Asbestos Report - TC761.pdf

Mr. Daniel Staten

Comprehensive Interior/Exterior Asbestos Survey Report

Building TC761 Camp Lejeune, North Carolina

February 26, 2024

Comprehensive Interior/Exterior Asbestos Survey Report

Building TC761 Camp Lejeune, NC

Robert Elbertson NC AHERA Inspector relbertson@cceinc.biz

Prepared for:

Mr. Daniel Staten

Prepared by:

Crystal Coast Environmental, Inc.

1407 Ramsey Road

Jacksonville, NC 28546

Tel: 910.330.7410 relbertson@gmail.com

Our Ref.:

24-6127

Date:

February 26, 2024

This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law.

Table of Contents

1. Introduction 1

2. Methodology 1

3. Analytical Methods 2

4. Findings 2

5. Conclusions and Recommendations 2

6. Additional Survey Limitations 4

TABLES

Table 1 Confirmed and Suspect Asbestos-Containing Materials

APPENDICES

A Limitations and Service Constraints B Inspector Accreditations C Homogeneous Applications D Asbestos Sample Locations E Laboratory Report (NVLAP) – Asbestos Bulk Sample Results F Photograph Logs

Survey Report

Mr. Daniel Staten February 26, 2024

1. Introduction

As requested by Mr. Daniel Staten, Crystal Coast Environmental, Inc. (CCEI) conducted a Comprehensive Interior/Exterior Asbestos Survey (CIES) of the above-referenced building/project. The survey consisted of visually observing the interior and exterior, then collecting a representative number of samples for subsequent laboratory analyses as described below. The objective of the survey was to identify and quantify asbestos-containing building materials (ACBMs) for the purpose of future planned renovations or demolition activity.

As directed by the client, destructive testing was performed on flooring material to identify materials which may be hidden or obstructed by layers of wood substrate.

Unless noted herein, no other destructive testing was conducted to expose other potentially hidden or obstructed material. Examples of other areas include, but are not limited to interior wall cavities, pipe chases, spaces above fixed ceilings, grout/adhesive beneath ceramic tiles/marble tiles/granite, and adhesives behind wall mounted mirrors, etc.

The survey was conducted on February 20, 2024, by Mr. Robert Elbertson. A copy of the inspector’s accreditation is provided in Appendix B.

2. Methodology

CCEI conducted the CIES in general accordance with ASTM E2356-09 Standard Practice for Comprehensive Building Asbestos Surveys. ASTM E2356-09 meets the applicable requirements of current Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) Standard 40 CFR 61, Subpart M (Asbestos); EPA Asbestos Hazard Emergency Response Act (AHERA) Standard 40 CFR 763, Subpart E; and Occupational Safety and Health Administration (OSHA) asbestos survey and/or sampling regulations.

CCEI visually observed readily accessible areas for suspected ACBMs. Identified suspect materials were divided into "Homogeneous Applications" (HAs) - i.e., building materials which were determined by the inspector to be homogeneous based on their color, texture, and assumed date of installation.

Representative samples were then collected from selected HAs. The numbers of samples collected was based on CCEI’s in-house sampling protocol, which is based in part on the U.S. Environmental Protection Agency (U.S. EPA) Asbestos Hazard Emergency Response Act (AHERA) regulations. Each sample was assigned its own unique identification number, placed in 4 mil sealable plastic bags, and tightly sealed

Survey Report

Mr. Daniel Staten February 26, 2024 for subsequent shipment under a chain of custody protocol to Hayes Microbial located in Midlothian, Virginia.

3. Analytical Methods

Material identification was performed by CEI using Polarized Light Microscopy with Dispersion Staining (PLM/DS) method in accordance with the U.S. EPA Method 600/R-93/116. Asbestos content in each sample was evaluated based on a visual examination of each sample using a stereoscope.

Hayes Microbial is a member of the American Industrial Hygiene Association (AIHA) and accredited through the National Voluntary Laboratory Accreditation Program (NVLAP) administered by the National Institute of Standards and Technology (NIST).

Accreditations are provided in Appendix B and laboratory analytical report is provided in Appendix E.

4. Findings

A total of two HAs were identified throughout the Site, and a total of four suspect ACBM bulk samples were collected and submitted for laboratory analysis. A listing of HAs identified along with each HA material description, location, condition, asbestos content, and estimated quantity are presented in Appendix C. Approximate sampling locations are shown in Appendix D.

A total of 2 HA materials were confirmed or presumed asbestos containing material (PACM) at concentration above 1% (ACBM is defined as a material containing more than 1% of asbestos by weight).

5. Conclusions and Recommendations

As presented in Appendix C and the laboratory data provided in Appendix E, the results of the asbestos survey did identify ACBMs at the Site.

In accordance with current EPA National Emission Standards for Hazardous Pollutants (NESHAP) regulations, certain types of ACM must be removed prior to being disturbed by demolition or renovation activities. Current EPA NESHAP and Health Hazards Control Unit (HHC) of North Carolina Department of Health and Human Service (DHHS) regulations require that all Regulated ACMs (RACM) be removed prior to being disturbed. RACMs are defined as:

• Friable ACM.

Survey Report

Mr. Daniel Staten February 26, 2024

• Non-Friable Category 1 ACM that has become friable.

• Non-Friable Category 1 ACM that has been or will be subjected to sanding, abrading, grinding, or cutting.

• Non-Friable Category 2 ACM that has a high probability of becoming friable or crumbled, pulverized, or otherwise reduced to powder by the demolition or renovation activities.

In some cases, materials which may be ACBMs were identified as “Suspect ACM, Not Sampled” in the HAT. These include materials that could not safely be accessed during the survey, were labeled as PACM based on the inspector’s field determination. Until determined otherwise, suspect, and not sampled materials have been assumed to be ACBMs and should be managed as asbestos-containing in accordance with the local, state, and federal regulations.

If other suspect materials that are not referenced in this report are identified during demolition and/or renovation activities, CCEI recommends that these materials be considered as ACBM until they are inspected by an appropriately licensed asbestos inspector and proven otherwise.

Prior to demolition activities and when it is safe to do so, CCEI recommends sampling the PACM identified in this survey. Should these materials prove to be non-ACMs this could result in significant cost savings.

Due to the inability to effectively separate some types of multi-layered ACBMs (i.e., floor tile/mastic, mastic/wood subflooring, gypsum board/joint compound, etc.) from non-ACMs these materials are considered “asbestos-contaminated” for the purposes of removal and should be managed as ACBM.

ACBMs identified at the Site that may be disturbed during demolition activities, must be removed by a licensed asbestos abatement contractor utilizing industry standard work procedures in accordance with all federal, state and local regulations governing asbestos.

Asbestos waste must be disposed at an asbestos waste receiving facility that is duly permitted by the state and/or local municipality in which it resides. The asbestos waste should be disposed in a landfill with a NESHAP condition in the facility’s air permit that allows acceptance of RACM.

6. Additional Survey Limitations

Survey Report

Mr. Daniel Staten February 26, 2024

CCEI’s asbestos survey is subject to the following limitations in addition to those presented in Appendix A:

• Utilities/services, including electric were assumed to be active in the areas surveyed. Materials associated with electrical components and energized equipment, were not safely accessible and were not sampled.

• Subsurface investigations, including access to below grade structures, underground piping, conduits, building footings and extent of subsurface soil asbestos contamination if any was not accessible at the time of the survey.

Should you decide to remove/demolish below grade structures, an additional investigation may be warranted to determine if the below grade structures contain or are coated with ACMs.

Limitations and Service Constraints

The opinions, conclusions and recommendations presented in this report are limited to the information obtained during the performance of the specific scope of service identified in the report. To the extent that

Crystal Coast Environmental, Inc. (CCEI) relied upon any information prepared by other parties not under direct contract to CCEI, no representation as to the accuracy or completeness of such information is made. This report is an instrument of professional service and the services described in the report were performed in accordance with generally accepted standards and level of skill and care ordinarily exercised by members of the profession working under similar conditions including comparable budgetary and schedule constraints. No warranty, guarantee or certification express or implied, is intended or given with respect to CCIE’s services, opinions, conclusions or recommendations. This statement is in lieu of any other statement either expressed or implied.

CCEI’s observations, the results of testing and CCEI’s opinions, conclusions and recommendations apply solely to conditions existing at the specific times when and specific locations where CCEI’s investigative work was performed. Observation and testing activities such as those conducted by CCEI are inherently limited and do not represent a conclusive or complete characterization. Conditions in other parts of the project site, building or area may vary from conditions at the specific locations where observations were made and where testing was performed by CCEI. Additionally, other building material hazards which were not identified by CCEI, may also be present in the indoor air, un-accessed areas and in walls, ceilings, cavities and floors. Therefore, the extent of CCEI’s opinions, conclusions and recommendations are limited and 100% confidence in these opinions, conclusions and recommendations cannot reasonably be achieved. Nothing contained in this report shall relieve any other party of its responsibility to abide by contract documents and applicable laws, codes, regulations, or standards nor shall it be considered medical advice or consultation.

This report may document whether work conducted by CCEI or under CCEI’s observation was done so in accordance with applicable regulatory standards. In the absence of standards such as is often the case for microbial assessment and abatement, this report may not be construed as providing clearance, approval, or authorization for use or re-occupancy of a given structure. Actual site conditions and quantities should be field verified and unless expressly stated.

This report is expressly for the sole and exclusive use of the party for whom this report was originally prepared for and for the particular purpose outlined in the report. Only the party for whom this report was originally prepared and/or other specifically named parties have the right to make use of and rely upon this report. Reuse of this report or any portion thereof for other than its intended purpose, or if modified, or if used by third parties, shall be at the user’s sole risk.

Homogeneous Application Table TC761, Canp Lejeune, NC

Project No.: 24-6127

HA No. Material Type Primary Color Texture Description NESHAP Cat. Friable Rooms Location Condition Amt. Units Remarks

M - Exterior - Window Glazing

Compound Gray Smooth Exterior Window Caulk/Glazing CAT 2 Non-friable ACM No Exterior Wall Damaged 250 LF Quantities are an approximation

2 M - Roof - Decking Silver Rough Roof Coating CAT 2 Non-friable ACM No Roof Roof Damaged 9000 SF Quantities are an approximation

T = Thermal System Insulation (TSI) Material S - Surface Material M - Miscellaneous Material

Results of Sample Analyses TC761, Camp Lejeune, NC

Project No.: 24-6127

HA No. Material Type ID Location Content Type Sample Date Consultant Method Lab

1 M - Exterior - Window Glazing Compound >1%-10% Chrysotile CCEI PLM Hayes 1 M - Exterior - Window Glazing Compound Pos Stop CCEI PLM Hayes 2 M - Roof - Decking >1%-10% Chrysotile CCEI PLM Hayes 2 M - Roof - Decking Pos Stop CCEI PLM Hayes

T = Thermal System Insulation (TSI) Material S = Surfacing Material M - Miscellaneous Material

Table 1 Confirmed and Presumed Asbestos-Containing Materials

TC761

Camp Lejeune, NC

HA No. Material Description Room(s)/Location Condition Friability Estimated Quantity

Unit Notes

M - Exterior - Window

Glazing Compound Exterior Damaged No >1%-10% Chrysotile 250 LF

Exterior Window Caulk/Glazing

2 M - Roof - Decking Roof Damaged No >1%-10% Chrysotile 9000 SF Roof Coating

Asbestos Content

Project Number: 22-3546 Page 3 of 1 robert Typewritten Text Building TC761, CLNC robert Typewritten Text Drawing is not to scale robert Line robert Typewritten Text N robert Callout 761-1-01 robert Callout 761-1-02 robert Callout 761-2-03 robert Callout 761-2-04

#24007550

Analysis Report prepared for

Crystal Coast Environmental, Inc

273 Hinson Lane Richland, NC 28574

Phone: (910) 938-7998

24-6127 Building TC 761

NRAS, NC

Collected: February 20, 2024 Received: February 21, 2024 Reported: February 23, 2024

We would like to thank you for trusting Hayes Microbial for your analytical needs!

We received 4 samples by FedEx in good condition for this project on February 21st, 2024.

The results in this analysis pertain only to this job, collected on the stated date, and should not be used in the interpretation of any other job. Information supplied by the customer can affect the validity of results. These results apply only to the samples as received. This report may not be duplicated, except in full, without the written consent of Hayes Microbial Consulting, LLC.

All information provided to Hayes Microbial is confidential information relating to our customers and their clients. We will not disclose, copy, or distribute any information verbally or written, except to those designated by the customer(s). We take confidentiality very seriously. No changes to the distribution list will be made without the express consent of the customer.

This laboratory bears no responsibility for sample collection activities, analytical method limitations, or your use of the test results. Interpretation and use of test results are your responsibility. Any reference to health effects or interpretation of mold levels is strictly the opinion of Hayes Microbial. In no event, shall Hayes Microbial or any of its employees be liable for lost profits or any special, incidental or consequential damages arising out of the use of these test results.

Steve Hayes, BSMT(ASCP) Laboratory Director Hayes Microbial Consulting, LLC.

EPA Laboratory ID: VA01419

Lab ID: #188863

DPH License: #PH-0198

Hayes Microbial Consulting, LLC. 3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 1 of 3

# Sample Material Description Non-Fibrous Non-Asbestos Fibers Asbestos Fibers

1 761-1-01 - Roof Sealant (Silver) Homogenous / Sealant / Silver 96% 4% Chrysotile

2 761-1-02 - Roof Sealant (Silver) Homogenous / Sealant / Silver ( Not Analyzed, Positive Stop )

3 761-2-03 - Exterior Window Caulk Homogenous / Caulk / Off-White 96% 4% Chrysotile

4 761-2-04 - Exterior Window Caulk Homogenous / Caulk / Off-White ( Not Analyzed, Positive Stop )

Robert Elbertson Crystal Coast Environmental, Inc 273 Hinson Lane Richland, NC 28574

(910) 938-7998

24-6127 Building TC 761

NRAS, NC

#24007550

Asbestos PLM Bulk EPA 600/R-93/116; EPA 40 CFR Appendix E to Subpart E of Part 763

Project Analyst:

Mark Bergstrom, Mark Bergstr�m Date:

02 - 22 - 2024 Reviewed By:

Brian Keith, Date:

02 - 23 - 2024

Collected:Feb 20, 2024 Received: Feb 21, 2024 Reported: Feb 23, 2024

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 2 of 3

Analysis Details All samples were received in acceptable condition unless otherwise noted on the report. This report must not be used by the client to claim product certification, approval, or endorsement by AIHA, NIST, NVLAP, NY ELAP, or any agency. The results relate only to the items tested. Hayes Microbial Consulting reserves the right to dispose of all samples after a period of 60 days in compliance with state and federal guidelines.

PLM Analysis All Polarized Light Microscopy (PLM) results include an inherent uncertainty of measurement associated with estimating percentages by PLM.

Materials with interfering matrix, low asbestos content, or small fiber size may require additional analysis via TEM Analysis.

TEM Analysis Analysis by TEM is capable of providing positive identification of asbestos type(s) and semi-quantitation of asbestos content.

Definitions 'None Detected' - Below the detected reporting limit of 1% unless point counting is performed, then the detected reporting limit is .25%.

New York ELAP Per NY ELAP198.6 (NOB), TEM is the only reliable method to declare an NOB material as Non-Asbestos Containing.

Any NY ELAP samples that are subcontracted to another laboratory will display the name and ELAP Lab Identification number in the report page heading of those samples. The original report provided to Hayes Microbial Consulting is available upon request.

Robert Elbertson Crystal Coast Environmental, Inc 273 Hinson Lane Richland, NC 28574

(910) 938-7998

24-6127 Building TC 761

NRAS, NC

#24007550

Asbestos Analysis Information

3005 East Boundary Terrace, Suite F. Midlothian, VA. 23112 (804) 562-3435 contact@hayesmicrobial.com Page: 3 of 3

Building TC761, CLNC

24-6127 Page 1 of 1

View of the Front of the Building HA-1: Exterior Window Glazing/Caulk

HA-2: Roof Coating