Pre-Demolition Asbestos Inspection Cash Lode Cabin Site.pdf

Asbestos Consulting Services

Sunrise Environmental, Inc.

PO Box 429 - 371 Crest View Drive

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

PRE-DEMOLITION

ASBESTOS INSPECTION

SPOT CASH LODE CABIN

SECTION 2, TOWNSHIP 8 SOUTH RANGE 78 WEST

GPS: 39° 23’ 03.95” NORTH –106° 04’ 28.60” WEST

WHITE RIVER NATIONAL FOREST

SUMMIT COUNTY, COLORADO

PREPARED FOR:

White River National Forest

900 Grand Avenue Glenwood Springs, Colorado

81601

PROJECT: SEI21-P097

PREPARED: July 20, 2021 http://www.sunrise-enviro.com/

Spot Cash Lode Cabin WRNF – Summit County Colorado

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 5

2.2 Building Description 5

2.3 Review of Existing Information 5

3.0 METHODS AND TECHNIQUES 6

3.1 Inspection 6

3.2 Bulk Sampling 6

3.3 Sample Analysis 7

4.0 ASBESTOS-CONTAINING MATERIAL DESCRIPTIONS

AND RECOMMENDATIONS 8

5.0 PRESUMED ASBESTOS CONTAINING MATERIAL

DESCRIPTIONS AND RECOMMENDATIONS 10

6.0 NON-ASBESTOS CONTAINING MATERIAL DESCRIPTIONS 10

7.0 INSPECTOR COMMENTS 11

8.0 CONCLUSIONS AND RECOMMENDATIONS 11

9.0 LIMITATIONS 12

Appendices

Appendix A – Analytical Data Appendix B – Site Diagram Appendix C – Bulk Sample Location Diagram Appendix D – Asbestos Containing Material Location Diagram 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 Spot Cash Lode Cabin, Section 2, Township 8 South, Range 78 West, GPS: 39° 23’ 03.95” North –106° 04’ 28.60” West, 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.

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 Spot Cash Lode Cabin, Section 2, Township 8 South, Range 78 West, GPS: 39° 23’ 03.95” North –106° 04’ 28.60” West, White River National Forest located in Summit County, Colorado. The inspection was performed by Mr. Scott D. Sanders of Sunrise Environmental, Inc. June 28, 2021. 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.

Sunrise Environmental, Inc. collected and analyzed a total of thirteen (13) samples from six (6) homogeneous areas for asbestos content, one (1) of which was found to contain greater than 1% asbestos. Sunrise Environmental, Inc. did not presume any additional Homogeneous Areas as asbestos containing.

The material found to contain greater than 1% asbestos at the site is listed below:

• Black roofing tar (H.A. #3) (roof)

The asbestos containing material listed above must be removed prior to manual deconstruction (demolition) of the cabin. Removal of these materials should be performed by personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the cabin.

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 cabin.

• Identify suspect asbestos containing materials (ACM) on the surface of the ground surrounding the cabin.

• 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 Inspector Scott D. Sanders.

2.2 Building Description

The cabin is primarily constructed of wood and with metal roofing.

2.3 Review of Existing Information

No previous asbestos inspection documentation regarding the site was provided for review.

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 of Sunrise Environmental, Inc.

performed the inspection June 28th, 2021. Mr. Scott D. Sanders is a Colorado Department of Public Health and Environment (CDPHE-AQCC) certified asbestos building inspector. The inspector visually inspected the cabin 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.

Sample locations for Surfacing Materials (if collected) were randomly determined according to the EPA “Pink Book” asbestos in buildings:

Simplified Sampling Scheme for Friable Surfacing Materials (1985).

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 thirteen (13) samples were collected for analysis from six (6) Homogeneous Areas.

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/R-93/116 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. None of the samples collected were submitted for point count analysis.

The analysis of the bulk samples was performed on July 16, 2021 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 – 3

Material Description: Black roofing tar 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 Roof, ~2 sq. ft. over ~300 sq. ft. Non-friable ACBM various locations of metal roofing

Sample No. Sample Location Composition 3-1 Roof, 30% Chrysotile

Northeast corner On metal roofing

3-2 Roof, 30% Chrysotile

North side West of center

General Recommendations

The black roofing tar is considered non-friable. Maintain material in undamaged condition. Do not sand, grind, drill or abrade the material. The black roofing tar should be removed by personnel trained in asbestos removal techniques and personal protective equipment prior to deconstruction of the cabin. Since the black roofing tar is scattered throughout the roof, all of the roofing must be removed if manual deconstruction of the cabin will be performed.

Photo of Homogeneous Area #3, 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 and were found to contain 1% or less asbestos:

Sample Number:

Homogeneous Area & Material Description:

Sample Location:

1-1 Homogeneous Area #1: (~1 sq. ft.)

White window caulk (Miscellaneous Material) (Non-Friable)

Lower west window, North side of window

1-2 Homogeneous Area #1: (~1 sq. ft.)

White window caulk (Miscellaneous Material) (Non-Friable)

Lower west window, South side of window

2-1 Homogeneous Area #2: (~1 sq. ft.)

(Miscellaneous Material) (Non-Friable)

North window, East side of window

2-2 Homogeneous Area #2: (~1 sq. ft.)

(Miscellaneous Material) (Non-Friable)

North window, West side of window

4-1 Homogeneous Area #4: (<1 sq. ft.)

Black tar paper roof underlayment (Miscellaneous Material) (Non-Friable)

Roof, Northeast corner

4-2 Homogeneous Area #4: (<1 sq. ft.)

Black tar paper roof underlayment (Miscellaneous Material) (Non-Friable)

Roof, Southeast corner

5-1 Homogeneous Area #5: (1 sq. ft.)

Tan ceramic tile adhesive (Miscellaneous Material) (Non-Friable)

Loose tiles at exterior southwest corner of cabin, East side

5-2 Homogeneous Area #5: (1 sq. ft.)

Tan ceramic tile adhesive (Miscellaneous Material) (Non-Friable)

Loose tiles at exterior southwest corner of cabin, West side

5-3 Homogeneous Area #5: (<1 sq. ft.)

White window caulk (Miscellaneous Material) (Friable)

South side, West window, Top of window

6-1 Homogeneous Area #6: (<1 sq. ft.)

Wood stove fire brick (Thermal System Insulation) (Non-Friable)

Wood stove, 25 ft. south of cabin, Upper west side of stove

6-2 Homogeneous Area #6: (<1 sq. ft.)

Wood stove fire brick (Thermal System Insulation) (Non-Friable)

Wood stove, 25 ft. south of cabin, Upper east side of stove

6-3 Homogeneous Area #6: (<1 sq. ft.)

Wood stove fire brick (Thermal System Insulation) (Non-Friable)

Wood stove, 25 ft. south of cabin, Middle east side of stove

7.0 Inspector Comments

Sunrise Environmental, Inc. identified and sampled a total of six (6) Homogeneous Areas, one (1) of which was found to contain greater than 1% asbestos. Sunrise Environmental, Inc. did not presume any additional building materials to contain greater than 1% asbestos. 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 Spot Cash Lode Cabin. The inspectors performed destructive access to access inaccessible areas. If hidden unidentified materials are encountered during demolition, additional bulk material samples should be collected to determine potential asbestos content.

Rodent feces were observed within the cabin 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 cabin.

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 cabin. Analytical Data can be found in Appendix A. Site Location Diagram is in Appendix B.

Bulk Sample Location Diagram is in Appendix C. Asbestos-Containing Material Location Diagram is in Appendix D. Inspector certifications are in Appendix E of this report.

8.0 Conclusions and Recommendations

The material found to contain greater than 1% asbestos at the site is listed below:

• Black roofing tar (H.A. #3) (roof)

Since the cabin will be deconstructed by hand, the asbestos-containing materials identified should be removed by personnel trained in asbestos removal techniques and personal protective equipment prior to the manual deconstruction (demolition) of the cabin.

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

ANALYTICAL DATA

FRS Geotech, Inc.

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

July 16, 2021

Mr. Scott Sanders Sunrise Environmental, Inc.

P.O. Box 429 Black Hawk, CO 80422

Re: Project: Spot Cash Cabin, White River Natl. Forest, Summit County, CO

FRS Lab Number 126245

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

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APPENDIX B

SITE DIAGRAM

APPENDIX C

ASBESTOS BULK SAMPLE

LOCATION DIAGRAM

39° 23'03.95"N, 106° 04'28.60"W

ASBESTOS BULK SAMPLE LOCATION DIAGRAM

APPROXIMATE - NOT TO SCALE

SHED

MAIN

CABIN

1-1

1-2

2-12-2

ROOF

3-1 4-1

ROOF

3-2

ROOF

4-2

5-15-2

WOOD

STOVE

6-1 6-2 6-3

APPENDIX D

ASBESTOS CONTAINING BUILDING MATERIAL

LOCATION DIAGRAM

39° 23'03.95"N, 106° 04'28.60"W

ASBESTOS CONTAINING

MATERIAL LOCATION DIAGRAM

APPROXIMATE - NOT TO SCALE

SHED

MAIN

CABIN

HA #3 - ROOFING TAR

APPENDIX E

CERTIFICATIONS