ASBESTOS_INSPECTION_McCelvey_Center_Museum.pdf

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ASBESTOS CONTAINING MATERIALS INSPECTION

Conducted on

McCelvey Center Museum 212 E Jefferson Street #A

York, South Carolina 29745

SUMMIT UES Project No. 0545.E0001

Inspection Date: April 25, 2023 Report Date: May 4, 2023

Prepared for:

Culture & Heritage Museums

1444 Brattonsville Road McConnells, South Carolina 29726

Attention: Ms. Sara Johnson

Prepared by:

SUMMIT Engineering, Laboratory & Testing, Inc.

Universal Engineering Sciences, Inc.

3575 Centre Circle Fort Mill, South Carolina 29715

(704) 504-1717 www.SUMMIT-companies.com www.UniversalEngineering.com

3575 Centre Circle | Fort Mill, South Carolina 29715 | p 704-504-1717 | www.SUMMIT-companies.com

May 4, 2023

Ms. Sara Johnson Culture & Heritage Museums 1444 Brattonsville Road McConnells, South Carolina 29726

Reference: ASBESTOS CONTAINING MATERIALS (ACM) INSPECTION REPORT

McCelvey Center Museum 212 E Jefferson Street #A York, South Carolina 29745 SUMMIT UES Project No. 0545.E0001

Dear Ms. Johnson:

On behalf of Culture & Heritage Museums (the “client”), SUMMIT Engineering, Laboratory & Testing, Inc., a Universal Engineering Sciences (SUMMIT UES) company has completed this National Emissions Standard for Hazardous Air Pollutants (NESHAP) Asbestos Containing Materials Inspection Report. This inspection was conducted in accordance with Chapter 61-145 of the Environmental Protection Agency’s (EPA) Title 40, Part 61, Subpart M of the Code of Federal Regulations (CFR) for the above-referenced property (the “subject property). SUMMIT UES performed this ACM inspection on Tuesday, April 25, 2023, to categorize and assess readily available suspect homogeneous material for the structure. SUMMIT UES collected thirty-nine (39) bulk samples from thirteen (13) homogeneous materials. The bulk samples were transported to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory using Polarized Light Microscopy (PLM) and/or Transmission Electron Microscopy (TEM) for the presence of asbestos fibers.

Asbestos Containing Materials (ACMs) are classified as materials containing asbestos fibers in excess of one percent (1%) detected in any of the homogeneous materials sampled. Additional details regarding the ACM Inspection conducted by SUMMIT UES are presented in the attached report.

Asbestos Containing Materials (ACMs) were found during the inspection, refer to Table 1 on Page 11 of this report.

SUMMIT UES appreciates this opportunity to provide environmental services to you and we look forward to future endeavors. If you have, any comments or questions regarding the information contained within this report or if we can be of further service, please contact the undersigned.

Respectfully submitted, Universal Engineering Sciences, Inc.

Asbestos-Containing Materials Inspection SUMMIT UES Project No. 0545.E0001

York, South Carolina 29745 May 4, 2023

Written by, James Gehman Environmental Technician SC DHEC AHERA Asbestos Inspector No. BI-002125 SC DHEC AHERA Asbestos Air Monitor No. AS-000682 SC DHEC AHERA Asbestos Supervisor No. SA-003786 Expiration Date: August 21, 2023

Reviewed by, Matthew Hoffman

Matthew Hoffman, E. I Environmental Branch Manager i

TABLE OF CONTENTS

1.0 Introduction

1.1 Limitations and Exclusions

1.2 Purpose and Scope of Work

2.0 Characteristics and Information

2.1 General

2.2 Available Building Information

2.3 Current Building Use

3.0 Inspection Protocol

3.1 Inspection Procedures

3.2 Suspected Asbestos Containing Materials

3.3 NESHAP Classification

4.0 LABORATORY ANALYSIS

4.1 Polarized Light Microscopy (PLM) Analysis

4.2 Point Count Analysis

4.2 Transmission Electron Microscope (TEM) Analysis

5.0 Findings

6.0 Summary of Asbestos Containing Materials

7.0 Regulatory information

8.0 Controlling Agency

9.0 CONDITIONS AND LIMITATIONS OF THIS INSPECTION

ii

LIST OF APPENDICES

APPENDIX A

Bulk Sample Location Map or Photograph Log ................................................................................ A

APPENDIX B

PLM Analytical Report & Chain-of-Custody Documentation ........................................................... B

APPENDIX C

Inspector(s) Certification ................................................................................................................. C

1.0 INTRODUCTION

SUMMIT Engineering, Laboratory & Testing, Universal Engineering Sciences (SUMMIT UES) conducted a pre-demolition Asbestos Containing Materials (ACM) Inspection on the subject building located at 212 E Jefferson Street #A in York, South Carolina 29745. The purpose of this inspection was to identify and sample accessible suspect ACM and provide information regarding the identity, location, and condition in anticipation of a renovation and/or demolition of the building.

This service was conducted based on the written authorization of Culture & Heritage Museums, dated March 6, 2023. This service was conducted according to proposal 0545.E0001, dated March 6, 2023. This inspection was conducted in accordance with the General Conditions, which are incorporated into the Client authorized agreement that governs this assessment.

This inspection was conducted in accordance with Chapter 61-145 of the Environmental Protection Agency’s (EPA) Title 40, Part 61, Subpart M of the Code of Federal Regulations (CFR).

1.1 Limitations and Exclusions

This inspection report is not intended to be used as a specification, project design or work plan. The indicated material quantities of ACM (if documented) are estimates based on SUMMIT UES’ field observations on the date(s) of the inspection(s), and should be considered preliminary in nature. All parties utilizing this report for proposal, estimation or contract negotiations are required to field verify the quantities of material prior to submission of proposal. These estimates should not be used for bidding purposes without verification by the asbestos abatement contractor. The asbestos abatement contractor should ascertain for themselves, by site measurements and inspection, the exact nature and extent of the work to be done.

Inspection and collection of bulk samples of suspect ACMs were limited to those materials readily accessible at the time of inspection. Destructive sampling techniques (such as wall and ceiling testing, and carpet cuts to expose underlying flooring) were employed in limited measures in the areas inspected and completed in a way to minimize disruption to operations and damage to building components. Extensive destructive sampling methods were not used, and exploratory demolition of walls and/or removal of fixed items were not conducted. No attempt was made by SUMMIT UES to observe conditions in spaces not generally accessible, including but not limited to crawlspaces, pipe chases, plenums or confined spaces.

Some materials may be hidden or masked by overlying materials such as flooring, carpeting or concealed walls.

Although every effort is made to locate all suspect ACMs, it is impossible to rule out the possibility that undiscovered asbestos materials may be present. If the building is to undergo major refurbishment or demolition, it is recommended that the persons carrying out the work are made aware of this and take sufficient precautions, as may be appropriate, to ensure the health and safety of their own employees and any other parties who may be affected by the works. Any suspected building materials not addressed in this report, which are encountered during demolition or renovation should be analyzed for asbestos content prior to being damaged and/or removed.

Asbestos has not been banned from use in building products in the United States. Newer buildings are not exempt. Certain uses of asbestos have been banned: such as spray applied fireproofing, pipe and boiler insulation and asbestos cardboard.

This inspection was limited to the following areas: auditorium, boiler room and attic above the auditorium.

1.2 Purpose and Scope of Work

The purpose of this study was to perform an evaluation of the above-referenced facility for the presence of ACMs, specifically those building materials which may be present or impacted during potential demolition or renovation activities. The activities and procedures used to accomplish this task were as follows:

1) A review of available building documents to identify potential locations of suspect ACMs;

2) Visual building inspection of accessible areas by a United States Environmental Protection Agency

(EPA) Asbestos Hazard Emergency Response Act (AHERA) accredited asbestos building inspector to identify suspect ACMs;

3) Once identified, homogeneous materials (materials which are uniform in color, texture, construction/application date, and general appearance) were determined;

4) Determine whether the suspect ACM is Friable (a material that when dry, may be crumbled, pulverized or reduced to powder by hand pressure) or Non-Friable;

5) Collection of bulk samples of each homogeneous suspect ACM. Record sample information on Asbestos Bulk Sample Forms (chain-of-custody sheets), which were signed, dated, and sent with the samples to the laboratory;

6) Analysis of the collected bulk samples at a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory using Polarized Light Microscopy (PLM) for the presence of asbestos fibers;

7) If applicable, confirmatory analysis of bulk samples documented by PLM analysis as containing less than one percent (<1%), were further analyzed utilizing the “Quantitation using 400 (or 1,000) Point Count Procedure” for asbestos analysis of bulk material via EPA method 600/R-93/116.

8) Approximate locations of the bulk samples were defined. Computer Assisted Drafting and Design (CADD) drawings were developed indicating sample locations. In addition, approximate quantities of identified ACM were also determined; and,

9) Prepare and submit a report.

2.0 CHARACTERISTICS AND INFORMATION

2.1 General

A summary of the subject structure characteristics are outlined in the table below. Information on the buildings was obtained by SUMMIT UES through our field inspection, review of available building documents and/or property appraiser records.

General

Facility Type Commercial Building

Construction Date 1920

Building Size 30,105 Square Feet

Number of Stories 3

Structural

Foundation N/A

Wall Support N/A

Wall Finish N/A

Roof Support N/A

Roof System Type N/A

Mechanical/ Plumbing

HVAC Type Boiler

Duct Type Soft frame, rigid frame

Pipe Insulation Pipe Wrap

Interior

Wall Substrates N/A

Wall Finishes Plaster

Floor Substrates N/A

Floor Finishes N/A

Ceiling Systems N/A

Ceiling Finishes Plaster, Drywall

Other None

2.2 Available Building Information

No previous asbestos inspection report(s), building plans or other material information were provided in reference to the structure located within the subject property.

2.3 Current Building Use

At the time of SUMMIT UES’ evaluation, the subject structure was a active commercial property.

3.0 INSPECTION PROTOCOL

Three forms of ACMs are typically found on structures. These materials are classified as follows:

• Surfacing Material – material that is sprayed-on, troweled-on, or otherwise applied to interior and exterior structural and architectural surfaces. Surfacing material includes acoustical plaster on ceilings, fireproofing on structural members, textured paint and exterior stucco, and other materials applied to surfaces for acoustical, decorative, fireproofing, and other purposes.

• Thermal System Insulation — material which is applied to interior and exterior mechanical components to reduce heat gain or loss. Thermal system insulation includes insulation on pipes, fittings, boilers, breeching, tanks, ducts, and other mechanical components.

• Miscellaneous Materials — material, other than surfacing material and thermal system insulation, on interior and exterior structural, mechanical, electrical, or architectural components, and surfaces. Miscellaneous material includes but is not limited to ceiling tiles, gaskets, floor coverings and mastics, wallboard joint compound, roofing materials, and cementitious products.

An inspection of the structure was conducted to identify these, and other materials present within the building which are suspected of containing asbestos.

3.1 Inspection Procedures

SUMMIT UES’ field inspection was performed April 25, 2023, by Jordan Suttles, an inspector accredited according to Federal Regulation 40 CFR, Part 763 (AHERA), and licensed in the state of North Carolina.

After a preliminary walk-through of the building, an inspection was conducted to evaluate the location and extent of the suspected Asbestos Containing Materials. Once identified, these materials were categorized into homogeneous areas containing materials of the same type, age, visual appearance, texture, composition, etc.

This type of inspection is designed to be used as a basis for tendering the removal of ACMs from the subject building(s) prior to demolition or renovation. The present condition of each ACM was evaluated by SUMMIT UES and classified as one of three categories: “good”, “damaged” and “significantly damaged.” As defined by AHERA. “Poor condition, for NESHAP Category I and II nonfriable materials, is synonymous to “damaged” and/or “significantly damaged,” depending on the percentage of damaged.

“damaged” and/or “significantly damaged.”

Federal regulations also require our inspectors to determine the potential for disturbance (or damage).

This potential for disturbance is based on the presumption that the building will not be demolished. The classifications for potential for disturbance ranges from low, to moderate, to high, and is based on vibration, contact and air erosion.

The number of bulk samples collected was based on the category of Homogeneous Area and the quantity of the material present, as follows:

AHERA Guidelines for Determining the Number of Samples to Collect HSA Category HSA Quantity Samples Required

Surfacing Materials <1,000 Square Feet 3

1,000 – 5,000 Square Feet 5 >5,000 Square Feet 7 or more

Thermal System Insulation No Stipulation 3+ (All repair patches must be sampled)

Miscellaneous Materials No Stipulation

Per AHERA Guidelines, these materials must be sampled “in a manner sufficient to determine whether or not they contain asbestos” typically two or more samples based upon the inspector’s judgement (Three or more samples are required in South Carolina).

HSA: Homogeneous Sampling Area (materials which are uniform in color, texture, construction/application date, and general appearance)

SUMMIT UES’ inspector(s) employed wet methods as applicable during bulk sample collection to reduce the potential for fiber release. Each sample was documented by labeling the container with a unique sample number, entering the sample material on a bulk sample log or chain-of-custody form, and noting the location of each sample on a floor plan. Throughout the sampling process, care was taken to prevent cross-contamination of the collected bulk samples. Sampling equipment was cleaned following the collection of each sample.

Random, and in some cases judgmental, samples of each homogeneous area of material were then collected. The physical condition of each material was assessed. In addition, a tactile inspection of the material was performed to evaluate friability. If the material, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure, it is considered friable. Samples from any homogeneous area where the inspector determine that the material was non-ACM (such as thermal insulation that obviously fibrous glass, foam glass, or rubber) were not collected. Certification for the inspector performing the building inspection is presented in Appendix C.

3.2 Suspected Asbestos Containing Materials

Based on SUMMIT UES’ review of the available building system information and thorough visual inspection of the subject building, thirteen (13) Homogeneous Areas were identified at the structure commonly suspected of containing asbestos. The Homogeneous Areas are detailed on the List of suspect ACMs. A map or photographic log illustrating the sample locations is included as Appendix A of this report.

3.3 NESHAP Classification

The materials assessed are classified as either: Friable (RACM), Category I – Non-Friable or Category II Non-Friable.

Friable ACM means “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.”

Non-Friable ACM “means 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.”

Non-Friable Organically Bound (NOB) materials mean “materials that are not friable and that consist of fibers and other particulate matter embedded in a solid matrix of asphaltic, vinyl or other organic substances.”

Category I nonfriable ACM means Asbestos containing packings, gaskets, resilient floor covering, and asphaltic roofing products containing more than 1 percent asbestos.

Category II nonfriable ACM means any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos.

Category I nonfriable ACM does not need to be removed/abated prior to demolition if it is not in poor condition and not friable, or will not be rendered friable. Standard demolition techniques are required.

No intentional burning, no explosives and no wrecking balls are allowed.

Landfills must be approved to accept asbestos waste, even if the ACM remains in place during demolition.

It is the owner’s responsibility to verify the landfill can accept the asbestos contaminated waste stream.

“In poor condition” means the binding of the material is losing its integrity as indicated by peeling, cracking, or crumbling of the material. Poor condition has been interpreted to mean “damaged” or “significantly damaged.”

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 powder by the forces expected to act on the material in the course of demolition or renovation operations.

https://www.ecfr.gov/current/title-40/part-763 https://www.ecfr.gov/current/title-40/part-763

RACM materials are subject to the NESHAP permitting requirements, refer to Table 1 for information regarding each suspect material.

4.0 LABORATORY ANALYSIS

4.1 Polarized Light Microscopy (PLM) Analysis

The samples of the suspected ACMs collected during the field inspection were transported with chain-of-custody documentation to Universal Engineering Sciences, Inc. asbestos testing laboratory located in Fort Mill, South Carolina. Universal Engineering Sciences, Inc. is an accredited laboratory for bulk sample analysis according to the National Voluntary Laboratory Accreditation Program (NVLAP) (Accreditation No. NVLAP 600344).

Bulk samples were analyzed for the presence of asbestos fibers using Polarized Light Microscopy (PLM).

The analyses were performed according to EPA Method 600/R-93/116 July 1993 “Method for the Determination of Asbestos in Bulk Building Materials.” This analytical method can be used for qualitative identification of six morphologically different types of asbestos fibers: Chrysotile, Amosite, Crocidolite, Tremolite, Actinolite and Anthophyllite. PLM analysis requires the microscopist to take a portion of the sample and treat it with an oil of specific refractive index. The prepared slide is then subjected to a variety of tests while being viewed under varying polarizations of light. Each type of asbestos displays unique characteristics when subjected to these tests.

The method specifies that the asbestos content in a bulk sample shall be estimated and reported as a finite percentage within the range of 0 to 100. Minute quantities of asbestos in bulk samples may be reported as “trace” or less than one percent (<1%). The analytical method determines the asbestos percentage by means of visual estimation technique. If analysis of the sample of a suspect ACM reveals a negative result, SUMMIT UES considers the material to be non-Asbestos containing. If at any time during the analytical process a sample tests positive, that material must be treated as Asbestos Containing Material (ACM).

4.2 Point Count Analysis

Point Counting is more labor intensive, and it is somewhat less subjective than a visual estimate for the Bulk Samples. The accuracy and precision are improved with Point Counting, and the more points analyzed (400 or 1,000) the better the accuracy and precision of the method.

Samples of the suspect ACM collected during the field inspection were not point counted as part of this inspection. See section 6.0 SUMMARY for recommendations pertaining to point counting.

4.2 Transmission Electron Microscope (TEM) Analysis

The TEM analysis uses a 10,000x magnification (compared to 400x magnification for PLM) and can detect and identify the smallest asbestos fibers. TEM analysis of NOBs demonstrating negative asbestos content by PLM is not mandated by the EPA, AHERA, OSHA and most state asbestos regulations. However, TEM analysis of NOBs is mandatory by regulation in the states of ME, NY, NJ, and SC.

Samples of the suspect ACMs collected during the field inspection were analyzed by TEM as part of this inspection.

5.0 FINDINGS

Thirteen (13) suspect homogeneous materials were identified at the subject building. Following AHERA guidelines, the appropriate number of bulk samples were collected from the identified homogeneous material and submitted for laboratory analysis. The laboratory analyses indicated that asbestos fibers were detected in excess of one percent in seven (7) of the homogeneous materials analyzed from the building. Table 1 presents the analytical results of the suspect asbestos containing materials (ACMs) and general information regarding the suspect ACMs.

TABLE 1

HSA

Sample

Number/ Name

Material Classification Current Condition

Potential for Disturbance

Asbestos Analytical Results

NESHAP

Category

Estimated Quantity RACM

DM 1, 2, 3 Duct Mastic Misc. Damaged Low NAD Category II - Nonfriable 200 LF NO

PL 1, 2, 3 Plaster Surfacing Good Low NAD Friable 10,000 SF NO

Attic Ins 1, 2, 3 Attic Insulation TSI Damaged Low NAD Friable 1,500 SF NO

Boiler Pipe 1, 2, 3 Pipe TSI TSI Damaged Low 10% Chrysotile Friable 30 LF YES

Pipe 2 1, 2, 3 Pipe TSI TSI Damaged Low 10% Chrysotile Friable 40 LF YES

Pipe 3 1, 2, 3 Pipe TSI TSI Damaged Low 20% Chrysotile Friable 40 LF YES

Pipe 4 1, 2, 3 Pipe TSI TSI Damaged Low 30% Chrysotile Friable 45 LF YES

Boiler Elbow 1, 2, 3 Pipe TSI TSI Damaged Low 30% Chrysotile Friable 30 LF YES

P Mastic 1, 2, 3 Pipe Mastic TSI. Damaged Low 30% Chrysotile Friable 20 LF YES

P Ins 1, 2, 3 Pipe Insulation TSI Damaged Low 15% Chrysotile Friable 200 LF YES

PL

Ceiling 1, 2, 3 Plaster Surfacing Damaged Low NAD Friable 300 SF NO

DW

Boiler Ceiling

1, 2, 3 Drywall, Joint Compound Surfacing

Damaged Low NAD Friable 200 SF NO

P Mortar 1, 2, 3 Pipe Mortar Misc. Damaged Low NAD Category II -

Nonfriable 15 SF NO

Table Notes and Definitions:

HSA: Homogeneous Sampling Area (materials which are uniform in color, texture, construction/application date, and general appearance) NESHAPs = National Emission Standards for Hazardous Air Pollutants SF = Square Feet LF = Linear Feet

EA = Each NF = Non-Friable NAD = No Asbestos Detected Surf = Surfacing TSI = Thermal System Insulation Misc. = Miscellaneous *Note* - The indicated material quantities are estimates based on SUMMIT UES’ field observations and should be considered preliminary in nature. These estimates should not be used for bidding purposes without verification by the asbestos abatement contractor.

*Note* - Damaged and Significantly Damaged Non-Friable Materials are classified as RACM per NESHAP.

6.0 SUMMARY OF ASBESTOS CONTAINING MATERIALS

Inspection of the subject buildings, located at 212 E Jefferson Street #A in York, South Carolina 29745, identified thirteen (13) materials suspected of containing asbestos fibers. Bulk samples of each material were collected and submitted to an NVLAP accredited laboratory for analysis. The results indicated that seven (7) of the suspect materials contained asbestos fibers in excess of one percent. The bulk sample laboratory report and associated chain-of-custody documentation is presented in Appendix B.

The Pipe TSI (Boiler Pipe, Pipe 2, Pipe 3, Pipe 4, Boiler Elbow), located in the boiler room were in damaged condition and contained asbestos fibers in excess of one percent. These materials would be classified as Friable according to the current NESHAP regulations.

The Pipe Mastic (P Mastic), located in the boiler room was in damaged condition and contained asbestos fibers in excess of one percent. This material would be classified as Friable according to the current NESHAP regulations.

The Pipe Insulation (P Ins), located in the boiler room was in damaged condition and contained asbestos fibers in excess of one percent. This material would be classified as Friable according to the current NESHAP regulations.

7.0 REGULATORY INFORMATION

Demolition under the NESHAP regulation is defined as the wrecking or taking out of any load supporting member of a facility together with any related handling operations. We recommend you contact the Controlling Agency requiring the notification and other requirements which and may be applicable.

Renovation or demolition of the structures located within the subject property should be conducted in strict compliance with the aforementioned federal statutes and other applicable regulations, and good health and safety practices.

Renovation or demolition of this structure should be conducted in strict compliance with the aforementioned federal statutes and other applicable regulations, and good health and safety practices.

All procedures, methods and documentation should be accomplished by and be the responsibility of appropriately licensed professionals (asbestos consultants and contractors). Any material identified as non-friable ACM must be treated as friable ACM when the material is about to become friable as a result of activities performed within the building.

There are federal and state statutes and regulations which govern the abatement and disposal of ACMs.

The renovation or demolition of buildings and roofs containing ACMs is regulated under the NESHAP statute. The NESHAP regulations require notification to the controlling agency and removal of all regulated asbestos containing materials (RACM) prior to renovation or demolition. RACM is defined as (1) friable asbestos material, (2) Category I non-friable asbestos containing material that has become friable, (3) Category I on-friable asbestos containing material that will be or has been subjected to sanding, grinding, cutting or abrading, or (4) Category II non-friable Asbestos Containing Material 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 NESHAP. We strongly recommend that you contact the Controlling Agency prior to renovation or demolition regarding the proper disposition of the ACMs. It is important to note that even though an activity may be exempt from the EPA NESHAP regulations, such exemption does not extend to Occupational Safety and Health Administration (OSHA) standards or other state and federal statutes.

Renovation or demolition activities in buildings and on roofs that contain ACM or Presumed Asbestos Containing Material (PACM) are regulated under the OSHA Asbestos Construction Standard (29 CFR 1926.1101). The OSHA standard requires the building owner to inform their employees who will work in or adjacent to areas containing ACM or PACM, perspective employers applying or bidding for work whose employees reasonably can be expected to work in or adjacent to areas containing ACM or PACM, all employers of employees on multi-employer work sites who will be performing work with or adjacent to areas containing asbestos and tenants who will occupy areas containing ACM or PACM, of the presence, location, and quantity of ACM or PACM at the work sites in their building and facilities. Further, the OSHA standard (29 CFR 1926.1101) requires employers who discover ACM or PACM to convey information concerning the presence, location and quantity of such newly discovered ACM or PACM to others employers of employees working at the work site within 24 hours of discovery. While OSHA says the notification can be written or personal communication, there are many advantages to written communication.

The OSHA construction standard (29 CFR 1926.1101) also contains specific training, work practices, procedures, engineering controls, notifications, permissible exposure limits, personal protection, record keeping and a multitude of other requirements for the demolition, renovation, construction, alterations, repair, maintenance of structures, substrates or portions thereof that contain asbestos. It should be noted that recent court rulings have exempted roofing cement from the OSHA Construction Industry Asbestos Standard.

Renovation or demolition of the structures and roofs that could potentially disturbed the ACM located within the subject property should be conducted in strict compliance with the aforementioned federal statutes and other applicable regulations, and good health and safety practices. All procedures, methods and documentation should be accomplished by and be the responsibility of appropriately licensed professionals (asbestos consultants and contractors). Any material identified as non-friable ACM must be treated as friable ACM when the material is about to become friable as a result of activities performed within the building.

8.0 CONTROLLING AGENCY

If the structure is to be renovated or demolished, a copy of this report and a notification of demolition or renovation forms must be submitted to The South Carolina Department of Health and Environmental Control (SCDHEC) Asbestos Section at least ten working days prior to these activities taking place. Please note, Friable RACM removals less than NESHAP size and non-Friable removals must still be permitted.

Refer to the SCDHEC Asbestos Abatement/Demolition Forms for fees and time restraints.

9.0 CONDITIONS AND LIMITATIONS OF THIS INSPECTION

A representative of SUMMIT UES obtained samples of building materials which were observed during an inspection of the building at the subject site that are typically suspected of containing asbestos as a constituent. The bulk samples were submitted to an NVLAP approved laboratory for analysis using EPA approved methods for industry-accepted standards. No other warranty is expressed or implied.

In general, inspection and sampling procedures were incorporated which allowed assessment of reasonably accessible building materials. Some materials may be hidden or masked by overlying materials such as flooring, carpeting or concealed walls. Though every effort was made to examine wall cavities and other areas for thermal system insulation, spray-applied or trowel applied surfacing material or other miscellaneous materials and other Presumed Asbestos Containing Material (PACM), this survey and report only deals with accessible areas of the building. There may be additional inaccessible areas above ceiling, behind walls and below floors that become evident during demolition or renovation activities. Any suspected building materials not addressed in this report, which are encountered during demolition or renovation should be analyzed for asbestos content prior to being damaged and/or removed. The building’s equipment fixtures, or stored materials were not inspected or sampled as part of this evaluation.

Bidders are responsible for their own calculations and estimates of quantities. Actual quantities may be more or less than indicated.

Federal OSHA Standard 26 CFR 1926.1101 has specific requirements relating to employee protection and notification during construction projects (including demolition and renovation projects) involving ACM as well as materials containing trace levels of asbestos which apply to this project. SUMMIT recommends complying with applicable OSHA regulations, which would include notifying the demolition contractor of the presence of asbestos.

Please note that SUMMIT UES did not collect samples of concrete slabs and walls. If the concrete is to be disturbed or recycled, or the building is going to be demolished, EPA and state regulations require that the concrete be sampled to verify that it is not Asbestos containing.

This inspection report is not intended to be used as an asbestos abatement specification or work plan.

The indicated material quantities of ACM (if documented) are estimates based on SUMMIT UES’ field observations on the date(s) of the inspection and should be considered preliminary in nature. All parties utilizing this report for proposal, estimation or contract negotiations are required to field verify the quantities of material prior to submission of proposal. These estimates should not be used for bidding purposes without verification by the asbestos abatement contractor. The asbestos abatement contractor should ascertain for themselves, by site measurements and inspection, the exact nature and extent of the work to be done.

APPENDIX A

York, Southy Carolina 29745 May 4, 2023

View of ACM Pipe Insulation under Duct Tape

View of ACM Insulation on Boiler

View of Pipe Mastic ACM

View of Pipe Insulation ACM

APPENDIX

Project: McCelvey Center

2023-4-26-0545.E0001

Date Analyzed: 5/3/2023

Date Reported: 5/3/2023

Total Samples Analyzed: 29

# Samples >1% Asbestos: 8

Method of Analysis:

EPA/600/R-93/116

Summit #:

Asbestos Laboratory Report Prepared for

Summit ELT, Inc.

App E to Sub E. of 40 CFR Part 763 and

Date Received: 4/26/2023

Date Analyzed: 5/3/2023 Date Reported: 5/3/2023

Project : McCelvey

Asbestos

Sample ID Description Appearance % Fibrous % Non-Fibrous % Asbestos

DM-1

2023-4-25-0545.E0001-1

Duct Mastic White Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

DM-2

2023-4-25-0545.E0001-2

Duct Mastic White Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

PL-1

2023-4-25-0545.E0001-3

Plaster Gray Fibrous Homogeneous

2% Synthetic 98% Non-fibrous (other)

None Detected

PL-2

2023-4-25-0545.E0001-4

Plaster Gray Fibrous Homogeneous

2% Synthetic 98% Non-fibrous (other)

None Detected

PL-3

2023-4-25-0545.E0001-5

Plaster Gray Fibrous Homogeneous

2% Synthetic 98% Non-fibrous (other)

None Detected

Attic Ins-1

2023-4-25-0545.E0001-6

Attic Insulation Brown,Black Fibrous Homogeneous

90% Cellulose 10% Non-fibrous (other)

None Detected

Attic Ins-2

2023-4-25-0545.E0001-7

Attic Insulation Brown,Black Fibrous Homogeneous

90% Cellulose 10% Non-fibrous (other)

None Detected

Attic Ins-3

2023-4-25-0545.E0001-8

Attic Insulation Brown,Black Fibrous Homogeneous

90% Cellulose 10% Non-fibrous (other)

None Detected

Boiler Pipe 1-1

2023-4-25-0545.E0001-9

Boiler Pipe TSI Gray Fibrous Homogeneous

90% Non-fibrous (other)

10% Chrysotile

Boiler Pipe 1-2

2023-4-25-0545.E0001-10

Boiler Pipe TSI Positive stop (not analyzed)

Boiler Pipe 1-3

2023-4-25-0545.E0001-11

Boiler Pipe TSI Positive stop (not analyzed)

Pipe 2-1

2023-4-25-0545.E0001-12

Pipe TSI Gray Fibrous Homogeneous

90% Non-fibrous (other)

10% Chrysotile

Pipe 2-2

2023-4-25-0545.E0001-13

Pipe TSI Positive stop (not analyzed)

Pipe 2-3

2023-4-25-0545.E0001-14

Pipe TSI Positive stop (not analyzed)

Pipe 3-1

2023-4-25-0545.E0001-15

Pipe TSI Gray Fibrous Homogeneous

80% Non-fibrous (other)

20% Chrysotile

UES Laboratories 2520 Whitehall Park Dr., Ste. 250

Phone: (704) 626.0834

UES Order: 2023-4-26-0545.E0001

Summit ELT, Inc.

3575 Centre Circle Fort Mill, SC 29715

Non-Asbestos

Test Report: Asbestos Analysis of Bulk Material via EPA 600/R-93/116 Method using Polarized Light Microscopy

Analyst(s): Maria Cao Page 2 of 5

Date Reported: 5/3/2023

Project : McCelvey

Asbestos

Sample ID Description Appearance % Fibrous % Non-Fibrous % Asbestos

UES Laboratories 2520 Whitehall Park Dr., Ste. 250

Phone: (704) 626.0834

UES Order: 2023-4-26-0545.E0001

Summit ELT, Inc.

3575 Centre Circle Fort Mill, SC 29715

Non-Asbestos

Test Report: Asbestos Analysis of Bulk Material via EPA 600/R-93/116 Method using Polarized Light Microscopy

Pipe 3-1

2023-4-25-0545.E0001-16

Pipe TSI Positive stop (not analyzed)

Pipe 3-1

2023-4-25-0545.E0001-17

Pipe TSI Positive stop (not analyzed)

Pipe 4-1-Tar

2023-4-25-0545.E0001-18

Pipe TSI Gray,Black Fibrous Homogeneous

4% Cellulose 94% Non-fibrous (other)

2% Chrysotile

Pipe 4-1-Insulation

2023-4-25-0545.E0001-18A

Pipe TSI Gray Fibrous Homogeneous

70% Non-fibrous (other)

30% Chrysotile

Pipe 4-2

2023-4-25-0545.E0001-19

Pipe TSI Positive stop (not analyzed)

Pipe 4-3

2023-4-25-0545.E0001-20

Pipe TSI Positive stop (not analyzed)

Boiler Elbow-1

2023-4-25-0545.E0001-21

Boiler Elbow Pipe TSI White Fibrous Homogeneous

70% Non-fibrous (other)

30% Chrysotile

Boiler Elbow-2

2023-4-25-0545.E0001-22

Boiler Elbow Pipe TSI Positive stop (not analyzed)

Boiler Elbow-3

2023-4-25-0545.E0001-23

Boiler Elbow Pipe TSI Positive stop (not analyzed)

P Mastic-1-Wrap

2023-4-25-0545.E0001-24

Pipe Mastic Gray Fibrous Homogeneous

30% Cellulose 70% Non-fibrous (other)

None Detected

P Mastic-1-Insulation

2023-4-25-0545.E0001-24A

Pipe Mastic White Fibrous Homogeneous

70% Non-fibrous (other)

30% Chrysotile

P Mastic-2

2023-4-25-0545.E0001-25

Pipe Mastic Positive stop (not analyzed)

P Mastic-3

2023-4-25-0545.E0001-26

Pipe Mastic Positive stop (not analyzed)

P Ins-1

2023-4-25-0545.E0001-27

Pipe Insulation TSI Gray Fibrous Homogeneous

85% Non-fibrous (other)

15% Chrysotile

P Ins-2

2023-4-25-0545.E0001-28

Pipe Insulation TSI Positive stop (not analyzed)

Analyst(s): Maria Cao Page 3 of 5

Date Reported: 5/3/2023

Project : McCelvey

Asbestos

Sample ID Description Appearance % Fibrous % Non-Fibrous % Asbestos

UES Laboratories 2520 Whitehall Park Dr., Ste. 250

Phone: (704) 626.0834

UES Order: 2023-4-26-0545.E0001

Summit ELT, Inc.

3575 Centre Circle Fort Mill, SC 29715

Non-Asbestos

Test Report: Asbestos Analysis of Bulk Material via EPA 600/R-93/116 Method using Polarized Light Microscopy

P Ins-3

2023-4-25-0545.E0001-29

Pipe Insulation TSI Positive stop (not analyzed)

PL Ceiling-1

2023-4-25-0545.E0001-30

Plaster/Ceiling Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

PL Ceiling-2

2023-4-25-0545.E0001-31

Plaster/Ceiling Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

PL Ceiling-3

2023-4-25-0545.E0001-32

Plaster/Ceiling Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

DW Boiler Ceiling 1-Drywall

2023-4-25-0545.E0001-33

Drywall and Joint Compound

Gray,Brown Fibrous Homogeneous

10% Cellulose 90% Non-fibrous (other)

None Detected

DW Boiler Ceiling 1-Joint Compound

2023-4-25-0545.E0001-33A

Drywall and Joint Compound

White Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

DW Boiler Ceiling 2-Drywall

2023-4-25-0545.E0001-34

Drywall and Joint Compound

Gray,Brown Fibrous Homogeneous

10% Cellulose 90% Non-fibrous (other)

None Detected

DW Boiler Ceiling 2-Joint Compound

2023-4-25-0545.E0001-34A

Drywall and Joint Compound

White Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

DW Boiler Ceiling 3-Drywall

2023-4-25-0545.E0001-35

Drywall and Joint Compound

Gray,Brown Fibrous Homogeneous

10% Cellulose 90% Non-fibrous (other)

None Detected

DW Boiler Ceiling 3Joint Compound

2023-4-25-0545.E0001-35A

Drywall and Joint Compound

White Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

P Mortar-1

2023-4-25-0545.E0001-36

Pipe Mortar Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

P Mortar-2

2023-4-25-0545.E0001-37

Pipe Mortar Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

P Mortar-3

2023-4-25-0545.E0001-38

Pipe Mortar Gray Non-fibrous Homogeneous

100% Non-fibrous (other)

None Detected

**Sample P Mastic contained wrap and insulation, no mastic is present

Analyst(s): Maria Cao Page 4 of 5

Analysis is determined by Calibrated Visual Estimate (CVE).

Temperature at the time of analysis (°C) : 23

NVLAP Code: 600344

Analyst(s):

UES Laboratories, 2520 Whitehall Park Dr. Ste. 250, Charlotte, NC Phone: (704) 504-1717

Approved By:

Maria Cao

Approved Signatory

METHOD: App E to Sub E. of 40 CFR Part 763 and EPA/600/R-93/116

This sheet may not be reproduced except with permission from UES Laboratories. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government.

For samples easily separated into homogeneous layers, each component will be analyzed separately. The sample may not be representative of the larger material in question. Interpretation and use of test results are the responsibility of the client. Due to the limitations of the EPA 600 Method, nonfriable organically bound materials (NOBs) such as vinyl floor tiles, mastic and roofing can be difficult to analyze by PLM.

Reanalysis by Transmission Electron Microscopy (TEM) to verify results of <1% or None Detect for these materials is recommended. The percentage of asbestos reported is a midpoint within an acceptable range.

The estimated measurement of uncertainty is available upon request. Results relate only to the items received by the laboratory as noted on the Chain of Custody provided by the client.

1/27/2023 (Rev. 5) Page 5 of 5 This is the last page of the report

May 4, 2023

3575 Centre Circle Fort Mill, SC 29715

CLIENT PROJECT: McCelvey; 0545.E0001

LAB CODE: ST230405

Dear Customer:

Enclosed are asbestos analysis results for TEM bulk samples received at our laboratory on April 27, 2023. The samples were analyzed for asbestos using transmission electron microscopy (TEM) per Chatfield/EPA 600/R-93/116 Sec. 2.5.5.1 method.

Sample results containing > 1% asbestos are considered asbestos-containing materials (ACMs) per the EPA regulatory requirements. The detection limit for the TEM Chatfield/EPA 600/R-93/116 Sec. 2.5.5.1 method is <1% depending on the processed weight and constituents of the sample.

Thank you for your business and we look forward to continuing good relations.

Tianbao Bai, Ph.D., CIH Laboratory Director

Kind Regards, 2752 Pleasant Rd Suite 100A • Fort Mill, SC 29708 • 803.526.5146

ASBESTOS ANALYTICAL REPORT

By: Transmission Electron Microscopy

Prepared for

SUMMIT Engineering, Laboratory & Testing, Inc.

CLIENT PROJECT:

LAB CODE:

TEST METHOD: Bulk Chatfield EPA 600 / R93 / 116 Sec. 2.5.5.1

REPORT DATE:

McCelvey; 0545.E0001

05/04/23

ST230405

ASBESTOS BULK ANALYSIS

By: TRANSMISSION ELECTRON MICROSCOPY

Lab Code: ST230405 Date Received: 04-27-23 Date Analyzed: 05-04-23 Date Reported: 05-04-23

Client ID Lab ID

Material Description

TEM BULK CHATFIELD / EPA 600 / R93 / 116 Sec. 2.5.5.1

Client: SUMMIT Engineering, Laboratory & Testing, Inc.

3575 Centre Circle Fort Mill, SC 29715

Project: McCelvey; 0545.E0001

Sample Weight

(g)

Organic Material

Acid Soluble Material

Acid Insoluble Material

Asbestos

ST05706

1 Gray Duct Mastic 0.1746 56.2 5.2 38.6 None

Detected

LEGEND: None

METHOD: CHATFIELD & EPA/600/R-93/116 Sec. 2.5.5.1

LIMIT OF DETECTION: Varies with the weight and constituents of the sample (<1%)

REGULATORY LIMIT: >1% by weight

This report relates only to the samples tested or analyzed and may not be reproduced, except in full, without written approval by Eurofins CEI (ECEI). ECEI makes no warranty representation regarding the accuracy of client submitted information in preparing and presenting analytical results.

Interpretation of the analytical results is the sole responsibility of the client. Estimated measurement of uncertainty is available on request and in compliance with regulatory requirements. Samples were received in acceptable condition unless otherwise noted.

Information provided by customer includes customer sample ID, location, volume and area as well as date and time of sampling.

ECEI recommends between 0.20 and 0.50 grams of sample material for TEM bulk analysis.

Any weight below 0.10 grams is considered below protocol guidelines.

**Indicates sample weight below 0.05 grams and is considered insufficient for quantitative analysis.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH Laboratory Director

Miguel Angel Maysonet

APPENDIX