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HomeMy WebLinkAboutB14-0104 Asbestos.pdf State of Colorado Asbestos Testing & Abatement Requirements Asbestos testing and abatement protects workers, homeowners, neighbors and emergency services responders from exposure to harmful asbestos. It is your responsibility to be in compliance with the State. Please contact the State directly for their requirements at the contact info listed below. When is asbestos testing required? ANY building projects disturbing more than these threshold levels of building materials require asbestos testing: One- and Two-Family Dwellings: 32 square feet All Others (commercial spaces, hotel rooms, etc): 160 square feet Definition of a single-family dwelling: any dwelling unit that is used primarily for a single family, including multi- family/condominium units, and fractional fee units. Tests which identify POSITIVE results at more than 1% require abatement by a State-certified abatement contractor. Project Checklist Will not disturb more than the threshold limits identified above. Tested negative, or at 1% or below (1 copies of test results included) Tested positive at more than 1%, requires abatement (1 copies of test results included) My project falls into the category checked below: Tips & Facts: xEven recent construction projects may include asbestos-containing materials, so buildings of any age require testing. x The "1989 Ban" on asbestos-containing materials is commonly misunderstood. "In fact, in 1991 the U.S. Fifth Circuit Court of Appeals vacated much of the so-called "Asbestos Ban and Phaseout" rule and remanded it to the EPA. Thus, much of the original 1989 EPA ban on the U.S. manufacturing, importation, processing, or distribution in com- merce of many asbestos-containing product categories was set aside and did not take effect." - CDPHE State of Colorado Contact: Colorado Department of Public Health and Environment Asbestos Compliance Assistance Group 303-692-3158 asbestos@state.co.us www.cdphe.state.co.us 2013-Feb 1 ■ Asbestos Inspection and Sampling Report 381 Beaver Dam Cir. Vail, CO, Colorado 81657 Presented To: Mr. Travis Coggin Triumph Development 12 Vail Road, Suite 700 Vail, CO 81657 travis@triumphdev.com 307-690-3716 Prepared By: Mr. Brandon Sinkbeil DS Consulting, Inc. PO Box 6864 Avon, CO 81620 970-476-4182 Brandon@dsconsultinginc.com Project Details: Project Number: 9584 Conducted: February 26, 2014 2 TABLE OF CONTENTS PROJECT OVERVIEW 1.0 Introduction 2.0 Scope of Work 3.0 Site Description 4.0 Certifications 5.0 Inspection, Sampling & Analytical Procedures 5.1 Inspection Procedures 5.2 Sampling Procedures 5.3 Analytical Procedures 6.0 Homogeneous Areas 6.1 Material Friability 6.2 Material Classifications 6.3 Material Conditions 6.4 Sample Quantities 7.0 Overview of Findings 8.0 Conclusion & Recommendations 9.0 Asbestos Abatement & Demolition Requirements 10.0 Major & Minor Asbestos Spill Response Actions 11.0 Disclaimer & Limitations 12.0 Copyright Notice APPENDIX A Inspector & Firm Asbestos Certificates APPENDIX B Analytical Data 3 PROJECT OVERVIEW 1.0 Introduction On February 26, 2014, Mr. Brandon Sinkbeil with DS Consulting, Inc. (DSC) conducted a limited asbestos inspection and collected asbestos bulk-samples of suspect asbestos-containing materials (ACM) within portions of the residence located at 381 Beaver Dam Cir. Vail, Colorado. The purpose of the limited inspection was to identify and sample potentially hazardous friable and non- friable ACM that will be impacted during upcoming renovation/remodeling activities. Asbestos bulk-samples were collected of the drywall surfacing textures throughout the residence. All of these samples were found to be none-detected for asbestos. 2.0 Scope of Work The scope of the limited inspection and bulk-sampling was limited to specific areas and materials of the residence defined by the client as listed above. The remaining areas and materials within the residence or any out-building on the property were not included in the scope of the inspection. The limited asbestos inspection did not constitute a full building inspection and does not fulfill the asbestos inspection requirements for structures that are to be demolished. 3.0 Site Description The residence is a tri-level, wood-framed, single-family residence with an attached garage built in 2000. 4.0 Certifications The limited asbestos inspection and bulk-sampling was conducted by Mr. Brandon Sinkbeil with DSC. DSC is a Colorado Department of Public Health and Environment (CDPHE) certified Asbestos Consulting Firm, Registration No. 14912. Mr. Sinkbeil is a CDPHE certified Building Inspector; having certification number 13442 (see Appendix A for certificates). 5.0 Inspection, Sampling & Analytical Procedures 5.1 Inspection Procedures The limited asbestos inspection was conducted by an Environmental Protection Agency (EPA) and CDPHE certified Building Inspector. The inspection procedures included identifying and sampling suspect ACM within the pre-defined areas, submitting samples to an accredited laboratory for analysis, classifying the materials and assessing their condition, and compiling a final report detailing the inspection and the analytical results of the bulk-samples. 5.2 Sampling Procedures Statistically random bulk-samples representative of the suspect ACM of each homogeneous area were collected according to the guidelines published as 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 CDPHE Regulation Number 8, Part B - Asbestos (Reg. 8). 4 DSC has collected the appropriate number of bulk-samples to meet all regulatory requirements for the classification and quantity of each homogeneous area. Some minor destructive sampling was conducted; however, walls, columns and perimeter pipe chases were not broken into in order to locate and quantify suspect ACM. It should be noted that additional ACM might be located in these and other inaccessible areas. 5.3 Analytical Procedures All asbestos bulk-samples were analyzed by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory via Polarized Light Microscopy (PLM) for asbestos content (see Appendix B for laboratory report). The percentage of asbestos within each individual bulk-sample can vary depending on sample location, homogeneity of the material, and the type of application. Any  sample  reporting  a  “TRACE”  amount  of   asbestos must be considered positive for asbestos greater than 1% unless it is re-analyzed utilizing the point-count method and verified to be less than 1%. Materials containing less than 1% asbestos are not regulated by CDPHE Regulation 8, Part B – Asbestos. However, all demolition/abatement activities should be performed following the applicable Occupational Safety and Health Administration (OSHA) regulations. This would include, but not limited to, the appropriate asbestos training for the type of material being removed/disturbed as well as having a properly trained supervisor onsite, using wet removal methods, wearing adequate personal protective equipment (HEPA-filtered particulate respirators), medical surveillance of workers, personal-exposure air monitoring, area air monitoring in occupied buildings, etc. There may also be landfill disposal requirements for these materials, depending on the facility. DSC recommends that all demolition/renovation areas involving any amount of asbestos be subjected to visual inspections and a final clearance air testing by a CDPHE-certified Air Monitoring Specialist (AMS) after the work has been completed, but before any containments are dismantled and the area is reoccupied. 6.0 Homogeneous Areas A Homogeneous Area (HA) includes materials that are uniform in appearance, color, texture and date of application. The asbestos content of the bulk-samples collected within a homogeneous area can be applied to the entire homogenous area if they conform to the above characteristics and the regulated minimum sample quantities of each type of material are collected and analyzed. 6.1 Material Friability A material can either be friable or non-friable. A friable material is one that, when dry, can be pulverized, or reduced to powder by hand pressure, a non-friable material cannot. A non-friable material may become friable if its condition had deteriorated or has been impacted by forces that have rendered it friable. 6.2 Material Classifications Sampled materials are divided into one of the following three categories:  Surfacing Material: sprayed or troweled onto structural building members  Thermal System Insulation (TSI): any type of pipe, boiler, tank, or duct insulation  Miscellaneous Material: all other materials not classified in the above two categories 5 6.3 Material Conditions Sampled materials are placed into one of the three following categories of conditions:  Good: none to very little visible damage or deterioration  Damaged: the surface is crumbling, blistered, water-stained, gouged, marred or otherwise abraded over less than one-tenth of the surface if the damage is evenly distributed, or one-quarter if the damage is localized  Significantly Damaged: the surface is crumbling, blistered, water-stained, gouged, marred or otherwise abraded over greater than one-tenth of the surface if the damage is evenly distributed, or one-quarter if the damage is localized 6.4 Sample Quantities DSC collected at least the minimum number of samples from each homogeneous area necessary to meet all regulatory requirements for the quantity of material to be disturbed. The quantities listed in this report are approximate and on-site verification of the exact quantity of each material is required. The following outlines the minimum sample quantities required per homogeneous area:  Surfacing Materials: up to 1,000 ft2 of material requires a minimum of three (3) samples; between 1,000 ft2 and 5,000 ft2 of material requires a minimum of five (5) samples; over 5,000 ft2 of material requires a minimum of seven (7) samples; one (1) sample of each patch  Thermal System Insulation (TSI): each homogeneous area requires a minimum of three (3) samples; at least one (1) sample must be collected from each patch; and collect enough samples sufficient to adequately assess the material and determine the asbestos content for TSI fittings such as pipe elbows  or  T’s.  Miscellaneous Materials: collect enough samples sufficient to determine the asbestos content 7.0 Overview of Findings DSC collected a total of five (5) asbestos bulk-samples of one (1) homogeneous area. Asbestos bulk- samples were collected of the drywall surfacing textures on the lower two levels of the residence and the garage. All of these samples were found to be none-detect for asbestos. Table 1 below describes the materials composing each homogeneous area as well as the locations of each bulk-sample collected. Also listed is the classification, condition, friability and estimated quantity of material to be removed and/or disturbed, as well as the asbestos content within each bulk-sample. Please see Appendix B: Analytical Data for the layer break-down of each bulk-sample. TABLE 1 HA - Homogeneous Area G - Good CHRY - Chrysotile SM - Surfacing Material ND - None-detect D - Damaged ACT - Actinolite MM - Miscellaneous Material TR - Trace, <1% Visual Estimate SD - Significantly Damaged TSI - Thermal System Insulation HA # Sample ID Material Description Sample Location Material Classification Material Condition Estimated Quantity Material Friability Asbestos Content 1 DW1-1 Off-White painted, knock- down Textured Drywall Laundry Room, West Wall SM G ~1,200 ft2 Friable ND DW1-2 Off-White painted, knock- down Textured Drywall Kitchen, East Wall above Cupboards SM G ~1,200 ft2 Friable DW1-3 Off-White painted, knock- down Textured Drywall Basement Bedroom Closet Wall SM G ~1,200 ft2 Friable DW1-4 Off-White painted, knock- down Textured Drywall Upstairs Spare Bedroom North Wall SM G ~1,200 ft2 Friable DW1-5 Off-White painted, knock- down Textured Drywall Upstairs Master Bedroom West Wall SM G ~1,200 ft2 Friable Conclusion & Recommendations Asbestos was not identified within the materials of the residence that were within the scope of the limited inspection and bulk-sampling performed on February 26, 2014; therefore, no professional abatement activities are required to remove or disturb the above-referenced sampled materials. 8.0 Asbestos Abatement & Demolition Requirements If ACM is to be removed or disturbed in a single-family residence and the total quantity exceeds any of the regulatory trigger levels of 50 linear ft. on pipes, 32 ft2 on other surfaces, or the volume equivalent of a 55- gallon drum, a CDPHE-certified General Abatement Contractor (GAC) is required to perform the work. The regulatory trigger levels within a commercial building are 260 linear ft. on pipes, 160 ft2 on other surfaces, or the volume equivalent of a 55-gallon drum. In addition, formal notification to CDPHE prior to the abatement of ACM as well as air monitoring, visual inspections, and final air clearances by a CDPHE- certified Asbestos AMS is required. DSC can provide the client or building owner with a proposal for project design, abatement oversight and air monitoring upon request. CDPHE regulations allow for the demolition of a building that contains non-friable asbestos-containing materials, such as caulking, mastic or resilient floor tiles. However, demolition must be completed without causing the non-friable ACM to be rendered friable. Burning a building with any ACM is prohibited. Operations such as sanding, cutting, crushing, grinding, pneumatic jacking, etc. of ACM are not permitted. Recycling of building materials such as concrete, metal, or wood that are bonded or contaminated with ACM, e.g. glue, caulking, or mastic is also prohibited. If any of the non-friable asbestos containing materials are to be recycled and rendered friable after demolition (i.e. crushing mastic-coated concrete), these materials must be abated of all ACM prior to shipping offsite for recycling. OSHA regulations regarding occupational exposure during demolition activities is still mandatory. OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities be protected from asbestos fibers in excess of the permissible exposure limit of 0.1 f/cc of air. Contractors are must comply with applicable provisions of OSHA 29 CFR 1926.1101 during demolition and renovation activities. These OSHA provisions include, but are not limited to, PPE and respirators, personnel training, personal- exposure air monitoring, employee medical surveillance, wet removal methods, signage for regulated areas, etc. 9.0 Major & Minor Asbestos Spill Response Actions If ACM is significantly damaged and the total quantity exceeds the regulatory trigger levels, the area is deemed  a  “Major  Asbestos  Spill.”    The  area  is  consequently  subject  to  the  requirements  in  Reg.  8,  Section   III.T.1. – Major Asbestos Spills, as outlined below. Additional asbestos air or dust sampling should also be conducted within the remaining areas not directly impacted by the Major Asbestos Spill to determine if asbestos-containing dust/debris has spread to adjacent areas. If asbestos fibers are found within any other areas or on building contents, they should be included in the scope of professional abatement and decontamination. The following response actions must be followed per Colorado Reg. 8 when a Major Asbestos Spill occurs:  Restrict access to the area and post warning signs to prevent entry to the area by persons other than those necessary to respond to the incident.  Shut off or temporarily modify the air handling system to prevent the distribution of asbestos fibers to other areas. 8  Immediately contact the Division by telephone, submit a notification in compliance with subsection III.E. (Notifications) and, if in an area of public access, apply for a permit in accordance with subsection III.G. (Permits).  Be exempted from the requirements to have a certified Supervisor on-site at all times, until such time as the immediate danger has passed. Any cleanup or asbestos abatement that must occur after the immediate danger has passed shall be supervised by a person certified by the Division.  Using certified Supervisors and certified Workers in accordance with section II. (Certification Requirements) of this Regulation, seal all openings between the contaminated and uncontaminated areas and establish none-detect air pressure within the contaminated area in accordance with paragraph III.J. (Air Cleaning and None-detect Pressure Requirements). This is to be accomplished using polyethylene sheeting to cover areas such as doorways, windows, elevator openings, corridor entrances, grills, drains, grates, diffusers and skylights.  HEPA vacuum or steam clean all carpets, drapes, upholstery, and other non-clothing fabrics in the contaminated area, or discard these materials.  Launder or discard contaminated clothing in accordance with subsection III.R. (Waste Handling).  HEPA vacuum or wet clean all surfaces in the contaminated area.  Discard all materials in accordance with subsection III.R. (Waste Handling).  Following completion of subparagraph III.T.1.a. through III.T.1.i. above, comply with air monitoring requirements as described in subsection III.P. (Clearing Abatement Projects); air samples shall be collected aggressively as described in 40 C.F.R. Part 763, Appendix A to Subpart E (EPA 1995), except that the air stream of the leaf blower shall not be directed at any friable ACM that remains in the area and  Comply with any other measures deemed necessary by the Division to protect public health. In the event of an asbestos spill involving less than or equal to the trigger levels, the building owner or contractor should take the following non-mandatory steps:  Restrict entry to the area and post warning signs to prevent entry to the area by persons other than those necessary to respond to the incident.  Shut off or temporarily modify the air handling system to prevent the distribution of fibers to other areas in the building.  Seal all openings between the contaminated and uncontaminated areas. This is to be accomplished by using polyethylene sheeting to cover all areas such as windows, doorways, elevator openings, corridor entrances, drains, grills, grates, diffusers and skylights.  HEPA vacuum or steam clean all carpets, draperies, upholstery and other non-clothing fabrics in the contaminated area, or discard all contaminated materials in accordance with subsection III.R. (Waste Handling).  Launder or discard contaminated clothing in accordance with subsection III.R. (Waste Handling).  HEPA vacuum or wet clean all non-fabric surfaces in the contaminated area.  Following completion of subparagraphs III.T.2.a. through III.T.2.f. of Regulation 8, conduct air monitoring as described in paragraph III.P.3 of Regulation 8. (Final Clearance Air Monitoring and Sample Analyses); air samples shall be collected aggressively as described in 40 C.F.R. Part 763, Appendix A to Subpart E (EPA 1995), except that the air stream of the leaf blower shall not be directed at any friable ACM that remains in the work area. 10.0 Disclaimer & Limitations The activities outlined in this report were conducted in a manner consistent with a level of care and expertise exercised by members of the environmental consulting and industrial hygiene profession. All 9 activities were performed in accordance with all applicable federal, state, and local regulations as well as generally accepted standards and professional practice. No warranty is either expressed or implied. DSC assumes no responsibility or liability for error in public information utilized, statements from sources other than DSC, or developments resulting from situations outside the scope of this project. The details provided within this report outline the inspection activities on the date(s) indicated and should not be relied upon to represent conditions at a later date, the limited number of bulk-samples collected, and the laboratory results of those bulk-samples. The laboratory results contained in this report apply specifically to the materials in which bulk-samples were collected. The results do not include or apply to any other materials within the structure that were not sampled, but may contain asbestos; including materials that may be hidden or inaccessible. Additional inspection and bulk-sampling activities would be required to determine if any other materials contain asbestos. This report has been prepared on behalf of and exclusively for use by the Client, with specific application to their project as discussed in the scope of work. The results of any surfacing material indicated in this report also includes any associated overspray of that material, e.g., under carpet, above suspended ceilings, etc. The information contained in this report is intended as supplementary material for abatement design and is not to be used as the scope of work for abatement activities, bidding or billing purposes. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. DSC can provide a full scope of work for abatement upon request. DSC 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. 11.0 Copyright Notice © DS Consulting, Inc. 2014. All Rights Reserved. This document contains material protected under Federal Copyright Laws. No part of this document or any of its contents may be reproduced, copied, modified or adapted, without the prior written consent of the author and DS Consulting, Inc. 10 APPENDIX A INSPECTOR & FIRM ASBESTOS CERTIFICATES 11 APPENDIX B ANALYTICAL DATA Reservoirs Environmental, Inc. Reservoirs Environmental QA Manual Effective January 1, 2013 T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc Subcontract Number:NA Laboratory Report:RES 283415-1 Project # / P.O. #None Given Project Description:381 Beaver Dam Cir. Vail, CO. RES 283415-1 Sincerely, is the job number assigned to this study. This report is considered highly confidential and the sole property of the customer.Reservoirs Environmental,Inc.will not discuss any part of this study with personnel other than those of the client.The results described in this report only apply to the samples analyzed. This report must not be used to claim endorsement of products or analytical results by NVLAP or any agency of the U.S.Government.This report shall not be reproduced except in full,without written approval from Reservoirs Environmental,Inc.Samples will be disposed of after sixty days unless longer storage is requested.If you have any questions about this report, please feel free to call 303-964-1986. Jeanne Spencer President March 5, 2014 Dear Customer, Reservoirs Environmental,Inc.is an analytical laboratory accredited for the analysis of Industrial Hygiene and Environmental matrices by the National Voluntary Laboratory Accreditation Program (NVLAP),Lab Code 101896-0 for Transmission Electron Microscopy (TEM)and Polarized Light Microscopy (PLM)analysis and the American Industrial Hygiene Association (AIHA),Lab ID 101533 -Accreditation Certificate #480 for Phase Contrast Microscopy (PCM)analysis.This laboratory is currently proficient in both Proficiency Testing and PAT programs respectively. Reservoirs Environmental,Inc.has analyzed the following samples for asbestos content as per your request.The analysis has been completed in general accordance with the appropriate methodology as stated in the attached analysis table. The results have been submitted to your office. DS Consulting, Inc. 5366 Flatrock Ct. Morrison CO 80465 Brandon Sinkbeil P: 303-964-1986 F: 303-477-4275 5801 Logan Street, Suite 100 Denver, CO 80216 Page 1 of 3 1-866-RESI-ENV www.reilab.com Reservoirs Environmental, Inc. Reservoirs Environmental QA Manual Effective January 1, 2014 T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Method:ND=None Detected Turnaround:TR=Trace, <1% Visual Estimate Date Analyzed:Trem-Act=Tremolite-Actinolite Client Non Non- Sample Sub Asbestos Fibrous Number Physical Part Fibrous Components Description (%)Mineral Visual Components (%) Estimate (%)(%) DW0101 EM 1126651 A B C D E White compound White tape White joint compound White/tan drywall Tan compound 5 15 15 15 50 ND ND ND ND ND 0 90 0 80 0 100 10 100 20 100 DW0102 EM 1126652 A B C D E White compound White tape White joint compound White/tan drywall Tan compound 5 15 15 20 45 ND ND ND ND ND 0 90 0 50 0 100 10 100 50 100 DW0103 EM 1126653 A B C D E White compound White tape White compound White/tan drywall Tan compound 5 15 15 25 40 ND ND ND ND ND 0 90 0 40 0 100 10 100 60 100 RESERVOIRS ENVIRONMENTAL, INC. NVLAP Lab Code 101896-0 TDH Licensed Laboratory # 30-0136 ID Number L A Y E R Lab 3-5 Day RES 283415-1 None Given DS Consulting, Inc. Asbestos Content February 26, 2014 381 Beaver Dam Cir. Vail, CO. EPA 600/R-93/116 - Short, Bulk March 5, 2014 P: 303-964-1986 F: 303-477-4275 5801 Logan Street, Suite 100 Denver, CO 80216 Page 2 of 3 1-866-RESI-ENV www.reilab.com Reservoirs Environmental, Inc. Reservoirs Environmental QA Manual Effective January 1, 2014 T:\QAQC\Lab\Reservoirs Environmental QA Manual.doc TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME RES Job Number: Client: Client Project Number / P.O.: Client Project Description: Date Samples Received: Method:ND=None Detected Turnaround:TR=Trace, <1% Visual Estimate Date Analyzed:Trem-Act=Tremolite-Actinolite Client Non Non- Sample Sub Asbestos Fibrous Number Physical Part Fibrous Components Description (%)Mineral Visual Components (%) Estimate (%)(%) RESERVOIRS ENVIRONMENTAL, INC. NVLAP Lab Code 101896-0 TDH Licensed Laboratory # 30-0136 ID Number L A Y E R Lab 3-5 Day RES 283415-1 None Given DS Consulting, Inc. Asbestos Content February 26, 2014 381 Beaver Dam Cir. Vail, CO. EPA 600/R-93/116 - Short, Bulk March 5, 2014 DW0104 EM 1126654 A B C White compound w/ tan paint White/tan drywall White compound w/ cream paint 10 20 70 ND ND ND 0 60 0 100 40 100 DW0105 EM 1126655 A B C White compound w/ cream paint White compound w/ cream paint White/tan drywall 3 10 87 ND ND ND 0 0 15 100 100 85 TEM Analysis recommended for organically bound material (i.e. floor tile) if PLM results are <1%. Analyzed by:Data QA: P: 303-964-1986 F: 303-477-4275 5801 Logan Street, Suite 100 Denver, CO 80216 Page 3 of 3 1-866-RESI-ENV www.reilab.com