C05 Atch 3a Creede Assistant Ranger House Testing Report.pdf

LIMITED SCOPE ASBESTOS

ASSESSMENT

Inspection Address: 505 Capital Ave. Creede, CO 81130

[Creede Ranger House] Inspection Date: 12/10/2025

ATCH 3a

AREAS INSPECTED AT PROPERTY

Scope of Work: As related to customer inquiry; development of material management plans.

PRESENTATION

Integrity Environmental (IE) was contacted to investigate potential asbestos containing materials (ACM) for the purposes of developing material management plans at the above-mentioned location and date (See cover page).

IE is an asbestos certified firm through the CDPHE (Certification #24117). Miles Garrison (CDPHE Cert. #

29865) & Kyle Schlafer (CDPHE Cert. # 29591) conducted the ACM survey. The property is a Residential Home

& Office; that was built in 1958. The samples were taken to a nationally certified NVLAP and analyzed through

Polar Light Microscopy (PLM).

Colorado Regulation No. 8 - Part B Section III.A.1, “Prior to any renovation or demolition in an area of public access which may disturb greater than the trigger levels of suspect asbestos-containing material (ACM), the facility component(s) to be affected by the renovation or demolition must either be assumed to be ACM or must be inspected to determine if abatement is required. Inspections conducted prior to renovation may be focused on the suspect ACM to be affected by the renovation. Inspections conducted prior to demolition must comprehensively identify all ACM in and on the facility or on the component(s) affected by the demolition.”

EXAMINATION PROCEDURE

All actions pertaining to the above referenced investigation were performed in accordance with the Environmental

Protection Agency/Asbestos Hazard Emergency Response Act. These procedures call for the visual inspection of all areas of concern including collection and analysis of representative bulk samples of suspect material.

The beginning steps of the procedure require the certified inspector to categorize the suspect materials into homogeneous areas. The categories include Surfacing Materials, Miscellaneous Materials and Thermal System

Insulation.

III.A.2. During renovation or abatement activities which will impact suspect materials in quantities greater than the trigger levels or during demolition activities, the asbestos inspection report must be available onsite at all times. The inspection report is not required to be on site during the first seventy-two (72) hours of abatement activities if the abatement is being conducted under situations addressed in

Sections III.E.1.e.(i), III.E.1.e.(ii), III.E.2.d.(i). and III.E.2.d.(ii).

III.A.3. For each area of public access inspected to determine the presence of ACM, the certified asbestos building inspector must:

III.A.3.a. Identify, quantify and categorize homogenous areas of suspect ACM.

III.A.3.b. Touch all suspect ACM to determine whether the material is friable.

III.A.3.c. Either assume homogeneous areas are ACM or collect, in a random manner representative of the homogeneous area, bulk samples of suspect ACM as follows:

III.A.3.c.(i) Surfacing material. Additional information on sampling surfacing materials can be found in the EPA “Pink Book,” Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials (1985).

III.A.3.c.(i)(A) At least three bulk samples must be collected from each homogenous area that is 1,000 square feet or less.

III.A.3.c.(i)(B) At least five bulk samples must be collected from each homogenous area that is greater than 1,000 square feet but less than or equal to 5,000 square feet.

III.A.3.c.(i)(C) At least seven bulk samples must be collected from each homogenous area that is greater than 5,000 square feet.

III.A.3.c.(i)(D) Surfacing material added onto base materials (e.g. sprayed or troweled on materials, textures, paints, etc.) must be sampled and analyzed separately from the base material.

III.A.3.c.(ii) Thermal system insulation. Additional information on sampling thermal system insulation can be found in the EPA “Purple Book.” Guidance for Controlling Asbestos-containing

Materials in Buildings (1985).

III.A.3.c.(ii)(A) At least three bulk samples from each homogenous area of thermal system insulation.

III.A.3.c.(ii)(B) At least one bulk sample from each homogenous area of patched thermal system insulation that is less than 6 square or linear feet.

III.A.3.c.(ii)(C) In a manner sufficient to determine whether the material is ACM, collect bulk samples from mechanical system fittings such as tees, elbows, or valves.

III.A.3.c.(ii)(D) Bulk samples are not required where the certified asbestos building inspector has determined the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACM insulation.

III.A.3.c.(iii). Miscellaneous

III.A.4.c.(iii)(A) In a manner sufficient to determine whether the material is asbestos-containing, collect bulk samples from each homogeneous area. A minimum of two samples of each homogeneous area of miscellaneous material must be collected.

Friability of each material must be assessed during the inspection. The certified inspection must physically touch each material to determine whether they are friable.

I.B.52. “Friable” means that the material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Friable includes previously nonfriable material after such previously non friable material becomes damaged or disturbed to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

I.B. 77. “Nonfriable” means material which, when dry, may not be crumbled, pulverized, or reduced to powder by hand pressure. Damaged nonfriable material or nonfriable materials in poor condition may become friable.

After categorizing each friable material during the inspection, “The Inspector shall classify the ACM and materials assumed to be ACM into one of the following categories”

(1) III.A.3.e.(v)(A). Damaged or significantly damaged thermal system insulation ACM.

(2) III.A.3.e.(v)(B) Damaged friable surfacing ACM.

(3) III.A.3.e.(v)(C) Significantly damaged friable surfacing ACM.

(4) III.A.3.e.(v)(D) Damaged or significantly damaged friable miscellaneous ACM.

(5) III.A.3.e.(v)(E) ACBM with potential for damage.

(6) III.A.3.e.(v)(F) ACBM with potential for significant damage.

(7) III.A.3.e.(v)(G) Any remaining friable ACBM or friable suspected ACBM containing materials

LABORATORY ASSESSMENT AND FINDINGS

The samples collected by Integrity Environmental were submitted to Reservoirs Environmental Incorporated laboratory. These samples were analyzed using the Environmental Protection Agency’s “Method for the

Determination of Asbestos in Bulk Building Materials” (Environmental Protection Agency 600/R/116, July 1993)

2.2.1 Principle and Applicability

Samples of bulk building materials taken for asbestos identification should first be examined with the simple stereomicroscope to determine homogeneity and preliminary fiber identification.

Subsamples should then be examined using PLM to determine optical properties of constituents and to provide positive identification of suspect fibers.

The principles of optical mineralogy are well-established.12·3 ·4 A light microscope equipped with two polarizing filters is used to observe specific optical characteristics of a sample. The use of plane polarized light allows for the determination of refractive indices relative to specific crystallographic orientations. Morphology and color are also observed while viewing under plane polarized light. Observation of particles or fibers while oriented between polarizing filters whose privileged vibration directions are perpendicular (crossed polars) allows for determination of isotropism/anisotropism, extinction characteristics of anisotropic particles, and calculation of birefringence. A retardation plate may be placed in the polarized light path for verification of the sign of elongation. If subsamples are prepared in such a way as to represent all sample components and not just suspect fibers, semi-quantitative analysis may also be performed. Semi- quantitative analysis involves the use of calibrated visual area estimation and/or point counting. Visual area estimation is a semi-quantitative method that must relate back to calibration materials. Point counting, also semi-quantitative, is a standard technique used in petrography for determining the relative areas occupied by separate minerals in thin sections of rock. Background information on the use of point counting3 and the interpretation of point count data-' is available. Although PLM analysis is the primary technique used for asbestos determination, it can show significant bias leading to false negatives and false positives for certain types of materials. PLM is limited by the visibility of the asbestos fibers. In some samples the fibers may be reduced to a diameter so small or masked by coatings to such an extent that they cannot be reliably observed or identified using PLM.

CDPHE Regulation 8 - III.A.4. Analysis

III.A.4.a. Bulk samples collected under Section III.A.3.c. and submitted for analysis must be analyzed for asbestos using laboratories accredited by the National Institutes of Standards and

Technology (NIST). Laboratories must also be registered as required in subsection II.M.

III.A.4.b. Bulk samples must be analyzed for asbestos content by PLM, using the United

States Environmental Protection Agency’s August 1994 Method EPA/600/R-93/116, “Method for

Determination of Asbestos in Bulk Building Materials.”

III.A.4.c. With the exception of drywall systems (drywall, tape, and joint compound), bulk samples must not be composited for analysis. Drywall and associated joint compound utilized to fill seams and nail holes may be composited utilizing the procedures given in the January 5, 1994

Federal Register, Volume 59, No. 3. Any composite analysis must be performed by the laboratory who analyzed the bulk sample. Materials added onto drywall and other base materials (e.g.

sprayed or troweled on materials, textures, paints, etc.) must be sampled and analyzed separately.

III.A.4.d. If the asbestos content of a sample of friable ACM is estimated to be 1% or less but greater than 0% by a method other than point counting, either the analytical process must be repeated by the accredited laboratory using the point counting technique utilizing PLM or the material will be assumed to be asbestos containing. If a result obtained by point count is different from a result obtained by visual estimation, the point count result must be used. Non-friable samples do not have to be point counted.

III.A.4.e. Interpreting Bulk Sample Results

III.A.4.e.(i) A homogeneous area is considered not to contain ACM only if the results of all samples required to be collected from that area show asbestos in amounts of one percent or less.

III.A.4.e.(ii) A homogeneous area will be determined to contain ACM based on a finding that the results of at least one sample collected from that area shows that asbestos is present in an amount greater than one percent.

If joint compound in a drywall system comes back above 1% asbestos, it may be analyzed under composite analysis at the laboratory. OSHA does not accept composite analysis but only regulates if the material is over 160 square feet of material.

OSHA - Clarification of multi-layered ACM system

When joint compound and/or tape is applied to wallboard it becomes a part of the wallboard and in effect becomes one material forming a system. Therefore, where a demolition or renovation impacts such a wall system, a composite analysis of the wall system (percent of asbestos in the joint compound, tape and wallboard) should be conducted. If the analysis shows an asbestos content of greater than one percent and at least 160 square feet of the wall system is involved in the demolition or renovation activities (whether planned or unplanned, during a calendar year), then the activities would be subject to the asbestos NESHAP.

Colorado Department of Public Health and Environment Compliance Bulletin April 2007, “Drywall and drywall mud may contain asbestos. The percent of asbestos contained in the drywall and its associated materials, including mud and tape, may be determined Below Analytical

Sensitivity on a representative composite sampling program.”

IE collected Twenty-Seven (27) samples from the above referenced location from Eleven (11) homogeneous area(s).

Polar Light Microscopy Results from Eurofins Reservoirs Environmental Cert.#101533 confirm that Four

(4) homogeneous areas that were tested contain asbestos.

I.B.16. “Asbestos-containing material (ACM)” means material containing more than 1% asbestos...

If the sampled materials are visually estimated under 1% (Trace) or the joint compound of a drywall system return a positive result, Integrity Environmental may request to have the materials point counted or composited at additional laboratory fees.

Please review the attached bulk sampling log to review areas sampled, their locations and the laboratory result and findings. Materials that are RED Highlighted contain asbestos above the regulatory levels and require abatement prior to being disturbed. Orange Highlighted indicates while the samples contain asbestos they are under the regulation levels requiring abatement. Abatement is recommended but not required for those materials. Any materials that were outside the scope of work and not tested are assumed to be ACM until tested.

Sample ID:

Material Description

Sample

Location(s) Homogeneous

Area

Condition Mitigation

Strategy

Friability Quantity Result

SM-01-01

“Orange Peel” Drywall

Texture Kitchen/Dining Room, Bedroom #1, Bedroom

#2, Livingroom Drywall

Walls & Ceilings

HA-1

5 2

Friable

1,000Sqft

ND

SM-01-02

Friable 3% Chrysotile

SM-01-03

Friable 3% Chrysotile

SM-01-04

Friable 3% Chrysotile

SM-01-05

Friable 3% Chrysotile

MM-02-06

Drywall W/ Joint Compound

& Tape

HA-2

Friable 3% Chrysotile

MM-02-07

Friable 3% Chrysotile

SM-03-08

“White, Knockdown”

Drywall Texture

Bathroom Drywall

Walls & Ceilings

HA-3

5 2

Friable

250Sqft

3% Chrysotile

SM-03-09

Friable

3% Chrysotile

SM-03-10

Friable

ND

MM-04-11

Drywall W/ Joint Compound

& Tape

HA-4

Friable Trace (Assumed)

MM-04-12

Friable

3% Chrysotile

SM-05-13

“White, Knockdown”

Drywall Texture

Entrée Room Drywall

Walls & Ceiling

HA-5

0 N/A

Friable

250Sqft

ND

SM-05-14

Friable ND

SM-05-15

Friable ND

MM-06-16

Drywall W/ Joint Compound

& Tape

HA-6

Friable ND

MM-06-17

Friable ND

MM-07-18

“Tan, Square Pattern” Vinyl

Floor Kitchen/Dining Room

HA-7

N/A

Non-Friable

100Sqft

ND

MM-07-19

Non-Friable ND

MM-08-20

“Tan” Linoleum Flooring Bathroom Flooring

HA-8

0 N/A

Non-Friable

25Sqft

ND

MM-08-21

Non-Friable ND

MM-09-22

Untextured Drywall Garage Drywall

HA-9

N/A

Friable

50Sqft

ND

MM-09-23

Friable ND

MM-10-24

Fireplace Mortar Livingroom (Fireplace)

HA-10

N/A

Friable

20Sqft

ND

MM-10-25

Friable ND

MM-11-26

“Brown” Cove base W/

Mastic Kitchen/ Dining Room

Walls

HA-11

N/A

Non-Friable

20Sqft

ND

MM-11-27

Non-Friable ND

Condition #0 Condition #1 Condition #2 Condition #3 Condition #4 Condition #5 Condition #6 Condition #7

No asbestos found

Damaged/Significantly

Damaged TSI

Damaged Friable

(Surface) ACM

Significantly

Damaged Friable

(Surface) ACM

Damaged or Sig.

Damaged Friable

Misc. ACM

ACBM W/

Potential for

Damage

ACBM W/

Potential for

Significant

Damage

Any Remaining

Friable ACBM or Suspect ACM

Material

Suggested Mitigation Strategy’s

Mitigation Strategy (1) -Abatement Mitigation Strategy (2) -Monitoring Mitigation Strategy (3) -Enclose Mitigation Strategy (4) -Encapsulate

Bulk Sampling Log Notes

Sample ID – (Example: MM02-03) The sample’s ID is composed of the classification of the homogeneous area (02), and the sample number of the set (03).

Material description & ID- details the material tested by its visual characteristics. (MM – Miscellaneous Material), (SM – Surface Material), (TSI- Thermal System Insulation).

Quantity of materials – This quantity is approximate and estimated based on the materials marked for removal. These numbers should not be used for quoted asbestos abated projects. Grouped material should be considered part of a single system (Example: Joint Compound and Drywall Walls, where one is HOT both are considered HOT) Homogeneous area- When “Material Description” is grouped it indicates the HA or “Homogeneous Area” for quick and easy identification.

CONSTRAINTS

This summary outlines the information retained and interpretations made by IE during the property evaluation and samples collected in bulk at the previously identified location. IE attests that all actions were executed within the appropriate guidelines as established by the Environmental Protection Agency and the State of Colorado and in a method congruent with the quality and assurance of other such professionals in comparative situations. Samples collected by the building inspector have been reviewed and interpreted by a certified report writer. The in-field building inspector is liable for the sampling method, while the report writer is responsible for the written report.

Respectfully Submitted, Field Inspector

Miles Garrison Colorado Asbestos Building Inspector Certification #29865

Kyle Schlafer Colorado Asbestos Building Inspector Certification #29591

Report Writer

Matthew S. Chandler Colorado Asbestos Building Inspector Certification #24390

Certifications

IE accepts no liability for collected information, suggestions rendered either in this summary or directly to the identified client, and/or any other promissory statements made by any other consulting agencies or qualified persons not affiliated with IE. No other indicative statement is made or inferred in any way to the client, including the offer of warranty on completed actions or service guarantee.

PROJECT DRAWING

LABORATORY ANALYSIS

AND CHAIN OF CUSTODY

END OF REPORT.