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HomeMy WebLinkAboutB14-0469 Asbestos Report.pdf Asbestos Inspection and Sampling Report 1030 Lions Ridge Loop, Unit 103, Vail, Colorado 81657 Presented To: Mr. Tod Stenger 1681 S Emerson St Denver, CO 80210 tods27@gmail.com Performed & Prepared By: Mr. Alex Johnsen DS Consulting, Inc. PO Box 6864 Avon, CO 81620 (970) 389-2908 Project Details: Project Number: 10930 Conducted: October 2, 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 Project Design & Project Manager Requirements 13.0 Copyright Notice APPENDIX A Inspector & Firm Asbestos Certificates APPENDIX B Analytical Data 3 PROJECT OVERVIEW 1.0 Introduction On October 2, 2014, Mr. Alex Johnsen with DS Consulting, Inc. (DSC) conducted a limited asbestos inspection and collected asbestos bulk-samples of suspect asbestos-containing materials (ACM) within a portion of the single-family residence located at 1030 Lions Ridge Loop, Unit 103, Vail, CO. The purpose of the limited inspection was to identify and sample potentially hazardous friable and non- friable ACM that may be impacted by renovation activities. Asbestos bulk-samples were collected of the orange peel drywall wall and ceiling texture, as well as the gold, sheet vinyl flooring on the floor of the boiler/utility room. The orange peel drywall wall and ceiling texture were found to be none-detect for asbestos. However, the gold, sheet vinyl flooring was found to contain 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 homeowner as listed above. The remaining areas and materials within the residence, garage 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 single-level, single-family residence in a multi-unit building. 4.0 Certifications The limited asbestos inspection and bulk-sampling was conducted by Mr. Alex Johnsen with DSC. DSC is a Colorado Department of Public Health and Environment (CDPHE) certified Asbestos Consulting Firm, Registration No. 14912. Mr. Johnsen is a CDPHE certified Building Inspector; having certification number 20533 (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 4 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). 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. 5 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 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 four (4) asbestos bulk-samples of two (2) homogeneous areas. Asbestos bulk- samples were collected of the orange peel drywall wall and ceiling texture, as well as the gold, sheet vinyl flooring on the floor of the boiler/utility room. The orange peel drywall wall and ceiling texture were found to be none-detect for asbestos. However, the gold, sheet vinyl flooring was found to contain 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 Orange peel drywall wall and ceiling texture W wall of S closet by front door SM G ~100 ft2 Friable ND DW1-2 Orange peel drywall wall and ceiling texture W wall of kitchen in NW corner SM G ~100 ft2 Friable DW1-3 Orange peel drywall wall and ceiling texture N wall of guest bathroom by toilet SM G ~100 ft2 Friable 2 SV1-1 Gold sheet vinyl flooring Floor of boiler/utility room MM G ~20 ft2 Friable Sheet vinyl: 25% CHRY (yellow mastic: ND) 8.0 Conclusion & Recommendations Asbestos was identified within some of the materials of the residence that were within the scope of the limited inspection and bulk-sampling performed on October 2, 2014; therefore, professional abatement activities are required to remove or disturb the above-referenced asbestos-containing materials. 9.0 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. 10.0 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. 11.0 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. 12.0 Project Design & Project Manager Requirements DSC can provide an Asbestos Project Design as well as fulfill the Colorado Asbestos Project Manager requirements for any asbestos abatement project, as applicable below. Project Design An abatement Project Design is an accurate and detailed scope of work, which includes project specifications and procedures, containment design/equipment placement, and descriptions of engineering controls and work practices for an asbestos abatement project or response action that is required by CDPHE Regulation Number 8, Part B - Asbestos (Reg. 8) on large asbestos abatement projects. Prior to the start of any asbestos abatement project in a non-school building, where the amount of asbestos-containing material (ACM) to be removed or disturbed exceeds 1,000 linear feet on pipes, or 3,000 square feet on surfaces, or in a school building in which the amount of friable ACM to be abated exceeds 3 linear feet on pipes, or 3 square feet on surfaces, a written Project Design must be developed by a State of Colorado certified Project Designer in accordance with subsection IV.G.7 of Regulation 8. A signed copy shall be posted on-site prior to commencing any abatement activities, shall be available on- site at all times, and shall remain onsite until final air clearances have been completed by a State of Colorado-certified Air Monitoring Specialist (AMS). Project Manager A Project Manager shall be used on all asbestos abatement projects in which the amount of friable asbestos-containing material to be abated exceeds 1,000 linear feet on pipes, or 3,000 square feet on other surfaces per CDPHE Regulation Number 8, Part B – Section III.B.6. An asbestos Project Manager on an abatement project shall be responsible for assessing that the project is conducted in accordance with Regulation 8, assessing that the Project Design is followed, assessing that the abatement project is cleared in accordance with Regulation 8, assessing that the asbestos waste generated on the project is properly 10 manifested and disposed of in accordance with Regulation 8, and communicating these assessments to the building owner or GAC. Project Managers must have proof of Colorado certification as an asbestos Project Designer and Air Monitoring Specialist in accordance with Section II of CDPHE Regulation 8 as well as a minimum of one (1) year of experience supervising, overseeing or monitoring asbestos abatement projects. A 4-year college degree in industrial hygiene, a degree in environmental health with a major concentration in industrial hygiene, or the possession of a certified industrial hygienist (CIH) certificate given by the American Board of Industrial Hygiene (ABIH) may be substituted for the Colorado asbestos Air Monitoring Specialist course. The GAC shall notify the building owner during bid proposals as to whether or not a project manager is required. Project managers shall be independent of the asbestos abatement contractor and work strictly on behalf of the building owner to the extent feasible, unless the abatement is being performed in-house. Project managers must sign the original copy of the abatement permit for the permit to be valid. 13.0 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. 11 APPENDIX A INSPECTOR & FIRM ASBESTOS CERTIFICATES 12 13 APPENDIX B ANALYTICAL DATA 780 Simms Street Suite 104 Golden, CO, 80401 303.232.3746 Certificate of Analysis www.aerobiology.net Client Name DS Consulting Date Collected:10/02/14 Street address 5366 Flatrock Ct.Date Received:10/02/14 City, State ZIP Morrison, CO 80465 Date Analyzed:10/09/14 Attn: Alex Johnson 200860-0 Date Reported:10/09/14 Client Project Name: 1030 Lions Ridge Loop, Unit 103 Vail, CO.Project ID:14020836 Job ID: Test Requested:3002, Asbestos in Bulk Samples Method:Polarized Light Microscopy / Dispersion Staining (PLM), Method for the Determination of Asbestos in Bulk Building Materials. EPA-600/R-93/116, July 1993. Non-Asbestos Non-Fibrous Matrix Fiber Material Material Client Percentage Percentage Composition P = PerliteB = BinderD=Diatoms NTR = Non-Asbestiform TR NAC = Non-Asbestiform AC 780 Simms Street, Suite 104, Golden, CO, 80401, 303.232.3746 DW 1-1 DW 1-2 DW 1-3 N N 5% 20% 50% N N Trace=Less Than 1% N N 50% 25% 50% ND=None Detected CHRY=Chrysotile M = MicaCR = Crocidolite T = TarTR = Tremolite A = Amosite Q = QuartzAC = Actinolite C = CarbonatesAN = Anthophyllite G = Gypsum G ND 100 G ND 100 C 15 85 G ND 100 C ND 98 2 ND ND 15 85 G ND 100 C ND 2 15 85 ND 100 C Asbestos Percentage White Tape ND 98N5% 10% Asbestos Detected White Joint Compound Laboratory Analyst Ron WeyandAsbestos Laboratory SupervisorPaul Knappe White Texture w/White Paint White/Tan Dryway White Texture w/White Paint 14020836-3B 14020836-2D 14020836-3A White Joint Compound14020836-2B White/Tan Dryway14020836-2C NVLAP Lab Code 14020836-1D 14020836-2A 20% N 65% 14020836-1C N Lab Sample Number N White/Tan Dryway White Tape White Texture w/White Paint Sample Identification Physical Description of Sample/Layer Homo- geneous (Y/N) Layer Percentage 14020836-1A 14020836-1B Page 1 of 3 780 Simms Street Suite 104 Golden, CO, 80401 303.232.3746 Certificate of Analysis www.aerobiology.net Client Name DS Consulting Date Collected:10/02/14 Street address 5366 Flatrock Ct.Date Received:10/02/14 City, State ZIP Morrison, CO 80465 Date Analyzed:10/09/14 Attn: Alex Johnson 200860-0 Date Reported:10/09/14 Client Project Name: 1030 Lions Ridge Loop, Unit 103 Vail, CO.Project ID:14020836 Job ID:0 Test Requested:3002, Asbestos in Bulk Samples Method:Polarized Light Microscopy / Dispersion Staining (PLM), Method for the Determination of Asbestos in Bulk Building Materials. EPA-600/R-93/116, July 1993. Non-Asbestos Non-Fibrous Matrix Fiber Material Material Client Percentage Percentage Composition P = PerliteB = BinderD=Diatoms NTR = Non-Asbestiform TR NAC = Non-Asbestiform AC 780 Simms Street, Suite 104, Golden, CO, 80401 NVLAP Lab Code Sample Identification Physical Description of Sample/Layer Homo- geneous (Y/N) Layer Percentage Asbestos Detected Asbestos Percentage Lab Sample Number 14020836-4A Yellow Mastic N 1%ND SV 1-1 100 B 14020836-4B Tan Sheet Vinyl w/White Fibrous Backing N 99%CHRY 25 5 70 B A = AmositeAC = Actinolite C = CarbonatesAN = Anthophyllite G = GypsumCHRY=Chrysotile M = Mica Q = Quartz Laboratory Analyst Asbestos Laboratory Supervisor ND=None Detected CR = Crocidolite T = TarTR = TremolitePaul Knappe Ron Weyand Trace=Less Than 1% Page 2 of 3 780 Simms Street Suite 104 Golden, CO, 80401 303.232.3746 Certificate of Analysis www.aerobiology.net DS Consulting Date Collected:10/02/14 5366 Flatrock Ct.Date Received:10/02/14 Morrison, CO 80465 Date Analyzed:10/09/14 Alex Johnson 200860-0 Date Reported:10/09/14 Client Project Name: 1030 Lions Ridge Loop, Unit 103 Vail, CO.Project ID:14020836 Job ID: General Notes  ND indicates no asbestos was detected; the method detection limit is 1 %.  Trace or "<1" indicates asbestos was identified in the sample, but the concentration is less than 1%. Notes Required by NVLAP  This test report relates only to the items tested or calibrated.  This report is not valid unless it bears the name of a NVLAP-approved signatory.  Any reproduction of this document must include the entire document in order for the report to be valid. 780 Simms Street, Suite 104, Golden, CO, 80401, 303.232.3746 NVLAP Lab Code  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.  All regulated asbestos minerals (i.e. chrysotile, amosite, crocidolite, anthophyllite, tremolite, and actinolite) were sought in every layer of each sample, but only those asbestos minerals detected are listed. Amosite is the common name for the asbestiform variety of the minerals cummingtonite and grunerite. Crocidolite is the common name used for the asbestiform variety of the mineral riebeckite.  Tile, vinyl, foam, plastic, and fine powder samples may contain asbestos fibers of such small diameter (< 0.25 microns in diameter) that these fibers cannot be detected by PLM. For such samples, more sensitive analytical methods (e.g. TEM, SEM, and XRD) are recommended if greater certainty about asbestos content is required. Semi-quantitative bulk TEM floor tile analysis is accepted under NESHAP regulations.        These results are submitted pursuant to Aerobiology Laboratory Associates, Inc.’s current terms and conditions of sale, including the company’s standard warranty and limitation  of liability provisions. No responsibility or liability is assumed for the manner in which the results are used or interpreted.  Unless notified in writing to return the samples covered by this report, Aerobiology Laboratory Associates, Inc. will store the samples for a minimum period of thirty (30) days before discarding. A shipping and handling charge will be assessed for the return of any samples.  Aerobiology does not guarantee the results of tape lifts, microvacs, wipe, and/or debris samples. Accurate analysis cannot be performed due to particle size, media used, and/or amount of material given. Analysis of these materials should be preformed by a TEM. A result of ND does not indicate that the sample area does not contain asbestos. It means the analyst could not identify asbestos in the specific sample for the reasons listed above. Page 3 of 3