Wayne County 64659-02 - 2661 Greenfield Rd ACM-HAZMAT Report (1)-Old Animal Shelter.pdf

Pre-Renovation Asbestos and Hazardous Materials Survey of

2661 Greenfield Road, Dearborn, MI 48122

Prepared for Mrs. Anne Wistow

Wayne County Land Bank 500 Griswold Street, 28th Floor, Detroit, MI 48226

Zachary Line Asbestos Building Inspector

Madison Konrad Group Manager Industrial Hygiene Services

Prepared by

Testing Engineers and Consultants, Inc. (TEC) 1343 Rochester Road, PO Box 249

Troy, Michigan 48099-0249

TEC Project Number: 64659-02

February 6, 2025

Pre-Renovation ACM/Haz-Mat Survey February 6, 2025 2661 Greenfield Road, Dearborn, MI

TABLE OF CONTENTS

1 EXECUTIVE SUMMARY

2 GENERAL BUILDING AND SURVEY INFORMATION

2.1 BUILDING INFORMATION

2.2 INSPECTION INFORMATION

3 FINDINGS

3.1 ASBESTOS INSPECTION RESULTS

4 ASSUMPTIONS, CONCLUSIONS & RECOMMENDATIONS

4.1 CONCLUSIONS

4.2 RECOMMENDATIONS

TABLES

TABLE 1 SUSPECT ACMs – SAMPLED AND ASSUMED

TABLE 2 SUSPECT HAZARDOUS MATERIALS – ASSUMED ONLY

LIST OF APPENDICES

APPENDIX A SCOPE, METHODS, AND REGULATORY GUIDELINES

APPENDIX B ASBESTOS GLOSSARY OF TERMS

APPENDIX C OSHA ABATEMENT PROCEDURES

APPENDIX D ASBESTOS SAMPLE LOG/CHAIN OF CUSTODY

APPENDIX E REPORT OF BULK SAMPLE ANALYSIS FOR ASBESTOS

APPENDIX F REPRESENTATIVE PHOTOGRAPHS OF ACM MATERIALS

APPENDIX G SAMPLE LOCATION MAP

Pre-Renovations ACM/Haz-Mat Survey February 6, 2025

1 EXECUTIVE SUMMARY

Testing Engineers and Consultants, Inc. (TEC) was retained by Wayne County Land Bank, to conduct an assessment for asbestos-containing materials (ACM)/Hazardous Materials (Haz-Mat) within the building located at 2661 Greenfield Road, Dearborn, MI 48122.

Asbestos Containing Materials (ACMs)

A total of 96 sample layers were collected/analyzed from 30 suspected asbestos-containing homogeneous materials (ACMs) identified during the assessment. The samples were analyzed by polarized light microscopy (PLM). A material is considered by the U.S. Environmental `Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA) and the State of Michigan to be ACM if PLM results detect greater than one percent (>1%) asbestos. Refer to Appendix G for the Sample Location Map.

One ACM (>1% asbestos) was identified through laboratory analysis during this investigation. Bold Depicts Positive Layer:

• Waterproofing (Black) – FS 1 (Around Concrete Foundation)

The following materials were not sampled and are assumed to be ACM:

• Fire Rated Doors – FS 2-4, 6-8, 9-15 – 13 Doors

• Fire Rated Door Frames – FS 7, 8, 10-12, 17 – 6 Frames

A summary of the laboratory results for the suspect ACM samples collected within the subject building are provided in Table 1, while the analytical laboratory results/chain of custody are included as Appendix D and Appendix E. Site diagrams identifying sample locations (Appendix G) are attached for review.

2 GENERAL BUILDING AND SURVEY INFORMATION

2.1 BUILDING INFORMATION

The subject building contains one address 2661 Greenfield Road, Dearborn, MI 48122.

2.2 INSPECTION INFORMATION

2.2.1 GENERAL BUILDING INFORMATION

Subject Property: 2661 Greenfield Road, Dearborn, MI 48122 Construction Date: Unknown Number of Floors: 1 Floor

Square Footage Est. 4,500 SF

Construction Type: Construction Masonry Unit (CMU), Concrete Foundation with Flat Membrane Roof

Building Occupant(s) Unoccupied

2.2.2 Inspection Information

Name of Inspector(s): Zachary Line

Signature:

State of Michigan Inspector No. A63411

Date(s) of Inspection:

December 31, 2024

Report Reviewed By: Madison Konrad

Signature:

3 FINDINGS

3.1 ASBESTOS RESULTS

A total of 96 samples were collected/analyzed from 30 suspect asbestos-containing homogenous materials identified during the assessment.

The “Report of Bulk Sample Analysis for Asbestos,” the “Asbestos Bulk Sample Log,” Photographs, and Asbestos Glossary are included in the Appendices. Table 1 attached to this report lists the suspect ACMs observed throughout the building that were sampled, along with the results of the inspection and laboratory analysis.

Table 1 provides descriptions of the materials, their general locations, condition, and friability, EPA National Emission Standard for Hazardous Air Pollutants (NESHAP) category, OSHA abatement classification and estimated quantity.

3.1.1 INACCESSIBLE AREAS / AREAS NOT INCLUDED

• None

3.1.2 NON-SUSPECT MATERIALS

The following materials were observed but are considered ‘non-suspect’ ACM due to their composition (fiberglass, rubber, etc.) and were not sampled.

• Metal, plastic, and glass building components

• Rubber/foam pipe insulation

• Fiberglass roll/bat insulation

• Ceramic bathroom fixtures (sink, toilet, tub, etc.)

4 CONCLUSIONS & RECOMMENDATIONS

4.1 CONCLUSIONS

1 – ACM was found within and on the subject property.

2 - Assumed ACMs were found within the subject property.

14 - Assumed HAZMAT Categories as presented on Table 2-Suspected HAZMATs

Inventory Checklist

4.1.1 ASSUMPTIONS/OBSERVATIONS

The following assumptions were used to develop TEC’s sampling strategy:

• Pipes throughout the building were either uninsulated (metal or PVC) or insulated with Fiberglass, Pipe Joints were insulated but found to be non-ACM.

• The air supply and return ducts in the building were either insulated with fiberglass or uninsulated, which is either non-ACM or non-suspect for asbestos.

4.2 RECOMMENDATIONS

ASBESTOS CONTAINING MATERIALS (ACM)

The materials identified in the subject buildings were generally found to be in good condition.

Prior to renovation, TEC recommends that the identified ACMs (assumed and sampled), be removed prior to renovation. Category I Non-Friable ACM may often be left in place during renovation/demolition if not made friable by cutting, grinding, or sanding. If left in place, these materials cannot be recycled or used as clean fill.

Any areas that were noted as being inaccessible during this assessment or any concealed areas, such as behind walls, where suspect ACMs could be discovered, may require additional assessment for ACM.

TEC has provided the regulatory abatement methods as defined by OSHA in Appendix C for each class of work applied to the materials noted in this report. These procedures can be performed by the renovation/demolition contractor if they are licensed to perform abatement in Michigan.

TABLES

1 F = Friable ; NF = Non-friable 2 Cond. = Condition of Materials; Either good, fair or poor 3 NAD = No Asbestos Detected, Ch = Chrysotile, Am = Amosite, Tr = Tremolite; Ver = Vermiculite; PT = Point Count Analysis; TEM = Transmission Electron Microscopy 4 NESHAP Category - Regulated ACM (RACM), Cat I NF=Category I Non-Friable ACM, Cat II NF= Category II Non-Friable ACM NA = Not Applicable 5 OSHA/EPA Class Definitions:

Class I asbestos work means activities involving the removal of TSI and surfacing ACM and PACM.

Class II asbestos work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

Class III asbestos work means repair and maintenance operations, where "ACM", including TSI and surfacing ACM and PACM, is likely to be disturbed.

Class IV asbestos work means maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.

TABLE 1 – SUSPECT ACMS – SAMPLED (BOLD DEPICTS A POSITIVE RESULT)

Site: 2661 Greenfield Road, Dearborn, MI Survey Date(s): 12/31/2024

Material Number &

Sample Number Material Description Material Location F/NF1 Cond.2 % Asbestos & type3

EPA NESHAP

Category 1, 4

OSHA Class Designation5

Estimated Quantity

1A-B

Floor Tile (12”x12” Faux Stone) w/ Glue

& Floor Tile (Brown) w/ Glue

& Flooring (Beige)

FS 2, 4 NF NA

NAD/

NAD/

NAD/

NAD/

NAD

NA NA NA

2A-B Cove Base (Cream) w/ Adhesive FS 2, 4 NF NA NAD/

NAD NA NA NA

3A-B Ceramic Floor Tile (Beige) w/ Grout & Adhesive

FS 3, 6 NF NA

NAD/

NAD/

NAD

NA NA NA

4A-B Interior Caulk (Grey – Painted White) FS 2, 5 NF NA NAD NA NA NA

5A-B Interior Caulk (Black – Painted White) FS 2, 5 NF NA NAD NA NA NA

6A-B Interior Door Frame Caulk (White) FS 2, 4, 5, 9 NF NA NAD NA NA NA

7A Fiberglass Insulation (Yellow) Throughout NF NA NAD NA NA NA

8A-B Cement Patch (Grey) FS 4 NF NA NAD NA NA NA

9A-B 12”x12” Floor Tile (Tan w/ Specks) w/ Mastic FS 5, 6, 9, 10 NF NA NAD/

NAD NA NA NA

10A-B Cove Base (Brown) w/ Adhesive FS 5, 9, 10 NF NA NAD/

NAD NA NA NA

11A-B Cove Base (Black) w/ Adhesive FS 5 NF NA NAD/

NAD NA NA NA

12A-B Drywall (White) w/ Joint Compound FS 5 NF NA NAD/

NAD NA NA NA

13A-B Vibration Dampener (Black) FS 6, 8 NF NA NAD NA NA NA

14A-C 2” Stright Pipe Insulation (Yellow) FS 7 NF NA NAD NA NA NA

15A-C Pipe Joint Insulation (White) FS 2, 7-10, 13 F NA NAD NA NA NA

1 F = Friable ; NF = Non-friable 2 Cond. = Condition of Materials; Either good, fair or poor 3 NAD = No Asbestos Detected, Ch = Chrysotile, Am = Amosite, Tr = Tremolite; Ver = Vermiculite; PT = Point Count Analysis; TEM = Transmission Electron Microscopy 4 NESHAP Category - Regulated ACM (RACM), Cat I NF=Category I Non-Friable ACM, Cat II NF= Category II Non-Friable ACM NA = Not Applicable 5 OSHA/EPA Class Definitions:

Class I asbestos work means activities involving the removal of TSI and surfacing ACM and PACM.

Class II asbestos work means activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

Class III asbestos work means repair and maintenance operations, where "ACM", including TSI and surfacing ACM and PACM, is likely to be disturbed.

Class IV asbestos work means maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.

Material Number & Sample Number Material Description Material Location F/NF1 Cond.2 % Asbestos & type3

EPA NESHAP

Category 1, 4

OSHA Class Designation5

Estimated Quantity

16A-B Spray-On Foam Insulation (White) FS 8 NF NA NAD NA NA NA

17A-B Ceramic Cove Base (Beige) w/ Mortar Bed & Grout

FS 8, 11 NF NA

NAD/

NAD/

NAD

NA NA NA

18A-B Interior Door Window Glaze (Black) FS 13, 15 NF NA NAD NA NA NA

19A-C >4” Stright Pipe Insulation (Yellow) Throughout F NA NAD NA NA NA

20A-C <4” Pipe Joint Insulation (Tan/Yellow) FS 13, 15 F NA NAD NA NA NA

21A-B CMU (Grey) & Mortar Throughout NF NA NAD/

NAD NA NA NA

22A-B Brick (Brown) & Mortar FS 1 NF NA NAD/

NAD NA NA NA

23A-B Exterior Caulk (Grey) FS 1 NF NA NAD NA NA NA

24A-B Exterior Soffit (White) FS 1 NF NA NAD NA NA NA

25A-B Expansion Joint (Grey) FS 1 NF NA NAD NA NA NA

26A-B Roofing Materials (Flute Black) w/ Foam & Tar

FS 1 (Roof) NF NA

NAD/

NAD/

NAD

NA NA NA

27A-B Waterproofing (Black) Exterior Around Concrete Foundation NF Good 5% Ch Cat II NF Class II 300 LF @6”

28A-B Exterior Window Frame Caulk (Dark Grey) FS 1 NF NA NAD NA NA NA

29A-B Exterior Caulk (Brown) FS 1 NF NA NAD NA NA NA

30A-B Exterior Door Frame Caulk (Light Grey) FS 1 NF NA NAD NA NA NA

Assumed Fire Rated Doors FS 2-4, 6-8, 9-15 NF Good Assumed Cat II NF Class II 13 Doors

Assumed Fire Rated Door Frames FS 7, 8, 10-12, 17 NF Good Assumed Cat II NF Class II 6 Frames

Table 2: Suspected HAZMATS Inventory Checklist Address: 2661 Greenfield Road, Dearborn, MI 48122- Total Quantities

Inspection Item Constituent of Concern Size/Quantity Notes:

Exit Signs Mercury / H-3 3 -

Transformers Lead 1 FS 1

Fire Extinguishers Potassium Carbonate, Potassium Acetate-based, wet chemical

2 -

Miscellaneous Items (Glue, Solvents, Cleaners, etc.)

Varied 1 (1) 5 Gallon

Paint Cans Lead/Asbestos 5 (4) 1 Gallon, (1) 5 Gallon

Light Ballasts PCBs 31 Throughout

4’ Fluorescent Bulbs Mercury 72 Throughout

4’ Slim Fluorescent Bulbs Mercury 106 Throughout

Drinking Fountains CFC/HCFC 1 FS 2

Spotlights Halogen, Metal Halide- 1 FS 1

Thermostats Mercury 2 FS 11, 12

Door Actuators PCBs 6 FS 2, 11, 14, 15

Exterior Lights Unknown 4 FS 1

APPENDIX A

SCOPE, METHODS, AND REGULATORY GUIDELINES

A1 INTRODUCTION

A1.1 SCOPE OF SERVICES

The scope of services for this project consisted of conducting a comprehensive ACM assessment, sampling, and analysis of accessible and exposed interior and exterior areas within the subject facility.

The pre-renovation assessment included areas within the structure where building materials could potentially be impacted during the upcoming renovation. The pre-renovation assessment included a visual inspection of the subject area(s), sample collection, PLM sample analysis, quantification of ACMs, and report preparation and review.

A1.2 PURPOSE

The purpose of this survey was to provide general information for the subject structure regarding the presence, condition, and quantity of accessible and/or exposed friable and non-friable, building materials that contain asbestos as well as substances that would require special handling and disposal prior to renovation.

A1.3 AUTHORIZATION

Authorization to perform this work was given by Wayne County Land Bank, as owner, through the issuance of a Signed Proposal.

A1.4 LIMITATIONS

The asbestos survey was intended to meet the requirements of the EPA NESHAP regulation for demolition or renovation. The survey included a thorough inspection of all areas of the building.

Roof Systems were assumed to be asbestos containing for the purposes of this study.

These materials can be treated as non-regulated demolition debris provided; they are not rendered friable during the demolition process.

TEC performed sampling requiring demolition or destructive activities such as knocking holes in walls, dismantling of equipment or removal of protective coverings. Reasonable efforts to access suspect materials within known areas of restricted access (e.g., catwalks) were made; however, confined spaces or areas which may pose a health or safety risk to TEC personnel were not sampled. Sampling did not include suspect materials which could not be safely reached with available ladders/man-lifts. TEC did not sample any system which presented a hazard to the inspection team such as energized electrical systems, confined spaces, or structurally unsafe areas. This survey was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building.

Void spaces which were evaluated included locations of suspected pipe or HVAC chases, wall cavities where fireproofing or other ACM was suspected, above finished ceiling systems where ACM was likely to exist, within pipe trenches or within concealed locations. Although TEC made an attempt to identify all areas of ACM, an exhaustive investigation of void spaces was not included in the scope of services for this project.

Inaccessible is defined as areas of the building that were locked, or where admittance was not possible. It also includes areas/materials that could not be tested (sampled) without destruction of the structure or a portion of the structure, and areas/materials that could not be safely reached by the inspector or inspection team. In the event that access to a portion of the building was not obtained (which otherwise would have been tested), such limitations specifically are identified in the Findings Section of this report.

The information contained in this report is relevant to the dates on which this survey was conducted and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by Wayne County land Bank for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. TEC does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied, is made.

The HAZMATs survey was visual only and did not include sampling of identified materials.

A1.5 WARRANTY

The field and laboratory results reported herein are considered sufficient in detail and scope to determine the presence of accessible and/or exposed suspect ACM/HAZMATs for the building structure. TEC warrants that the findings contained herein have been prepared in general accordance with accepted professional practices at the time of its preparation as applied by professionals in the community. Changes in the state of the art or in applicable regulations cannot be anticipated and have not been addressed in this report.

The survey and analytical methods have been used to provide the client with information regarding the presence of accessible and/or exposed suspect ACMs existing at the time of the inspection. Test results are valid only for the material(s) tested. There is a distinct possibility that conditions may exist which could not be identified within the scope of the study, or which were not apparent during the site visit. This assessment covered only those areas that were exposed and/or physically accessible to the Inspector. The study is also limited to the information available from the client at the time it was conducted.

A2 METHODOLOGY

Inspection and sampling procedures were performed in general accordance with the guidelines published by the EPA. The inspection and survey described below was performed by an EPA and Michigan accredited inspector.

A2.1 RECORD DOCUMENT REVIEW

Prior to conducting the visual inspection, TEC typically reviews documents provided by the client, including: drawings, floor plans, historical data, maintenance records, previous survey reports, laboratory reports, etc. for information regarding construction history and building materials.

No documents were provided by the client for review as a part of this Asbestos and HAZMAT Survey.

A2.2 VISUAL INSPECTION PROCEDURES

A2.2.1 Asbestos

An initial facility walkthrough was conducted to determine the presence of suspect asbestos-containing materials that were accessible and/or exposed within all areas scheduled for upcoming renovation activities.

Materials which were similar in color, texture, general appearance and which appear to have been installed at the same time were grouped in Homogeneous Sampling Areas.

Such materials are termed "homogeneous materials" by the EPA. During this walkthrough, the approximate locations of these homogeneous materials were also noted.

The inspector evaluated the overall condition of the material and determined whether the materials were friable or non-friable by touching the material, where practical. A friable material is defined as any material able to be crushed, crumbled, pulverized or reduced to a powder by hand pressure when dry.

Each material was further assessed for overall condition. Conditions were rated as good, damaged or significantly damaged. TEC’s inspector also identified the EPA NESHAP classification of the material based on the materials current condition. TEC’s inspector provided estimated quantities of the materials identified as ACM, based only on materials that were accessible and exposed.

A2.3 ASBESTOS SAMPLING PROCEDURES

Following the walkthrough, the Inspector collected samples of suspect materials.

EPA guidelines were used to determine the sampling protocol. Sampling locations were chosen to be representative of the homogeneous sampling area. While an effort was made to collect samples randomly, samples were taken preferentially from areas already damaged or areas which were the least visible to minimize disturbance of the material.

Each sample location was sprayed with amended water and was kept wet during the entire sampling process. Samples were collected by coring through the material from the surface down to the base substrate. All layers of the material were extracted and placed into a sample container for transport to the laboratory. Sample containers were sealed and labeled with a unique sample identification number. Where appropriate, sampled materials were sealed with an encapsulant or covered with tape after sampling. TEC is not responsible for restoring the sampled areas to their pre-sampled condition.

A2.4 ASBESTOS ANALYSIS PROCEDURES

All samples were analyzed by

• APEX Research, Inc.

11054 Hi Tech Drive Whitmore Lake, Michigan 48189

This Laboratory is National Voluntary Laboratory Accreditation Program (NVLAP) Accredited.

The samples were analyzed for asbestos on a “positive-stop” basis by PLM and in accordance with the “EPA Method for the Determination of Asbestos in Bulk Building Materials” (EPA/600/R-93/116 July 1993). Analysis was performed by observing the bulk samples and slide preparation(s) for microscopic examination and identification. The samples were mounted on slides and then analyzed for asbestos (chrysotile, amosite, crocidolite, anthophyllite, actinolite/tremolite), and fibrous non-asbestos constituents (mineral wool, fiberglass, cellulose, etc.). Asbestos was identified by refractive indices, morphology, color, pleochroism, birefringence, extinction characteristics, and signs of elongation. The same characteristics were used to identify the non-asbestos constituents.

Using a stereoscope, the microscopist visually estimated relative amounts of each constituent by determining the volume of each constituent in proportion to the total volume of the sample.

The EPA method allows samples which are visually determined to have less than 10% asbestos to be quantified using a Point Count procedure. An ocular reticule (cross hair or point array) is used to visually superimpose a point or points on the microscope field of view. A total of 400 points superimposed on either asbestos fibers or non-asbestos matrix material must be counted over at least eight different preparations of representative subsamples. If an asbestos fiber and matrix particle overlap so that a point is superimposed on their visual intersection, a point is scored for both categories. Point counting provides a quantification of the area percent asbestos. Point counted results supersede the results of the visual estimation. No samples were point counted for this survey.

It should be noted that some ACM might not be accurately identified or quantified by PLM.

As an example, the original fabrication of vinyl floor tiles routinely involved milling of asbestos fibers to extremely small sizes. As a result, these fibers may go undetected under the standard PLM method. Transmission Electron Microscopy (TEM) is recommended for a more definitive analysis of these materials.

A2.4.1 Laboratory Quality Control Program

Each laboratory maintains an in-house quality control program. This program involves blind reanalysis of ten (10) percent of all samples, precision and accuracy controls, and use of standard bulk reference materials. In addition, the Laboratories are accredited by NVLAP, which also has quality control procedures inherent in its program.

A2.5 REGULATORY GUIDELINES:

ACM Definition – The EPA and OSHA consider a material to be ACM if at least one sample from the homogeneous area shows asbestos in an amount greater than 1%.

Point Count Quantification – If a material is found to contain less than 1% asbestos via PLM visual estimation, it can be treated as non-ACM per EPA Regulations, if verified to contain 1% or less asbestos by the Point Count Quantification Procedure. If not point counted, a sample in which asbestos was visually detected and estimated (including trace to ≤fz1%) must be assumed to be greater than 1% and treated as ACM. Please refer to the laboratory analyses for a more detailed description of the microscopic analysis of individual samples.

No samples were quantified by the Point Count Procedure in this Asbestos Survey.

EPA NESHAP Category – EPA classifies ACM into the following categories:

• RACM as defined by the Asbestos NESHAP is any (a) Friable asbestos material,

(b) Category I non-friable ACM that has become friable, (c) Category I non- friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

• Category I Non-friable ACM includes packings, gaskets, resilient floor covering, and asphalt roofing products which contain more than one percent asbestos.

• Category II Non-friable ACM includes any material, except for a Category I non-friable ACM, which contains more than one-percent asbestos and cannot be reduced to a powder by hand pressure when dry.

OSHA –

OSHA requires all suspect materials to be analyzed by layer, even materials such as drywall/joint compound, which may sometimes be composited per the EPA. If any layer contains asbestos in a concentration >1%, the material is considered an ACM.

OSHA has a classification system (I thru IV) for ACM depending on the type of material and the disturbance as follows:

• Class I work is defined as activities involving the removal of ACM or presumed ACM (PACM) that is thermal system insulation (TSI) and surfacing materials.

• Class II activities involve removal of ACM/PACM other than TSI or surfacing material.

• Class III work includes repair and maintenance operations which are likely to disturb ACM/PACM.

• Class IV work includes maintenance and custodial activities during which employees contact but do not disturb ACM/PACM.

Materials where asbestos is detected, but where point counting is conducted and determined that the concentration is ≤1% asbestos, are not considered to be ACM by OSHA. However, these materials are considered unclassified asbestos work per OSHA. Some OSHA work control practices and prohibitions will still apply, with the extent depending on whether the worker's exposure to airborne asbestos exceeds the OSHA permissible exposure limit (PEL).

Additional details of the OSHA asbestos regulations related to the construction industry can be found in 29 CFR Part 1926.1101.

A2.6 QUANTIFICATION

Quantification of suspect ACMs were conducted using visual estimation by an accredited asbestos inspector. This visual estimation was performed in accordance with generally accepted practices in the asbestos industry based on materials that were accessible and exposed. These values are sufficiently accurate for the purpose of documenting the presence of asbestos within its space for the purpose of identifying abatement control conditions or for general policy considerations. Actual quantities may differ between visually estimated values and physical measurements. If a licensed asbestos abatement contractor is engaged to remove the identified ACM, they should be made responsible for verifying reported quantities of ACM.

APPENDIX B

ASBESTOS GLOSSARY OF TERMS

Asbestos Glossary of Terms

-A-

Abatement – The encapsulation, enclosure, removal or repair of a material.

ACM - Asbestos Containing Material. Any material containing greater than 1% asbestos by weight.

Accessible - When referring to ACM, the material is subject to disturbance by occupants or maintenance personnel in the course of their normal activities.

AHERA – The Asbestos Hazard Emergency Response Act (AHERA); Environmental Protection Agency (EPA), 40 CFR 763, Asbestos-Containing Materials in Schools Asbestos - Any of a group of commercially mined minerals that tend to break into fibers. The regulated asbestos minerals are the serpentine mineral chrysotile and the asbestiform varieties of the amphibole minerals grunerite (amosite), riebeckite (crocidilite), tremolite, actinolite and anthophylitte. Amphibole minerals occur in both the regulated, asbestiform varieties and the non-regulated, non-asbestiform varieties. The fibers are resistant to high temperatures, have high tensile strength, and in some cases can be woven into cloth.

Asbestosis - A chronic fibrosis of the lungs typically caused by prolonged, heavy exposures to asbestos, usually affecting miners, ship-builders and mill-workers. There are different scales of asbestosis but in the worst cases, it will restrict breathing and often be degenerative. It takes between 15 and 30 years for the disease to manifest following exposure to asbestos.

Asbestos Abatement - The encapsulation, enclosure, removal or repair of an asbestos containing material.

Asbestos-containing Construction Material (ACM) - Any manufactured construction material which contains more than one 1-percent asbestos by weight.

-B-

Bulk Sample - A sample of material such as boarding, insulation or debris taken by an accredited surveyor to be tested for asbestos fiber content by an accredited laboratory.

-C-

Category I Nonfriable Asbestos-Containing Material (ACM) - Asbestos-containing packing, gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos as determined using the method specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy.

Category II Nonfriable ACM - Any material, excluding Category I nonfriable ACM, containing more than 1 percent asbestos as determined by using the methods specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Cementitious - A material that is typically a densely packed granular matrix of sand and limestone and is typically considered, non-friable.

Class I asbestos work - Activities involving the removal of thermal system insulation (TSI) and surfacing ACM and PACM. These types of activities will not be conducted by university employees.

Class II asbestos work - Activities involving the removal of ACM which is not thermal system insulation or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics.

Class III asbestos work - Repair and maintenance operations, where "ACM" including TSI and surfacing ACM and PACM, is likely to be disturbed.

Class IV asbestos work - Maintenance and custodial activities during which employees contact but do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities.

-D-

Damaged Friable Miscellaneous ACM - 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 indicated damage.

Damaged Friable Surfacing ACM - Friable surfacing Asbestos Containing Material which has deteriorated or sustained physical injury such that the internal structure (cohesion) of the asbestos 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 repeat water stains, scrapes, gouges, mares or other signs of physical injury on the ACM. Asbestos debris originating from the ACBM in question may also indicate damage.

Damaged or Significantly Damaged Thermal System Insulation ACM - 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 indicating damage.

Delaminate - To separate into layers. In asbestos terms, to separate from the substrate.

Demolition - Means the wrecking, razing, or removal of any structure or load-supporting structural item of any structure, including any related material handling operations, and includes the intentional burning of any structure.

-E-

EPA - Environmental Protection Agency; a federal government agency dealing with environmental regulations; 401 M Street, S.W., Washington, D.C. 20460.

EPA Regulations - Regulatory standards which cover emissions into the outside environment from a workplace and disposal of hazardous wastes from job sites, as well as, asbestos issues in school buildings.

-F-

Fireproofing – Spray or trowel applied fire resistant materials.

Floor Tile – a flat piece of hard clay, stone, or other material that is used for covering floors.

Friable - Any material that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure, and includes previously nonfriable material after such previously nonfriable material becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

Friable Asbestos - Any material containing more that 1 percent asbestos as determined using Polarized Light Microscopy, that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. If the asbestos content is less than 10 percent as determined by a method other than point counting by polarized light microscopy (PLM), verify the asbestos content by point counting using PLM.

Functional Space - A room, group of rooms, or homogeneous area (including crawl spaces or the space between a dropped ceiling and the floor or roof deck above) designated by a person accredited to prepare management plans, design asbestos abatement projects, or conduct asbestos response actions.

-G, H-

Homogenous - Evenly mixed and similar in appearance and texture throughout.

Homogeneous Area - An area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture.

-I-

In Poor Condition - The binding of the asbestos containing material is losing its integrity as indicated by peeling, cracking, or crumbling of the material.

Installation - Any building or structure or any group of buildings or structures at a single demolition or renovation site that are under the control of the same owner or operator (or owner or operator under common control).

Inspector - Means an individual who is trained and licensed by the appropriate local, state or federal Department to identify and assess the condition of ACM. Inspectors shall perform their duties in accordance with the techniques, knowledge, training and responsibilities outlined in the appropriate OSHA and EPA regulations.

Intact - ACM that has not been crumbled, pulverized, or otherwise deteriorated.

-J, K, L-

License - Means an authorization issued by the appropriate local, state or federal Department permitting a business entity to engage in an asbestos project.

Linoleum - a material consisting of a canvas backing thickly coated with a preparation of linseed oil and powdered cork, used especially as a floor covering; includes

-M-

MIOSHA – Michigan Occupational Safety and Health Administration.

Miscellaneous ACM - Miscellaneous material that is an 'asbestos containing material' in a building.

Miscellaneous Material - 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.

-N-

Non-friable - Material which when dry may not be crumbled, pulverized, or reduced to powder by hand pressure.

Non-friable Asbestos Containing Material (Non friable ACM) - Any material containing more that 1 percent asbestos as determined using Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

-O-

OSHA – the Occupational Health and Safety Administration.

-P-

P.P.E. - Personal Protective Equipment worn to protect a worker from exposure to, or contact with, any harmful material or force. Such as overalls, masks, gloves, safety glasses, steel-toed boots, hearing protection, cool collars, etc.

-Q-

Quantity – all quantities should be considered as estimates.

-R-

Random Sample - An asbestos sample drawn in such a way that there is no set pattern and is designed to give a true representation of the entire area.

Regulated Asbestos-Containing Material (RACM) - Means (a) Friable asbestos material, (b) Category I nonfriable ACM that has become friable, (c) Category I nonfriable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II nonfriable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations regulated by this subpart.

Removal - All operations where ACM and/or PACM is taken out or stripped from structures or substrates, including demolition operations.

Remove (Asbestos) - To take out RACM or facility components that contain or are covered with RACM from any facility.

-S-

Significantly Damaged Friable Miscellaneous ACM - Damaged friable miscellaneous Asbestos Containing Material where the damage is extensive and severe.

Structure or Structural Item - Means roofs, walls, ceilings, floors, structural supports, pipes, ducts, fittings and fixtures that have been installed as an integral part of any structure.

Surfacing material - Material that is sprayed, troweled-on or applied to surfaces (such as acoustical plaster on ceilings and fireproofing materials on structural members).

Surfacing ACM - Surfacing material which contains more than 1% asbestos.

Suspect Material - Material with the potential for being asbestos containing: synonymous with “presumed asbestos-containing material” (PACM).

-T-

Test Till Positive (TTP) or First Positive Stop (FPS) Sample Analysis – a bulk sample direction given to the laboratory by the asbestos surveyors to instruct the laboratory to stop analyzing multiple samples of the same material after the first sample comes back positive for asbestos.

This is most typically utilized to minimize costs.

Thermal System Insulation - Material 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.

Thermal System Insulation ACM - Thermal system insulation that is an Asbestos Containing Material.

-U, V, W, X, Y, Z -

USEPA (EPA) - United States Environmental Protection Agency Vermiculite - A micaceous mineral that is sometimes used as a substitute for asbestos which is lightweight and highly water-absorbent.

APPENDIX C

OSHA ABATEMENT PROCEDURES

Part Number: 1926

• Part Title: Safety and Health Regulations for Construction

• Subpart: Z

• Subpart Title: Toxic and Hazardous Substances

• Standard Number: 1926.1101

• Title: Asbestos

The following excerpts are taken from the subject Regulation identified above; they are provided to provide work practice guidance with respect to asbestos abatement of the materials identified in the assessment. This section is not a replacement for the entire regulation nor is it a replacement for a project specification; it is a guidance document only. The tables identify an OSHA Class designation for each asbestos containing material identified; those Classes and their respective abatement methods are identified in the following:

1926.1101(e)(1)

All Class I, II and III asbestos work shall be conducted within regulated areas. All other operations covered by this standard shall be conducted within a regulated area where airborne concentrations of asbestos exceed, or there is a reasonable possibility they may exceed a PEL. Regulated areas shall comply with the requirements of paragraphs (2), (3),(4) and (5) of this section.

1926.1101(e)(2)

Demarcation. The regulated area shall be demarcated in any manner that minimizes the number of persons within the area and protects persons outside the area from exposure to airborne asbestos.

Where critical barriers or negative pressure enclosures are used, they may demarcate the regulated area. Signs shall be provided and displayed pursuant to the requirements of paragraph (k)(7) of this section.

1926.1101(e)(3)

Access. Access to regulated areas shall be limited to authorized persons and to persons authorized by the Act or regulations issued pursuant thereto.

1926.1101(e)(4)

Respirators. All persons entering a regulated area where employees are required pursuant to paragraph (h)(1) of this section to wear respirators shall be supplied with a respirator selected in accordance with paragraph (h)(2) of this section.

1926.1101(e)(5)

Prohibited activities. The employer shall ensure that employees do not eat, drink, smoke, chew tobacco or gum, or apply cosmetics in the regulated area.

1926.1101(e)(6) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101 https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(e)(1)

Competent Persons. The employer shall ensure that all asbestos work performed within regulated areas is supervised by a competent person, as defined in paragraph (b) of this section. The duties of the competent person are set out in paragraph (o) of this section.

1926.1101(g)

Methods of compliance.

1926.1101(g)(1)

Engineering controls and work practices for all operations covered by this section. The employer shall use the following engineering controls and work practices in all operations covered by this section, regardless of the levels of exposure:

1926.1101(g)(1)(i)

Vacuum cleaners equipped with HEPA filters to collect all debris and dust containing ACM and PACM, except as provided in paragraph (g)(8)(ii) of this section in the case of roofing material.

1926.1101(g)(1)(ii)

Wet methods, or wetting agents, to control employee exposures during asbestos handling, mixing, removal, cutting, application, and cleanup, except where employers demonstrate that the use of wet methods is infeasible due to for example, the creation of electrical hazards, equipment malfunction, and, in roofing, except as provide in paragraph (g)(8)(ii) of this section; and

1926.1101(g)(1)(iii)

Prompt clean-up and disposal of wastes and debris contaminated with asbestos in leak-tight containers except in roofing operations, where the procedures specified in paragraph (g)(8)(ii) of this section apply.

1926.1101(g)(2)

In addition to the requirements of paragraph (g)(1) of this section, the employer shall use the following control methods to achieve compliance with the TWA permissible exposure limit and excursion limit prescribed by paragraph (c) of this section;

1926.1101(g)(2)(i)

Local exhaust ventilation equipped with HEPA filter dust collection systems;

1926.1101(g)(2)(ii)

Enclosure or isolation of processes producing asbestos dust;

1926.1101(g)(2)(iii)

Ventilation of the regulated area to move contaminated air away from the breathing zone of employees and toward a filtration or collection device equipped with a HEPA filter;

https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(1) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(1)(ii) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(1)(iii) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(2)(ii)

1926.1101(g)(2)(iv)

Use of other work practices and engineering controls that the Assistant Secretary can show to be feasible.

1926.1101(g)(2)(v)

Wherever the feasible engineering and work practice controls described above are not sufficient to reduce employee exposure to or below the permissible exposure limit and/or excursion limit prescribed in paragraph (c) of this section, the employer shall use them to reduce employee exposure to the lowest levels attainable by these controls and shall supplement them by the use of respiratory protection that complies with the requirements of paragraph (h) of this section.

1926.1101(g)(3)

Prohibitions. The following work practices and engineering controls shall not be used for work related to asbestos or for work which disturbs ACM or PACM, regardless of measured levels of asbestos exposure or the results of initial exposure assessments:

1926.1101(g)(3)(i)

High-speed abrasive disc saws that are not equipped with point of cut ventilator or enclosures with HEPA filtered exhaust air.

1926.1101(g)(3)(ii)

Compressed air used to remove asbestos, or materials containing asbestos, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air.

1926.1101(g)(3)(iii)

Dry sweeping, shoveling or other dry clean-up of dust and debris containing ACM and PACM.

1926.1101(g)(3)(iv)

Employee rotation as a means of reducing employee exposure to asbestos.

1926.1101(g)(4)

Class I Requirements. In addition to the provisions of paragraphs (g)(1) and (2) of this section, the following engineering controls and work practices and procedures shall be used.

1926.1101(g)(4)(i)

All Class I work, including the installation and operation of the control system shall be supervised by a competent person as defined in paragraph (b) of this section;

1926.1101(g)(4)(ii)

For all Class I jobs involving the removal of more than 25 linear or 10 square feet of thermal system insulation or surfacing material; for all other Class I jobs, where the employer cannot produce a negative exposure assessment pursuant to paragraph (f)(2)(iii) of this section, or where employees are working in https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(3) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(3)(i) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(3)(ii) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(3)(iv) areas adjacent to the regulated area, while the Class I work is being performed, the employer shall use one of the following methods to ensure that airborne asbestos does not migrate from the regulated area:

1926.1101(g)(4)(ii)(A)

Critical barriers shall be placed over all the openings to the regulated area, except where activities are performed outdoors; or

1926.1101(g)(4)(ii)(B)

The employer shall use another barrier or isolation method which prevents the migration of airborne asbestos from the regulated area, as verified by perimeter area surveillance during each work shift at each boundary of the regulated area, showing no visible asbestos dust; and perimeter area monitoring showing that clearance levels contained in 40 CFR Part 763, Subpt. E, of the EPA Asbestos in Schools Rule are met, or that perimeter area levels, measured by Phase Contrast Microscopy (PCM) are no more than background levels representing the same area before the asbestos work began. The results of such monitoring shall be made known to the employer no later than 24 hours from the end of the work shift represented by such monitoring. Exception: For work completed outdoors where employees are not working in areas adjacent to the regulated areas, this paragraph (g)(4)(ii) is satisfied when the specific control methods in paragraph (g)(5) of this section are used.

1926.1101(g)(4)(iii)

For all Class I jobs, HVAC systems shall be isolated in the regulated area by sealing with a double layer of 6 mil plastic or the equivalent;

1926.1101(g)(4)(iv)

For all Class I jobs, impermeable dropcloths shall be placed on surfaces beneath all removal activity;

1926.1101(g)(4)(v)

For all Class I jobs, all objects within the regulated area shall be covered with impermeable dropcloths or plastic sheeting which is secured by duct tape or an equivalent.

1926.1101(g)(4)(vi)

For all Class I jobs where the employer cannot produce a negative exposure assessment, or where exposure monitoring shows that a PEL is exceeded, the employer shall ventilate the regulated area to move contaminated air away from the breathing zone of employees toward a HEPA filtration or collection device.

1926.1101(g)(5)

Specific control methods for Class I work. In addition, Class I asbestos work shall be performed using one or more of the following control methods pursuant to the limitations stated below:

1926.1101(g)(5)(i) https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_1101&src_anchor_name=1926.1101(g)(5)

Negative Pressure Enclosure (NPE) systems: NPE systems may be used where the configuration of the work area does not make the erection of the enclosure infeasible, with the following specifications and work practices.

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