Attachment 3d Chattooga Cabin Asbestos Report (30 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

Chattooga River Cabin

119 Beaver Lane Mountain Rest, SC

INSPECTION DATE: March 24, 2020 REPORT DATE: April 1, 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 # 17966‐IN

TABLE OF CONTENTS

INSPECTION REPORT/LETTER

BACKGROUND INFORMATION

BUILDING/AREA DESCRIPTION

INSPECTION STRATEGY/SAMPLING PROTOCOL

RESULTS

RELEVANT REGULATORY REQUIREMENTS/RECOMMENDATIONS

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

April 1, 2020

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

Re: Asbestos Inspection Report Chattooga River Cabin & Well Vault

119 Beaver Lane, Mountain Rest, SC CRE Project Number: 17966‐IN

Dear Mr. Alcorn:

Crossroads Environmental, LLC (CRE) completed an asbestos inspection of the Chattooga River Cabin, located at 119 Beaver Lane in Mountain Rest, SC on March 24, 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(s) associated with the cabin and well vault. The house is a one‐story wood framed structure, built over a concrete block foundation. The interior consists of wood floors covered in various vinyl flooring materials, wood walls, and wood ceilings. Attic insulation was non‐suspect fiberglass.

The well vault is constructed entirely of concrete, with no suspect asbestos‐containing materials.

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 collected from each homogeneous area (three samples of each miscellaneous material, three samples of each type of thermal system insulation, and the sample requirements

Asbestos Inspection Report April 1, 2020 Chattooga River Cabin Page 2 of 3 Project Number: 17966‐IN for surfacing are based on square footage). Following completion of the on‐site inspection/sampling, samples were submitted to an accredited laboratory for analysis.

As of June 27, 2008, SC‐DHEC requires that any non‐friable organically bound (NOB) material that is suspect to contain asbestos, such as floor tile, mastics, roofing material, and caulking must be analyzed by transmission electron microscopy (TEM) if polarized light microscopy (PLM) analyses of that material indicate that no asbestos was detected.

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. It should be noted that items containing <1% asbestos are covered to some extent by the OSHA’s Asbestos Standard for the Construction Industry

(29 CFR 1926.1101).

Results indicated that greater than one percent asbestos was detected in the white/green vinyl flooring (HA04); and window glaze (HA05).

Relevant Regulatory Requirements/Recommendations

Friability‐Friable materials are defined as materials that can be reduced to powder by hand pressure. It should be noted that non‐friable materials may become friable depending on the method of removal. All non‐friable materials must be removed by properly accredited asbestos personnel. If the non‐friable materials are removed in a friable manner, then all regulations in regards to friable abatement will apply, and the abatement must be performed by a SC‐DHEC Licensed Asbestos Contractor, and in accordance with all state and federal regulations.

Air Monitoring‐Air monitoring by a SC‐DHEC Licensed Air Monitor will be required on this project.

CRE can further assist with Project Design, Air Monitoring, and/or help in selecting an asbestos abatement contractor.

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.

Asbestos Inspection Report April 1, 2020 Chattooga River Cabin Page 3 of 3 Project Number: 17966‐IN

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 Licensed Asbestos Inspector

Attachments‐ (4)

ATTACHMENT I

ASBESTOS SUMMARY TABLE

CRE JOB #: 17966‐IN

Location:

Client: DATE: 3/24/2020

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

121‐flooring

121‐mastic

NAD

NAD

Living Room

122‐flooring

122‐mastic

NAD

NAD

Bedroom 1

123‐flooring

123‐mastic

NAD

NAD

Bedroom 2

124‐flooring

124‐glue

NAD

NAD

Kitchen

125‐flooring

125‐glue

NAD

NAD

Kitchen

NAD

NAD

Kitchen

127‐tile

127‐mastic

NAD

NAD

Bathroom

128‐tile

128‐mastic

NAD

NAD

Bathroom

129‐tile

129‐mastic

NAD

NAD

Bathroom

130‐tile

130‐mastic

7% C

NAD

Living Room

131‐tile

131‐mastic

SP

NAD

Living Room

SP

<1% C Living Room

CROSSROADS ENVIRONMENTAL, LLC ASBESTOS INSPECTION REPORT

Chattooga River Cabin, 119 Beaver Lane, Mountain Rest, SC

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

01 Misc.

Beige Square‐

Patterned Sheet

Vinyl Flooring

N/A Good;

Non‐friable

Located in all rooms, except bathroom.

02 Misc.

Self‐Stick Vinyl

Floor Tile N/A

Good;

Non‐friable

Located in kitchen (on floor and on countertop).

03 Misc. 9" Red Vinyl Floor N/A Good;

Non‐friable Located in the bathroom.

04 Misc.

White/Green Vinyl

Flooring & Black

Mastic

300 sq. ft. Friable

Located under Living Room and bathroom under vinyl flooring and a layer of plywood.

*TEM probable contamination from positive tile.

Asbestos Inspector's Accreditation #: ASB-23394 Asbestos Inspector Printed Name: Kay H. Horton Page 1 of 2

CRE JOB #: 17966‐IN

Location:

Client: DATE: 3/24/2020

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

CROSSROADS ENVIRONMENTAL, LLC ASBESTOS INSPECTION REPORT

Chattooga River Cabin, 119 Beaver Lane, Mountain Rest, SC

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

133 3% C / Back of house

134 SP / Back of house

135 / SP Back of house

136‐Layer 1

136‐Layer 2

NAD

NAD

Porch

137‐Layer 1

137‐Layer 3

NAD

NAD

Porch

138‐Layer 1

138‐Layer 4

NAD

NAD

Porch

N/A Good;

Non‐friable Misc.

Roofing Shingles

(no felt present)

Located on overhang of back porch/stoop and over roof ridge. The remainder of the roof is metal.

05 Misc. Window Glaze 9 windows, 3'x4' each

Good;

Non‐friable

Located around panes of all windows.

Asbestos Inspector's Accreditation #: ASB-23394 Asbestos Inspector Printed Name: Kay H. Horton Page 2 of 2

ATTACHMENT II

LABORATORY REPORT(S)

March 27, 2020

Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

CLIENT PROJECT: Chattooga Cabin, 17966-IN

CEI LAB CODE: A203912

Dear Customer:

Enclosed are asbestos analysis results for PLM Bulk samples received at our laboratory on March 26, 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:

Chattooga Cabin, 17966-IN

A203912

03/27/20

Asbestos Report Summary By: POLARIZING LIGHT MICROSCOPY

PROJECT: Chattooga Cabin, 17966-IN LAB CODE: A203912

Client ID Lab ID Color Sample Description

ASBESTOS

%Layer

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

A62882A Gray,Off-white Vinyl Sheet Flooring None Detected121

A62882B Tan Mastic None Detected

A62883A Gray,Off-white Vinyl Sheet Flooring None Detected122

A62883B Tan Mastic None Detected

A62884A Sample Submitted for TEM Analysis

A62884B Sample Submitted for TEM Analysis

A62885A Tan Self-stick Vft None Detected124

A62885B Clear Mastic None Detected

A62886A Tan Self-stick Vft None Detected125

A62886B Clear Mastic None Detected

A62887A Sample Submitted for TEM Analysis

A62887B Sample Submitted for TEM Analysis

A62888A Red Vft None Detected127

A62888B Tan Mastic None Detected

A62889A Red Vft None Detected128

A62889B Tan Mastic None Detected

A62890A Sample Submitted for TEM Analysis

A62890B Sample Submitted for TEM Analysis

A62891A Tan Vft Chrysotile130 7% A62891B Black Mastic None Detected

A62892A Sample Not Analyzed per COC131

A62892B Black Mastic None Detected

A62893A Sample Not Analyzed per COC132

A62893B Sample Submitted for TEM Analysis

A62894 White,Off-white Window Glaze Chrysotile133 3% A62895 Sample Not Analyzed per COC134

Asbestos Report Summary

PROJECT: Chattooga Cabin, 17966-IN LAB CODE: A203912

Client ID Lab ID Color Sample Description

ASBESTOS

%Layer

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

A62896 Sample Not Analyzed per COC135

Layer 1 A62897 Black,Brown Roofing Shingles None Detected136

Layer 2 A62897 Black,Brown Roofing Shingles None Detected

Layer 1 A62898 Black,Brown Roofing Shingles None Detected137

Layer 2 A62898 Black,Brown Roofing Shingles None Detected

Layer 1 A62899 Sample Submitted for TEM Analysis

Layer 2 A62900 Sample Submitted for TEM Analysis

ASBESTOS BULK ANALYSIS

Lab Code: A203912 Date Received: 03-26-20 Date Analyzed: 03-26-20 Date Reported: 03-27-20

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: Chattooga Cabin, 17966-IN

Fibrous

Gray,Off-white Vinyl Sheet Flooring121

A62882A 40% 5%

Heterogeneous

Fibrous Bound

40% 15%

Cellulose Fiberglass

Vinyl Binder

None Detected

Tan MasticA62882B 2%Homogeneous

Non-fibrous Bound

98%Cellulose Mastic None Detected

Gray,Off-white Vinyl Sheet Flooring122

A62883A 40% 5%

Heterogeneous

Fibrous Bound

40% 15%

Cellulose Fiberglass

Vinyl Binder

None Detected

Tan MasticA62883B 2%Homogeneous

Non-fibrous Bound

98%Cellulose Mastic None Detected

Sample Submitted for TEM Analysis

A62884A

Sample Submitted for TEM Analysis

A62884B

Tan Self-stick Vft124

A62885A <1%Homogeneous

Non-fibrous Bound

100%Synthetic Fiber Vinyl None Detected

Clear MasticA62885B <1%Homogeneous

Non-fibrous Bound

100%Cellulose Mastic None Detected

Lab Code: A203912 Date Received: 03-26-20 Date Analyzed: 03-26-20 Date Reported: 03-27-20

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: Chattooga Cabin, 17966-IN

Fibrous

Tan Self-stick Vft125

A62886A <1%Homogeneous

Non-fibrous Bound

100%Synthetic Fiber Vinyl None Detected

Clear MasticA62886B <1%Homogeneous

Non-fibrous Bound

100%Cellulose Mastic None Detected

Sample Submitted for TEM Analysis

A62887A

Sample Submitted for TEM Analysis

A62887B

Red Vft127

A62888A Homogeneous

Non-fibrous Bound

100% Vinyl None Detected

Tan MasticA62888B 3%Homogeneous

Non-fibrous Bound

97%Cellulose Mastic None Detected

Red Vft128

A62889A Homogeneous

Non-fibrous Bound

100% Vinyl None Detected

Tan MasticA62889B 3%Homogeneous

Non-fibrous Bound

97%Cellulose Mastic None Detected

Sample Submitted for TEM Analysis

A62890A

Lab Code: A203912 Date Received: 03-26-20 Date Analyzed: 03-26-20 Date Reported: 03-27-20

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: Chattooga Cabin, 17966-IN

Fibrous

Sample Submitted for TEM Analysis

A62890B

Tan Vft130

A62891A Homogeneous

Fibrous Bound

93% Vinyl 7% Chrysotile

Black MasticA62891B <1%Homogeneous

Non-fibrous Bound

100%Cellulose Mastic None Detected

Sample Not Analyzed per COC

A62892A

Black MasticA62892B <1%Homogeneous

Non-fibrous Bound

100%Cellulose Mastic None Detected

Sample Not Analyzed per COC

A62893A

Sample Submitted for TEM Analysis

A62893B

White,Off-white Window Glaze133

A62894 Heterogeneous

Non-fibrous Bound

95% 2%

Binder Paint

3% Chrysotile

Sample Not Analyzed per COC

A62895

Sample Not Analyzed per COC

A62896

Lab Code: A203912 Date Received: 03-26-20 Date Analyzed: 03-26-20 Date Reported: 03-27-20

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: Chattooga Cabin, 17966-IN

Fibrous

Black,Brown

A62897

45%Heterogeneous

Fibrous Bound

40% 15%

Fiberglass Tar Gravel

None Detected Layer 1

Roofing Shingles

Black,Brown Roofing Shingles

A62897 45%Heterogeneous

Fibrous Bound

40% 15%

Fiberglass Tar Gravel

None DetectedLayer 2

Black,Brown

A62898

45%Heterogeneous

Fibrous Bound

40% 15%

Fiberglass Tar Gravel

None Detected Layer 1

Roofing Shingles

Black,Brown Roofing Shingles

A62898 45%Heterogeneous

Fibrous Bound

40% 15%

Fiberglass Tar Gravel

None DetectedLayer 2

A62899 Layer 1

Sample Submitted for TEM Analysis

Sample Submitted for TEM AnalysisA62900

Layer 2

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

McLane Brown

March 30, 2020

Crossroads Environmental 1258 Boiling Springs Road Spartanburg, SC 29303

CLIENT PROJECT: Chattooga Cabin, 17966-IN

LAB CODE: T200721

Dear Customer:

Enclosed are asbestos analysis results for TEM bulk samples received at our laboratory on March 27, 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:

Chattooga Cabin, 17966-IN

T200721

03/30/20

By: TRANSMISSION ELECTRON MICROSCOPY

Lab Code: T200721 Date Received: 03-27-20 Date Analyzed: 03-30-20 Date Reported: 03-30-20

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: Chattooga Cabin, 17966-IN

Sample Weight

(g)

Organic Material

Acid Soluble Material

Acid Insoluble Material

Asbestos

T04239 123 Vinyl Sheet Flooring 0.276 63 16.3 20.7 None

Detected

T04240 123 Mastic 0.222 54.1 14 31.9 None

Detected

T04241 126 Self-stick VFT 0.234 28.6 66.2 5.2 None

Detected

T04242 126 Mastic 0.109 81.7 17.4 .9 None

Detected

T04243 129 VFT 0.316 27.2 55.1 17.7 None

Detected

T04244 129 Mastic 0.112 67 7.1 25.9 None

Detected

T04245 132 Mastic

Probable contamination from positive floor tile.

0.106 95.3 3.8 .9 <1% Chrysotile

T04246 138 Black/Brown Shingle

( Type 1)

0.321 35.2 33.6 31.2 None

Detected

T04247 138 Black/Brown Shingle

( Type 2)

0.461 25.2 34.3 40.5 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)