Attachment D - Limited Asbestos Renovation Survey Report (Roof).pdf

3 Neptune Road, Suite A18E

Poughkeepsie, New York 12601

845.462.1466 (phone) www.paradigmenv.com

Limited Asbestos Renovation Survey Report prepared for:

Ulster County DPW 313 Shamrock Lane

Kingston, New York 12401 performed by:

Paradigm Environmental, LLC.

3 Neptune Road – Suite A-18E performed at:

The Trudy Center – Roof 50 Center Street

Ellenville, New York 12428

Date Performed: Wednesday, March 18th, 2026

Paradigm Job #26.8176P http://www.paradigmenv.com/

Section #1: Project Information:

Project Description:

Limited Asbestos Renovation Survey The Trudy Center – Roof 50 Center Street Ellenville, New York 12428

Client:

Ulster County DPW 313 Shamrock Lane Kingston, New York 12401 Mr. David Gruskiewicz

845.340.3141 (phone) dgru@co.ulster.ny.us

Survey Performed by:

3 Neptune Road – Suite A-18E Poughkeepsie, New York 12601

845.462.1466 (phone) jkunicki@paradigmenvllc.com NYSDOL Asbestos Handling License 130569

Bulk Sampling Performed by:

Robert See – NYSDOL Asbestos Certificate 26.6Z9U9.SHAB

Dates Performed:

Wednesday, March 18th, 2026

Bulk Sample Analysis Performed by:

Paradigm Environmental Services, Inc.

179 Lake Avenue Rochester, New York 14608

NYSDOH ELAP #10958

mailto:dgru@co.ulster.ny.us mailto:jkunicki@paradigmenvllc.com

Section #2: Introduction:

Paradigm Environmental, LLC. (PARADIGM) was retained by Ulster County DPW to perform a Limited Asbestos Renovation Survey for presumed asbestos-containing material (PACM) and suspect miscellaneous asbestos-containing material (ACM) at the Trudy Center – Roof located at 50 Center Street, Ellenville, New York. The survey was limited to accessible areas within the defined renovation scope.

Prior to any building demolition work, the building owner is required to perform an asbestos survey completed by a licensed asbestos contractor using inspectors certified in compliance with NYSDOL ICR-56, to determine whether or not the building or structure, or portion(s) thereof to be demolished, renovated, remodeled, or have repair work, contains ACM (asbestos-containing material), PACM (presumed asbestos-containing material) or asbestos material.

The asbestos survey shall include a thorough inspection for and identification of all PACM, suspect miscellaneous ACM, or asbestos material throughout the building/structure or portion thereof to be demolished, renovated, remodeled, or to have repair work. The required inspection shall be performed by a certified asbestos inspector, and, at a minimum, shall include identification of PACM, suspect miscellaneous ACM or asbestos material by all of the following methods:

1. The review of building/structure plans and records, if available, for references to asbestos, ACM, PACM, suspect miscellaneous ACM or asbestos material used in construction renovation or repair; and

2. A visual inspection for PACM and suspect miscellaneous ACM throughout the building/structure or portion thereof to be demolished, renovated, remodeled, or repaired. All PACM and suspect miscellaneous ACM visually assessed shall be treated and handled as ACM and shall be assumed to be ACM, unless bulk sampling is conducted as per standard EPA and OSHA accepted methods, including multi-layered systems sampling protocols; the subsequent analyses are performed by a laboratory that meets the requirements of NYSDOL ICR-56; and the analyses satisfies both ELAP and federal requirements, including multi-layered sample analyses, to document non-asbestos containing material.

Section #3: Asbestos Overview:

Asbestos is a commercial name for several naturally occurring, fibrous, inorganic minerals. Asbestos has been commonly used in building materials since the early 1900’s, due to its characteristics of high tensile strength, heat and chemical resistance and excellent frictional properties. Asbestos consumption in the United States peaked in 1972 at about 800,000 tons per year.

Among the most common uses remaining in buildings today are vinyl asbestos floor tiles, vinyl asbestos sheet flooring, patching compounds, textured paints, ceilings, Sheet rock, stove and furnace insulation, pipe insulation, wall and ceiling insulation, roofing, shingles and siding. For ease in cataloging, the Environmental Protection Agency (EPA) has apportioned the aforementioned categories into three forms:

1. Surfacing materials sprayed or troweled on ceilings and walls.

2. Insulation around hot or cold pipes, ducts, boilers and tanks.

3. A variety of other products, such as ceiling and floor tiles, and wallboards.

In general, asbestos containing materials in categories (1) and (2) provides the greatest concern, especially if it is friable.

Friable asbestos material is defined to mean any asbestos or asbestos containing material that can be crumbled, pulverized or reduced to powder when dry, by hand pressure. When asbestos-containing material is friable, it slowly releases microscopic particles into the air.

Section #4: Field Procedures:

The inspection was conducted in accordance with EPA Document 560/585-024, June 1985 “Guidance for Controlling Asbestos Containing Materials in Buildings.”

1. Upon initiation of the inspection, suspect building materials are first grouped into various homogeneous materials such as boiler insulation, 12”x12” textured ceiling tile, 9”x9” gray floor tile, pipe joint cement, etc. This is performed during a walk-through of the building.

2. After determining what suspect materials are present in the building, the inspectors then determine the approximate number of samples for each material.

3. The inspectors then systematically inspect the building, attempting to enter all rooms and/or spaces. If inspection of the entire building is not requested by the client the inspectors attempt to enter only those areas which the client desires inspected.

4. If a suspended ceiling exists in an area, inspectors try to gain full visibility of the area above the suspend ceiling. This is difficult to obtain, in most cases, due to ductwork and structural materials commonly found above the suspended ceiling.

5. If the space above the suspended ceiling is not accessible, (e.g. plasterboard ceiling with no access panels), the inspectors may assume that ACBM is located above the ceiling.

6. If a suspended ceiling is comprised of interlock ceiling tiles (A.K.A. “tongue and groove”), inspection above these areas may require damaging one or more ceiling tiles. The client will be notified of this fact for permission to enter this space. PARADIGM will not be held responsible for replacement of such tile.

7. Inspectors may or may not sample all types of floor tile in the building. Unless otherwise requested, only predominant floor tile types will be sampled. This material, unless severely damaged by water or other means, is not considered friable. Carpeted areas should be assumed to have asbestos containing floor tile underneath the carpeting. Representative sampling will be performed in order to preserve the integrity of the carpeting.

8. Roofing materials within the project scope were evaluated and representative bulk samples were collected from multiple roofing system layers, including but not limited to shingles, underlayments, membranes, sealants, and insulation materials. Sampling was performed in a manner intended to minimize disturbance while maintaining the integrity of the roofing system.

9. After the completion of each inspection day, the inspectors fill out a chain of custody form for the samples that were collected. The samples are turned over to the laboratory for logging in and subsequent analysis. The investigators organize the paper work that was generated that day, and file it in the appropriate file for subsequent report generation.

Section #5: Laboratory Procedures:

Bulk samples were analyzed by a NYSDOH ELAP-certified laboratory using Polarized Light Microscopy (PLM) in accordance with ELAP Method 198.1. Where required for non-friable organically bound (NOB) materials, additional analysis was performed using Transmission Electron Microscopy (TEM) in accordance with ELAP Methods 198.4 and 198.6.

In accordance with ELAP requirements, PLM alone may not be sufficient to reliably detect asbestos in certain non-friable materials. Where applicable, TEM analysis was utilized to confirm non-asbestos determinations.

Section #6: Assessment Classifications:

Asbestos containing materials discovered during the course of the limited asbestos survey were examined to determine their condition. It is important to understand the definition of the terms routinely used in this report to describe the asbestos containing material’s condition and associated hazard of airborne asbestos. The following classifications will be used in this report:

Significantly Damaged:

Asbestos-containing material in poor condition is damaged or has deteriorated. This damage may be due to time, physical contact or improper installation. Additionally, water leaks, erosion from forced air sources, and excessive vibrations can cause damage. Material in poor condition would be expected to release airborne fibers due to simple building motion and air currents. These materials present an immediate hazard due to airborne asbestos fibers and should be properly removed.

Damaged:

Asbestos-containing material in fair condition is generally complete but shows signs of damage or deterioration. As such, it would be expected to release airborne asbestos when disturbed. In this case, there is the potential hazard of airborne asbestos and the damaged material should be repaired and made complete.

Good:

Asbestos-containing material in good condition is whole and complete and typical of new insulation. As such, it should not be expected to release airborne asbestos unless severely damaged. In this case, there is no immediate hazard of airborne asbestos and no corrective action is necessary.

Section #7: Summary of Findings:

PARADIGM’s findings are based on visual observations of accessible areas within the defined renovation scope and on laboratory analysis of representative bulk samples collected during the survey. This report reflects site conditions as observed on the date of inspection and is limited to the scope of work requested.

Section 7.1: Asbestos Containing Materials:

No asbestos-containing materials (ACM) were identified within the areas surveyed as part of this limited asbestos renovation survey.

Table 1: Asbestos-Containing Materials

Material Classification

Sample +

LAB ID

Number

Homogenous Material Description/Location

Analysis Type

Assessment Classification

Approximate Quantity

No asbestos-containing materials were identified within the surveyed areas

Section 7.2: Materials Sampled and Found to Be Non-Asbestos-Containing:

Suspect materials within the renovation scope were sampled and analyzed by a NYSDOH ELAP-certified laboratory. Based on laboratory analytical results, asbestos was not detected in concentrations exceeding one percent (1%) in any of the materials sampled.

Certain non-friable materials were analyzed in accordance with ELAP protocols for non-friable organically bound (NOB) materials. Where applicable, initial PLM results were supplemented with TEM analysis to confirm non-asbestos determinations. Laboratory results indicated either no asbestos detected or trace residual material below regulatory thresholds.

Materials determined to be non-asbestos-containing are summarized in Table 2.

Table 2: Non-Asbestos-Containing Materials

Material Classification

Sample +

LAB ID

Number

Homogenous Material Description/Location

Analysis Type

Assessment Classification

Approximate Quantity

Non-ACM 1 – 15967 2 – 15968

Brown Asphalt Roof Shingles on Pitch Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 3 – 15969 4 – 15970

Black Felt/Underlayment under Brown Asphalt Roof Shingles on Pitch Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 5 – 15971 6 – 15972

Black Tar at Transition from Pitch Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 7 – 15973 8 – 15974

Black Membrane on Flat Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 9 – 15975

10 – 15976 Black Felt/Underlayment – 2nd Layer on Flat Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 11 – 15977 12 – 15978

Brown Perlite – 3rd Layer on Flat Roof

PLM

(198.1)

Not Applicable

Not Applicable

Non-ACM 13 – 15979 14 – 15980

Black Felt/Underlayment – Bottom Layer on Flat Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 15 – 15981 16 – 15982

Black Sealant on Membrane Seams on Flat Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Non-ACM 17 – 15983 18 – 15984

Black Caulk on Pitched Roof Termination Bar

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Table 2: Non-Asbestos-Containing Materials

Material Classification

Sample +

LAB ID

Number

Homogenous Material Description/Location

Analysis Type

Assessment Classification

Approximate Quantity

Non-ACM 19 – 15985 20 – 15986

Black Water & Ice Shield on Pitch Roof

PLM/TEM

(198.6 &

198.4)

Not Applicable

Not Applicable

Field & Analysis Notes:

1. No asbestos-containing materials (ACM) were identified within the surveyed areas based on laboratory analysis of collected bulk samples. Analytical results are material-specific and apply only to the samples tested. All quantities provided are approximate and should be field verified prior to disturbance.

2. Although reasonable efforts were made to identify and characterize accessible suspect materials within the limited renovation area, additional suspect materials may be present in concealed or inaccessible locations, including but not limited to beneath finish layers, above ceilings, within wall cavities, or behind structural components. If suspect materials not previously identified or characterized are encountered during renovation activities, such materials shall be assumed to be ACM until appropriately sampled and analyzed or otherwise addressed in accordance with NYSDOL ICR-56.

3. Variations between field descriptions and laboratory descriptions may occur due to separation and independent analysis of material layers in accordance with ELAP requirements. Laboratory results govern final material classification.

Section #8: Definitions:

The following terms are used throughout this report. These definitions were derived from NYSDOL

ICR 56-2.

Asbestos. Any naturally occurring hydrated mineral silicate separable into commercially usable fibers, including Chrysotile (serpentine), Amosite (cumingtonite-grunerite), Crocidolite (riebeckite), Tremolite, Anthophyllite and Actinolite.

Asbestos Containing Material (ACM). Any material containing greater than one percent (1%) of asbestos, also known as Asbestos Material.

Asbestos Survey. A thorough inspection for and identification of all PACM, suspect ACM, or asbestos material throughout the building/structure or portion thereof to be demolished, renovated, remodeled, or repaired. (See Subpart 56-5)

Bulk Sampling. Accepted methods for collecting samples of suspect materials for appropriate analyses by NYS ELAP approved laboratories, to determine asbestos content.

Category I Non-Friable ACM. NESHAP classification - Asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products, containing more than one percent (1%) asbestos, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Category II Non-Friable ACM. NESHAP classification - Any material, excluding Category I Non-Friable ACM, containing more than one percent (1%) asbestos, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure

Demolition. The wrecking or removal of any load-supporting structural member of a building or structure.

Friable. Any material that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure, or is capable of being released into the air by hand pressure.

Non-Asbestos Material. Any material documented to contain one percent (1%) or less of asbestos.

Non-Friable. Any material that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure, and is not capable of being released into the air by hand pressure.

Non-Friable Organically Bound (NOB) Asbestos Material. Non-friable asbestos materials embedded in flexible-to-rigid asphalt or vinyl matrices, including but not limited to flooring materials, adhesives, mastics, asphalt shingles, roofing materials and caulks.

Presumed Asbestos Containing Material (PACM). All Thermal System Insulations and Surfacing Materials found in buildings constructed no later than 1980. PACM is considered to be ACM unless proven otherwise by appropriate bulk sampling and laboratory analyses.

Regulated Asbestos-Containing Material (RACM). Friable ACM or PACM, Category I Non-friable ACM that has become friable or has been or will be subjected to sanding, grinding, cutting or abrading, or Category II Non-friable 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.

Remodel. For purposes of this code, remodel shall mean the same as renovation.

Removal. Abatement, consisting of operations where ACM, PACM or asbestos material is removed or stripped from structures or substrates. This includes demolition operations.

Renovation. The altering of an existing building/structure, or a portion of building/structure components or systems, including the stripping, removal or abatement of ACM from a building or structure. Operations in which load supporting structural members are wrecked or taken out are demolitions.

Repair (Asbestos). Abatement, consisting of corrective action for a Minor Asbestos Project using required work practices to control fiber release from damaged ACM, PACM or asbestos material.

Repair. The replacement, overhaul, rebuilding, reconstructing or reconditioning of any part of a building/structure component or system with like or similar material or parts, due to damage or excessive wear.

Suspect Miscellaneous ACM. Any suspect asbestos-containing material that is not PACM, such as floor tiles, ceiling tiles, mastics/adhesives, sealants, roofing materials, cementitious materials, etc. A listing of typical suspect miscellaneous ACM can be found in NYSDOL ICR 56-5. All suspect miscellaneous ACM must be assumed to be ACM, unless proven otherwise by appropriate bulk sampling and laboratory analyses.

Surfacing Material. Material that is sprayed-on, troweled-on, or otherwise applied to surfaces (such as acoustical or finish plaster on ceilings and walls, and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes).

Thermal System Insulation. Insulation material applied to pipes, fittings, boilers, breeching, tanks, ducts or other structural components to prevent heat gain or loss.

Section #9: Final Notes:

Based on the results of this limited asbestos renovation survey, no ACM was identified within the surveyed areas. As such, no asbestos abatement is required for the materials identified in this report, provided no additional suspect materials are encountered during renovation activities.

If the building/structure asbestos survey finds that the portion of the building/structure to be demolished, renovated, remodeled, or have repair work contains ACM, PACM, suspect miscellaneous ACM assumed to be ACM, or asbestos material, the owner or the owner’s agent shall conduct, or cause to have conducted, asbestos removal performed by a licensed asbestos abatement contractor in conformance with all standards set forth in ICR-56.

All ACM, PACM, suspect miscellaneous ACM assumed to be ACM, or asbestos material impacted by the demolition, renovation, remodeling or repair project shall be removed as per ICR-56, prior to access or disturbance by other uncertified trades or personnel. No demolition, renovation, remodeling or repair work shall be commenced by any owner or the owner’s agent prior to the completion of the asbestos abatement in accordance with the notification requirements of ICR-56.

For multi-phased work, the access restriction for uncertified trades or personnel applies to each intermediate portion of the entire project.

Upon completion of the intermediate portion of the asbestos project, other trades or personnel may access that portion of the work site.

Unidentified and Unassessed Asbestos:

When any construction activity, such as demolition, remodeling, renovation or repair work, reveals PACM or suspect miscellaneous ACM that has not been identified by the asbestos survey, or has not been identified by other inspections as per current OSHA or EPA requirements, all activities shall cease in the area where the PACM or suspect miscellaneous ACM is found and the Asbestos Control Bureau shall be notified by telephone followed with a written notice in accordance with the notification requirements of ICR-56. Unassessed PACM or suspect miscellaneous ACM shall be treated and handled as ACM and assumed to be ACM, unless proven otherwise by standard EPA and OSHA accepted methods, including multilayered systems sampling protocols; subsequent analyses performed by a laboratory that meets the requirements ICR-56; and the analyses satisfies both NYS ELAP and federal requirements, including multilayered sample analyses, to document non-asbestos containing material.

The report represents the opinion of the reporting inspector at the time of the limited asbestos survey and accurately reflects Federal, State, and Local guidelines.

Due to know dangers and health effects of human exposure to airborne asbestos fibers, there exist both Federal and State regulations and recommendations which must be followed in the asbestos removal process.

Section #10: Disclaimer:

This report is for your exclusive use and is only to be used as a guide in determining the presence and condition of Asbestos-Containing Materials in the subject premises at the time of the inspection.

All quantities of asbestos containing material are approximations. All quantities of asbestos containing materials should be field verified by prospective asbestos abatement contractors prior to providing asbestos abatement costs for the aforementioned materials.

This report is based solely upon a visual inspection and sampling of the premises where accessible at the time inspection was performed and makes no determinations with respect to portions of the premises that were not tested.

PARADIGM assumes no liability with respect to your compliance with local, state, or federal statutes, regulations or rules. This report sets forth relevant excerpts from manuals published by the EPA; however, PARADIGM assumes no responsibility for the credibility and completeness of the said excerpted material or future modifications of the same.

PARADIGM assumes no liability for the use of this report by any other person or entity than the customer for whom it has been prepared. Any and all liability on the part of PARADIGM shall be limited solely to the cost of this survey report. PARADIGM shall have no liability for any other damages, whether consequential, compensatory, punitive, or special, arising out of, incidental to, or as a result of this report.

If you have any additional questions concerning this report, please do not hesitate to call me at

845.462.1466 or email me at jkunicki@paradigmenvllc.com. Thank you.

Sincerely, Jack Kunicki mailto:jkunicki@paradigmenvllc.com

DIVISION OF SAFETY & HEALTH LICENSE AND CERTIFICATE UNIT, STATE OFFICE CAMPUS, BLDG. 12, ALBANY, NY 12226 ASBESTOS HANDLING LICENSE Paradigm Environmental LLC

3 Neptune Road, Suite A18E, Poughkeepsie, NY, 12601

This license has been issued in accordance with applicable provisions of Article 30 of the Labor Law of New York State and of the New York State Codes, Rules and Regulations (12 NYCRR Part 56). It is subject to suspension or revocation for a (1) serious violation of state, federal or local laws with regard to the conduct of an asbestos project, or (2) demonstrated lack of responsibility in the conduct of any job involving asbestos or asbestos material.

This license is valid only for the contractor named above and this license or a photocopy must be prominently displayed at the asbestos project worksite. This license verifies that all persons employed by the licensee on an asbestos project in New York State have been issued an Asbestos Certificate, appropriate for the type of work they perform, by the New York State Department of Labor.

Amy Phillips, Director For the Commissioner of Labor

SH 432 (12/21)

License Number:

License Class:

Date of Issue:

Expiration Date:

Duly Authorized Representative:

130569

RESTRICTED

03/28/2025 04/30/2026 Jack Kunicki