Attachment 3b Parsons Mtn Asbestos Report (29 pages).pdf

1258 Boiling Springs Road • Spartanburg, SC 29303 • Phone 864‐541‐8736 / Fax 864‐541‐8776 www.crossroadsenv.net

ASBESTOS INSPECTION REPORT

FOR

CLIENT

Francis Marion & Sumter National Forest

4931 Broad River Road Abbeville, SC 29620

SITE LOCATION

Parson’s Mountain Campground Structures Scheduled for Demolition

454 Parson’s Mountain Road Abbeville, SC 29620

INSPECTION DATE: March 11, 2020 REPORT DATE: March 18, 2020

INSPECTOR

Kay H. Horton – SC‐DHEC License #ASB‐23394

(864) 541‐8736

For

Crossroads Environmental, LLC 1258 Boiling Springs Road

Spartanburg, South Carolina 29303

(864) 541‐8736

CRE Project # 17945‐IN

TABLE OF CONTENTS

INSPECTION REPORT/LETTER

BACKGROUND INFORMATION

BUILDING/AREA DESCRIPTION

INSPECTION STRATEGY/SAMPLING PROTOCOL

RESULTS

CLOSING STATEMENTS AND LIMITATIONS

ATTACHMENTS

ATTACHMENT I: ASBESTOS SUMMARY TABLE

ATTACHMENT II: LABORATORY REPORT

ATTACHMENT III: BUILDING/AREA SKETCH

ATTACHMENT IV: INSPECTOR’S LICENSE/ACCREDITATION

March 18, 2020

Mr. Mike Alcorn Forest Service Francis Marion & Sumter National Forest Service 4931 Broad River Road Columbia, SC 29212

Re: Limited Asbestos Inspection Report Parson’s Mountain Campground (Structures to be Demolished)

454 Parson’s Mountain Road, Abbeville, SC 29620 CRE Project Number: 17945‐IN

Dear Mr. Alcorn:

Crossroads Environmental, LLC (CRE) completed asbestos inspections of multiple structures within Parson’s Mountain Campground, located at 454 Parson’s Mountain Road in Abbeville, South Carolina on March 11, 2020. The inspection was performed by a SC‐DHEC Licensed Asbestos Inspector, and in accordance with South Carolina Department of Health and Environmental Control (SC‐DHEC) and Environmental Protection Agency (EPA) Requirements. A detailed summary table of the sampling is included in Attachment I; however, this report should be read in its entirety.

Building Description

CRE’s scope of work included sampling suspect material in association with the former pump house (Bldg. 334), “day use” bath house (Bldg. 310), and the campsite bath house (Bldg. 724). The former pump house is of concrete construction; thus, no suspect material was identified. The only suspect materials identified in association with the “day use” bath house and campsite bath house, which are both cinderblock construction, were roofing shingles and associated felt.

Inspection Strategy/Sampling Protocol

The inspection consisted of grouping suspect asbestos containing materials into homogeneous areas based on the color and texture of the material, and then performing representative sampling of the materials included in those homogeneous areas. SC‐DHEC has requirements for the minimum number of samples that can be

Limited Asbestos Inspection Report March 18, 2020 Parsons’s Mountain Campground Page 2 of 2 Project Number: 17945‐IN collected from each homogeneous area (three samples of each miscellaneous material, three samples of each type of thermal system insulation, and the sample requirements for surfacing are based on square footage). Following completion of the on‐site inspection/sampling, samples were submitted to an accredited laboratory for analysis.

Results

EPA recognizes a material as Asbestos Containing Material (ACM) if an asbestos content of greater than one percent asbestos is detected in a representative sample analyzed by polarized light microscopy.

Results indicated that no asbestos was detected in the materials sampled.

Closing Statements and Limitations

Every effort was made to identify all materials in accessible areas. There is the possibility that suspect materials were not identified in inaccessible areas. If any suspect material is discovered that is not included within this report, it should be sampled before it is physically disturbed.

This document has been prepared by Crossroads Environmental, LLC at the request of and for the exclusive use of the Forest Service. This report represents the findings from the date that it was inspected, and is limited in scope to that indicated above.

Crossroads Environmental, LLC appreciates the opportunity to provide the Forest Service with our consultative services. Should you have any questions or need additional information, please do not hesitate to contact us.

Sincerely, Kay Horton President

HJ

Attachments‐ (4)

ATTACHMENT I

ASBESTOS SUMMARY TABLE

CRE JOB #: 17945‐IN

Location:

Client: DATE: 3/11/2020

HA#

Type of

Material

TSI, Surf, Misc.

Material Type Sample Number

Asbestos

Content

(PLM)

Asbestos

Content

(TEM)

Location of Sample Approx.

Quantity

Physical

Condition Location/ Comments

155‐Shingle

155‐Felt

NAD

NAD

Day Use Restroom

156‐Shingle

156‐Felt

NAD

NAD

Day Use Restroom

157‐Shingle

157‐Felt

NAD

NAD

Day Use Restroom

158‐Black,Brown

Shingle

158‐Black,Red Shingle

158‐Felt

NAD

NAD

NAD

Bath House @

Campground

159‐Black,Brown

Shingle

159‐Black,Red Shingle

159‐Felt

NAD

NAD

NAD

NAD

Bath House @

Campground

160‐Black,Red Shingle

160‐Felt

NAD

NAD

Bath House @

Campground

CROSSROADS ENVIRONMENTAL, LLC ASBESTOS INSPECTION REPORT

Parsons Mountain Camp Ground, Structures Scheduled for Demolition

Francis Marion & Sumter Forest Service

Key: A=Amosite, C=Chrysotile, Cr=Crocidolite, Tr=Tremolite, Ac=Actinolite Asbestos, Misc.=Miscellaneous, HA#=Homogeneous Area #, PLM=Polarized Light Microscopy, TEM=Transmission Electron Microscopy, /=PLM and/or TEM Analysis Not Required sq.ft.=Square Feet, cu.ft.=Cubic Feet, ln.ft.=Linear Feet, HJI=Hard Joint Insulation, TSI=Thermal System Insulation, BUR=Built‐up Roofing, Surf=Surfacing

NAD=No Asbestos Detected, SP=Stop Positive

Located on the roof of the 'day use' bath house building.

N/A

Roofing Shingles &

Felt Paper N/A

N/A

Located on the roof of the bath house at the camprground.02 Misc. N/A

Misc.

Roofing Shingles &

Felt Paper

Asbestos Inspector's Accreditation #: ASB-23184 Asbestos Inspector Printed Name: Kay Horton Page 1 of 1

ATTACHMENT II

LABORATORY REPORT(S)

March 16, 2020

Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

CLIENT PROJECT: Parson's Mtn., 17945-IN

CEI LAB CODE: B202023

Dear Customer:

Enclosed are asbestos analysis results for PLM Bulk samples received at our laboratory on March 13, 2020. The samples were analyzed for asbestos using polarizing light microscopy (PLM) per the EPA 600 Method.

Sample results containing >1% asbestos are considered asbestos-containing materials (ACMs) per EPA regulatory requirements. The detection limit for the EPA 600 Method is <1% asbestos by weight as determined by visual estimation.

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

730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Tianbao Bai, Ph.D., CIH Laboratory Director

Kind Regards, ASBESTOS ANALYTICAL REPORT

By: Polarized Light Microscopy

Prepared for

Crossroads Environmental

CLIENT PROJECT:

LAB CODE:

TEST METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORT DATE:

TOTAL SAMPLES ANALYZED:

# SAMPLES >1% ASBESTOS:

Parson's Mtn., 17945-IN

B202023

03/16/20

Asbestos Report Summary By: POLARIZING LIGHT MICROSCOPY

PROJECT: Parson's Mtn., 17945-IN LAB CODE: B202023

Client ID Lab ID Color Sample Description

ASBESTOS

%Layer

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

Layer 1 B32635 Black,Gray Roofing Shingle None Detected155

Layer 2 B32635 Black,Brown Felt None Detected

Layer 1 B32636 Black,Gray Roofing Shingle None Detected156

Layer 2 B32636 Black,Brown Felt None Detected

B32637 Sample Submitted for TEM Analysis

Layer 1 B32638A Black,Brown Roofing Shingle (type 1) None Detected158

Layer 2 B32638A Black,Red Roofing Shingle (type 2) None Detected

B32638B Black,Brown Felt None Detected

Layer 1 B32639A Black,Brown Roofing Shingle (type 1) None Detected159

Layer 2 B32639A Black,Red Roofing Shingle (type 2) None Detected

B32639B Black,Brown Felt None Detected

B32640 Sample Submitted for TEM Analysis

ASBESTOS BULK ANALYSIS

Lab Code: B202023 Date Received: 03-13-20 Date Analyzed: 03-16-20 Date Reported: 03-16-20

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600 METHOD

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

Project: Parson's Mtn., 17945-IN

Fibrous

Black,Gray

B32635

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None Detected Layer 1

Roofing Shingle

Black,Brown Felt

B32635 55%Heterogeneous

Fibrous Bound

35% 10%

Cellulose Tar Binder

None DetectedLayer 2

Black,Gray

B32636

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None Detected Layer 1

Roofing Shingle

Black,Brown Felt

B32636 55%Heterogeneous

Fibrous Bound

35% 10%

Cellulose Tar Binder

None DetectedLayer 2

Sample Submitted for TEM Analysis

B32637

Black,Brown

B32638A

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None Detected Layer 1

Roofing Shingle (type 1)

Black,Red Roofing Shingle (type 2)B32638A

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None DetectedLayer 2

Black,Brown FeltB32638B 55%Heterogeneous

Fibrous Bound

35% 10%

Cellulose Tar Binder

None Detected

Lab Code: B202023 Date Received: 03-13-20 Date Analyzed: 03-16-20 Date Reported: 03-16-20

Client ID Lab ID

Lab Attributes

Lab Description

ASBESTOS

ASBESTOS BULK PLM, EPA 600 METHOD

NON-ASBESTOS COMPONENTS

Non-Fibrous

Client: Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

Project: Parson's Mtn., 17945-IN

Fibrous

Black,Brown

B32639A

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None Detected Layer 1

Roofing Shingle (type 1)

Black,Red Roofing Shingle (type 2)B32639A

<1% 25%

Heterogeneous

Fibrous Bound

25% 40% 10%

Cellulose Fiberglass

Tar Gravel Silicates

None DetectedLayer 2

Black,Brown FeltB32639B 55%Heterogeneous

Fibrous Bound

35% 10%

Cellulose Tar Binder

None Detected

Sample Submitted for TEM Analysis

B32640

LEGEND: Non-Anth = Non-Asbestiform Anthophyllite Non-Trem = Non-Asbestiform Tremolite Calc Carb = Calcium Carbonate

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORTING LIMIT: <1% by visual estimation

REPORTING LIMIT FOR POINT COUNTS: 0.25% by 400 Points or 0.1% by 1,000 Points

REGULATORY LIMIT: >1% by weight

Due to the limitations of the EPA 600 method, nonfriable organically bound materials (NOBs) such as vinyl floor tiles can be difficult to analyze via polarized light microscopy (PLM). EPA recommends that all NOBs analyzed by PLM, and found not to contain asbestos, be further analyzed by Transmission Electron Microscopy (TEM). Please note that PLM analysis of dust and soil samples for asbestos is not covered under NVLAP accreditation. Estimated measurement of uncertainty is available on request.

This report relates only to the samples tested or analyzed and may not be reproduced, except in full, without written approval by Eurofins CEI. Eurofins CEI 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. Samples were received in acceptable condition unless otherwise noted. This report may not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. Government.

Information provided by customer includes customer sample ID and sample description.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH

Scott Minyard

March 17, 2020

Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

CLIENT PROJECT: Parson's Mtn., 17945-IN

LAB CODE: T200627

Dear Customer:

Enclosed are asbestos analysis results for TEM bulk samples received at our laboratory on March 16, 2020. 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.

730 SE Maynard Road • Cary, NC 27511 • 919.481.1413

Tianbao Bai, Ph.D., CIH

Kind Regards, ASBESTOS ANALYTICAL REPORT

By: Transmission Electron Microscopy

Prepared for

Crossroads Environmental

CLIENT PROJECT:

LAB CODE:

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

REPORT DATE:

Parson's Mtn., 17945-IN

T200627

03/17/20

By: TRANSMISSION ELECTRON MICROSCOPY

Lab Code: T200627 Date Received: 03-16-20 Date Analyzed: 03-17-20 Date Reported: 03-17-20

Client ID Lab ID

Material Description

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

Client: Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

Project: Parson's Mtn., 17945-IN

Sample Weight

(g)

Organic Material

Acid Soluble Material

Acid Insoluble Material

Asbestos

T03575 157 Roofing Shingle 0.557 21.4 46 32.6 None

Detected

T03576 157 Felt 0.705 91.1 2.7 6.2 None

Detected

T03577 160 Roofing Shingle (type 2) 0.586 19.3 16 64.7 None

Detected

T03578 160 Felt 0.618 93.4 2.6 4 None

Detected

T03606 159 Roofing Shingle (type 1)

Roofing shingle type 1 is present in 159, not 160.

0.376 27.1 20.2 52.7 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. Eurofins CEI 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. 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.

ANALYST: APPROVED BY:

Tianbao Bai, Ph.D., CIH

Emily Morris

ATTACHMENT III

SAMPLE LOCATION SKETCH AND/OR PHOTOS

ATTACHMENT IV

ACCREDITATION(S)