Attachment E-1 Asbestos Survey and Lead-Based Paint Inspection.pdf
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- Solicitation number
- S-DASOBO-00015523
- Issued by
- Douglas County, Oregon
About this file
Summary: Asbestos Survey and Lead-Based Paint Inspection Report
This document is a pre-renovation asbestos survey and lead-based paint inspection report prepared by G2 Consultants for the Oregon Employment Department's Roseburg Facility located at 846 Pine Street, Roseburg, Oregon. The inspection was conducted on May 2, 2024, and covers the approximately 10,340 square-foot, two-story commercial office building constructed pre-1978. The survey identified multiple asbestos-containing materials (ACM) throughout the facility, including drywall joint compound (12,400 sq. ft.), sheet vinyl flooring (215 sq. ft.), floor tile (285 sq. ft.), pipe fitting insulation, window putty around 18 exterior windows, and black mastic under floor tile. Asbestos was found in quantities ranging from 2% to 10% chrysotile across various materials. The inspection also identified lead-based paint (LBP) at concentrations equal to or above 1.0 mg/cm² on interior wood components including door trim, door jambs, and closet doors, as well as lead present in ceramic tile glazing and enamel fixtures such as urinals, toilets, sinks, and baseboards. All identified LBP was found to be in intact condition at the time of inspection.
The report establishes that all identified ACM materials must be removed by a licensed asbestos abatement contractor prior to disturbance during renovation activities, in compliance with Oregon Administrative Rules and EPA/OSHA requirements. The inspection was performed by certified inspectors Andrew Lutz (Asbestos Building Inspector IRO-24-4144B and Lead-Based Paint Risk Assessor) and Sarah Hueni (Asbestos Building Inspector IN-23-0833C), utilizing industry-standard methodologies including polarized light microscopy for asbestos analysis and X-ray fluorescence (XRF) for lead-based paint detection. The report recommends lead-safe work practices for any surfaces impacted during renovation, including containment of work areas, wet sanding and scraping, and proper disposal of paint chips and debris. Laboratory analysis was conducted by SEEML Labs, which is NVLAP accredited for bulk asbestos analysis.
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Asbestos Survey & Lead-Based Paint Inspection Purpose: Pre-Renovation
Client:
Oregon Employment Department 875 Union Street NE Salem, Oregon 97301
Project:
OED Roseburg Facility 846 Pine Street Roseburg, Oregon 97470
G2 Project #: G24-452
June 28, 2024
Prepared By:
G2 Consultants
17750 SW Upper Boones Ferry Road, Suite #150
Portland, Oregon 97224
888-998-4224 www.g2ci.com
CCB #223539
http://www.g2ci.com
Asbestos Survey & Lead-Based Paint Inspection G2 Consultants Project #: G24-452
Purpose of Inspection: Pre-Renovation
Scope of Inspection: Asbestos Survey & Lead-Based Paint Inspection
Project Description: OED Roseburg Facility
Project Address: 846 Pine Street
Roseburg, Oregon 97301
Owner or Facility Operator:
Oregon Employment Dapartment
875 Union Street NE
Salem, Oregon 97301
Owner or Facility Operator Phone #:
877-345-3484
Technical Certifications
Consultant Discipline Certification # Regulatory Agency
Phone Number
Andrew Lutz Asbestos Building Inspector
IRO-24-4144B EPA 503-798-8868
Lead-Based Paint Risk Assessor
2526-Indv-R
9152526-RA
OHA
CCB
Sarah Hueni Asbestos Building
Inspector
IN-23-0833C EPA 971-864-2121
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G2 Consultants | www.g2ci.com | 888-998-4224
Asbestos Survey and Lead-Based Paint Inspection
Roseburg OED Facility - 846 Pine Street, Roseburg, OR
Table of Contents
• Executive Summary
• Description of Structure(s)
• Scope of Inspection
• Inspection Findings
• Recommended Response Actions
• Methodology
• Limitations
Appendices
Appendix A: Laboratory Analysis Results & Chain of Custody
Appendix B: Asbestos Material & Sample Location Drawings
Appendix C: XRF Readings Table
Appendix D: Performance Characteristic Sheet (PCS)
Appendix E: Certifications & Accreditation
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G2 Consultants (G2) was retained by Oregon Employment Department (OED) to conduct a limited building inspection for asbestos-containing materials (ACM) and lead-based paint (LBP). The survey was conducted at the OED Roseburg Facility, located at 846 Pine Street, in Roseburg, Oregon. The scope of the inspection was limited to readily accessible interior, exterior and roofing materials in anticipation of the upcoming renovation activities, as specified by OED. Authorization was provided by Ron Adkins, Sr. Construction Project Manager with OED.
Date(s) of Inspection: May 2, 2024
Purpose of Inspection: Pre-Renovation
Scope of Inspection: Limited to all readily accessible interior, exterior and roof suspect asbestos and lead-containing materials at the facility.
Asbestos
Results of the inspection have determined that asbestos is present in the following suspect materials presumed or sampled as part of this limited survey:
NOTE: Friability listed is based on conditions at the time of G2’s survey. Materials may become friable if disturbed.
* The material locations and quantities provided, represents the areas within the scope of work only. It does not represent the potential location/quantity of materials throughout the site.
Details of the inspection, descriptions and locations of materials, quantities, condition and friability can be found in the following sections of this report.
Executive Summary
Asbestos-Containing Materials Identified or Presumed - Overview
Material Description Material Location* Approx.
Quantity*
Condition Friable Y/N
Drywall Joint Compound First Floor - Throughout 12,400 sq. ft. Fair N
Sheet Vinyl, Beige w/Orange, White & Gray Specks
Second Floor - Women’s Restroom 201 & Men’s Restroom 202
215 sq. ft. Good N
Floor Tile, 12” x 12” Light Beige Specked
First Floor - Storage Room 112 285 sq. ft. Good N
Pipe Fitting Insulation on Fiberglass Insulated Pipe Runs
First Floor - Custodial Closet 107 1 Fitting Good Y
First & Second Floors - Within Walls, Ceilings, Attics & Crawlspaces Throughout
Unable to be Quantified
Good-Poor Y
Putty around Metal Windows First Floor - Exterior Throughout 18 windows Fair Y
Black Mastic under Floor Tile First Floor - Custodial Closet 107 40 sq. ft. Good N
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Lead-Based Paint
Results of the inspection have determined that LBP is present on the interior of the building that is equal to or above the concentration of 1.0 milligram per centimeter squared (mg/cm2). Lead above the 1.0 mg/cm2 threshold was also identified in the glazing of various ceramic tile and enamel components within the building.
Additional details of the inspection are located in the following sections of this report and in the X-Ray Fluorescence (XRF) Readings Table found in Appendix C.
Description of Structure(s)
Type of facility: Commercial Office
Past uses: Commercial Office
Age of construction: Pre-1978
Approximate square footage: 10,340 sq. ft.
Number of floors: 2
Outbuildings included in inspection: None
Inaccessible rooms/areas: None
Aerial Photo of Subject Property Location of Subject Property
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G2 was contracted by OED to perform a limited building inspection for ACM and LBP. The survey was conducted at the OED Roseburg Facility, located at 846 Pine Street, in Roseburg, Oregon.
The scope of the inspection was limited to readily accessible interior, exterior and roofing materials in anticipation of the upcoming renovation activities, as specified by Ron Adkins with OED. The sampling was conducted to represent all suspect materials within the scope of work.
The scope of services was to perform a visual and tactile inspection, and identify the presence, quantity and location of the accessible ACM, within the area(s) of the scope of work. All identified accessible suspect materials were sampled. The building was occupied at the time of the survey, therefore, destructive sampling techniques were not utilized to gain access to potentially hidden materials such as within wall cavities or other interstitial spaces.
The LBP inspection was performed in accordance with the U.S. Environmental Protection Agency Renovation, Repair and Painting Rule (EPA RRP) because it was conducted by a licensed LBP inspector using documented methodologies, such as those in Housing and Urban Development (HUD) Guidelines Chapter 7 (2012 Edition), and the EPA RRP guidelines.
Readings of the lead content of painted surfaces throughout the areas within the scope of work were collected using an X-Ray Fluorescence device. The readings were taken from the predominant accessible interior and exterior paint films including surfaces coated with shellac, varnish, stain, etc., in order to provide a general indication of the distribution of lead. All Federal and State regulations governing the inspection of LBP were followed.
Results of the inspection have determined that asbestos is present in the following suspect materials sampled as part of this limited survey:
Scope of Inspection
Inspection Findings
Asbestos-Containing Materials Identified
HM
No.†
Material Description Material Location* Approx.
Quantity*
No. of Samples
Asb. Type &
Condition Friable Y/N
3 Drywall Joint Compound
First Floor - Throughout 12,400 sq.
ft.
5 Drywall - ND
Joint Compound - Chrysotile 2%
Fair N
6 Drywall Joint Compound #2 (Mechanical Room)
First Floor - Mechanical Room 103
21 Sheet Vinyl, Beige w/ Orange, White & Gray Specks
Second Floor - Women’s Restroom 201 & Men’s Restroom 202
215 sq. ft. 2 Chrysotile 10% Good N
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NOTE: Friability listed is based on conditions at the time of G2’s survey. Materials may become friable if disturbed.
† - Homogeneous material number
* The material locations and quantities provided, represents the areas within the scope of work only. It does not represent the potential location/quantity of materials throughout the site.
Results of the inspection have determined that asbestos is not present in the following materials sampled:
26 Floor Tile, 12” x 12” Light Beige Specked
First Floor - Storage Room
285 sq. ft. 2 Chrysotile 3% Good N
29 Pipe Fitting Insulation on Fiberglass Insulated Pipe Runs
First Floor - Custodial Closet
1 Fitting 3 Chrysotile 6-7%
Good Y
First & Second Floors - Within Walls, Ceilings, Attics & Crawlspaces Throughout
Unable to be Quantified
Good- Poor
Y
42 Putty around Metal Windows
First Floor - Exterior Throughout windows
2 Chrysotile 2% Fair Y
44 Black Mastic under Floor Tile
First Floor - Custodial Closet
40 sq. ft. 2 Chrysotile 3% Good N
Asbestos-Containing Materials Identified
HM
No.†
Material Description Material Location* Approx.
Quantity*
No. of Samples
Asb. Type &
Condition Friable Y/N
Non Asbestos-Containing Materials Identified
HM
No.†
Material Description Material Location* No. of Samples
1 Glue, Tan, under Carpet Tiles First & Second Floors - Throughout 2
2 Ceiling Tile, 2’ x 4’ Gouged w/Pinholes First & Second Floors - Throughout 2
4 Cove Base, 4” Off White First Floor - Meeting Room 103 2
5 Adhesive, Tan, behind Various Cove Base First & Second Floors - Throughout 2
7 Fiberglass Pipe Insulation First & Second Floors - Throughout 3
8 Acoustic Wall Tile, 12” x 12” Fissure First Floor - Open Office 101 2
9 Adhesive, Brown, behind Wall Tile First Floor - Open Office 101 2
10 Mortar, Gray, under Ceramic Floor Tile First Floor - Women’s Restroom 117 & Men’s Restroom 118
11 Grout, Gray, between Ceramic Floor Tile First Floor - Women’s Restroom 117 & Men’s Restroom 118
12 Wall & Ceiling Texture, Troweled On First Floor - Storage Rooms 110 & 116 3
13 Floor Tile, 12” x 12” Beige Streaked First Floor - Custodial Closet 117 2
14 Glue, Tan, under Various 12” x 12” Floor Tile First Floor - Custodial Closet 117 & Storage Room 112
15 Stair Tread, Brown Non-Slip First & Second Floors - Stairways 111 & 115 2
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† - Homogeneous material number
* The material locations provided, represents the areas within the scope of work only. It does not represent the potential locations/quantities of materials throughout the site.
Details of the samples collected, including locations of individual samples can be found in Appendix A: Laboratory Analysis Results & Chain of Custody.
16 Glue, Tan, under Stair Tread First Floor - Storage Rooms 110 & 116 2
17 Sheet Vinyl, Gray Pebble Pattern Second Floor - Staff Break Room 208 2
18 Glue, Tan, under Sheet Vinyl Second Floor - Staff Break Room 208 2
19 Adhesive, Tan, behind Formica Backsplash Second Floor - Staff Break Room 208 2
20 Drywall & Joint Compound #3 (2nd Floor) Second Floor - Throughout 3
22 Adhesive, White, behind Faux Wall Tile Paneling First Floor - Women’s Restroom 117 2
23 Grout, Gray, between Ceramic Wall Tile First Floor - Men’s Restroom 106 2
24 Mortar, Gray, behind Ceramic Wall Tile First Floor - Men’s Restroom 106 2
25 Ceiling Tile, 2' x 4' Replacement Fissure w/Pinholes First & Second Floors - Throughout 2
27 Cove Base, 4" Brown First Floor - Storage Room 112 2
28 Adhesive, Brown, behind Various Cove Base First & Second Floors - Throughout 2
30 Membrane Roof Core Roof - Lower South Roof 2
31 Duct Seam Compound, Gray Roof - Lower South Roof 2
32 Sealant, Gray, around Exhaust Vents Roof - Lower South Roof 2
33 Putty, White, around Windows Exterior - Second Floor 2
34 Sealant, Gray, on Flashing Roof - Lower South Roof 2
35 Texture on Concrete Exterior - Second Floor 3
36 Built-Up Roof Core Roof - Upper North Roof 2
37 Silver Roofing around Flashing & HVAC Ducts Roof - Upper North Roof 2
38 Roof Patch & Repair, Gray Roof - Upper North Roof 2
39 Mortar, around Decorative Rock Siding Exterior - First Floor 2
40 Vapor Barrier, Black, behind Decorative Rock Siding Exterior - First Floor 2
41 Window Glazing, White Exterior - First Floor 2
43 CMU Mortar, Gray Exterior - First Floor 2
Non Asbestos-Containing Materials Identified
HM
No.†
Material Description Material Location* No. of Samples
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The types of components listed in the following table indicate the presence of lead at or above the EPA RRP and HUD Guidelines action level. The EPA and HUD definition of “positive” LBP is lead equal to or greater than 1.0 mg/cm2. Additional details including reading number, floor, substrate, side, color and lead content details are located in the XRF Readings Table found in Appendix C.
Readings in the table noted as LBP, are paint films with lead concentrations at or above 1.0 mg/cm2. Readings in the table noted as Positive, are non-painted surfaces, such as ceramic tile, with lead concentrations at or above 1.0 mg/cm2
Per HUD guidelines, for each era of construction to be inspected, all testing combinations in each room equivalent were identified and tested by XRF. A testing combination is characterized by the room equivalent, the component type, and the substrate. A room equivalent is an identifiable part of a building (room, exterior, foyer, etc.). Painted surfaces include any surface coated with paint, shellac, varnish, stain, paint covered by wallpaper, or any other coating.
According to HUD Guidelines Chapter 7, if one testing combination (i.e. window, door) is positive for lead in an interior or exterior room equivalent, then all other similar testing combinations in those areas are also assumed to be positive for lead.
The XRF testing was conducted using an XRF lead paint analyzer. A surface-by-surface visual assessment of the painted and/or finished surfaces was conducted to determine which lead-coated surfaces/components are deteriorated at or above de minimis levels, specifically, the EPA’s minor repair and maintenance activities thresholds (40 CFR § 745.83). The EPA de minimis thresholds apply to work that disrupts: (a) 6 square feet or less of painted surface per room for interior activities; or (b) 20 square feet or less of painted surface for exterior activities; provided that none of the work practices prohibited or restricted by 40 CFR § 745.85(a)(3) were used and where the work does not involve window replacement or demolition of painted surface areas.
EPA regulations define deteriorated paint as, “any interior or exterior paint or other coating that is peeling, chipping, chalking or cracking, or any paint or coating located on an interior or exterior surface or fixture that is otherwise damaged or separated from the substrate" (40 CFR § 745.63).
Testing Combinations with Lead Equal to or Greater than 1.0 mg/cm2
Site/Address Structure Component Room Equivalent Substrate Condition Result
846 Pine Street, Roseburg, Oregon
Main Building Wall Tile Interior Ceramic Intact Positive
Main Building Urinal Interior Enamel Intact Positive
Main Building Toilet Interior Enamel Intact Positive
Main Building Sink Interior Enamel Intact Positive
Main Building Baseboard Interior Ceramic Intact Positive
Main Building Door Trim Interior Wood Intact LBP
Main Building Door Jamb Interior Wood Intact LBP
Main Building Closet Door Trim Interior Wood Intact LBP
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Results of the survey have determined that multiple interior and exterior materials are ACMs.
All materials were observed to be in good to fair condition at the time of the survey.
If any untested suspect materials are encountered during renovation activities, they should be assumed to be ACM and not disturbed, unless sampling and analysis of the materials proves otherwise.
Friability is determined by whether a material can be crumbled, pulverized or reduced to a powder by pressure of an ordinary human hand. The friability of materials listed in this report are based on the present state and actual conditions of the materials observed at the time of G2’s survey.
Materials listed as non-friable can become friable through impact or damage.
All identified and presumed ACM must be removed by a licensed asbestos abatement contractor, or other certified individual, prior to impact if they are to be disturbed during renovation activities. ACM remaining in the building should be managed in good condition, under an Operations and Maintenance Plan, and checked regularly for damage.
OR-OSHA requires a variety of actions when ACM is present in a commercial structure. These include labelling, warning signs, hazard communication and periodic inspections. All of the requirements of a building owner/operator with regard to asbestos can be found in Oregon Administrative Rules (OAR) 437, Division 2.
Any ACM likely to be disturbed during renovation or demolition activities, other than by incidental contact with no generation of debris related to other construction activities, should be abated by a licensed asbestos abatement contractor. Any activities conducted where the primary object of the activity is the removal of ACM must be conducted by a licensed asbestos abatement contractor or other properly trained individuals.
The National Emissions Standards for Hazardous Air Pollutants (NESHAPs) requires that all Regulated Asbestos-Containing Materials (RACMs) be removed from a building prior to demolition.
Recommended Response Actions
Asbestos-Containing Materials (ACM)
Any building material which contains asbestos in an amount greater than 1% is considered an ACM by the United States Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA), and by the State of Oregon Department of Environmental Quality (DEQ) and the Oregon Occupational Safety and Health Division (OR-OSHA).
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No materials were identified during this survey that contained 1% or less asbestos.
Many of the engineering controls and work practices required by the EPA and OSHA are applicable only to materials that contain greater than 1% asbestos. However, OSHA has established work practice requirements and prohibitions that apply when asbestos in any quantity is present, and/or whenever worker exposure exceeds the PEL regardless of the amount of asbestos in the materials involved. Applicable requirements for materials that contain 1% or less asbestos can be found in the OSHA Asbestos Construction Standard 29 CFR 1926.1101.
G2 has determined that LBP is present on the interior of the building that is equal to or above the concentration of 1.0 mg/cm2. The LBP films were observed to be in “intact” condition at the time of the inspection. Lead above the 1.0 mg/cm2 threshold was also identified in the glazing of various ceramic tile and enamel components within the building.
Lead-containing paint (LCP), paint films with lead concentrations greater than zero but less than
1.0 mg/cm2, may be present on other painted surfaces. The presence/absence of LCP cannot be confirmed via XRF analysis.
LBP and LCP films could create lead dust or lead contaminated soil hazards if the paint is turned to dust by abrasion, scraping or sanding. If conditions of intact paint surfaces become destabilized, these conditions will need to be addressed. All paint films in poor condition must be stabilized if the structure is to be demolished. If any construction or modernization work is done on the premises, this report should be given to the contractor(s). The Occupational Safety and Health Administration (OSHA) and Oregon OSHA (OR-OSHA) have requirements for employees working with or around LBP and LCP.
Contractors and other personnel who may impact these materials should be informed of the results of this inspection. LBP is a common cause of lead poisoning in children and represents a threat to the health and welfare of the occupants. Where economically feasible, it is our recommendation that all components that tested positive, and any similar untested components, be considered lead-laden, and lead-safe procedures is incorporated into any overall renovation and maintenance strategy in order to reduce the potential for contamination and/or exposure. Safe methods include:
containing any work area to prevent dispersal of lead dust and chips, wet sanding and scraping at a minimum; collecting all paint chips and debris and, properly disposing of them.
Details of the locations and lead content for all of the readings can be found in Appendix C: XRF Readings Table.
If additional painted surfaces are discovered that were not tested as part of this inspection, or that are expected to be impacted as part of any renovation or demolition work, they should be presumed LBP until tested to show otherwise.
Asbestos-Containing Materials - 1% Asbestos or Less
Any building material which contains asbestos in an amount of 1% or less is considered asbestos-containing by OSHA and OR-OSHA. Although these materials are not considered ACMs, workers must be protected from exposure to asbestos, regardless of the percentage.
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A risk assessment has not been conducted to evaluate potential lead hazards present at the building and surrounding soil as part of this scope of work.
The field work was conducted using industry best practices. Samples of representative accessible suspect materials within the scope of work were collected during the course of the inspection.
Materials were sampled according to homogeneous groupings using the Asbestos Hazard Emergency Response Act (AHERA) sampling guidelines.
Asbestos samples were collected in such a manner as to minimize release of the material into the surroundings. Sample number, material description, sample location and material location were recorded at the time of sampling. Each sample was placed in a sample container labeled with a unique sample number and submitted to a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory, for analysis under chain of custody documentation. Samples were analyzed in accordance with EPA Method 600/R-93-116, using PLM with dispersion staining and using visual area estimation to determine percent asbestos content. This method allows for the identification of the primary types of asbestos used in building materials. The lower limit of detection for this method is one percent. Samples containing one percent or less asbestos by PLM with visual area estimation are reported as “Trace”.
All testing of suspect LBP was conducted utilizing a SciAps X-ray fluorescence LBP analyzer, Model X550Pb (Rh) bearing Serial #01583. The device uses a rhodium X-ray fluorescence tube as opposed to a radioactive source. G2 followed the Performance Characteristics Sheets (PCS) for the specific X-Ray fluorescence instrument used during the LBP evaluation of the property. The XRF PCS is presented in Appendix D. The instrument was calibrated to the manufacturer's specifications and was also periodically verified against the National Institute of Standards and Testing (NIST) Standard Reference Material (SRM) 2579 lead film (1.0 mg/cm2).
The calibration of the instrument is conducted in accordance with the PCS for this instrument.
These instruments are calibrated using a calibration standard block of known lead content. If for any reason the instruments do not maintain a consistent calibration reading within the manufacturer’s standards for performance on the calibration block supplied by the manufacturer, manufacturer’s recommendations are used to bring the instrument into calibration. If the instrument cannot be brought back into calibration, it is taken off the site and sent back to the manufacturer for repair and/or re-calibration.
Wall “A” in each room is the wall where the front entrance door opening is located (or aligned with street). Going clockwise and facing Wall “A,” Wall “B” will always be to your right, Wall “C” directly to the rear and Wall “D” to the left. Doors, windows and closets may be designated as left, center or right depending on their location on the wall. Doors, windows, and closets are designated as left, center or right depending on their location on the wall.
Methodology
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All individuals who performed this XRF testing and visual assessment have EPA and/or state licenses as Lead Inspector/Risk Assessors and have been trained in the use, calibration and maintenance of the XRF, along with the principles of radiation safety, in accordance with the work practices of 40 CFR 745, section 227, for states and Native American tribal groups.
G2 has performed this inspection in accordance with best industry methods and practices of the profession, and consistent with the level of care and skill ordinarily exercised by reputable environmental consultants under similar circumstances and conditions. The observations contained within this assessment are based upon site conditions readily accessible at the time of the site inspection. No other representation, guarantee or warranty, express or implied, is included or intended in this hazardous materials survey report. If any untested suspect materials are encountered during demolition activities, they should be assumed to be ACM and not disturbed, unless sampling and analysis of the materials proves otherwise.
The LBP portion of the inspection was planned, developed, and implemented based on G2’s professional experience in performing LBP inspections. G2 performed an inspection for lead-containing paint of the predominant painted surfaces in order to provide a general indication of the distribution of lead for demolition purposes. G2 utilized state-of-the-art practices and techniques in accordance with regulatory standards while performing this inspection. A copy of personnel and company certifications has been provided in Appendix E. G2’s evaluation of the painted surfaces identified during this inspection is based on conditions observed at the time of the inspection. G2 cannot be responsible for changing conditions that may alter the relative exposure risk for future changes in accepted methodology.
The owner is responsible to convey information regarding identified lead content to inhabitants, contractors, etc. expected to potentially be exposed. G2 recommends that both the contractor and the owner keep the records for three years.
This report consists of a visual survey, and XRF analysis of the readily accessible areas of this building and tested components. The presence or absence of LBP or LBP hazards applies only to the tested or assessed surfaces on the date(s) of the field visit and it should be understood that conditions may change due to deterioration or maintenance. The results and material conditions noted within this report were accurate at the time of the evaluation and in no way reflect the conditions at the property after the date of the evaluation.
As with all environmental investigations, this inspection is limited to the defined scope and does not purport to set forth all hazards, nor indicate that other hazards do not exist.
Respectfully submitted and reviewed by:
Andrew Lutz
Director of Operations
Limitations
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Appendix A:
Laboratory Analysis Results
& Chain of Custody
G2 Consultants
Asbestos Analytical Report By: Polarized Light Microscopy
Client Project Name: Oregon Employment Department The Following report was prepared using this test method(s) contained within this document.
SEEML Reference Number:
G-240506064
This report has been prepared for G2 Consultants the information and data has been checked for thoroughness and accuracy. The results reported apply only to the materials as received. The documents(s) contained herein are confidential and privileged information intended for the exclusive use of the individual or entity named above. This report shall not be reproduced except in full without SEEML’s approval.
Approved By : Andrea Berrios
Thank you for choosing SEEML Labs. We strive to provide superior quality testing, analytical data and customer service. SEEML is accredited through the National Institute of Standards and Technology (NIST) National Voluntary Accreditation Program (NVLAP) for bulk asbestos analysis NVLAP # 201031-0 and licensed by the Texas Department of State Health Services (License Number: 300474). This report must not be used to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the US government.
Date Issued: 05/09/2024
Southeast Environmental Microbiology Laboratories 102 Edinburgh Court Greenville, SC 29607
Phone: (864) 233-3770 Fax: (864) 233-6589
PLM Bulk Asbestos Fiber Analysis:EPA – Appendix E to Subpart E of 40 CFR Part 763; Interim Method for the Determination of Asbestos in Bulk Insulation Samples
PLM 400 Point Count (<0.25%) EPA 600/R-93/116
PLM 1000 Point Count (<0.1%) EPA 600/R-93/116
PLM Carb 435 Level A Reporting Limit (<0.25%)
PLM Carb 435 Level B (Reporting limit <0.1%)
PLM by EPA/600/R-93/116 with Milling Prep 400 Point Count
PLM Vermiculite Initial Screening EPA 600R-93/116
PLM Cincinnati Method 600/R-04/004 (Amphibole Only)
PLM Vermiculite Method SOF-V 198.8 (Step 1 Chrysotile & Prep)
PLM Vermiculite Method SOF-V 198.8 (Step 2 (Amphibole)
Form 16 Rev. 7 05/11/20 Page 1 of 20
Texas Lic: 300474
Lab No.:
Client No.:
288A
G-24-452-1
288B
G-24-452-1
288C
G-24-452-1
288D
G-24-452-1
289A
G-24-452-2
289B
G-24-452-2
289C
G-24-452-2
290A
G-24-452-3
291A
G-24-452-4
Form 8.0 Rev. 8 04/29/20
100% Organic Matrix
(Gray) Cementitious Material/n/a
Roseburg, OR 97470
846 Pine St.
100% Carbon/Quartz
10% Organic Matrix (Blue) Carpet/n/a
100% Organic Matrix
G-240506064SEEML Ref#:
100% Organic Matrix
Description/Location
(Blue) Carpet/n/a
(Brown) Carpet Pad/n/a
(Tan) Mastic/n/a
10% Organic Matrix
% Non-Fibrous Material
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
Project No:
Analyzed by: Linh Nguyen City, State. ZIP:
Project Address:
% Asbestos Type % Fibrous Non-
Asbestos Material Type
Methodology:
None Detected
90% Synthetic
None Detected
None Detected
None Detected
None Detected
90% Synthetic
None Detected
None Detected
None Detected
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
Date Sampled:
Date Received:
G2 Consultants
PLM Asbestos Bulk Sample Summary
05/03/2024
05/06/202417750 SW Upper Boones Ferry Rd Suite 150
NVLAP Lab ID:201031-0
Approved By: Andrea Berrios Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected
(White) Ceiling Tile/n/a
None Detected
5% Fiberglass,80%
Cellulose
10% Perlite,5%
Binder/Filler (White) Ceiling Tile/n/a
10% Perlite,5%
Binder/Filler
None Detected
None Detected
None Detected
None Detected 5% Fiberglass,80%
Cellulose
(Brown) Carpet Pad/n/a
(Tan) Mastic/n/a100% Organic Matrix
Date Revised:
Portland,OR,97224
(888)998-4224/debra@g2ci.com
05/09/2024Date Analyzed:
Date Reported:
Project Name:
05/09/2024
Oregon Employment Department
G24-452
Lab No.:
Client No.:
292A
G-24-452-5
292B
G-24-452-5
292C
G-24-452-5
293A
G-24-452-6
293B
G-24-452-6
294A
G-24-452-7
294B
G-24-452-7
295A
G-24-452-8
295B
G-24-452-8
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
Approved By: Andrea Berrios Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Gray) Covebase/n/a
None Detected 10% Cellulose 90% Gypsum (White) Drywall/n/a
None Detected None Detected 100% Organic Matrix (Gray) Covebase/n/a
None Detected 10% Cellulose 90% Gypsum (White) Drywall/n/a
None Detected None Detected 100% Binder/Filler (White) Joint Compound/n/a
2% Chrysotile None Detected 98% Binder/Filler (Tan) Joint Compound 1/n/a
2% Chrysotile None Detected 98% Binder/Filler (Tan) Joint Compound 2/n/a
Methodology:
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
SEEML Ref#: G-240506064
% Asbestos Type % Fibrous Non-
Asbestos Material Type % Non-Fibrous Material Description/Location
Analyzed by: Linh Nguyen Project Address: 846 Pine St.
City, State. ZIP: Roseburg, OR 97470
Project Name: Oregon Employment Department
Project No: G24-452
(888)998-4224/debra@g2ci.com Date Reported: 05/09/2024
Date Revised:
17750 SW Upper Boones Ferry Rd Suite 150 Date Received: 05/06/2024
Portland,OR,97224 Date Analyzed: 05/09/2024
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
NVLAP Lab ID:201031-0
PLM Asbestos Bulk Sample Summary
G2 Consultants Date Sampled: 05/03/2024
Lab No.:
Client No.:
296A
G-24-452-9
296B
G-24-452-9
296C
G-24-452-9
297A
G-24-452-10
297B
G-24-452-10
298A
G-24-452-11
298B
G-24-452-11
299A
G-24-452-12
299B
G-24-452-12
None Detected 15% Fiberglass,85% Min
Wool None Detected (Tan) Insulation/n/a
Approved By: Andrea Berrios Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected 15% Fiberglass,85% Min
Wool None Detected (Tan) Insulation/n/a
None Detected 10% Fiberglass,80%
Cellulose 10% Organic Matrix (Tan) Insulation Wrap/n/a
None Detected 10% Cellulose 90% Gypsum (White) Drywall/n/a
None Detected 10% Fiberglass,85%
Cellulose 5% Organic Matrix (Tan) Insulation Wrap/n/a
None Detected 10% Cellulose,2%
Fiberglass 88% Gypsum (White) Drywall/n/a
2% Chrysotile None Detected 98% Binder/Filler (Tan) Joint Compound/n/a
2% Chrysotile None Detected 98% Binder/Filler (Tan) Joint Compound 1/n/a
2% Chrysotile None Detected 98% Binder/Filler (Tan) Joint Compound 2/n/a
Methodology:
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
SEEML Ref#: G-240506064
% Asbestos Type % Fibrous Non-
Asbestos Material Type % Non-Fibrous Material Description/Location
Analyzed by: Linh Nguyen Project Address: 846 Pine St.
City, State. ZIP: Roseburg, OR 97470
Project Name: Oregon Employment Department
Project No: G24-452
(888)998-4224/debra@g2ci.com Date Reported: 05/09/2024
Date Revised:
17750 SW Upper Boones Ferry Rd Suite 150 Date Received: 05/06/2024
Portland,OR,97224 Date Analyzed: 05/09/2024
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
NVLAP Lab ID:201031-0
PLM Asbestos Bulk Sample Summary
Lab No.:
Client No.:
300A
G-24-452-13
300B
G-24-452-13
301A
G-24-452-14
301B
G-24-452-14
302A
G-24-452-15
302B
G-24-452-15
303A
G-24-452-16
304A
G-24-452-17
305A
G-24-452-18
None Detected None Detected 100% Carbon/Quartz (Gray) Grout/n/a
Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected None Detected 100% Carbon/Quartz (Gray) Mortar/n/a
None Detected None Detected 100% Carbon/Quartz (Gray) Grout/n/a
None Detected None Detected 100% Carbon/Quartz (Gray) Cementitious Material/n/a
None Detected None Detected 100% Carbon/Quartz (Gray) Mortar/n/a
None Detected 40% Fiberglass,5%
Cellulose,50% Min Wool 5% Organic Matrix (White) Wall Tile/n/a
None Detected None Detected 100% Organic Matrix (Brown) Mastic/n/a
None Detected 40% Fiberglass,5%
Cellulose,50% Min Wool 5% Binder/Filler (White) Wall Tile/n/a
None Detected None Detected 100% Organic Matrix (Brown) Mastic/n/a
Methodology:
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
SEEML Ref#: G-240506064
% Asbestos Type % Fibrous Non-
Asbestos Material Type % Non-Fibrous Material Description/Location
Analyzed by: Linh Nguyen Project Address: 846 Pine St.
City, State. ZIP: Roseburg, OR 97470
Project Name: Oregon Employment Department
Project No: G24-452
(888)998-4224/debra@g2ci.com Date Reported: 05/09/2024
Date Revised:
17750 SW Upper Boones Ferry Rd Suite 150 Date Received: 05/06/2024
Portland,OR,97224 Date Analyzed: 05/09/2024
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
NVLAP Lab ID:201031-0
PLM Asbestos Bulk Sample Summary
Lab No.:
Client No.:
306A
G-24-452-19
307A
G-24-452-20
308A
G-24-452-21
308B
G-24-452-21
309A
G-24-452-22
309B
G-24-452-22
309C
G-24-452-22
310A
G-24-452-23
310B
G-24-452-23
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Gray) Floor Tile/n/a
None Detected 4% Cellulose 96% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Gray) Floor Tile/n/a
None Detected 2% Cellulose 98% Gypsum (White) Granular Plaster/n/a
None Detected 10% Cellulose 90% Gypsum (White) Drywall/n/a
None Detected 2% Cellulose 98% Gypsum (White) Granular Plaser/n/a
None Detected 2% Cellulose 98% Gypsum (White) Granular Plaster/n/a
Methodology:
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
SEEML Ref#: G-240506064
% Asbestos Type % Fibrous Non-
Asbestos Material Type % Non-Fibrous Material Description/Location
Analyzed by: Linh Nguyen Project Address: 846 Pine St.
City, State. ZIP: Roseburg, OR 97470
Project Name: Oregon Employment Department
Project No: G24-452
(888)998-4224/debra@g2ci.com Date Reported: 05/09/2024
Date Revised:
17750 SW Upper Boones Ferry Rd Suite 150 Date Received: 05/06/2024
Portland,OR,97224 Date Analyzed: 05/09/2024
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
NVLAP Lab ID:201031-0
PLM Asbestos Bulk Sample Summary
Lab No.:
Client No.:
310C
G-24-452-23
311A
G-24-452-24
311B
G-24-452-24
311C
G-24-452-24
311D
G-24-452-24
312A
G-24-452-25
312B
G-24-452-25
312C
G-24-452-25
312D
G-24-452-25
None Detected 3% Cellulose 97% Organic Matrix (Tan) Mastic/n/a
Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected None Detected 100% Organic Matrix (Yellow) Mastic/n/a
None Detected 2% Cellulose 98% Binder/Filler (Gray) Leveling Compound/n/a
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Black) Stair Tread/n/a
None Detected None Detected 100% Organic Matrix (Yellow) Mastic/n/a
None Detected 3% Cellulose 97% Binder/Filler (Gray) Leveling Compoung/n/a
3% Chrysotile None Detected 97% Organic Matrix (Black) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Black) Stair Tread/n/a
Methodology:
EPA – Appendix E to Subpart E of 40 CFR Part 763;
Interim Method for the Determination of Asbestos in
Bulk Insulation Samples.
SEEML Ref#: G-240506064
% Asbestos Type % Fibrous Non-
Asbestos Material Type % Non-Fibrous Material Description/Location
Analyzed by: Linh Nguyen Project Address: 846 Pine St.
City, State. ZIP: Roseburg, OR 97470
Project Name: Oregon Employment Department
Project No: G24-452
(888)998-4224/debra@g2ci.com Date Reported: 05/09/2024
Date Revised:
17750 SW Upper Boones Ferry Rd Suite 150 Date Received: 05/06/2024
Portland,OR,97224 Date Analyzed: 05/09/2024
Southeast Environmental Microbiology Laboratories - Asbestos Division
102 Edinburgh Court Greenville, SC 29607
Phone: 864-233-3770, Fax: 864-233-6589 , www.seeml.com
NVLAP Lab ID:201031-0
PLM Asbestos Bulk Sample Summary
Lab No.:
Client No.:
313A
G-24-452-26
313B
G-24-452-26
314A
G-24-452-27
314B
G-24-452-27
314C
G-24-452-27
314D
G-24-452-27
315A
G-24-452-28
315B
G-24-452-28
316A
G-24-452-29
None Detected 2% Cellulose 98% Gypsum (White) Granular Plaster/n/a
Disclaimer:
The results in this report only apply to the samples as received.
NOB samples are tested as a preliminary analysis. We highly recommend for Negative NOB samples resulting in less than 1% Asbestos to be verified by TEM or Point Analysis.
Inhomogeneous samples are separated into homogeneous subsamples and analyzed individually. NAD means no asbestos fibers were detected. When detected the minimum detection and reporting limit is less than 1% unless point counting is performed. Floor tile samples may contain large amounts of interference material and it is recommended that the sample be analyzed by gravimetric point count analysis to lower the detection limit and to aid in asbestos identification.
Guidelines for Interpretation:
Any opinions/interpretations expressed in this report are outside the scope of this laboratory's accreditation. Interpretation of the data and information within this document is left to the company, consultant, and/or persons who conducted the fieldwork. A material is considered regulated asbestos containing material (ACM) where the asbestos content is determined to be one percent or greater. Several organizations, including the
American Conference of Government Industrial Hygienists (ACGIH); the American Industrial Hygiene Association (AIHA); the Indoor Air Quality Association (IAQA); the United States Environmental Protection Agency (USEPA);
the Centers for Disease Control (CDC) as well as the California Department of Health Services (CADHS) have published guidelines for assessment and interpretation of analytical data indicating a tested material is ACM.
None Detected 2% Cellulose 98% Gypsum (White) Granular Plaster/n/a
None Detected 2% Cellulose 98% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Organic Matrix (Tan) Mastic/n/a
None Detected None Detected 100% Binder/Filler…
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