T.S. Kings Pointer - Asbestos Survey Report - Sept. 2020 (Rev. 1).pdf

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TRAINING VESSEL KINGS POINTER (TVKP) FY 25 REGULATORY DRY DOCK
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6933A224Q000010
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About this file

This document is an Asbestos Survey Report for the Training Ship T.S. Kings Pointer located at the United States Merchant Marine Academy (USMMA) in Kings Point, NY. The survey was conducted on September 29, 2020 by Castle Hill Associates (Prime) and BSI Services and Solutions Inc. (Sub) for the U.S. Maritime Administration.

The key findings are that two types of asbestos-containing materials were identified - red and tan linoleum sheet flooring in various locations throughout the vessel. The total quantity of asbestos-containing materials is 110 square feet. The materials are in good condition and the recommended response action is Operations and Maintenance (O&M) until their removal at the time of renovation. No other asbestos-containing materials were detected during the survey.

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Text version

ASBESTOS SURVEY REPORT

FOR

T.S. KINGS POINTER

AT

USMMA

300 STEAMBOAT ROAD

KINGS POINT, NY 11024

CLIENT:

U.S. MARITIME ADMINISTRATION

DIVISION OF ATLANTIC OPERATIONS

7737 HAMPTON BLVD. – BLDG. 19, STE 300

NORFOLK, VA 23505

ORDER # 6933A220P000062

INSPECTION DATE:

SEPTEMBER 29, 2020

PRIME CONTRACTOR:

CASTLE HILL ASSOCIATES, LLC

218-A MECHANIC ST.

WATERVILLE, OH 43566

567-952-0212

T.S. KINGS POINTER - USMMA

SEPTEMBER 2020

TABLE OF CONTENTS

1. ASBESTOS INSPECTION

• PROJECT SUMMARY

• INSPECTION OVERVIEW & FINDINGS

• INSPECTOR INFORMATION

• ASBESTOS BACKGROUND INFORMATION

• ASBESTOS CONTAINING MATERIAL PHOTOS

• ASBESTOS MATERIALS ASSESSMENT

• HOMOGENEOUS SAMPLING AREA DESCRIPTIONS

• ASBESTOS BULK SAMPLING DATA & LAB RESULTS

APPENDICES

Appendix A – Asbestos Sample Location Plans

Appendix B – Asbestos Laboratory Reports & Chain of Custody

Appendix C – Consultant Certifications

Appendix D – Laboratory Certifications

PROJECT SUMMARY

On September 29, 2020, Castle Hill Associates (Prime) and BSI Services and Solutions Inc.

(Sub) performed an asbestos survey of the Training Ship T.S. Kings Pointer located at the United States Merchant Marine Academy (USMMA) in Kings Point, NY in accordance with the SOW issued by the U.S. Maritime Administration. The intent was to identify the asbestos containing materials inside and outside the vessel including mechanical systems, structural components, and finishes.

Prior to this inspection, an interview was conducted with the Chief Engineer along with records of previous asbestos testing. According to previous testing, it was determined that the only asbestos containing materials identified in the vessel were linoleum sheet flooring.

Some of this flooring was reported to have been replaced as part of previous renovations to the vessel.

Vessel Background Information

Builder: Atlantic Marine Inc. Fort George Island, Florida Operator: USMMA Launched: October 01, 1980 Class and type: Solid Rocket Booster Recovery Vessel, School Ship Tonnage: 484 GRT Length: 176 ft Beam: 37 ft Height: 72 ft Draft: 12 ft Propulsion: 2 x 1450 hp GM EMD 12-645E6A Diesel Engines, 2 x 450 hp Detroit Diesel 8V71 engine driving bow and stern thrusters.

Speed: 15 knots Complement: 50 (6 crew, 44 cadets) on day voyage less than 12 hours. On voyages over 12 hours (9 crew, 31 cadets).

INSPECTION OVERVIEW & FINDINGS

SAMPLING OVERVIEW

A total of 15 asbestos bulk samples and sample layers analyzed in accordance with the State of New York regulations as follows:

• PLM NYS 198.1 Friable (7 layers)

• PLM NYS 198.6 NOB (10 layers)

• TEM NYS 198.4 NOB (9 layers)

All samples were collected in and on the vessel of suspect asbestos containing materials. All bulk sampling of suspected asbestos was based upon the appearance, texture, and location of the material in accordance with US EPA NESHAP regulations. All bulk samples were analyzed utilizing current EPA and NYS methods for PLM (Polarized Light Microscopy) and TEM (Transmission Electron Microscopy) by EMSL Analytical, Inc. in Cinnaminson, NJ. The laboratory is accredited by the NIST, NVLAP program (National Institute of Standards and Technology, National Voluntary Laboratory Accreditation Program), is an American Industrial Hygiene Association (AIHA) accredited laboratory, and is certified by the State of New York as an asbestos bulk sample laboratory.

FINDINGS:

Asbestos Containing

Material Locations Quantity Condition

Red linoleum sheet flooring Top of stairs to lower deck off Galley

6 sf Good – No Damage

Tan linoleum sheet flooring Lower deck – Forward hallway and passage hall to Engine room

104 sf Good – No Damage

INSPECTOR INFORMATION

The project manager for the survey was Brett Brumbaugh of Castle Hill Associates who is an EPA trained asbestos inspector, management planner, and project designer since 1987. He is a Registered Environmental Property Assessor (REPA) and Certified Environmental and Safety Officer (CESCO) through the NREP (National Registry of Environmental Professionals).

The NY certified asbestos inspector for the survey was Ryan Baksh who is certified by the NY Dept. of Labor, license #16-05688.

Chief Highlight

ASBESTOS BACKGROUND INFORMATION

The term asbestos describes six naturally occurring fibrous minerals found in certain types of rock formations. The minerals chrysotile, amosite, and crocidolite have been most commonly used in building products such as floor tile, pipe insulation, boiler insulation, asbestos cement materials, roofing materials, and plasters. The minerals anthophyllite, actinolite, and tremolite are not frequently found in ACBM.

Intact and undisturbed ACBM do not pose a health risk. They may, however, become a health hazard if they are damaged, disturbed, or deteriorate over time and release fibers into the air. If released into the air, asbestos fibers may be inhaled. After prolonged or intense exposure, inhaled asbestos fibers may cause various types of lung disease. The health risks associated with asbestos exposure are greater for those who smoke.

REGULATORY BACKGROUND INFORMATION

Federal Regulations The United States Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and delegated states are responsible for regulating environmental exposure and protecting workers from asbestos exposure. OSHA is responsible for the health and safety of workers who may be exposed to asbestos in connection with their jobs (Occupational Exposure to Asbestos; Title 29, Code of Federal Regulations (CFR) Parts 1910.1001 and 1926.1101). The EPA and state regulators are responsible for developing and enforcing regulations necessary to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health.

In 1979, EPA began an asbestos technical assistance program for building owners, environmental groups, contractors, and industry. In May 1982, EPA issued the first regulation intended to control asbestos in schools under the authority of the Toxic Substances Control Act (TSCA); this regulation is known as the Asbestos-in-Schools Rule.

Two EPA regulations govern asbestos: The Asbestos Hazard Emergency Response Act (AHERA) and the National Emission Standards for Hazardous Air Pollutants (NESHAP).

AHERA

In 1986, Congress enacted AHERA (Title 40, CFR Part 763) which mandated a regulatory program to address the asbestos hazards in schools. A part of AHERA deals with the mandatory training and accreditation of persons who perform certain types of asbestos-related work in schools.

Subsequently, in 1990 Congress amended AHERA to extend some of the training and accreditation requirements to persons performing such work in public and commercial buildings.

AHERA requires inspections of school buildings to determine the conditions of ACBM and preparation of management plans which recommend the best way to reduce the asbestos hazards. U.S.

government agencies have adopted many of the requirements of AHERA for surveys performed at federal facilities. The methods may include removal, encapsulation, enclosure, repair, and operations and maintenance to protect human health and the environment from ACBM.

NESHAP

The Clean Air Act (CAA) of 1970 required EPA to develop and enforce regulations to protect the general public from exposure to airborne contaminants that are known to be hazardous to human health; therefore, EPA promulgated NESHAP (Title 40, CFR Part 61) on April 6, 1973.

NESHAP is intended to minimize the release of asbestos fibers during certain activities (i.e., renovations, demolition, and installations). It specifies work practices to be followed during renovations of buildings (except apartment buildings that have no more than four dwelling units) which contain a specific amount of friable asbestos. NESHAP requires that buildings be inspected for ACBM prior to renovation/demolition projects.

NESHAP also requires owners and operators subject to the asbestos rules to notify delegated state and local agencies and/or the regional EPA offices before demolition or renovation activities begin. In addition, NESHAP requires the removal of all friable ACBM prior to demolition.

OSHA

OSHA began regulating workplace asbestos exposure in 1970, adopting a permissible exposure limit (PEL) to regulate worker exposure. The original asbestos standard has been revised several times to better protect workers. On August 10, 1994, OSHA issued a revised final standard regulating asbestos exposure in all industries. The newly revised standard for the construction industry lowers the PEL. The revised standard also establishes a new classification system for asbestos construction work, which clearly spells out mandatory work practices to follow to reduce worker exposures (see Occupational Exposure to Asbestos, Title 29, CFR 1926.1101).

State and Local Regulations New York state regulations are similar to the Federal regulations. In many instances state and local asbestos regulations are more stringent, therefore, it is recommended that the applicable state asbestos regulation(s) be reviewed before the start of any renovation/demolition projects.

State asbestos regulations include requirements for licensing and certification of personnel who will perform asbestos-related work activities. All personnel who engage in asbestos-related activities must comply with the state licensing/certification requirements as well as with all Federal requirements.

ANALYTICAL METHODS AND LIMITATIONS

Bulk Sampling Protocol EPA and OSHA define an ACBM as any material which contains greater than 1percent asbestos (some state regulations may be more stringent). The ACBM inspection and bulk sampling were performed in accordance with the methods outlined in the EPA guidance document titled Guidance for Controlling Asbestos-Containing Materials in Buildings (Document No. 560/5-85/024). In addition, bulk sampling of asbestos was performed in accordance with 40 CFR Part 763, AHERA requirements for number of samples and types of ACBM to be sampled. According to these requirements, materials are classified as either surfacing (e.g., decorative plaster, spray-applied fireproofing), thermal system insulation (e.g., pipe insulation, pipe fitting insulation, boiler insulation), or miscellaneous materials (e.g., floor tile, ceiling tile, plaster, wallboard, mastics).

The number of samples collected from each material varies based on the classification of the material and increases as the potential for a non-uniform mixture of asbestos in the material increases. Typically, regulations require a minimum number of samples to be collected from the different classifications of suspect ACBM, as follows:

• Surfacing Material

a) Three samples from homogeneous areas up to 1,000 square feet

b) Five samples from homogeneous areas between 1,000 and 5,000 square feet

c) Seven samples from homogeneous areas over 5,000 square feet

• Thermal System Insulation

a) Minimum of three samples per homogeneous area

• Miscellaneous Material

a) Minimum of one sample per homogeneous area, but must be sufficient to determine asbestos content based on the discretion of the inspector

EXPLANATION OF ASSESSMENT OF ACM’S

Asbestos inspection protocols are based on the Asbestos Hazard Emergency Response Act (AHERA), Environmental Protection Act’s (EPA’s) revised Asbestos Model Accreditation Plan (MAP) mandated by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA). The tabular listing included in this report contains Room Number, Material Category (i.e., TSI, SM or MM), Material Type, quantity, a numerical priority ranking, condition, potential for damage, potential for human exposure, drawing number, hazard ranking, recommended response action and associated cost estimate for implementation of those response actions.

The material assessment categories of the ACM identified in the building is formatted in the following order for the summary tables enclosed in this report:

• Material Category - Surfacing Material (SUR); Thermal System Insulation (TSI); Miscellaneous (MM)

• Material Type - Friable (F); Non-Fable (NF)

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

• Recommended Response Action - 1 through 7

Material category is the type of material such as surfacing material (SUR), thermal system insulation (TSI), and miscellaneous (MM)

• Surfacing Material (SUR) - Surfacing ACM means surfacing material that is ACM. Surfacing material means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

• Thermal System Insulation (TSI) - Thermal system insulation ACM means thermal system insulation that is ACM. Thermal system insulation means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

• Miscellaneous (MM) - Miscellaneous ACM means miscellaneous material that is ACM Miscellaneous material means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

Material type refers to the hardness of a material to be crumbled, pulverized, or reduced to powder by hand pressure as friable (F), and includes previously non-friable (NF) material after such previously non-friable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

• Condition of Material - Good; Fair; Poor

• Potential for Damage - Low; Medium; High

• Physical Assessment - Low; Medium; High

Seven Categories define in the AHERA regulation one of which must be assigned to each friable surfacing and miscellaneous ACBM and each asbestos-containing TSI during the inspection/re-inspection.

1. Damaged or significantly damaged TSI ACBM - Damaged or significantly damaged thermal system insulation ACM means thermal system insulation ACM on pipes, boilers, tanks, ducts, and other thermal system insulation equipment where the insulation has lost its structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured, missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by occasional punctures, gouges or other signs of physical injury to ACM; occasional water damage on the protective coverings/jackets;

or exposed ACM ends or joints. Asbestos debris originating from the ACBM in question may also indicate damage.

2. Damaged friable surfacing ACBM - Damaged friable surfacing ACM means friable surfacing ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or which has delaminated such that its bond to the substrate (adhesion) is inadequate, or which, for any other reason, lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

3. Significantly damaged friable surfacing ACBM - Significantly damaged friable surfacing ACM means damaged friable surfacing ACM in a functional space where the damage is extensive and severe.

4. Damaged or significantly damaged friable miscellaneous ACBM - Damaged friable miscellaneous ACM means friable miscellaneous ACM which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is inadequate or, if applicable, which has delaminated such that its bond to the substrate (adhesion) is inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the substrate; flaking, blistering, or crumbling of the ACM surface; water damage; significant or repeated water stains, scrapes, gouges, mars or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

5. ACBM with Potential for Damage - Potential damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

6. ACBM with potential for significant damaged - Potential significant damage means circumstances in which:

(1) Friable ACBM is in an area regularly used by building occupants, including maintenance personnel, in the course of their normal activities.

(2) There are indications that there is a reasonable likelihood that the material or its covering will become significantly damaged, deteriorated, or delaminated due to factors such as changes in building use, changes in operations and maintenance practices, changes in occupancy, or recurrent damage.

7. Any remaining friable ACBM or Friable Suspected ACBM

CONCLUSION/RECOMMENDATIONS

An operations and maintenance (O&M) program should be developed for the positively identified ACBM in the vessel. Any renovation/demolition work which may impact these positive materials should be conducted in accordance with the O&M program and all applicable Federal, state, and local regulations by appropriately trained and approved personnel and contractors. Since demolition was not performed as part of the inspection, certain areas such as pipe chases and areas above fixed permanent ceilings were not inspected or tested.

Prior to renovation and alteration work which could impact these areas, Castle Hill recommends that exploratory demolition be performed and a qualified inspector be utilized to examine the areas and collect samples as needed.

Respectfully Submitted:

Brett L. Brumbaugh – Project Manager

TABLE 1

LIST OF ACRONYMS

ACBM Asbestos Containing Building Material ACM Asbestos Containing Material AHERA Asbestos Hazard Emergency Response Act AIHA American Industrial Hygiene Association CAA Clean Air Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency HazCom Hazard Communication HEPA High Efficiency Particulate Air Filter HVAC Heating, Ventilation, and Air Conditioning MISC Miscellaneous Asbestos Containing Material NESHAP National Emission Standards for Hazardous Air Pollutants NIOSH National Institute for Occupational Safety and Health NIST National Institute of Standards and Technology NOB Non-friable Organically Bound NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PAT AIHA Proficiency Analytical Testing Program PCM Phase Contrast Microscopy PEL Permissible Exposure Limit PLM Polarized Light Microscopy TEM Transmission Electron Microscopy TSCA Toxic Substances Control Act TSI Thermal Systems Insulation Castle Hill Castle Hill Associates, LLC XRD X-Ray Diffraction

TABLE 2

REMOVAL PRIORITY PROTOCOLS

HAZARD

RANK

REMOVAL

PRIORITY

AHERA

CATEGORY

RESPONSE ACTION

RECOMMENDATION

7 1 Significantly Damaged

Evacuate or isolate the area.

Remove or repair if feasible.

O&M for all friable ACM.

6 2 Damaged with potential for significant damage

Evacuate or isolate the area.

Remove, encapsulate, or repair if feasible. O&M for all friable

ACM.

5 3 Damaged with potential for damage

Remove, encapsulate, or repair. O&M for all friable ACM.

4 4 Damaged Remove, encapsulate, or repair. O&M for all friable ACM.

3 5 Potential for significant damage

Take steps to reduce potential for damage. O&M for all friable

ACM.

2 6 Potential for damage O&M for all friable ACM.

1 7 No problem O&M for all friable ACM.

ASBESTOS CONTAINING MATERIAL PHOTOS

PHOTOGRAPHS OF ASBESTOS MATERIALS

Photo A-1 Red linoleum sheet flooring at top of stairs from main deck galley to lower deck

Photo A-2

Tan linoleum sheet flooring in passage hallway to

Engine Room under carpet runner and 12” self-stick floor tile

Photo A-3 Tan linoleum sheet flooring in forward hallway by quarters in lower deck

ASBESTOS MATERIALS ASSESSMENT

T.S. Kings Pointer

USMMA - Kings Point, NY

Asbestos Assessments and Cost Estimates

September 2020

Asbestos Material Locations Quantity

AHERA

Category Friability

AHERA

Assessment Recommendation

Removal

Priority

Repair Cost

Estimate

Removal Cost

Estimate

Red Linoleum sheet flooring Main Deck - Stair landing to lower deck off of

Galley 6 SF MISC Non-friable 1 O&M; Remove at renovation 7 No damage $1,500

Tan Linoleum sheet flooring Lower deck – Forward hallway and passage hall to Engine room 104 SF MISC Non-friable 1 O&M; Remove at renovation 7 No damage $4,000

TOTAL $5,500

HOMOGENEOUS SAMPLING AREA DESCRIPTIONS

ASBESTOS HOMOGENEOUS SAMPLING AREA DESCRIPTIONS

HOMOG.

AREA

MATERIAL

ASBESTOS

MATERIAL

A Gray duct seam mastic No B Red pattern linoleum sheet flooring YES C Linoleum mastic (yellow) No D Black vinyl cove base No E Brown mastic No F Gray pattern linoleum sheet flooring No G Linoleum mastic (yellow) No H Tan pattern linoleum sheet flooring YES I Linoleum mastic (yellow) No J Diesel exhaust flue block insulation No K Diesel exhaust flue block insulation No L Diesel exhaust flue block insulation No M Interior window frame caulking No

ASBESTOS BULK SAMPLING DATA

ASBESTOS BULK SAMPLE DESCRIPTIONS & RESULTS

Vessel: T.S. Kings Pointer Location: USMMA – Kings Point, NY Sampling Date: September 29, 2020 Analysis Dates: October 6-7, 2020 Laboratory: EMSL Analytical, Inc. – Cinnaminson, NJ Certification: NVLAP Lab Code 101048-0, NY Accredited PLM Laboratory Methods: PLM (NYS 198.1 Friable; 198.6 VCM; 198.6 NOB) TEM by NYS 198.4 NOB)

SAMPLE

# HA SAMPLE LOCATION MATERIAL DESCRIPTION LABORATORY RESULTS

A Main Level forward storage exhaust duct Gray duct seam mastic No Asbestos Detected

2a B Stair landing – Main level

Red linoleum sheet flooring 3.90% Chrysotile Asbestos

2b C “” Linoleum mastic (yellow) No Asbestos Detected

3a D Stair landing – Main level

Black vinyl cove base No Asbestos Detected

3b E “” Brown mastic No Asbestos Detected

4a F Lower deck hallway – Aft Gray pattern linoleum sheet flooring <1% Chrysotile Asbestos

4b G “” Linoleum mastic (yellow) No Asbestos Detected

5a H Lower deck hallway - Forward

Tan linoleum sheet flooring 2.40% Chrysotile Asbestos

5b I “” Linoleum mastic (yellow) No Asbestos Detected

6 J Detroit diesel engine 1 Diesel exhaust flue block insulation No Asbestos Detected

7 J Detroit diesel engine 2 Diesel exhaust flue block insulation No Asbestos Detected

8 J Main engine 1 Diesel exhaust flue block insulation No Asbestos Detected

9 J Main engine 2 Diesel exhaust flue block insulation No Asbestos Detected

10 K Engine in passage to thruster room

Diesel exhaust flue block insulation No Asbestos Detected

11 L Bow thruster engine room – 14” exhaust pipe

Diesel exhaust flue block insulation No Asbestos Detected

12 L Bow thruster engine room – 30” exhaust pipe

Diesel exhaust flue block insulation No Asbestos Detected

13a D Forecastle deck hallway Black vinyl cove base No Asbestos Detected

13b E “” Brown mastic <1% Chrysotile Asbestos

14 M Bridge window Interior window frame caulking No Asbestos Detected

15a F Bridge deck Gray pattern linoleum sheet flooring No Asbestos Detected

15b G “” Linoleum mastic (yellow) No Asbestos Detected

Notes:

1. Asbestos containing materials are defined by the EPA as containing greater than 1% asbestos

2. HA = Homogeneous Sampling Area (includes areas with homogeneous building materials)

APPENDIX A

ASBESTOS SAMPLE LOCATION PLANS

APPENDIX B

ASBESTOS LABORATORY ANALYTICAL REPORTS

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042023925EMSL Order:

Customer ID: CHAS42

Customer PO:

Project ID:

Attention: Phone:Brett Brumbaugh (567) 952-0212

Fax:Castle Hill Associates, LLC

Received Date:218-A Mechanic St. 10/01/2020 9:30 AM

Analysis Date:Waterville, OH 43566 10/06/2020 - 10/07/2020

Collected Date: 09/29/2020

Project: TV Kings Pointer - USMMA

Test Report:Asbestos Analysis of Bulk Material

Test Color

Analyzed

Date Fibrous Non-Fibrous Asbestos

Non-Asbestos

Sample ID 1 Description - Gray Duct Seam Mastic

042023925-0001 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray None Detected10/07/2020 100.00% Other

Sample ID 2 Description - Red Linoleum

042023925-0002 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Red10/06/2020 None 100.00% Other Inconclusive : <1% Chrysotile

TEM NYS 198.4 NOB Red10/07/2020 None 96.10% Other 3.90% Chrysotile

Sample ID 3-Cove Base Description - Black Cove Base

042023925-0003 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray None Detected10/07/2020 100.00% Other

Sample ID 3-Mastic Description - Mastic

042023925-0003A Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Yellow Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Yellow None Detected10/07/2020 100.00% Other

Sample ID 4 Description - Gray Linoleum

042023925-0004 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray10/07/2020 None 100.00% Other <1% Chrysotile

Initial report from: 10/07/2020 12:34:05

Page 1 of 4ASB_198x_0009 - 1.71 Printed 10/7/2020 11:47:35PM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042023925EMSL Order:

Customer ID: CHAS42

Customer PO:

Project ID:

Test Report:Asbestos Analysis of Bulk Material

Test Color

Analyzed

Date Fibrous Non-Fibrous Asbestos

Non-Asbestos

Sample ID 5 Description - Tan Linoleum

042023925-0005 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Tan10/06/2020 None 97.60% Other 2.40% Chrysotile

TEM NYS 198.4 NOB Not Analyzed

Sample ID 6 Description - Exhaust Breeching Insulation

042023925-0006 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 30.00% Min. Wool 70.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 7 Description - Exhaust Breeching Insulation

042023925-0007 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 5.00% Cellulose 95.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 8 Description - Exhaust Breeching Insulation

042023925-0008 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 10.00% Cellulose 90.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 9 Description - Exhaust Breeching Insulation

042023925-0009 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 10.00% Cellulose 90.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 10 Description - Exhaust Breeching Insulation

042023925-0010 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 10.00% Cellulose 90.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Page 2 of 4ASB_198x_0009 - 1.71 Printed 10/7/2020 11:47:35PM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042023925EMSL Order:

Customer ID: CHAS42

Customer PO:

Project ID:

Test Report:Asbestos Analysis of Bulk Material

Test Color

Analyzed

Date Fibrous Non-Fibrous Asbestos

Non-Asbestos

Sample ID 11 Description - Exhaust Breeching Insulation

042023925-0011 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 10.00% Cellulose 90.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 12 Description - Exhaust Breeching Insulation

042023925-0012 Homogeneity Homogeneous

PLM NYS 198.1 Friable Gray None Detected10/06/2020 10.00% Cellulose 90.00% Non-fibrous (other)

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Not Analyzed

TEM NYS 198.4 NOB Not Analyzed

Sample ID 13-Cove Base Description - Black Cove Base

042023925-0013 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray None Detected10/07/2020 100.00% Other

Sample ID 13-Mastic Description - Mastic

042023925-0013A Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Yellow10/06/2020 None 100.00% Other Inconclusive : <1% Chrysotile

TEM NYS 198.4 NOB Yellow10/07/2020 None 100.00% Other <1% Chrysotile

Sample ID 14 Description - Inter. Window Frame Caulk

042023925-0014 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray None Detected10/07/2020 100.00% Other

Sample ID 15 Description - Gray Linoleum

042023925-0015 Homogeneity Homogeneous

PLM NYS 198.1 Friable Not Analyzed

PLM NYS 198.6 VCM Not Analyzed

PLM NYS 198.6 NOB Gray Inconclusive: None Detected10/06/2020 100.00% Other

TEM NYS 198.4 NOB Gray None Detected10/07/2020 100.00% Other

Page 3 of 4ASB_198x_0009 - 1.71 Printed 10/7/2020 11:47:35PM

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042023925EMSL Order:

Customer ID: CHAS42

Customer PO:

Project ID:

Test Report:Asbestos Analysis of Bulk Material

Analyst(s):

John Witcraft PLM NYS 198.1 Friable (2) Sarah Kleinbrahm PLM NYS 198.1 Friable (5)

Sarah Kleinbrahm PLM NYS 198.6 NOB (10) Diane Turcios TEM NYS 198.4 NOB (9)

Samples reviewed and approved by:

Samantha Rundstrom, Laboratory Manager or Other Approved Signatory

NOB = Non Friable Organically Bound N/A = Not Applicable VCM = Vermiculite Containing Material

-In New York State, TEM is currently the only method that can be used to determine if NOB materials can be considered or treated as non-asbestos containing.

All samples examined for the presence of vermiculite when analyzed via NYS 198.1.

-NYS Guidelines for Vermiculite containing samples are available at http://www.wadsworth.org/labcert/elapcert/forms/VermiculiteInterimGuidance_Rev070913.pdf EMSL maintains liability limited to cost of analysis. This report relates only to the samples reported above and may not be reproduced, except in full, without written approval by

EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations. Interpretation and use of test results are the responsibility of the client.

Samples were received in good condition unless otherwise noted.

This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the federal government. This report may contain data that is not covered by the NVLAP accreditation.

Samples analyzed by EMSL Analytical, Inc. Cinnaminson, NJ NYS ELAP 10872, PA ID# 68-00367

Page 4 of 4ASB_198x_0009 - 1.71 Printed 10/7/2020 11:47:35PM

OrderID: 042023925

OrderID: 042023925

APPENDIX C

CONSULTANT CERTIFICATIONS

Brett Brumbaugh

State Asbestos Licenses

State License/Cert Number License/Training

Ohio ES3488 Asbestos Hazard Evaluation Specialist

Ohio PD60095 Asbestos Project Designer

Indiana 192916010 Asbestos Inspector, Mgt. Planner, and Project Designer

Illinois 100-09972 Asbestos Inspector

Michigan A3686 Asbestos Inspector, Mgt. Planner, and Project Designer

Minnesota AI14402 Asbestos Inspector

Missouri 7136041420MOII21053 Asbestos Inspector

Pennsylvania 49043 Asbestos Inspector

Pennsylvania 49043 Asbestos Project Designer

Kentucky 62525 Asbestos Project Designer

Kentucky 62524 Asbestos Inspector & Mgt. Planner

Virginia 3303004018 Asbestos Inspector

Virginia 3305001292 Asbestos Project Designer

West Virginia AI010074 Asbestos Inspector

North Carolina 12411 Asbestos Inspector

Iowa 19-3383 & 19-3384 Asbestos Inspector & Mgt. Planner

Tennessee A-I-46297-78155 Asbestos Inspector

South Dakota 8517 Asbestos Inspector

South Dakota 8517 Asbestos Mgt. Planner

South Dakota 8571 Asbestos Project Designer

APPENDIX D

LABORATORY CERTIFICATIONS

File details come from the government source that posted it. Updated .