Pre-Demolition Asbestos Inspection Burke Martin Site.pdf

Sunrise Environmental, Inc.

PO Box 429 - 371 Crest View Drive

Black Hawk, Colorado 80422 720-209-5282 | www.sunrise-enviro.com

Asbestos Consulting Services

PRE-DEMOLITION

ASBESTOS INSPECTION

BURKE-MARTIN MINE SITE

WHITE RIVER NATIONAL FOREST

SUMMIT COUNTY, COLORADO

SOUTHEAST ¼ of SECTION 35

TOWNSHIP 5 SOUTH, RANGE 76 WEST (6th PM) GPS: 39° 34’ 20.6” North 105° 51’ 45.9” West

PREPARED FOR:

White River National Forest 900 Grand Avenue

Glenwood Springs, Colorado 81601

PROJECT: SEI19-P145

PREPARED: September 29, 2019

TABLE OF CONTENTS

SECTION DESCRIPTION PAGE

CERTIFICATION OF RESULTS 3

1.0 EXECUTIVE SUMMARY 4

2.0 SCOPE AND FACILITY INFORMATION 5

2.1 Inspection Objectives and Scope

2.2 Site Description 5

2.3 Review of Existing Information 6

3.0 METHODS AND TECHNIQUES 7

3.1 Inspection 7

3.2 Bulk Sampling 7

3.3 Sample Analysis 8

4.0 ASBESTOS-CONTAINING MATERIAL DESCRIPTIONS

AND RECOMMENDATIONS 9

5.0 PRESUMED ASBESTOS CONTAINING MATERIAL

DESCRIPTIONS AND RECOMMENDATIONS 23

6.0 NON-ASBESTOS CONTAINING MATERIAL DESCRIPTIONS 23

7.0 INSPECTOR COMMENTS 27

8.0 CONCLUSIONS AND RECOMMENDATIONS 28

9.0 LIMITATIONS 29

Appendices

Appendix A - Laboratory Results Appendix B - Google Maps Satellite Image of Site Appendix C - Site Map Appendix D - Mill Building Debris Pile Inspection Report Appendix E - Certifications

CERTIFICATION OF RESULTS

This Pre-Demolition Asbestos Inspection was performed on behalf of the White River National Forest, (hereafter referred to as “Client”), subsidiaries, partners, directors and officers, and all successors and assigns, solely for use in evaluation of the presence of asbestos-containing building materials sampled at the Burke-Martin Mine Site, Southeast ¼ of Section 35, Township 5 South, Range 76 West, GPS: North 39° 34’ 20.6” – West 105° 51’ 45.9” White River National Forest located in Summit County, Colorado (hereafter referred to as the “Site”). The information herein is only for the specific use of White River National Forest and Sunrise Environmental, Inc. Use by any other parties is unauthorized. Sunrise Environmental, Inc accepts no responsibility for the use, interpretation, or reliance by other parties on the information contained herein, unless written authorization is obtained by Sunrise Environmental, Inc.

Scott D. Sanders President CDPHE Building Inspector Certificate #633

1.0 EXECUTIVE SUMMARY

Sunrise Environmental, Inc. has completed a Pre-Demolition Asbestos Inspection of the Burke- Martin Mine Site, Southeast ¼ of Section 35, Township 5 South, Range 76 West, GPS: North 39° 34’ 20.6” – West 105° 51’ 45.9” White River National Forest located in Summit County, Colorado.

The inspection was performed by Mr. Scott D. Sanders and Mary-Jean Sanders of Sunrise Environmental, Inc. July 24th, 2019 (mill building debris pile) and September 4th, 2019 (remainder of the site). After identifying homogeneous areas of suspect Asbestos Containing Building Materials (ACBM), the inspector collected samples from each Homogeneous Area. The samples were submitted to an independent laboratory where they were analyzed by Polarized Light Microscopy (PLM).

Sunrise Environmental, Inc. collected a total of nine (9) samples from three (3) homogeneous areas from the mill debris pile inspected on July 24th 2019. All three (3) Homogeneous Areas inspected at the mill debris pile were found to contain greater than 1% asbestos.

Sunrise Environmental, Inc. collected a total of fifty-one (51) samples from twenty-two (22) Homogeneous Areas for asbestos content from the remainder of the site (other than the mill building debris pile) on September 4th 2019, five (5) of which were found to contain greater than 1% asbestos.

Sunrise Environmental, Inc. did not presume any additional Homogeneous Areas as asbestos containing.

The building materials found to contain greater than 1% asbestos at the site are listed below:

· Gray/tan cementitious paneling (mill debris pile) (H.A. #1 from7/24/19 inspection)

· Gray cementitious paneling (mill debris pile) (H.A. #2 from 7/24/19 inspection)

· Black roofing tar (mill debris pile) (H.A. #3 from 7/24/19 inspection)

· Gray caulk (trailer/cabin) (H.A #8 from 9/4/19 inspection)

· Black & silver roofing tar (trailer/cabin) (H.A. #10 from 9/4/19 inspection)

· Multilayered floor tiles (former office trailer) (H.A. #13 from 9/4/19 inspection)

· Gray caulk (storage shed) (H.A #15 from 9/4/19 inspection)

· Black roofing tar (storage building) (H.A. #17 from 9/4/19 inspection)

The asbestos containing materials listed in bold print above must be removed prior to demolition of the structures or clean-up of the debris piles. Removal of these materials should be performed by a licensed General Abatement Contractor (GAC).

Laboratory analysis of the following building materials identified less than 1.0% asbestos in the samples submitted. These materials are not regulated by EPA or CDPHE-AQCC. However, OSHA regulations require employees to document potential exposure to employees handling these materials and maintain exposure limits below the Permissible Exposure Limit (PEL) of 0.1 fibers/cubic Centimeter (f/cc) over an eight-hour time weighted average (TWA). The materials found to contain 1.0% or less (trace) asbestos content are listed below:

¨ White metal window glazing (H.A #18 from 9/4/19 inspection) (ore loadout structure) ¨ White metal window glazing (H.A #20 from 9/4/19 inspection)

(window framing on ground east of storage building) ¨ White metal window glazing (H.A #22 from 9/4/19 inspection) (mine entry structure)

2.0 SCOPE AND FACILITY INFORMATION

2.1 Inspection Objectives and Scope

The White River National Forest requested Sunrise Environmental Inc. inspect the site for the presence of asbestos containing building materials (ACBM). Sunrise Environmental, Inc.

performed a Pre-Demolition Asbestos Inspection in accordance with the requirements of 40 CFR 61, National Standards for Hazardous Air Pollutants (NESHAP), and Colorado Department of Public Health and Environment Air Quality Control Commission (CDPHE-AQCC) Regulation 8, which require that a structure be thoroughly inspected for the presence of asbestos-containing building materials prior to demolition.

Our scope of services included the following:

· Identify suspect asbestos containing building materials (ACBM) at the site.

· Identify suspect asbestos containing materials (ACM) on the surface of the ground surrounding the structures.

· Collect bulk samples of all identified suspect materials in accordance with 40 CFR

763.86 and CDPHE-AQCC Regulation # 8.

· Submit the bulk samples to a NVLAP accredited asbestos laboratory for analysis;

· Specify the condition of the suspect ACBM;

· Compile a final report of findings.

Sunrise Environmental, Inc. made reasonable efforts to locate and identify asbestos containing building materials (ACBM) at the site. The inspection was conducted by CDPHE Certified Asbestos Building Inspectors Scott D. Sanders & Mary-Jean Sanders.

2.2 Site Description

The site is a former silver mine with several buildings. The buildings identified at the site are as follows:

1. Trailer/cabin. The trailer/cabin is a metal trailer with wood addition built on to the west side of the trailer, with a wood and sheet metal roof built over the trailer/cabin. The trailer/cabin is still intact and in good condition with some non-friable asbestos-containing roofing materials and non-friable asbestos-containing caulking.

2. Former office trailer (floor). The former office trailer reportedly collapsed many years ago and all that remains is the floor of the trailer with significantly damaged friable asbestos-containing multilayered floor tiles. The former office trailer floor is considered a major asbestos spill and is located to the east of the trailer/cabin.

3. Outhouse. The outhouse is constructed of wood with composite shingles, and is located southwest of the trailer/cabin. No asbestos-containing building materials were identified with regard to the outhouse.

4. Scale building. The scale building is a metal roof on wooden framing and wood poles located southeast of the trailer/cabin. No asbestos containing building materials were identified with regard to the scale building.

5. Storage shed. The storage shed is a small structure constructed of wood with metal roofing and siding located to the north of the trailer/cabin. A small amount of non-friable asbestos-containing caulk was identified on the south side metal paneling of the shed.

6. Storage Building. The storage building is mainly constructed of wood with metal roofing.

Some non-friable asbestos-containing tar was observed on the metal roof of the storage building. The storage building is located north of the trailer cabin and the storage shed, and south of the mill building debris pile.

7. Mill building debris pile- The mill building debris pile is considered a major asbestos spill, consisting of mainly wood timbers with friable asbestos-containing cementitious paneling & roofing materials scattered throughout the debris pile. The mill building debris pile is located north of the storage building.

8. Ore-loadout structure – The ore loadout structure consists of metal beams and metal framing with windows. No asbestos-containing building materials were identified with regard to the ore loadout structure. The loadout structure is located west of the storage building. Some of the window framing from the ore loadout structure was also observed on the ground to the east of the storage building. No asbestos-containing building materials were identified with regard to the metal framed windows east of the storage building.

9. Mine entry structure. The mine entry structure consists of metal beams and metal framing with windows. No asbestos-containing building materials were identified with regard to the mine entry structure.

2.3 Review of Existing Information

No previous asbestos inspection documentation regarding the site was provided for review. The mill building debris pile was inspected by Sunrise Environmental, Inc. on July 24th, 2019. A copy of the inspection report for the mill building debris pile dated August 21, 2019 and the addendum issued on August 25th, 2019 can be found in Appendix D of this report.

3.0 METHODS AND TECHNIQUES

3.1 Inspection

Sunrise Environmental, Inc. inspected the site to locate and identify friable and non-friable asbestos containing building materials. Mr. Scott D. Sanders and Ms. Mary-Jean Sanders of Sunrise Environmental, Inc. performed the inspection of the mill building debris pile on July 24th 2019 and performed the inspection of the remainder of the site on September 4th, 2019. Mr. Scott D. Sanders and Ms. Mary-Jean Sanders are Colorado Department of Public Health and Environment (CDPHE-AQCC) certified asbestos building inspectors. The inspectors visually inspected the structures at the site to locate and identify suspect ACBM, touched suspect ACBM to determine friability, and determined the extent of Homogeneous Areas of friable and non-friable suspect ACBM.

3.2 Bulk Sampling

Random bulk samples, representative of the suspect asbestos containing building materials of each homogeneous area, were collected according to guidelines published as Environmental Protection Agency (EPA) Final Rule: Title II of the Toxic Substances Control Act (TSCA), 15 USC, Sections 2641 through 2654 and in compliance with 40 CFR, Part 763 and Colorado Department of Public Health and Environment (CDPHE), Regulation Number 8. Representative sampling is based on the following criteria:

1. The distribution of the suspect material throughout the homogeneous area.

2. The suspect materials physical characteristics and application.

3. Random sampling patterns determined for each homogeneous area.

Suspect materials sampled and analyzed should be considered representative of materials in each homogeneous area if:

1. They exhibit similar physical characteristics.

2. The application of the sampled material can be correlated to the application of un-sampled material.

Suspect materials similar in appearance and application were sampled as homogeneous areas.

Suspect materials were divided into three classifications and sampled according to applicable regulations based on classification of each homogeneous material and the quantity of each homogeneous material as listed below:

1. Surfacing Materials - Troweled on or sprayed on material

· 1,000 square feet requires a minimum of three (3) samples

· Greater than 1,000 square feet but less than or equal to 5,000 square feet requires a minimum of five (5) samples

· Greater than 5,000 square feet requires a minimum of seven (7) samples

2. Thermal System Insulation

· Each system requires three (3) samples

3. Miscellaneous - other suspect materials not classified in the above categories

· Sufficient samples to adequately characterize the materials with a minimum of two

(2) samples

After identifying homogeneous areas of suspect ACBM, representative samples from each homogeneous area were collected. The inspector randomly selected the sample locations and collected samples in a manner to minimize the release of fibers into the air. At each sample location, the inspector collected a small bulk sample of the material using an appropriate tool (e.g, clean knife or chisel), and placed each bulk sample into an unused, uniquely labeled, sealable bag.

The inspector documented each Homogeneous Area, sample location, sample number and other pertinent information at the time of the inspection.

A total of nine (9) samples were collected for analysis from three (3) Homogeneous Areas from the mill building debris pile inspected on July 24th, 2019. A total of fifty-one (51) samples were collected for analysis from twenty-two (22) Homogeneous Areas from the inspection of the remainder of the site performed on September 4th, 2019.

3.3 Sample Analysis

Bulk samples collected were submitted for analysis at FRS Geotech, Inc., 1441 West 46th Avenue, Suite 14, Denver, Colorado 80211 and were analyzed by Polarized Light Microscopy (PLM) for asbestos content. FRS Geotech, Inc. is accredited by the National Institute of Standards and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP).

PLM was performed in compliance with guidelines established by the USEPA (EPA 600 Method).

A building material of a given homogeneous area is considered to be ACBM based on a finding that at least one sample collected from the material showed asbestos present in an amount greater than one percent (1%). A building material is not to be considered ACBM only if the results of all samples collected from the material showed asbestos content to be equal to or less than one percent (1%).

The Colorado Department of Public Health & Environment Regulation No. 8, Section III.A.1.c requires that if the asbestos content of a friable asbestos containing material is estimated to be 1% asbestos or less, but greater than 0%, the material must be treated as asbestos-containing or the material must be submitted for the point count analysis technique using Polarized Light Microscopy. If the point count result is different from the result obtained from visual estimation, the point count result must be used. EPA-NESHAP recommends point count analysis for visual estimations from greater than 1% to 10% to disprove false positive results or consider the material to be asbestos containing. Samples 0904-18-1, 0904-18-2, 0904-18-3, 0904-20-1, 0904-20-2, 0904-20-3, 0904-22-1, 0904-22-2, 0904-22-3 were submitted for point count analysis and all samples of the window glazing materials were reported to contain less than 1% asbestos.

The PLM analysis of the bulk samples collected from the mill building debris pile was performed on July 26th, 2019. The PLM analysis of the bulk samples collected on September 4th, 2019 from the remainder of the site was performed on September 12th, 2019 and the point count analysis was performed on September 16th, 2019 as listed in the Analytical Data Section of this report (See Appendix A). Condition assessments were performed by the accredited inspector at the time of inspection.

4.0 Asbestos Containing Material Descriptions and Recommendations

The following pages include asbestos containing material descriptions and a table listing the asbestos containing building materials identified at the site. A Photograph of each asbestos-containing material identified at the Site can be found following the General Recommendations for each Homogeneous Area.

All material quantity estimates are approximations and should be verified in the field by contractors bidding for abatement of the asbestos-containing materials and/or demolition of the structures.

The building materials listed in this section contain concentrations of asbestos greater than 1% by visual estimation when analyzed by Polarized Light Microscopy.

HOMOGENEOUS AREA – 1 (from 7/24/19 inspection of mill building debris pile)

Material Description: Gray/tan cementitious paneling Type of Material: Miscellaneous Material Friability: Friable Material Condition: Significantly Damaged

Potential for Disturbance Frequency of Potential Contact: Medium Influence of Vibration: Low Potential for Air Erosion: High

Material Location Material Quantity AHERA Category Mill building debris pile, Approx. 3 sq. ft. #4 Damaged or significantly damaged South side of debris pile observed friable miscellaneous ACBM

Sample No. Sample Location Composition 1-1 Mill debris pile, 20% Chrysotile

South edge of debris pile East side of panel

1-2 Mill debris pile, 20% Chrysotile

South edge of debris pile west side of panel

General Recommendations

The gray/tan cementitious paneling is considered friable due to the significantly damaged condition of the paneling. The entire mill building debris pile is considered a major asbestos spill.

See the inspection report dated August 21st 2019 and the addendum issued on August 25th, 2019 in Appendix D of this report which discusses the mill building debris pile major asbestos spill.

Photo on next page.

Photo of Homogeneous Area #1, tan/gray cementitious paneling (from 7/24/19 inspection of mill building debris pile):

HOMOGENEOUS AREA – 2 (from 7/24/19 inspection of mill building debris pile)

Material Description: Gray cementitious paneling Type of Material: Miscellaneous Material Friability: Friable Material Condition: Significantly Damaged

Potential for Disturbance Frequency of Potential Contact: Medium Influence of Vibration: Low Potential for Air Erosion: High

Material Location Material Quantity AHERA Category Mill building debris pile, Approx. 32 sq. ft. #4 Damaged or significantly damaged East center of debris pile observed friable miscellaneous ACBM

Sample No. Sample Location Composition 2-1 Mill debris pile, 17% Chrysotile

East center of debris pile Top of panel

2-2 Mill debris pile, 17% Chrysotile

East center of debris pile Bottom of panel

General Recommendations

The gray cementitious paneling is considered friable due to the significantly damaged condition of the paneling. The entire mill building debris pile is considered a major asbestos spill. See the inspection report dated August 21st 2019 and the addendum issued on August 25th, 2019 in Appendix D of this report which discusses the mill building debris pile major asbestos spill.

Photo of Homogeneous Area #2, gray cementitious paneling

HOMOGENEOUS AREA – 3 (from 7/24/19 inspection of mill building debris pile)

Material Description: Black roofing tar on non-ACM green roofing Type of Material: Miscellaneous Material Friability: Friable Material Condition: Significantly Damaged

Potential for Disturbance Frequency of Potential Contact: Medium Influence of Vibration: Low Potential for Air Erosion: High

Material Location Material Quantity AHERA Category Mill building debris pile Scattered over approx. #4 Damaged or significantly damaged 8,000 sq. ft. of debris friable miscellaneous ACBM

Sample No. Sample Location Composition 3-1 Mill debris pile, 10% Chrysotile

Center of debris pile

3-2 Mill debris pile, 10% Chrysotile East end of debris pile

General Recommendations

The black roofing tar on non-ACM green roofing is considered friable due to the significantly damaged condition of the roofing materials. The entire mill building debris pile is considered a major asbestos spill. See the inspection report dated August 21st 2019 and the addendum issued on August 25th, 2019 in Appendix D of this report which discusses the mill building debris pile major asbestos spill.

Photo of Homogeneous Area #3, black roofing tar on non-ACM green roofing

HOMOGENEOUS AREA – 8 (from 9/4/19 inspection of remainder of site)

Material Description: Gray caulk Type of Material: Miscellaneous Material Friability: Non-Friable Material Condition: Good

Potential for Disturbance Frequency of Potential Contact: Low Influence of Vibration: Low Potential for Air Erosion: Low

Material Location Material Quantity AHERA Category Trailer/Cabin, Approx. 3 sq. ft. Non-friable ACBM Behind window & door trim

Sample No. Sample Location Composition 0904-8-1 Trailer/cabin, 15% Chrysotile

West kitchen window Top of window

0904-8-2 Trailer/cabin, 15% Chrysotile

East living room window Top of window

General Recommendations

The gray caulk is considered non-friable. Maintained in good condition the material poses minimal risk of fiber release. Avoid activities such as grinding, sanding, and cutting, which may cause the material to become damaged. Should the materials become damaged, removal should be performed by personnel trained and certified to remove, transport and dispose of asbestos containing material.

The non-friable gray caulk must be removed utilizing personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the trailer/cabin. The caulk may remain if the trailer/cabin is demolished with an excavator and the caulk remains non-friable.

Demolition debris must go to an EPA approved landfill that accepts non-friable asbestos-containing materials.

Photo of Homogeneous Area #8, gray caulk:

HOMOGENEOUS AREA – 10 (from 9/4/19 inspection of remainder of site)

Material Description: Black & silver roofing tar Type of Material: Miscellaneous Material Friability: Non-Friable Material Condition: Good Frequency of Potential Contact: Low Influence of Vibration: Low Potential for Air Erosion: Low

Material Location Material Quantity AHERA Category Trailer/Cabin, Approx. 120 sq. ft. Non-friable ACBM Trailer roof perimeter & seams

Sample No. Sample Location Asbestos Composition 0904-10-1 Trailer/Cabin, 10% Chrysotile (black tar) Trailer roof, east side, 7% Chrysotile (silver tar) Above east entry

0904-10-2 Trailer/Cabin, 10% Chrysotile (black tar) Trailer roof, west side, 7% Chrysotile (silver tar)

South of north window

0904-10-3 Trailer/Cabin, 10% Chrysotile (black tar) Trailer roof, east side 7% Chrysotile (silver tar) South of east entry, Above north kitchen window

The non-friable black and silver roofing tar was observed on the perimeter edges and seams of the roof on the trailer portion of the trailer/cabin.

General Recommendations

The black & silver roofing tar is considered non-friable. Maintained in good condition the material poses minimal risk of fiber release. Avoid activities such as grinding, sanding, and cutting, which may cause the material to become damaged. Should the materials become damaged, removal should be performed by personnel trained and certified to remove, transport and dispose of asbestos containing material.

The black & silver roofing tar must be removed utilizing personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the trailer cabin. The black & silver roofing tar may remain if the trailer/cabin is demolished with an excavator and the black & silver roofing tar remains non-friable. Demolition debris must go to an EPA approved landfill that accepts non-friable asbestos-containing materials.

Photo of Homogeneous Area #10, black & silver roofing tar:

HOMOGENEOUS AREA – 13 (from 9/4/19 inspection of remainder of site)

Material Description: Multilayered floor tile Type of Material: Miscellaneous Material Friability: Friable Material Condition: Significantly Damaged

Potential for Disturbance Frequency of Potential Contact: High Influence of Vibration: Low Potential for Air Erosion: High

Material Location Material Quantity AHERA Category Former office trailer floor Approx. 400 square feet #4 Damaged or significantly Damaged friable miscellaneous

ACBM

Sample No. Sample Location Composition 0904-13-1 Former office trailer floor, 11% Chrysotile (tan tile)

North center 12% Chrysotile (gray tile) 7% Chrysotile (white tile) None Detected (pink tile) None Detected (black tar paper)

0904-13-2 Former office trailer floor, 11% Chrysotile (tan tile)

Center 12% Chrysotile (gray tile) 7% Chrysotile (white tile) None Detected (pink tile) None Detected (black tar paper)

0904-13-3 Former office trailer floor, 11% Chrysotile (tan tile)

South center 12% Chrysotile (gray tile) 7% Chrysotile (white tile) None Detected (pink tile) None Detected (black tar paper) General Recommendations

The multilayered floor tiles were observed to be significantly damaged and friable due to exposure to weather and represents a major asbestos spill. Some of the floor tiles were observed on the ground beneath and beside the trailer floor. The office trailer reportedly collapsed many years ago due to heavy snowfall and the walls and sides of the trailer were removed from the site many years ago.

A major asbestos spill response (clean-up) of the floor tiles must be performed by a CDPHE licensed General Abatement Contractor (GAC) utilizing personnel trained in asbestos removal techniques and personal protective equipment in accordance with CDPHE Regulation No. 8. The major spill response (clean-up) must include the removal of at least 2 inches of soil from beneath and beside the trailer base. At the time of the inspection, the damaged floor tiles were observed on top of and beneath the trailer base and within 2 feet of the sides of the trailer base. The former office trailer floor with friable significantly damaged asbestos-containing floor tiles should be stabilized with an application of magnesium chloride or covered in polyethylene sheeting until the major asbestos spill response clean-up is performed.

Photos of Homogeneous Area #13, multilayered floor tiles:

HOMOGENEOUS AREA – 15 (from 9/4/19 inspection of remainder of site)

Material Description: Gray caulk Type of Material: Miscellaneous Material Friability: Non-Friable Material Condition: Good

Potential for Disturbance Frequency of Potential Contact: Low Influence of Vibration: Low Potential for Air Erosion: Low

Material Location Material Quantity AHERA Category Storage shed north of Approx. 1 sq. ft. Non-friable ACBM Trailer /cabin

Sample No. Sample Location Composition 0904-15-1 Storage shed, 15% Chrysotile

North of the trailer/cabin North side of shed, east end

0904-15-2 Storage shed, 15% Chrysotile

North of the trailer/cabin North side of shed, west end

The gray caulk was observed on the metal panel on the north side of the storage shed.

General Recommendations

The gray caulk is considered non-friable. Maintained in good condition the material poses minimal risk of fiber release. Avoid activities such as grinding, sanding, and cutting, which may cause the material to become damaged. Should the materials become damaged, removal should be performed by personnel trained and certified to remove, transport and dispose of asbestos containing material.

The caulk must be removed utilizing personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the trailer cabin. The caulk may remain if the trailer/cabin is demolished with an excavator and the caulk remains non-friable. Demolition debris must go to an EPA approved landfill that accepts non-friable asbestos-containing materials.

Photos on next page.

Photos of Homogeneous Area #15, gray caulk:

HOMOGENEOUS AREA – 17 (from 9/4/19 inspection of remainder of site)

Material Description: Black roofing tar Type of Material: Miscellaneous Material Friability: Non-Friable Material Condition: Good Frequency of Potential Contact: Low Influence of Vibration: Low Potential for Air Erosion: Low

Material Location Material Quantity AHERA Category Storage building Approx. 5 sq. ft. Non-friable ACBM

Sample No. Sample Location Asbestos Composition 0904-17-1 Storage building 10% Chrysotile West side roof, north end

0904-17-2 Storage building 10% Chrysotile West side roof, center

The black roofing tar was located on the roof of the storage building on seams & penetrations.

General Recommendations

The black roofing tar is considered non-friable. Maintained in good condition the material poses minimal risk of fiber release. Avoid activities such as grinding, sanding, and cutting, which may cause the material to become damaged. Should the materials become damaged, removal should be performed by personnel trained and certified to remove, transport and dispose of asbestos containing material.

The black roofing tar must be removed utilizing personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the storage building. The black roofing tar may remain if the storage building is demolished with an excavator and the black roofing tar remains non-friable. Demolition debris must go to an EPA approved landfill that accepts non-friable asbestos-containing materials.

Photos on next page.

Photos of Homogeneous Area #17, black roofing tar:

5.0 Presumed Asbestos Containing Building Materials

No additional building materials at the site were presumed to contain greater than 1% asbestos.

6.0 Non-Asbestos Containing Building Materials

The following materials were sampled at the site on September 4th, 2019 and were found to contain 1% or less asbestos:

Sample #: Homogeneous Area & Material Description:

Sample Location:

0904-1-1 Homogeneous Area #1:

Multicolored sheet vinyl flooring & brown mastic (Miscellaneous Material) (Non-Friable) (Approx. 500 sq. ft.)

Trailer/Cabin, Kitchen, North end, center

0904-1-2 Homogeneous Area #1:

Multicolored sheet vinyl flooring & brown mastic (Miscellaneous Material) (Non-Friable) (Approx. 500 sq. ft.)

Trailer/Cabin, Bathroom, Center

0904-1-3 Homogeneous Area #1:

Multicolored sheet vinyl flooring & brown mastic (Miscellaneous Material) (Non-Friable) (Approx. 500 sq. ft.)

Trailer/Cabin, South bedroom Southeast corner

0904-2-1 Homogeneous Area #2:

White drywall ceiling texture (Surfacing Material) (Friable) (Approx. 605 sq. ft.)

Trailer/Cabin, South bedroom Ceiling, center

0904-2-2 Homogeneous Area #2:

White drywall ceiling texture (Surfacing Material) (Friable) (Approx. 605 sq. ft.)

Trailer/Cabin, Hall, Center adjacent bathroom

0904-2-3 Homogeneous Area #2:

White drywall ceiling texture (Surfacing Material) (Friable) (Approx. 605 sq. ft.)

Trailer/Cabin, Kitchen, North end, center

0904-3-1 Homogeneous Area #3:

Drywall ceiling paneling (Miscellaneous Material) (Friable) (~500 sq. ft.)

Trailer/Cabin, South bedroom Ceiling, center

0904-3-2 Homogeneous Area #3:

Drywall ceiling paneling (Miscellaneous Material) (Friable) (~500 sq. ft.)

Trailer/Cabin, Kitchen, Ceiling, center

& Material Description:

Sample Location:

0904-4-1 Homogeneous Area #4:

White sink undercoating (Miscellaneous Material) (Non-Friable) (1 sink) (~5 sq. ft.)

Trailer/Cabin, Kitchen, East underside of sink

0904-4-2 Homogeneous Area #4:

White sink undercoating (Miscellaneous Material) (Non-Friable) (1 sink) (~5 sq. ft.)

Trailer/Cabin, Kitchen, West underside of sink

0904-5-1 Homogeneous Area #5:

Ceramic tile, adhesive, grout & underlayment (Miscellaneous Material) (Non-Friable) (~1 sq. ft.)

Trailer/Cabin, Kitchen, East end of counter top

0904-5-2 Homogeneous Area #5:

Ceramic tile, adhesive, grout & underlayment (Miscellaneous Material) (Non-Friable) (~1 sq. ft.)

Trailer/Cabin, Kitchen, West end of counter top

0904-6-1 Homogeneous Area #6:

Drywall wall paneling (Miscellaneous Material) (Friable) (~250 sq. ft.)

Trailer/Cabin, West addition, West wall, north end

0904-6-2 Homogeneous Area #6:

Drywall wall paneling (Miscellaneous Material) (Friable) (~250 sq. ft.)

Trailer/Cabin, West addition, West wall, Bathroom

0904-7-1 Homogeneous Area #7:

Ceramic tile, adhesive, grout & underlayment (Miscellaneous Material) (Non-Friable) (~38 sq. ft.)

Trailer/Cabin, West addition, Bathroom, Northwest corner wall

0904-7-2 Homogeneous Area #7:

Ceramic tile, adhesive, grout & underlayment (Miscellaneous Material) (Non-Friable) (~38 sq. ft.)

Trailer/Cabin, West addition, Bathroom, Southwest corner wall

0904-9-1 Homogeneous Area #9:

Exterior window glazing (Miscellaneous Material) (Non-Friable) (~2 sq. ft.)

Trailer/Cabin, Kitchen West window, Top of window

0904-9-2 Homogeneous Area #9:

Exterior window glazing (Miscellaneous Material) (Non-Friable) (~2 sq. ft.)

Trailer/Cabin, Living room, East window, Top of window

0904-11-1 Homogeneous Area #11:

Composite roofing shingles (Miscellaneous Material) (Non-Friable) (~5 sq. ft.)

Trailer/Cabin, East side of roof, Above main entrance

& Material Description:

Sample Location:

0904-11-2 Homogeneous Area #11:

Composite roofing shingles (Miscellaneous Material) (Non-Friable) (~5 sq. ft.)

Trailer/Cabin, East side of roof, Above kitchen window

0904-12-1 Homogeneous Area #12:

Black roofing tar (Miscellaneous Material) (Non-Friable) (~20 sq. ft.)

Trailer/Cabin, West side of roof, Center

0904-12-2 Homogeneous Area #12:

Black roofing tar (Miscellaneous Material) (Non-Friable) (~20 sq. ft.)

Trailer/Cabin, West side of roof, North of center

0904-14-1 Homogeneous Area #14:

Composite roofing shingles (Miscellaneous Material) (Non-Friable) (~50 sq. ft.)

Outhouse, Roof, Southeast corner

0904-14-2 Homogeneous Area #14:

Composite roofing shingles (Miscellaneous Material) (Non-Friable) (~50 sq. ft.)

Outhouse, Roof, Northwest corner

0904-16-1 Homogeneous Area #16:

Drywall wall paneling (Miscellaneous Material) (Friable) (~300 sq. ft.)

Storage building, East wall, Behind shelves, Center

0904-16-2 Homogeneous Area #16:

Drywall wall paneling (Miscellaneous Material) (Friable) (~300 sq. ft.)

Storage building, East wall, Behind shelves, South end

**0904-18-1 Homogeneous Area #18:

Exterior window glazing (Miscellaneous Material) (Friable) (~750 sq. ft.)

Ore load-out structure, Window framing, North end

**0904-18-2 Homogeneous Area #18:

Exterior window glazing (Miscellaneous Material) (Friable) (~750 sq. ft.)

Ore load-out structure, Center

0904-18-3 Homogeneous Area #18:

(Miscellaneous Material) (Friable) (~750 sq. ft.)

Ore load-out structure, South end

0904-19-1 Homogeneous Area #19:

Rubber gaskets with woven cloth (Miscellaneous Material) (Non-Friable) (~50 sq. ft.)

Ore load-out structure, North center

& Material Description:

Sample Location:

0904-19-2 Homogeneous Area #19:

Rubber gaskets with woven cloth (Miscellaneous Material) (Non-Friable) (~50 sq. ft.)

Ore load-out structure, South center

**0904-20-1 Homogeneous Area #18:

(Miscellaneous Material) (Friable) (~600 sq. ft.)

Window framing on ground, East of storage building, Southeast corner of framing

0904-20-2 Homogeneous Area #18:

(Miscellaneous Material) (Friable) (~600 sq. ft.)

Window framing on ground, Center of framing

**0904-20-3 Homogeneous Area #18:

(Miscellaneous Material) (Friable) (~600 sq. ft.)

Window framing on ground, North end of framing

0904-21-1 Homogeneous Area #21:

(Miscellaneous Material) (Non-Friable) (~30 sq. ft.)

Window framing on ground, Southeast corner of framing

0904-21-2 Homogeneous Area #21:

(Miscellaneous Material) (Non-Friable) (~30 sq. ft.)

Window framing on ground, Center of framing

**0904-22-1 Homogeneous Area #22:

(Miscellaneous Material) (Friable) (~1,250 sq. ft.)

Mine entry structure, East side, south end

**0904-22-2 Homogeneous Area #22:

(Miscellaneous Material) (Friable) (~1,250 sq. ft.)

Mine entry structure, East side, center

**0904-22-3 Homogeneous Area #22:

(Miscellaneous Material) (Friable) (~1,250 sq. ft.)

Mine entry structure, Ceiling, center

** Point count analysis identified ≤ 1.0% asbestos in the sample submitted. The material is not regulated by EPA or CDPHE-AQCC. OSHA regulations require employees to document potential exposure to employees handling these materials and maintain exposure limits below the Permissible Exposure Limit (PEL) of 0.1 fibers/cubic Centimeter (f/cc) over an eight-hour time weighted average (TWA).

7.0 Inspector Comments

Sunrise Environmental, Inc. collected and analyzed a total of nine (9) samples from three (3) homogeneous areas from the mill debris pile inspected on July 24th 2019. All three (3) Homogeneous Areas inspected at the mill debris pile were found to contain greater than 1% asbestos.

Sunrise Environmental, Inc. collected and analyzed a total of fifty-one (51) samples from twenty-two (22) homogeneous areas for asbestos content from the remainder of the site (other than the mill building debris pile) on September 4th 2019, five (5) of which were found to contain greater than 1% asbestos. Sunrise Environmental, Inc. did not presume any additional Homogeneous Areas as asbestos containing.

The CDPHE-AQCC requires the removal of friable materials and non-friable materials that may become friable during demolition activities prior to demolition. This asbestos inspection was performed for the purpose of demolition.

Sunrise Environmental, Inc. made reasonable efforts to locate and identify Asbestos Containing Building Materials (ACBM) at the Burke-Martin Mine site. The inspectors performed destructive access to access inaccessible areas. If any unidentified materials are encountered during demolition, additional bulk material samples should be collected to determine potential asbestos content.

Rodent feces were observed within the structures at the site during the inspection, making Hantavirus a possibility. Proper precautions and Personal Protective Equipment (PPE) for Hantavirus should be considered by Contractors involved in abatement or demolition activities and any person entering the structures.

All asbestos-containing material quantities listed in Section 4.0 of this report are estimations and should be verified in the field by contractors bidding on asbestos abatement or demolition of the structures. Laboratory results can be found in Appendix A of this report. Google Maps Satellite Image of the Burke-Martin Mine can be found in Appendix B of this report. A site map can be found in Appendix C. The Mill Building Debris Pile Inspection Report performed on July 24th, 2019 can be found in Appendix D. Inspector certifications can be found in Appendix E of this report.

8.0 Conclusions and Recommendations

The materials found to contain greater than 1% asbestos at the site are listed below:

· Gray/tan cementitious paneling (mill debris pile) (H.A. #1 from7/24/19 inspection)

· Gray cementitious paneling (mill debris pile) (H.A. #2 from 7/24/19 inspection)

· Black roofing tar (mill debris pile) (H.A. #3 from 7/24/19 inspection)

· Gray caulk (trailer/cabin) (H.A #8 from 9/4/19 inspection)

· Black & silver roofing tar (trailer/cabin) (H.A. #10 from 9/4/19 inspection)

· Multilayered floor tiles (former office trailer) (H.A. #13 from 9/4/19 inspection)

· Gray caulk (storage shed) (H.A #15 from 9/4/19 inspection)

· Black roofing tar (storage building) (H.A. #17 from 9/4/19 inspection)

The asbestos containing materials listed in bold print above must be removed prior to demolition of the structures or clean-up of the debris piles. Removal of these materials must be performed by a licensed General Abatement Contractor (GAC). If the trailer/cabin, storage shed, or the storage building will be deconstructed by hand, then the non-friable asbestos-containing materials must also be removed prior to deconstruction of those structures.

The mill building debris pile and the former office trailer floor are considered major asbestos spills and must be addressed as soon as possible. Both the mill building debris pile and the former office trailer floor must be stabilized by an application of magnesium chloride, or covered with polyethylene sheeting until such time that the major asbestos spill clean-up at these two areas are performed by a CDPHE licensed GAC in accordance with CDPHE Regulation No. 8.

Laboratory analysis of the following building materials identified less than 1.0% asbestos in the samples submitted. These materials are not regulated by EPA or CDPHE-AQCC. However, OSHA regulations require employees to document potential exposure to employees handling these materials and maintain exposure limits below the Permissible Exposure Limit (PEL) of 0.1 fibers/cubic Centimeter (f/cc) over an eight-hour time weighted average (TWA). The materials found to contain 1.0% or less (trace) asbestos content are listed below:

¨ White metal window glazing (H.A #18 from 9/4/19 inspection) (ore loadout structure) ¨ White metal window glazing (H.A #20 from 9/4/19 inspection)

(window framing on ground east of storage building) ¨ White metal window glazing (H.A #22 from 9/4/19 inspection) (mine entry structure)

The Occupational Safety and Health Administration (OSHA) requires contractors and workers be notified of the presence and location of asbestos and requires employers to protect employees from exposure to asbestos above the permissible exposure limit of 0.10 f/cc, as determined by personnel monitoring, over an 8-hour time weighted average. Appropriate asbestos training for workers is also required. Contractors are responsible to comply with OSHA 29 CFR 1926.1101 requirements.

Building and/or facility owners are required to notify prospective employers applying or bidding for work that can reasonably be expected to work in or occupy areas containing ACM and/or PACM, of the presence of such materials.

9.0 Limitations

The findings set forth in this report are strictly limited in time and scope to the date of the evaluation(s). The conclusions presented in the report are based solely on the services described therein, and not on scientific tasks or procedures beyond the scope of agreed upon services.

Because of the hidden nature of many building components, it may be impossible to determine if all building components have been located and subsequently tested. Destructive testing in some instances is not a viable option. Sunrise Environmental, Inc. does not, therefore, guarantee that all potential ACBM has been located. For the same reasons, estimates of quantities are subject to readily apparent situations. We do warrant, however, that the investigations and methodology reflect Sunrise Environmental, Inc’s best efforts based upon prevailing standard of care and due diligence in the environmental field.

The purpose of this report was to assess the physical characteristics of the subject Site with respect to the presence of asbestos containing building materials. No specific attempt was made to check on the compliance of present or past owners or operators of the Site with federal, state or local laws and regulations, environmental or otherwise.

APPENDIX A

LABORATORY RESULTS

FRS Geotech, Inc.

1441 W. 46th Ave, Ste. 14 Denver, CO 80211-2338

September 12, 2019

Mr. Scott Sanders Sunrise Environmental, Inc.

P.O. Box 429 Black Hawk, CO 80422

Re: Project: Burke-Martin Mine, White River National Forest, Summit County

FRS Lab Number 125114

Phone: (303) 477-2559

(800) 386-3136

FAX: (303) 477-2580

e-mail: frsgeo@ix.netcom.com

Dear Mr. Scott Sanders:

The bulk samples submitted to FRS Geotech, Inc. have been analyzed by polarized light microscopy (PLM), the EPA-recommended method for determination of fibrous constituents in building materials. The percent of asbestos contained in the samples is a visual estimation based upon comparisons with published charts. The results of these analyses are summarized in the enclosed table. This report relates only to the items received and tested by our laboratory. According to requirements set by the National Institute of Standards and Technology/NVLAP, this report must not be used by the client to claim certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. Also, NVLAP guidelines specify that this report should not be reproduced, except in full, without the written approval of FRS.

A copy of your Chain of Custody is attached for your convenience. This report is considered highly confidential. Results will not be discussed with any person not associated with you.

Please call if you have any questions about this work.

Sincerely, David A. Schroeder, Ph.D.

Data Controller

Enclosures

NVLAP Accredited Lab #102078-0

FRS GEOTECH, INC.

1441 W. 46th Avenue, Ste. 14 Denver, CO 80211-2338

Phone: (303) 477-2559

Fax: (303) 477-2580 e-mail: frsgeo@ix.netcom.com

(800) 386-3136RESULTS OF BULK ASBESTOS SAMPLE ANALYSIS

BY POLARIZED LIGHT MICROSCOPY (PLM) EPA-600/R-93/116

Client: Sunrise Environmental, Inc.

Project: Burke-Martin Mine, White River National Forest, Summit County

Lab No.: 125114

Sample No. [layer] Sample Date Summary (%)

Nonasbestos Fibrous Material (%)

Asbestos Minerals (%)Volume (%)Description

0904-1-1

Multi-colored sheet flooring & mastic [brown]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

0904-1-2

Multi-colored sheet flooring & mastic [brown]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

0904-1-3

Multi-colored sheet flooring & mastic [brown]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

0904-2-1

Texture [white sandy with white paint]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

0904-2-2

Texture [white sandy with white paint]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

0904-2-3

Texture [white sandy with white paint]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 100 Others .

100%

--Other Fibrous Material

* Composite analysis (multilayered sample, see individual layer analyses).

Analyst(s): 09/12/2019Completed:

Chris Carbino

Denver, CO 80211-2338

Phone: (303) 477-2559

Fax: (303) 477-2580 e-mail: frsgeo@ix.netcom.com

(800) 386-3136RESULTS OF BULK ASBESTOS SAMPLE ANALYSIS

BY POLARIZED LIGHT MICROSCOPY (PLM) EPA-600/R-93/116

Client: Sunrise Environmental, Inc.

Project: Burke-Martin Mine, White River National Forest, Summit County

Lab No.: 125114

Sample No. [layer] Sample Date Summary (%)

Nonasbestos Fibrous Material (%)

Asbestos Minerals (%)Volume (%)Description

0904-3-1

Drywall panel [white]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

Other Fibrous Material

0904-3-2

Drywall panel [white]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

Other Fibrous Material

0904-4-1

White sink undercoating

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

10 10 Other Fibrous Material

0904-4-2

White sink undercoating

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

10 10 Other Fibrous Material

0904-5-1

Ceramic tile/adhesive/grout/underlayment [white/tan/white/gray]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 80 Others .

100%

Other Fibrous Material

0904-5-2

Ceramic tile/adhesive/grout/underlayment [white/tan/white/gray]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 80 Others .

100%

Other Fibrous Material

* Composite analysis (multilayered sample, see individual layer analyses).

Denver, CO 80211-2338

Phone: (303) 477-2559

Fax: (303) 477-2580 e-mail: frsgeo@ix.netcom.com

(800) 386-3136RESULTS OF BULK ASBESTOS SAMPLE ANALYSIS

BY POLARIZED LIGHT MICROSCOPY (PLM) EPA-600/R-93/116

Client: Sunrise Environmental, Inc.

Project: Burke-Martin Mine, White River National Forest, Summit County

Lab No.: 125114

Sample No. [layer] Sample Date Summary (%)

Nonasbestos Fibrous Material (%)

Asbestos Minerals (%)Volume (%)Description

0904-6-1

Drywall panel [white]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

Other Fibrous Material

0904-6-2

Drywall panel [white]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 90 Others .

100%

Other Fibrous Material

0904-7-1

Ceramic tile/adhesive/grout & underlayment [white/white/white/gray]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 80 Others .

100%

Other Fibrous Material

0904-7-2

Ceramic tile/adhesive/grout & underlayment [white/white/white/gray]

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: None DetectedFiberglass Cellulose

Synthetics

Nonfibrous Material 80 Others .

100%

Other Fibrous Material

0904-8-1

Gray caulk

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: 15Fiberglass Cellulose

Synthetics

Nonfibrous Material 85 Others .

100%

-- 15 Other Fibrous Material

0904-8-2

Gray caulk

09/04/19 Amosite Anthophyllite

Chrysotile Crocidolite Trem./Act.

Total Asbestos: 15Fiberglass Cellulose

Synthetics

Nonfibrous Material 85 Others .

100%

-- 15 Other Fibrous Material

* Composite analysis…