Appendix A. Asbestos Containing Material Lead Based Paint Survey Report.pdf
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Department of Agriculture Forest Service
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This document is an Asbestos and Lead-Based Paint (ACM/LBP) Inspection Report for three recreation residences located within the Cibola National Forest in New Mexico: Crest House, Dyer House, and Del Toro House. The survey was conducted on August 27, 2025, by Red J Environmental Corporation (UEI: D6MLVMWQD3F8) under Project Number 1-25FS009, presented to the USDA Forest Service Southwestern Region and Cibola National Forest.
The inspection identified asbestos-containing materials at two locations exceeding EPA and NESHAP thresholds. At Dyer House, a popcorn texture ceiling sample in Bedroom 1 tested positive for 2% Chrysotile asbestos (Sample #22). At Crest House, roofing mastic over the water storage area tested positive for 3% Chrysotile asbestos (Sample #32). No lead-based paint was detected in any of the eleven samples collected across all three properties; all lead concentrations were below the 1.0 mg/cm² regulatory threshold. The Dyer House asbestos finding does not trigger federal NESHAP requirements because it is a single-family dwelling, and the Crest House finding remains below the 160 square feet threshold for commercial building NESHAP applicability. The report recommends precautions during any demolition work where asbestos has been detected, though formal NESHAP compliance is not currently required. All testing was performed by Licensed OSHA Lead Sampling Technician Vonnie Young in accordance with EPA regulations and current industry guidelines.
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Crest House and Casa Loma Recreation Residences AMC/LBP Survey
Cibola National Forest
Crest House…701Sandia Crest Road, Sandia Park, New Mexico, 87047 Lat/Long 35.210262, -106.449416
Dyer House…91 Casa Loma Road, Cedar Crest, New Mexico, 87008 Lat/Long 35.109864, -106.387267
Del Toro House… 69 Casa Loma Road, Cedar Crest, New Mexico, 87008 Lat/Long 35.110333, -106.384337
Presented to:
Hailey Stock COR Assistant Regional Environmental Engineer
USDA Forest Service Southwestern Region
Danae Giersch
Forest Project Inspector/Government Technical Monitor Civil Engineer
USDA Forest Service Cibola National Forest
Red J Environmental Corporation
UEI: D6MLVMWQD3F8
Project Number
1-25FS009
September 23, 2025
Date of On-Site Inspection: Aug. 27, 2025 Re: Asbestos and Lead-Based Paint Inspection Report Property Addresses: Crest House…701Sandia Crest Road, Sandia Park, New Mexico, 87047
Dyer House…91 Casa Loma Road, Cedar Crest, New Mexico, 87008 Del Toro House… 69 Casa Loma Road, Cedar Crest, New Mexico, 87008
Property Owner: Cibola National Forest
Dear Client:
Please find enclosed the asbestos and lead-based paint inspection report for the property located at the aforementioned locations. The survey was performed within the current acceptable industry guidelines, and EPA regulations. Red J Environmental Corporation (Red J) conducted the asbestos surveys and lead-based paint inspection services at the above-referenced sites on August 27,2025. Licensed OSHA Lead Sampling Technician Vonnie Young (Certification No. 2159-ANTLS72925-8012, expiration date 07/08/2026) performed the inspection services. Licensed EPA AHERA Building Inspector (Certification No. 2604-
ANTRBI81325-8012)
At the specific time and date of the inspection services, Red J detected no lead-based paint in the property. The asbestos tested did find two locations at separate sites that do contain asbestos above industry guidelines.
If you have any questions or concerns regarding this report, please feel free to contact us at (928)288-3239.
Sincerely, Stephen Solomon
Stephen Solomon General Manager
Table of Contents Executive Summary
Asbestos Overview
Lead Overview
Limitations
Scope of Surveys and Inspections
Asbestos Recommendations
Lead Recommendations
Certifications/Laboratory Report/Chain of Custody
Glossary
Executive Summary
On August 27th, 2025, Red J Environmental Corporation (Red J) was authorized to conduct a limited Asbestos Containing Material (ACM) Survey and Lead-Based Paint (LBP) Inspection of three separate properties located within the Cibola National Forest. A Kick-Off meeting was conducted on Aug. 19th, 2025 to discuss the activities to take place at two (2) of the properties which are single-family detached dwellings and are believed to be built between 1940 and 1950. The third property is a combination of former Commercial and Residential use and was constructed in 1978.
Red J tested all components according to the specifications described in the protocols for a limited ACM survey/testing and LBP inspection/testing, within all applicable Federal, State, and Local regulations. This Survey/Inspection was conducted on site by an EPA-trained professional asbestos building inspector.
This report contains the results of the Surveys and Inspections conducted. This report is intended for the exclusive use of our client. The findings are relevant to the conditions observed during the physical process of performing the Survey. These findings should not be treated as absolute, nor should they be relied upon to represent conditions at significantly later dates.
Asbestos Overview
The purpose of this ACM Survey was to identify the presence of asbestos-containing materials that may be disturbed during a planned demolition. Limited bulk samples were collected and AHERA protocols were adhered to. RED J tested a total of eleven (11) surfaces. Two (2) were found to contain asbestos at levels greater than or equal to the EPA and NESHAP recommendations using the point-counting procedure for confirmation of asbestos percentage in friable materials that are visually estimated by Polarized Light Microscopy (PLM) methodology to contain less than 10% asbestos. The 400 Point Count Procedure referenced in EPA 600/M4-82-020 (1987) and EPA 600/R-93/116 (1993) is commonly employed. Without the material being point counted or if point counting determined that material contains greater than one percent asbestos, it would be deemed an asbestos containing material and would need to be removed by a New Mexico licensed asbestos contractor prior to disturbance.
The Asbestos Survey consisted of three basic procedures:
1) conducting a visual inspection of the property
2) identifying homogeneous areas (HAs) of suspect surfacing, thermal system insulation, and miscellaneous materials 3)sampling accessible, friable, and non-friable suspect materials.
Some building components may have been inaccessible at the time of this screening, or were not tested because they were covered by other building materials (paneling, tile, siding, etc.). It is possible that ACBMs may be hidden by these materials. The property was visually inspected for the presence of building materials that are suspected to contain asbestos. With regard to asbestos, bulk material samples were collected and analyzed for asbestos content. These services were performed exercising the customary skill and competence of consulting professionals in the relevant disciplines in this region. Bulk samples of identified suspect ACM were collected and placed into individual containers for transport to A.E.S.L Environmental Laboratory, a National Voluntary Lab Accreditation Program (NVLAP)/American Industrial Hygiene Association (AIHA)-accredited laboratory for analysis. The collection of bulk samples consisted of physically removing a small piece of material and placing it in a marked, airtight container. The sample container identification numbers were also recorded in the field notes.
Asbestos is a generic name given to a fibrous variety of naturally occurring minerals that have been used for many years in commercial products, based on specific properties of the minerals.
Asbestos occurs in fiber bundles, which are composed of long and thin fibers that can be easily separated from one another. These mineral products possess high tensile strength, flexibility, resistance to chemical and thermal degradation, and high electrical resistance. The minerals are easily woven into various types of textiles, fabrics, cloths, sheets, panels, or mixed into adhesives, coatings, surfacing materials and cement products.
Typically, asbestos-containing building materials (ACBM) are segregated into three categories:
• Thermal System Insulation (TSI) usually found on pipes, boilers, and HVAC ducts;
surfacing materials such as sprayed or troweled-on fireproofing and insulation, and plasters; and miscellaneous materials including vinyl composite floor tiles, floor sheeting, adhesives, roofing materials, window glazing and cement products.
• Friable asbestos-containing material (ACM), is defined as any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM), that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure.
(Sec. 61.141)
• Nonfriable ACM is any material containing more than one percent (1%) asbestos as determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1, Polarized Light Microscopy (PLM), that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. EPA also defines two categories of nonfriable ACM, Category I and Category II nonfriable ACM, which are described later in this guidance.
"Regulated Asbestos-Containing Material" (RACM) is
(a) friable asbestos material
(b) Category I nonfriable ACM that has become friable
(c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting or Abrading
(d) Category II nonfriable 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.
The EPA.s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations regulate the removal and disposal of asbestos-containing building materials (any material containing more than 1% asbestos). Potential effects on workers or occupants in buildings where asbestos-containing materials (ACM) are present may occur when exposure to asbestos fibers is caused by deterioration, damage or renovation disturbance of ACBMs. Federal regulations pertaining to asbestos include 40 Code of Federal Regulations (CFR) 763 (a subchapter of the Toxic Substance Control Act (TSCA)); Occupational Safety and Health Act (OSHA) 29 CFR 1910 Subpart Z and 29 CFR 1926 Subpart Z.
Asbestos NESHAP regulations must be followed for demolitions and/or renovations of facilities with at least 260 linear feet of regulated asbestos containing materials (RACM) on pipes, 160 square feet of regulated asbestos-containing materials on other facility components, or at least 35 cubic feet of facility components where the amount of RACM previously removed from pipes and other facility components could not be measured before stripping. If dimensions fall below these thresholds, Asbestos NESHAP regulations need not be followed for demolition and/or renovation activities.
Background on the Asbestos NESHAP EPA's air toxics regulation for asbestos is intended to minimize the release of asbestos fibers during activities involving the handling of asbestos. The air toxics provisions of the Clean Air Act (CAA) require EPA to develop and enforce regulations to protect the public from exposure to airborne contaminants that are known to be hazardous to human health. In accordance with Section 112 of the CAA, EPA establishes National Emission Standards for Hazardous Air Pollutants (NESHAP). The list of hazardous air pollutants (HAP), or “air toxics”, includes specific compounds that are known or suspected to cause cancer or other serious health effects.
Three of the major health effects associated with asbestos exposure are lung cancer, mesothelioma, and asbestosis. Asbestos was one of the first hazardous air pollutants regulated under the air toxics program. On March 31, 1971, EPA identified asbestos as a hazardous pollutant, and on April 6, 1973, EPA promulgated the Asbestos NESHAP, currently found in 40 CFR Part 61, Subpart M. The Asbestos NESHAP has been amended several times, most comprehensively in November 1990. In 1995, the rule was amended to correct cross-reference citations to OSHA, DOT, and other EPA rules governing asbestos.
Renovation and Demolition of Buildings Air toxics regulations under the Clean Air Act specify work practices for asbestos to be followed during demolitions and renovations of all facilities, including, but not limited to, structures, installations, and buildings (excluding residential buildings that have four or fewer dwelling units). The regulations require a thorough inspection where the demolition or renovation operation will occur. The regulations require the owner or the operator of the renovation or demolition operation to notify the appropriate delegated entity (often a state agency) before any demolition, or before any renovations of buildings that contain a certain threshold amount of regulated asbestos-containing material. The rule requires work practice standards that control asbestos emissions. Work practices often involve removing all asbestos-containing materials, adequately wetting all regulated asbestos-containing materials, sealing the material in leak tight containers and disposing of the asbestos-containing waste material as expediently as practicable, as the regulation explains in greater detail. These work practice standards are designed to minimize the release of asbestos fibers during building demolition or renovation, waste packaging, transportation and disposal.
Institutional, Commercial and Industrial Buildings Any demolition or renovation operation at an institutional, commercial or industrial building is regulated by the Asbestos NESHAP. At a minimum, the thorough inspection requirement applies. The notification requirements apply to any demolition and to renovations over a certain threshold amount of regulated asbestos-containing material.
Large-Scale Residential Demolition In 1990, EPA amended the NESHAP for asbestos. In the revised rule, EPA noted that it does not consider residential structures that are demolished or renovated as part of a commercial or public project to be exempt from the NESHAP. For example, EPA explained that the demolition of one or more houses as part of an urban renewal project, a highway project, or a project to develop a shopping mall, industrial facility, or other private development would be subject to the NESHAP. In 1995, EPA issued a Clarification of Intent (PDF) (2pp, 147k) regarding demolition of isolated single-family homes.
Exceptions to the Asbestos Removal Requirements If the total amount of asbestos to be removed or disturbed is less than 260 linear feet, 160 square feet, or 35 cubic feet off of facility components (if the material could not be measured previously), then the Asbestos NESHAP does not require regulated asbestos-containing material to be removed before demolition or renovation activities occur.
Asbestos Control Method The Asbestos NESHAP requires specific work practices to control the release of asbestos fibers.
To help ensure that the work practice standards of the Asbestos NESHAP are followed during a demolition or renovation operation, the asbestos NESHAP requires at least one onsite representative trained in the regulatory provisions and the means of compliance. This trained individual needs to receive refresher training every two years, including: applicability of the rule; notifications; material identification; control procedures for removal; adequate wetting;
local exhaust ventilation; negative pressure enclosures; glove-bag procedures; High Efficiency Particulate Air (HEPA) filters; waste disposal work practices; reporting and record keeping; and, asbestos hazards and worker protection. EPA has not approved any alternatives to the demolition requirements of the Asbestos NESHAP.
Waste Disposal and Transportation The rule generally requires that asbestos-containing waste material be sealed in a leak-tight container while wet, labeled, and disposed of properly in a landfill qualified to receive asbestos waste. Landfills have special requirements for handling and securing the asbestos containing waste to prevent releases of asbestos into the air. Transportation vehicles that move the waste from the point of generation to the asbestos landfill have special labeling requirements and waste shipment record keeping requirements.
Lead Overview
Red J’s scope of services for LBP involved a surface-by-surface visual inspection of all painted surfaces throughout the entire property to determine which LBP surfaces/components are deteriorated (above de minimis level).
RED J tested a total of eleven (11) surfaces. Zero (0) were found to contain lead at levels greater than or equal to the regulatory level of 1.0 mg/cm2. These surfaces are identified in Section III:
G. This report represents all field data, observations and findings related to the lead inspection performed in the above referenced property. The results, assessments and findings stated in this report are representative of the conditions observed in this property at the time of the inspection services.
This inspection measures lead in both deteriorated and intact paint surfaces. The procedure involved taking samples from representative surfaces throughout the testing area or room.
Some building components may have been inaccessible at the time of the inspection services, or were not tested because they were covered by other building materials (paneling, tile, siding, etc.). It is possible that painted surfaces may be hidden by these materials. Such surfaces should be assumed to contain lead-based paint, or should be tested by a licensed lead-based paint inspector or risk assessor.
Limitations
This report has been prepared to assist in evaluating the potential presence of ACM and LBP on the properties listed. The objective of this assessment was to perform the work with care, exercising the customary skill and competence of consulting professionals in the relevant disciplines in this region. The conclusions presented in this report are professional opinions based upon visual observations of the site at the time of Red J.s investigation and the results of laboratory analysis. The opinions presented herein apply to site conditions existing at the time of our investigation and those reasonably foreseeable. The results and opinions in this report, based solely upon the conditions found on the property as of the date of the Survey, will be valid only as of the date of the Survey.
Please note that the test results relate only to those homogeneous materials tested. If conditions or materials, other than those addressed in this report are encountered during the planned renovation/demolition activities, Red J should be contacted to assess the potential impact of these materials or conditions relative to the findings or recommendations included herein. The survey was performed by observing suspect materials throughout the structure where accessible. Red J must emphasize that it is not possible to look within every location of a building. The visual survey documents only general locations of suspect materials but does not determine exact boundaries. Concealed locations of asbestos or lead paint may exist at the subject property, and the levels may vary from those stated in this report. There may be variations in the composition of materials which appear similar. Materials may be hidden from view and not accessible. No attempt was made to disassemble equipment or demolish structural elements and finishes as this is beyond the scope of our authorized services. Visual observations were made only at safe and convenient locations. Due to these limitations, wall voids, flooring under carpet, building cavities and mechanical equipment, and other areas may contain unreported asbestos-containing materials. Suspect materials not previously identified in this report may be encountered during any renovation/demolition activity. These materials should be assumed asbestos containing material or lead based paint until sample collection and subsequent analysis prove otherwise. Unsafe structures should be assumed to contain asbestos materials unless the suspect material is noted as sampled. All fire doors should be assumed asbestos containing material since disassembly of locks and/or other work to access the door insulation is not possible.
Scope of Surveys and Inspections
DYER RESIDENTIAL RESIDENCE
Bedroom 1 Bedroom 2
Bedroom 3
Kitchen Living Room
Unknown
Garage/Basement
Porch
Dining Room
Legend N
= Asbestos Testing
= Lead Based Paint Testing
= ACM
Below is a photographic journal of structures and testing locations during the Dyer ACM Surveys and LBP Inspections.
North facing side of the Residency East facing side of the Residency
South facing side of the Residency West facing side of the Residency
ACM Testing Locations and Results at Dyer
Bedroom 1 Ceiling Kitchen Floor Roof Tile Sample #22 Sample #23 Sample #24
Of the three samples taken at the Dyer House one of them was positive for 2% Chrysotile asbestos. That sample was #22 taken from Bedroom 1 on the ceiling. The other two samples did not detect any asbestos.
Bulk Collection and Sample Analysis Results Sample Number
Description Condition Friable Asbestos
Percent and Type Location NESHAP Category
22 Popcorn Texture Intact Yes 2% Chrysotile
Bedroom
Ceiling
NA
23 Floor Tile Intact No None Detected
Kitchen Floor
NA
24 Asphalt Shingle/Black
Intact No None Detected
Typical Exterior
Roof
NA
LBP Testing Locations and Results at Dyer
Bedroom 1 Window Sill Diningroom Wall Porch Window Sill and Wall Sample #1 Sample #2 Sample #3 & #4
XRF
Shot
Number
Client Number
Description Condition Location Concentration
1 1 Yellow Paint Peeling Bedroom 1 <17ppm
2 2 Multicolor Paint Intact Dining Room <17ppm
3 3 White Paint Peeling Porch Window <17ppm
4 4 Maroon Paint Peeling Outside Wall <17ppm
Zero (0) were found to contain lead at levels greater than or equal to the regulatory level of 1.0 mg/cm2 or 5,000ppm.
DEL TORO RESIDENTIAL RESIDENCE
Bedroom 1 Bedroom 2/Bathroom
Livingroom
Kitchen Garage
Porch
Legend
= Asbestos Testing N
= Lead Based Paint Testing
Below is a photographic journal of structures and testing locations during the Del Toro ACM Survey and LBP Inspection.
South facing side of the Residency East facing side of the Residency
West facing side of the Residency North facing side of the Residency
ACM Testing Locations and Results at Del Toro
Sample #25 Sample #26 Bedroom 1 wall/ceiling tile Tar paper
Sample #27 Sample #28 Outside Shingle Green Shingle
Of the four (4) samples taken at the Del Toro House none of them detected any asbestos.
Number
Description Condition Friable Asbestos Percent and Type
Location NESHAP Category
25 Wall/Ceiling Tile
Intact No None Detected Bedroom 1 Wall
NA
26 Tar Paper Torn No None Detected Above front door
NA
27 Shingle Torn No None Detected Above door to garage
28 Green Shingle Torn No None Detected South side wall NA
LBP Testing Locations and Results at Del Toro
Sample #5 Sample #6 Bedroom 1 Window Sill Kitchen Window Sill
Sample #7 Sample #8 Garage Wall Outside Wall on Porch
XRF Shot Number
Client Number
Description Condition Location Concentration
5 5 Multicolor Paint Peeling Bedroom 1 <17ppm
6 6 Multicolor Paint Intact Kitchen Window <17ppm
7 7 Blue/White Paint Peeling Garage Wall <17ppm
8 8 Brown Paint Peeling Outside Wall <17ppm
CREST HOUSE
Upstairs Downstairs
Kitchen
Porch Dining Area
Gift Store
Visitor Center
Dry Storage
Apartment 1 Mechanical / Storage
Apartment 2
Office
Legend
= Asbestos Testing N
= Lead Based Paint Testing
Water Storage
Below is a photographic journal of structures and testing locations during the Crest House ACM Survey and LBP Inspection.
North Side of Building
West Side of Building South Side of Building
ACM Testing Locations and Results at Crest House
Sample # 29 Sample #30 Basement Storage Ceiling Basement Tile
Sample #31 Sample #32 Outside South Wall Roof Over Water Storage
Number
Description Condition Friable Asbestos Percent and
Type
Location NESHAP Category
29 Ceiling Texture Intact No None Detected Basement Ceiling
NA
30 Floor Tile Cracked No None Detected Basement Tile
NA
31 Stucco Cracked No None Detected Outside Wall NA 32 Roofing Mastic Torn Yes 3% Chrysotile Roof Over
Water Storage
LBP Testing Locations and Results at Crest House
Sample # 9 Sample #10 Apartment 2 Wall Basement Wall
Sample #11 Dining Room Wall
XRF Shot Number
Client Number
Description Condition Location Concentration
9 9 White Paint Peeling Apartment 2 <17ppm
10 10 White Paint Intact Basement Wall <17ppm
11 11 White Paint Intact Dining Room Wall
<17ppm
Asbestos Recommendations
The results of the asbestos survey conducted at the Dyer House show there is 2% Chrysotile at located on the ceiling in bedroom 1. Due to Federal and State laws NESHAP does not apply in this case since it is a single-family home.
According to the New Mexico Environmental Department (NMED), A home owner who has always used the home as a single-family dwelling is not subject to the federal asbestos NESHAP. Refer to 40 CFR 60 subpart M for demolition and remediation requirements for other types of residences.
The results of the asbestos survey conducted at the Sandia Crest House showed there is 3% Chrysotile in the black mastic located over the water storage on the south side of the main building. While it is a commercial building, the area affected is believed to only be up to 152 square feet, which falls under the 160 square feet requirement for NESHAP. Therefore, it too is exempt from NESHAP.
If the total amount of asbestos to be removed or disturbed is less than 260 linear feet, 160 square feet, or 35 cubic feet off of facility components (if the material could not be measured previously), then the Asbestos NESHAP does not require regulated asbestos-containing material to be removed before demolition or renovation activities occur.
Precautions should always be taken when demolition occurs where asbestos has been detected.
At this time NESHAP is not required when demolition takes place at any of the aforementioned locations.
Lead Recommendations
No lead-based paint was found in any of the samples taking at the time of investigation.
Precautions should always be taken during demolition of any building built before 1970.
Certifications/Laboratory Report/Chain of Custody
Glossary
Abatement: A measure or set of measures designed to permanently eliminate lead-based paint hazards or lead based paint. Abatement strategies include the removal of lead-based paint, enclosure, encapsulation, replacement of building components coated with lead-based paint, removal of lead-contaminated dust, and removal of lead-contaminated soil or overlaying of soil with a durable covering such as asphalt (grass and sod are considered interim control measures). All of these strategies require preparation, cleanup, waste disposal, post-abatement clearance testing, record keeping, and, if applicable, monitoring. See also Complete Abatement and Interim controls.
Accreditation: A formal recognition certifying that an organization, such as a laboratory, is competent to carry out specific tasks or types of tests.
Accuracy: The degree of agreement between an observed value and an accepted reference value (a true value); a data quality indicator. Accuracy includes a combination of random errors (Precision) and systematic errors (bias) due to sampling and analysis.
Active waste disposal site: any disposal site other than an inactive site.
Adequately wet: sufficiently mix or penetrate with liquid to prevent the release of particulates.
If visible emissions are observed coming from asbestos-containing material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet.
Asbestos: the asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), cummingtonite-grunerite, anthophyllite, and actinolite-tremolite.
Asbestos-containing waste materials: mill tailings or any waste that contains commercial asbestos and is generated by a source subject to the provisions of this subpart. This term includes filters from control devices, friable asbestos waste material, and bags or other similar packaging contaminated with commercial asbestos. As applied to demolition and renovation operations, this term also includes regulated asbestos-containing material waste and materials contaminated with asbestos including disposable equipment and clothing.
Asbestos mill: any facility engaged in converting, or in any intermediate step in converting, asbestos ore into commercial asbestos. Outside storage of asbestos material is not considered a part of the asbestos mill.
Asbestos tailings: any solid waste that contains asbestos and is a product of asbestos mining or milling operations.
Asbestos waste from control devices: any waste material that contains asbestos and is collected by a pollution control device.
Bare soil: Soil not covered with grass, sod, some other similar vegetation, or paving, including the sand in sandboxes.
Building component: Any element of a building that may be painted or have dust on its surface, e.g. walls, stair treads, floors, railings, doors, windowsills, etc.
Category I nonfriable asbestos-containing material (ACM): asbestos containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy.
Category II nonfriable ACM: any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined using the methods specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Certification: The process of testing and evaluating against certain specifications the competence of a person, organization, or other entity in performing a function or service, usually for a specified period of time.
Certified: The designation for Contractors who have completed training and other requirements to safely allow them to undertake risk assessments, inspections, or abatement work. Risk assessors, inspectors, and Abatement Contractors should be certified by the appropriate local, State, or Federal agency.
Chewed surface: Any painted surface that shows evidence of having been chewed or mouthed by a young child. A chewed surface is usually a protruding, horizontal part of a building, such as an interior windowsill.
Cleaning: The process of using a vacuum and wet cleaning agents to remove leaded dust. The process includes the removal of bulk debris from the work area. OSHA prohibits the use of compressed air to clean lead-contaminated dust from a surface.
Clearance examination: Visual examination and collection of environmental samples by an inspector or risk assessor, or, in some circumstances, a Sampling Technician, and analysis by an accredited laboratory upon completion of an abatement project, interim control intervention, or maintenance job that disturbs lead-based paint (or paint suspected of being lead-based). The clearance examination is performed to ensure that lead exposure levels do not exceed standards established by the EPA Administrator pursuant to Title IV of the Toxic Substances Control Act, and that any cleaning following such work adequately meets those standards.
Commercial asbestos: any material containing asbestos that is extracted from ore and has value because of its asbestos content.
Common area: A room or area that is accessible to all residents in a community (e.g. hallways or lobbies). In general, any area not kept locked.
Composite sample: A single sample made up of individual subsamples. Analysis of a composite sample produces the arithmetic mean of all subsamples.
Containment: A process to protect workers and the environment by controlling exposures to the lead-contaminated dust and debris created during abatement.
Cutting: to penetrate with a sharp-edged instrument and includes sawing, but does not include shearing, slicing, or punching.
Demolition: 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.
Deteriorated lead-based paint: Any lead-based paint coating on a damaged or deteriorated surface or fixture, or any interior or exterior lead-based paint that is peeling, chipping, flaking, worn, chalking, alligatoring, cracking, or otherwise becoming separated from the substrate.
Disposal (of waste): The discharge, deposit, injection, dumping, spilling, leaking, or placement of solid or liquid waste on land or in water so that none of its constituents can pollute the environment by being emitted into the air or discharged into a body of water, including groundwater.
Emergency renovation operation: a renovation operation that was not planned but results from a sudden, unexpected event that, if not immediately attended to, presents a safety or public health hazard, is necessary to protect equipment from damage, or is necessary to avoid imposing an unreasonable financial burden. This term includes operations necessitated by nonroutine failures of equipment.
Encapsulation: Any covering or coating that acts as a barrier between lead-based paint and the environment, the durability of which relies on adhesion and the integrity of the existing bonds between multiple layers of paint and between the paint and the substrate. See also Enclosure.
Enclosure: The use of rigid, durable construction materials that are mechanically fastened to the substrate to act as a barrier between the lead-based paint and the environment.
Evaluation: Risk assessment, paint inspection, reevaluation, investigation, clearance examination, or risk assessment screen.
Fabricating: any processing (e.g., cutting, sawing, drilling) of a manufactured product that contains commercial asbestos, with the exception of processing at temporary sites (field fabricating) for the construction or restoration of facilities. In the case of friction products, fabricating includes bonding, debonding, grinding, sawing, drilling, or other similar operations performed as part of fabricating.
Facility: 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 this subpart is not excluded, regardless of its current use or function.
Facility component: any part of a facility including equipment.
Federal Register (FR): A daily Federal publication that contains proposed and final regulations, rules, and notices.
Friable asbestos material: any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 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 10 percent as determined by a method other than point counting by polarized light microscopy (PLM), verify the asbestos content by point counting using PLM.
Fugitive source: any source of emissions not controlled by an air pollution control device.
Glove bag: a sealed compartment with attached inner gloves used for the handling of asbestos-containing materials. Properly installed and used, glove bags provide a small work area enclosure typically used for small-scale asbestos stripping operations. Information on glove-bag installation, equipment and supplies, and work practices is contained in the Occupational Safety and Health Administration's (OSHA's) final rule on occupational exposure to asbestos (appendix G to 29 CFR 1926.58).
Grinding: to reduce to powder or small fragments and includes mechanical chipping or drilling.
Impact Surface: An interior or exterior surface (such as surfaces on doors) subject to damage by repeated impact or contact.
In poor condition: the binding of the material is losing its integrity as indicated by peeling, cracking, or crumbling of the material.
Inactive waste disposal site: any disposal site or portion of it where additional asbestos-containing waste material has not been deposited within the past year. Installation means any building or structure or any group of buildings or structures at a single demolition or renovation site that are under the control of the same owner or operator (or owner or operator under common control).
Inspection (of paint): A surface-by-surface investigation to determine the presence of lead-based paint (in some cases including dust and soil sampling) and a report of the results.
Interim controls: A set of measures designed to temporarily reduce human exposure or possible exposure to lead-based paint hazards. Such measures include specialized cleaning, repairs, maintenance, painting, temporary containment, and management and resident education programs. Monitoring, conducted by Owners, and reevaluations, conducted by professionals, are integral elements of interim control. Interim controls include dust removal, paint film stabilization, treatment of friction and impact surfaces, installation of soil coverings such as grass or sod, and land use controls. See also Monitoring, Reevaluations, and Abatement.
Interior windowsill: The portion of the horizontal window ledge that protrudes into the interior of the room, adjacent to the window sash when the window is closed. Often called the window stool.
Latex: A waterborne emulsion paint made with synthetic binders, such as 100% acrylic, vinyl acrylic, terpolymer, or styrene acrylic. A stable emulsion of polymers and pigment in water.
Lead: Lead includes metallic lead and inorganic and organic compounds of lead.
Lead-based paint: Any paint, varnish, shellac, or other coating that contains lead equal to or greater than 1.0 mg/cm2 (milligrams of lead per square centimeter of surface) as measured by XRF or laboratory analysis, or 0.5% by weight (5,000ug/g, 5,000 ppm (parts per million), or 5,000 mg/kg) as measured by laboratory analysis (Local definitions may vary.)
Lead-based paint hazard: A condition in which exposure to lead from lead-contaminated dust, lead-contaminated soil, or deteriorated lead-based paint would have an adverse effect on human health (as established by the EPA Administrator under Title IV of the Toxic Substances Control Act). Lead-based paint hazards include, for example, deteriorated lead-based paint, leaded dust levels above applicable standards. And bare leaded soil above applicable standards.
Lead-based paint hazards control: Activities to control and eliminate lead-based paint hazards, including interim controls, abatement, and complete abatement.
Lead-contaminated dust: Surface dust in residences that contains an area concentration of lead in excess of the standard established by the EPA Administrator, pursuant to Title IV of the Toxic Substances Control Act. As of April 01, 2017, EPA standards for lead dust for risk assessments are ≥10 ug/ft2 (micrograms of lead per square foot) for floors, and ≥100 ug/ft2 for interior windowsills. The EPA standard for clearance are <10 ug/ft2 for floors, 100 ug/ft2 for windowsills, and 100 ug/ft2 for window troughs. Porch floors are also wiped during final clearance, with a lead dust clearance action level of <40 ug/ft2.
Lead-contaminated soil: Bare soil on residential property that contains lead in excess of the standard established by the EPA Administrator, pursuant to Title IV of the Toxic Substances Control Act. The standard is 400 ug/g in play areas and 1,200 ug/g in the rest of the property.
Leak-tight: solids or liquids cannot escape or spill out. It also means dust-tight.
Licensed: Holding a valid license or certification issued by the EPA or by an EPA-approved State program pursuant to Title IV of the Toxic Substances Control Act. The license is based on certification for lead-based paint hazard control work. See also Certified.
Maintenance: Work intended to maintain adequate living conditions in a dwelling, which has the potential to disturb lead-based paint or paint that is suspected of being lead-based.
Malfunction: any sudden and unavoidable failure of air pollution control equipment or process equipment or of a process to operate in a normal or usual manner so that emissions of asbestos are increased. Failures of equipment shall not be considered malfunctions if they are caused in any way by poor maintenance, careless operation, or any other preventable upset conditions, equipment breakdown, or process failure.
Manufacturing: the combining of commercial asbestos-or, in the case of woven friction products, the combining of textiles containing commercial asbestos-with any other material(s), including commercial asbestos, and the processing of this combination into a product. Chlorine production is considered a part of manufacturing.
Mean: The arithmetic average of a series of numerical data values. For example, the algebraic sum of the data values divided by the number of data values.
Microgram (ug): 1/1,000,000 of a gram. Used to measure weight
Monitoring: Surveillance to determine (1) that known or suspected lead-based paint is not deteriorating, (2) that lead-based paint hazard controls, such as paint stabilization, enclosure, or encapsulation have not failed, and (3) that structural problems do not threaten the integrity of hazard controls.
Natural barrier: a natural object that effectively precludes or deters access. Natural barriers include physical obstacles such as cliffs, lakes or other large bodies of water, deep and wide ravines, and mountains. Remoteness by itself is not a natural barrier.
Nonfriable asbestos-containing material: any material containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.
Nonscheduled renovation operation: a renovation operation necessitated by the routine failure of equipment, which is expected to occur within a given period based on past operating experience, but for which an exact date cannot be predicted.
Outside air: the air outside buildings and structures, including, but not limited to, the air under a bridge or in an open-air ferry dock.
Owner: A person, firm, corporation, guardian, conservator, receiver, trustee, executor, government agency or entity, or other judicial officer who, alone or with others, owns, holds, or controls the freehold or leasehold title or part of the title to property, with or without actually possessing it. This definition includes a vendee who possesses the title, but does not include a mortgagee or an Owner of a reversionary interest under a ground rent lease.
Paint inspector: An individual who has completed training from an accredited program and been licensed or certified by the appropriate State or local agency to (1) perform inspections to determine and report the presence of lead-based paint on a surface-by-surface basis through onsite testing, (2) report the findings of such an inspection, (3) collect environmental samples for laboratory analysis, (4) perform clearance testing, and optionally (5) document successful compliance with lead-based paint hazard control requirements or standards.
Paint removal: An abatement strategy that entails the removal of lead-based paint from surfaces. For lead hazard control work, this can mean using chemicals, heat guns below 1,100 F, and certain contained abrasive methods. Open-flame burning, open-abrasive blasting, sandblasting, extensive dry scraping, and stripping in a poorly ventilated space using a volatile stripper are prohibited paint removal methods. Hydroblasting is not recommended.
Particulate asbestos material: finely divided particles of asbestos or material containing asbestos.
Planned renovation operations: a renovation operation, or a number of such operations, in which some RACM will be removed or stripped within a given period of time and that can be predicted. Individual nonscheduled operations are included if a number of such operations can be predicted to occur during a given period of time based on operating experience.
Polyethylene plastic: All references to polyethylene plastic refer to 6 mil plastic sheeting or polyethylene bags (or double bags if using 4 mil polyethylene bags), or any other thick plastic material shown to demonstrate at least the equivalent dust contamination performance. Plastic used to contain waste should be capable of completely containing the waste and, after being properly sealed, should remain leak tight with no visible signs of discharge during movement or relocation.
Polyurethane: An exceptionally hard and wear-resistant coating (created by the reaction of polyols with a multifunctional isocyanate). Often used to seal wood floors following lead-based paint hazard control work and cleaning.
Reevaluation: In lead hazard control work, the combination of a visual assessment and collection of environmental samples performed by a certified risk assessor to determine if a previously implemented lead-based paint hazard control measure is still effective and if the dwelling remains lead-safe.
Regulated asbestos-containing material (RACM): (a) Friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected 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 powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.
Remove: to take out RACM or facility components that contain or are covered with RACM from any facility.
Renovation: altering a facility or one or more facility components in any way, including the stripping or removal of RACM from a facility component. Operations in which load-supporting structural members are wrecked or taken out are demolitions.
Replacement: A strategy of abatement that entails the removal of building components coated with lead-based paint (such as windows, doors, and trim) and the installation of new components free of lead-based paint.
Resident: A person who lives in a dwelling.
Resilient floor covering: asbestos-containing floor tile, including asphalt and vinyl floor tile, and sheet vinyl floor covering containing more than 1 percent asbestos as determined using polarized light microscopy according to the method specified in appendix E, subpart E, 40 CFR part 763, Section 1, Polarized Light Microscopy.
Risk assessment: An onsite investigation of a residential dwelling to discover any lead-based paint hazards. Risk assessments include an investigation of the age, history, management, and maintenance of the dwelling, and the number of children under age 6 and women of childbearing age who are residents; a visual assessment; limited environmental sampling (i.e.
collection of dust wipe samples, soil samples, and deteriorated paint samples); and preparation of a report identifying acceptable abatement and interim control strategies based on specific conditions.
Risk assessor: A certified individual who has completed training with an accredited training program and who has been certified to (1) perform risk assessments, (2) identify acceptable abatement and interim control strategies for reducing identified lead-based paint hazards, (3) perform clearance testing and reevaluations, and (4) document the successful completion of lead-based paint hazard control activities.
Roadways: surfaces on which vehicles travel. This term includes public and private highways, roads, streets, parking areas, and driveways.
Site: The land or body of water where a facility is located or an activity is conducted. The site includes adjacent land used in connection with the facility or activity.
Spectrum analyzer: A type of XRF analyzer that provides the operator with a plot of the energy and intensity, or counts of both K and L x-ray spectra, as well as a calculated lead concentration.
See also XRF analyzer.
Standard deviation: A measure of the precision of a reading. The spread of the deviation from the mean. The smaller the standard deviation, the more precise the analysis. The standard deviation is calculated by first obtaining the mean, or the arithmetic average, of all of the readings. A formula is then used to calculate how much the individual values vary from the mean. the standard deviation is the square root of the arithmetic average of the squares of the deviation from the mean. Many hand calculators have an automatic standard deviation function.
Strip: to take off RACM from any part of a facility or facility components.
Structural member: any load-supporting member of a facility, such as beams and load supporting walls; or any non-load-supporting member, such as ceilings and non-load-supporting walls.
Subsample: A representative portion of a sample. A subsample may be either a field sample or a laboratory sample. A subsample is often combined with other subsamples to produce a composite sample. See also Composite sample.
Substrate: A surface on which paint, varnish, or other coating has been applied or may be applied. Examples of substrates include wood, plaster, metal, and drywall.
Substrate effect: The radiation returned to an XRF analyzer by the paint, substrate, or underlying material, in addition to the radiation returned by any lead present. This radiation, when counted as lead x-rays by an XRF analyzer contributes to substrate equivalent lead (bias).
The inspector may have to compensate for this effect when using XRF analyzers. See also XRF analyzer.
Substrate Equivalent Lead (SEL): The XRF measurement taken on an unpainted surface, used to calculate the corrected lead concentration on a surface by using the following formula:
Apparent Lead Concentration-Substrate Equivalent Lead = Corrected Lead Concentration. See also, XRF analyzer.
Target housing: Any residential unit constructed before 1978, except dwellings that do not contain bedrooms or dwellings that were developed specifically for the elderly or persons with disabilities, unless a child younger than 6 resides or is expected to reside in the dwelling. In the case of jurisdictions that banned the sale or use of lead-based paint before 1978, the Secretary of HUD may designate an earlier date for defining target housing.
Test location: A specific area on a testing combination where XRF instruments will test for lead-based paint.
Trained: Successful completion of a training course in a particular discipline. For lead hazards control work, the training course must be accredited by the EPA or by an EPA-approved State program, pursuant to Title IV of the Toxic Substances Control Act.
Treatment: In residential lead-based paint hazard control work, any method…
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