sampled material can be correlated to the application of un-sampled material.

Suspect materials similar in appearance and application were sampled as homogeneous areas.

Suspect materials were divided into three classifications and sampled according to applicable regulations based on classification of each homogeneous material and the quantity of each homogeneous material as listed below:

1. Surfacing Materials - Troweled on or sprayed on material 1,000 square feet requires a minimum of three (3) samples Greater than 1,000 square feet but less than or equal to 5,000 square feet requires a minimum of five (5) samples Greater than 5,000 square feet requires a minimum of seven (7) samples

2. Thermal System Insulation Each system requires three (3) samples

3. Miscellaneous - other suspect materials not classified in the above categories Sufficient samples to adequately characterize the materials with a minimum of one (1) sample

After identifying homogeneous areas of suspect ACBM, representative samples from each homogeneous area were collected. The inspector randomly selected the sample locations and collected samples in a manner to minimize the release of fibers into the air. At each sample location, the inspector collected a small bulk sample of the material using an appropriate tool (e.g, clean knife or chisel), and placed each bulk sample into an unused, uniquely labeled, sealable bag. The inspector documented each Homogeneous Area, sample location, sample number and other pertinent information at the time of the inspection. A total of three (3) samples were collected for analysis from two (2) Homogeneous Areas.

3.3 Sample Analysis

Bulk samples collected were submitted for analysis at Reservoirs Environmental, Inc. 5801 Logan Street, Suite 100, Denver, Colorado 80216 and were analyzed by Polarized Light Microscopy (PLM) for asbestos content. Reservoirs Environmental, Inc. is accredited by the National Institute of Standards and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP). PLM was performed in compliance with guidelines established by the USEPA (EPA/600/R-93/116).

A building material of a given homogeneous area is considered to be ACBM based on a finding that at least one sample collected from the material showed asbestos present in an amount greater than one percent (1%). A building material is not to be considered ACBM only if the results of all samples collected from the material showed asbestos content to be equal to or less than one percent (1%).

The CDPHE-AQCC require point count analysis for friable materials greater than 0% but equal to or less than 1% to disprove false negative results analyzed by visual estimation. EPA- NESHAP recommends point count analysis for visual estimations from greater than 1% to 10% to disprove false positive results or consider the material to be asbestos containing. None of the samples collected were submitted for point count analysis.

The analysis of the bulk samples was performed on August 27, 2014 as listed in the Analytical Data Section of this report (See Appendix A). Condition assessments were performed by the accredited inspector at the time of inspection.

4.0 Asbestos Containing Material Descriptions and Recommendations

The following pages include asbestos containing material descriptions and a table listing the asbestos containing building materials identified at the Draper Cabin. A Photograph of each asbestos-containing building material identified at the Site can be found following the General Recommendations for each Homogeneous Area.

All material quantity estimates are approximations and should be verified in the field by contractors bidding for abatement of the materials and/or demolition of the structures.

The building materials listed in this section contain concentrations of asbestos greater than 1% by visual estimation when analyzed by Polarized Light Microscopy.

HOMOGENEOUS AREA – 2

Material Description: Black roofing tar

Miscellaneous/Non-Friable

Material Location Material Quantity Material Condition Roof Approx. 200 sq. ft. Good, with potential for damage

Sample No. Sample Location Composition 2-1 North side of roof 10% Chrysotile

2-2 South side of roof 10% Chrysotile

General Recommendations

The black roofing tar is considered non-friable. Maintained in good condition the material poses minimal risk of fiber release. Avoid activities such as grinding, sanding, and cutting, which may cause the material to become damaged. Should the material become damaged, repair or removal should be performed by personnel trained and certified to remove, transport and dispose of asbestos containing material.

The CDPHE does not require the removal of non-friable roofing tar containing asbestos prior to demolition, provided the materials are not burned, crushed, pulverized, recycled or otherwise rendered friable. All demolition debris must go to a landfill that will accept non-friable asbestos containing materials and no amount of the asbestos containing roofing tar may be left in the soil following the demolition. If demolition debris from the building must go to a landfill that does not accept non-friable asbestos-containing materials, the asbestos-containing roofing tar must be removed prior to demolition of the building.

Photos of Homogeneous Area #2, black roofing tar:

Black tar beneath metal roofing:

North side – black roofing tar is beneath metal roofing:

South side – black roofing tar is beneath metal roofing:

5.0 Presumed Asbestos Containing Building Materials

No additional building materials were presumed to contain greater than 1% asbestos.

6.0 Non-Asbestos Containing Building Materials

The following building materials were sampled at the Draper Cabin and found to contain 1% or less asbestos:

Sample #: Homogeneous Area & Material Description:

Sample Location:

1-1 Homogeneous Area 1:

White caulk

South interior wall

7.0 Inspector Comments

Sunrise Environmental, Inc. identified and sampled a total of two (2) Homogeneous Areas, one

(1) of which was found to contain greater than 1% asbestos. Sunrise Environmental, Inc. did not presume any additional building materials to contain greater than 1% asbestos. The CDPHE- AQCC requires the removal of friable materials and non-friable materials that may become friable during demolition activities prior to demolition. This asbestos inspection was performed for the purpose of demolition.

Sunrise Environmental, Inc. made reasonable efforts to locate and identify asbestos containing building materials. Should unidentified materials be encountered, additional bulk material samples should be collected to determine potential asbestos content.

All asbestos-containing material quantities listed in Section 4.0 of this report are estimations and should be verified in the field by contractors bidding on asbestos abatement or demolition of the structures. Inspector certifications can be found in Appendix B of this report.

8.0 Conclusions and Recommendations

Asbestos containing building materials identified at the Draper Cabin are listed below.

Black roofing tar (Homogeneous Area #2)

The non-friable roofing tar listed above can remain on the structure during demolition. The Colorado Department of Public Health and Environment (CDPHE) does not require the removal of materials that are non-friable and that will remain non-friable during demolition, provided the materials will not be crushed, pulverized, recycled, burned or otherwise rendered friable. All demolition debris must go to a landfill that will accept non-friable asbestos containing materials.

No amount of the non-friable roofing tar is permitted to remain in the soil at the site after the demolition has been completed. If demolition debris from the building must go to a landfill that does not accept non-friable asbestos-containing materials, the roofing tar must be removed prior to demolition of the building.

The Occupational Safety and Health Administration (OSHA) requires contractors and workers be notified of the presence and location of asbestos and requires employers to protect employees from exposure to asbestos above the permissible exposure limit of 0.10 f/cc, as determined by personnel monitoring, over an 8 hour time weighted average for more than 30 days per year.

Appropriate asbestos training for workers is also required. Contractors involved in demolition activities must be made aware of remaining non-friable materials. Contractors are responsible to comply with OSHA 29 CFR 1926.1101 requirements.

Building and/or facility owners are required to notify prospective employers applying or bidding for work that can reasonably be expected to work in or occupy areas containing ACM and/or PACM, of the presence of such materials.

Rodent feces were observed within the cabin at the site during the inspection, making Hantavirus a possibility. Proper precautions and Personal Protective Equipment (PPE) for Hantavirus should be considered by Contractors involved in abatement or demolition activities and any person entering the cabin.

9.0 Limitations

The findings set forth in this report are strictly limited in time and scope to the date of the evaluation(s). The conclusions presented in the report are based solely on the services described therein, and not on scientific tasks or procedures beyond the scope of agreed upon services.

Because of the hidden nature of many building components, it may be impossible to determine if all building components have been located and subsequently tested. Destructive testing in some instances is not a viable option. Sunrise Environmental, Inc. does not, therefore, guarantee that all potential ACBM has been located. For the same reasons, estimates of quantities are subject to readily apparent situations. We do warrant, however, that the investigations and methodology reflect Sunrise Environmental, Inc’s best efforts based upon prevailing standard of care and due diligence in the environmental field.

The purpose of this report was to assess the physical characteristics of the subject Site with respect to the presence of asbestos containing building materials. No specific attempt was made to check on the compliance of present or past owners or operators of the Site with federal, state or local laws and regulations, environmental or otherwise.

APPENDIX A

LABORATORY RESULTS

APPENDIX B

CERTIFICATIONS