ASBESTOS SURVEY FOR DEMOLITION (ACM) OFFICE BUILDING 315 CENTRAL AVENUE CRESCENT CITY, FL Prepared for:

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1 ASBESTOS SURVEY FOR DEMOLITION (ACM) OFFICE BUILDING 315 CENTRAL AVENUE CRESCENT CITY, FL Prepared for: Mr. Patrick Kennedy, City Manager Crescent City 3 N. Summit Street Crescent City, FL Prepared by: PbO3 Environmental Testing & Service Co., Inc. 473 North Pine Meadow Drive DeBary, Florida (386) Project No September 13, 2010 Asbestos License # ZA

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3 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No Table of Contents 1.0 INTRODUCTION Inspection and Sampling Procedure Methods of Laboratory Analysis Quality Control Procedures Determination of ACM Classification Inspection Limits Statement of Inaccessibility & Assumptions Inspection Date FACILITY CONSTRUCTION INFORMATION Facility Maintenance and/or Renovation History Suspect Sample Summary of Homogeneous Materials RESULTS CONCLUSIONS RECOMMENDATIONS...8 Appendices Appendix A: Laboratory Analysis Reports Appendix B: Drawing Appendix C: Photographs Appendix D: Asbestos Hazard Control Specification Appendix E: Certifications PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 2 ASBESTOS LICENSE # ZA

4 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No INTRODUCTION PbO 3 was contracted by Crescent City to conduct an Asbestos Survey of the suspect asbestos containing materials found in the office building known as 315 Central Avenue, Crescent City, Florida. The goal of the sampling and visual assessment is as follows: 1) Identify suspect asbestos-containing material that may be encountered during the demolition of this building. 1.1 Inspection and Sampling Procedure PbO 3 inspection and sample collection procedures are based on the Environmental Protection Agency (EPA) protocols. An initial facility walk through is conducted to familiarize the inspector with the facility layout. The facility is then divided into functional available spaces that can be accessed. The suspect homogeneous materials are selected for bulk sampling. Samples are collected and placed into separate, sealed plastic bags. Each sample is individually numbered and sample information is entered onto a Field Data Sheet. Sample tools are decontaminated after sample collection. The samples are delivered to an accredited laboratory for analysis, accompanied by a completed Chain of Custody Form. Suspect materials are divided into three categories: surfacing materials (such as plaster and surface coatings), thermal system insulation (TSI) (such as mudded TSI fittings, duct insulation, and pipe insulation), and miscellaneous material (such as floor tile, drywall, and mastic). Asbestos-containing materials are classified according to: Friability * Friable * Non-friable Friable materials are materials that, when dry, can be crushed, pulverized, or reduced to powder by hand pressure. Prior to sampling, these materials are wetted with amended water to minimize potential for incidental exposure or accidental fiber release. At the inspector's discretion, personal protective equipment (PPE) is used as an added precaution. Bulk samples are collected using EPA guidelines for the type of suspect material sampled. Where practical, minimal damage will occur to facility structures or finishes. A particular suspect material may be found in several different locations within a facility. The EPA does not require that these materials be sampled in each location, provided the materials are of the same type, age, appearance, have the same date of installation, and are sampled in accordance with EPA requirements to provide statistically reliable data that can be extrapolated onto all remaining non-sampled areas. Accredited inspectors determine the number of samples of each material to be collected, depending on the material's category and the amount of material present. PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 3 ASBESTOS LICENSE # ZA

5 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No Methods of Laboratory Analysis Samples are analyzed in accordance with AHERA requirements using the following reference methods: EPA Interim Method for the Detection of Asbestos in Bulk Insulation Samples (EPA 600/M , December 1982). McCrone Research Institute's The Asbestos Particle Atlas. All bulk samples are analyzed using PLM visual area estimate (VAE). Friable materials containing asbestos estimated at less than ten percent by PLM-VAE may be reanalyzed by PLM point counting. Additional treatment and tests may be used as required to accurately define composition (i.e., ashing, extractions, and TEM). All bulk sample laboratory reports are verified through an established quality assurance (QA) procedure. 1.3 Quality Control Procedures Laboratories accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) analyze all samples. These laboratories participate in the NVLAP, as well as the American Industrial Hygiene Association (AIHA) Bulk Asbestos Sample Quality Assurance Program. PbO 3 verifies all sample data for accuracy by cross-referencing Field Data Sheets, Chain of Custody Forms, and field notes. 1.4 Determination of ACM Classification The positive identification of asbestos in a material or product can only be made through laboratory analysis. Visual inspection or common knowledge is not a positive test. The asbestos content of a suspect material is determined by collecting a bulk sample and having it analyzed by PLM. The PLM technique determines the specific type of asbestos present in the bulk sample and VAE provides an estimate of the percentage of asbestos. The EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) - National Emission Standard for Asbestos (40 CFR Part 61, subpart M) defines a non-friable asbestos-containing material as any material with an asbestos content greater than one percent as determined by PLM analysis. A friable material estimated to contain less than ten percent asbestos as determined by PLM-VAE must be analyzed by PLM point counting and determined to contain less than one- percent asbestos in order to be considered a non-regulated ACM. A clarification memorandum issued by the EPA regarding the NESHAP regulation included the following statement: The parties legally responsible for a building (owner or operator) may take a conservative approach to being regulated by the NESHAP. The responsible party - may choose to act as though the building material is an asbestos-containing material (greater than 1%) at any level of asbestos content (even less than 1% asbestos). PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 4 ASBESTOS LICENSE # ZA

6 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No Thus, if the analyst detects asbestos in the sample and estimates the amount to be less than 10% by visual estimation, the parties legally responsible (owner or operator) of the building may elect to assume the amount to be greater than 1% and treat the material as regulated asbestos containing material or require verification of the amount by point counting. 1.5 Inspection Limits PbO 3 has performed the Client requested tasks in a thorough and professional manner consistent with commonly accepted standard industry practices, using state of the art practices and best available known technology, as of the date of the assessment. PbO 3 cannot guarantee and does not warrant that this Asbestos Source Survey has identified all adverse environmental factors and/or conditions affecting the subject properties on the date of the Assessment. PbO 3 cannot and will not warrant that the Asbestos Source Survey that was requested by the client will satisfy the dictates of, or provide a legal defense in connection with, any environmental laws or regulations. It is the responsibility of the client to know and abide by all applicable laws, regulations, and standards. The results reported and conclusions reached by PbO 3 are solely for the benefit of the client. The results and opinions in this report, based solely upon the conditions found on the property as of the date of the Assessment, will be valid only as of the date of the Assessment. No attempt was made to disassemble equipment or demolish structural elements and finishes as this is beyond the scope of our authorized services. Visual observations were made at convenient locations for the presence of floor tile and mastic below existing finishes. Due to these limitations, wall voids, building cavities and mechanical equipment, and other areas may contain unreported asbestos-containing materials. We typically try to examine fire doors, but there are times when disassembly of locks and/or other work to access the door insulation is not possible or the door is used for security. Location and sampling of underground items, such as asbestos-cement pipes, would have been outside of the scope. The primary purpose of the survey was to locate, identify and assess building materials that may contain asbestos, and propose recommendations relative to the impending demoltion. Quantities shown in this survey are estimates, actual quantities may vary. Field verification is the responsibility of the contractor. Contractors are responsible for their own verification of quantities prior to bid submittal. 1.6 Statement of Inaccessibility & Assumptions There are certain spaces within a building that cannot be accessed during the course of a normal survey without significant demolition activities. Those areas would include, but are not limited to: The BUR Roof is presumed asbestos containing material. Tunnels, crawlways, and/or rooms which are enclosed, very small or unsafe or locked. Floor tile and other vinyl flooring are all presumed non-friable asbestos containing material unless noted in this report. Materials located at a height not accessible by ladders or other means. Fire doors, if present are presumed asbestos containing material unless noted in this report. Electrical system and Underground pipelines. PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 5 ASBESTOS LICENSE # ZA

7 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No Suspect materials not previously identified in this report may be encountered during any renovation and/or maintenance activities. These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise. 1.7 Inspection Date PbO 3 employee Kevin O Malley inspected the project on August 19 th, FACILITY CONSTRUCTION INFORMATION The single story office building is attached to the east side of the 1 S. Summit building. The office building is constructed of block. The roof is a built up roof (BUR) with asphaltic material. The interior is gypsum board and plaster. The building is approximately 2,400 sqft. The building was constructed in Facility Maintenance and/or Renovation History Unknown 2.2 Suspect Sample Summary of Homogeneous Materials Drywall and Joint Compound 1 x1 Acoustical Ceiling Tile (Rough Finish) 2 x2 Acoustical Ceiling Tile (Smooth Finish) 2 x2 Acoustical Ceiling Tile (Snowflake Finish) Plaster with Skim Coat 12 x12 Floor Tile-Brown Mortar Concrete 3.0 RESULTS There was a total of twenty-seven (27) samples analyzed by EPA Method 600/R-93/116 (PLM) and three (3) drywall/joint compound samples were confirmed by the EPA Point Count Method. Based upon our visual observations, bulk sampling of suspect materials and subsequent microscopic analysis, we have determined that NO regulated amounts of asbestos containing material was detected. JobLocation AnalysisDate ClientSample Sample Indentification LayerID LayerName MacroDescription Asbestos Material Asbestos Qty 315 Central Ave 8/24/ RM-1 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE <1% 315 Central Ave 8/24/ RM-10 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE <1% 315 Central Ave 8/24/ RM-11 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE <1% 315 Central Ave 9/16/ EPA Pt Ct RM-1 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE 0.50% 315 Central Ave 9/16/ EPA Pt Ct RM-10 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE 0.50% 315 Central Ave 9/03/ EPA Pt Ct RM-10 1 Drywall/Joint Cmpd White, Powdery/Granular CHRYSOTILE 0.0% PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 6 ASBESTOS LICENSE # ZA

8 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No CONCLUSIONS PbO 3 was contracted by Crescent City to conduct an Asbestos Survey of the suspect asbestos containing materials found in the office building known as 315 Central Avenue, Crescent City, Florida. The goal of the sampling and visual assessment is as follows: 1) Identify suspect asbestos-containing material that may be encountered during the demolition of this building. The criterion used for determining the status of a suspect material as ACM is the USEPA definition of being asbestos-containing, which is that the material is determined to contain greater than 1.0% of asbestos by weight (40 CFR 61, Subpart M). Complete listing of the materials tested for asbestos, chain of custody, and laboratory results with sample locations are included in Appendix A. Drywall/Joint Compound Results of the reanalysis of representative samples by point count methodology, has determined that the drywall/joint compound was less (<1.0%) asbestos. As a result, this material is not regulated by the US EPA and Florida Department of Environmental Protection (FDEP), However, U.S. Occupational Safety and Health Administration (OSHA) regulations still apply to the disturbance of material; containing any percentage of asbestos fibers. This work must be performed by a contractor who has workers and a supervisor trained for Class II asbestos work activities. Presumed Asbestos Containing Roofing Materials Non-friable Asbestos Containing Materials are presumed in the Roofing System. The EPA NESHAP (40 CFR Part 61, Appendix A to Subpart M) classifies the roofing materials as Category I, non-friable ACM. Removal is not required by NESHAP provided the demolition activities do not subject this material to cutting, sanding, grinding, abrading, or otherwise rendering them friable during renovation or demolition. PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 7 ASBESTOS LICENSE # ZA

9 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No RECOMMENDATIONS Controlled Wet demolition of all materials in place provided the demolition activities do not subject non-friable asbestos containing material to cutting, sanding, grinding, abrading, or otherwise rendering them friable during demolition. 29 CFR OSHA's Asbestos Standard for the Construction Industry does apply to the demolition of all buildings identified with asbestos containing material. The contractor will need to comply with the specific training, duties and responsibilities outlined in this CFR. The EPA s National Emission Standard for Hazardous Air Pollutants (NESHAP) regulations and the Florida Department of Environmental Protection (DEP) Asbestos program regulate the removal and disposal of asbestos-containing building materials. The Florida Department of Environmental Protection (DEP) administers an asbestos removal program under Chapter , Florida Administrative Code. The Asbestos NESHAP has been adopted by reference in section , Florida Administrative Code. The program s intent is to minimize the release of asbestos fibers during activities involving the processing, handling, and disposal of asbestos-containing material. The regulations of these agencies require the removal of friable asbestos-containing materials prior to extensive renovation or demolition projects, and the removal of non-friable asbestos-containing materials that may be rendered friable in the course of renovation or demolition projects. Only a Florida licensed asbestos contractor using properly trained, certified, and licensed asbestos workers can perform asbestos removal projects in Florida. Air monitoring during and after abatement activities is also recommended to document the fiber levels inside and outside the abatement work area. The asbestos NESHAP requires that an asbestos trained person be on site i.e. 40 CFR (c) (8) states in part no RACM shall be stripped, removed, or otherwise handled or disturbed at a facility regulated by this section unless at least one on-site representative, such as a foreman or management level person or other authorized person, trained in the provisions of this regulation and the means of complying with them is present. DEP recommends that this trained person be on site when nonfriable ACM is present so that developing problems can be caught early and corrected without delay. In addition, the regulations require the owner of the building and/or the operator to notify the applicable DEP District Office or Local Pollution Control Agency before any demolition, or before renovations of buildings that contain a certain threshold amount of asbestos or asbestos containing materials. Florida requires the submission of a 10-Day Notification for all renovations and demolitions of facilities with at least 260 linear feet of regulated asbestos-containing materials (RACM), 160 square feet of regulated asbestos containing materials on other facility components, or at least one cubic meter (35 cubic feet) off facility components. Asbestos waste requires disposal at an approved solid waste disposal facility. Local agencies may also have specific requirements for demolition/renovation projects involving asbestos-containing building materials. PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 8 ASBESTOS LICENSE # ZA

10 Asbestos Survey for Demolition Office Building 315 Central Avenue Crescent City, FL Project No OSHA 29 CFR requires the communication of information concerning asbestos hazards. Employees engaged in work activities with installed ACM may be exposed to asbestos fibers. The owner or operator should take the necessary steps to reduce the potential for disturbance. Suspect materials not previously identified in this report may be encountered during any renovation and/or maintenance activities. If encountered all work in the immediate area shall cease. These materials should be assumed asbestos containing material until sample collection and subsequent analysis prove otherwise. PbO 3 ENVIRONMENTAL TESTING & SVC. CO., INC Page 9 ASBESTOS LICENSE # ZA

11 APPENDIX A LABORATORY RESULTS

12 SCHNEIDER LABORATORIES I N C O R P O R A T E D 2512 W. Cary Street Richmond, Virginia LABS (5227) (FAX) Excellence in Service and Technology AIHA/ELLAP , NVLAP , NYELAP/NELAC 11413, CAELAP 2078, NC 593, SC LABORATORY ANALYSIS REPORT Asbestos Identification by EPA Method¹ 600/M4/82/020 ACCOUNT #: CLIENT: PbO3 ENV TESTING & SERVICES INC ADDRESS: 473 N PINE MEADOW DR DEBARY, FL PROJECT NAME: Crescent City JOB LOCATION: 315 Central Ave PROJECT NO.: Demo PO NO.: Using SLI A6 DATE COLLECTED: 8/18/2010 DATE RECEIVED: 8/23/2010 DATE ANALYZED: 8/24/2010 DATE REPORTED: 8/26/2010 SampleType: BULK Client SLI Sample Sample No. Sample/ Layer ID RM-1 Identification/ Layer Name Asbestos Fibers PLM Analysis Results Other Materials Layer 1: Drywall/Joint Cmpd <1% CHRYSOTILE 3% CELLULOSE FIBER White, Powdery/Granular 97% NON FIBROUS MATERIAL RM-10 Layer 1: Drywall/Joint Cmpd <1% CHRYSOTILE 3% CELLULOSE FIBER White, Powdery/Granular 97% NON FIBROUS MATERIAL RM-11 Layer 1: Drywall/Joint Cmpd <1% CHRYSOTILE 4% CELLULOSE FIBER White, Powdery/Granular 96% NON FIBROUS MATERIAL Hall Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Tan, Fibrous 15% NON FIBROUS MATERIAL RM-2 Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Tan, Fibrous 15% NON FIBROUS MATERIAL Total Number of Pages in Report: 4 Results relate only to samples as received by the laboratory. Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the limitations of light microscopy including matrix interference. Gravimetric reduction and correlative analyses are recommended for all non-friable, organically bound materials. This method has a reporting limit of 1% or greater. Visual estimation contains an inherent range of uncertainty. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other gov't agency endorsement.

13 Account - Workorder (Continued) Page 2 (Continued) Client SLI Sample Sample Sample/ Identification/ PLM Analysis Results No. Layer ID Layer Name Asbestos Fibers Other Materials RM-6 Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Tan, Fibrous 15% NON FIBROUS MATERIAL RM-5 Throughout Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Brown, Fibrous 15% NON FIBROUS MATERIAL RM-5 Throughout Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Brown, Fibrous 15% NON FIBROUS MATERIAL RM-5 Throughout Layer 1: Ceiling Tile None Detected 85% CELLULOSE FIBER Brown, Fibrous 15% NON FIBROUS MATERIAL Hall 502 Layer 1: Ceiling Tile None Detected 75% CELLULOSE FIBER White, Fibrous 10% MINERAL/GLASS WOOL 15% NON FIBROUS MATERIAL Hall 502 Layer 1: Ceiling Tile None Detected 75% CELLULOSE FIBER White, Fibrous 10% MINERAL/GLASS WOOL 15% NON FIBROUS MATERIAL Hall 502 Layer 1: Ceiling Tile None Detected 75% CELLULOSE FIBER White, Fibrous 10% MINERAL/GLASS WOOL 15% NON FIBROUS MATERIAL RM-5 Layer 1: Plaster/Skim Coat None Detected 3% CELLULOSE FIBER green/gray/white, Granular/Powdery 97% NON FIBROUS MATERIAL RM-5 Layer 1: Plaster/Skim Coat None Detected 4% CELLULOSE FIBER green/gray/white, Granular/Powdery 96% NON FIBROUS MATERIAL Total Number of Pages in Report: 4 Results relate only to samples as received by the laboratory. Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the limitations of light microscopy including matrix interference. Gravimetric reduction and correlative analyses are recommended for all non-friable, organically bound materials. This method has a reporting limit of 1% or greater. Visual estimation contains an inherent range of uncertainty. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other gov't agency endorsement.

14 Account - Workorder (Continued) Page 3 (Continued) Client SLI Sample Sample Sample/ Identification/ PLM Analysis Results No. Layer ID Layer Name Asbestos Fibers Other Materials RM-5 Layer 1: Plaster/Skim Coat None Detected 3% CELLULOSE FIBER green/gray/white, Granular/Powdery 97% NON FIBROUS MATERIAL RM-6 Layer 1: Floor Tile None Detected 100% NON FIBROUS MATERIAL Brown, Organically Bound Layer 2: Mastic None Detected 3% CELLULOSE FIBER Yellow, Soft 97% NON FIBROUS MATERIAL RM-6 Layer 1: Floor Tile None Detected 100% NON FIBROUS MATERIAL Brown, Organically Bound Layer 2: Mastic None Detected 2% CELLULOSE FIBER Yellow, Soft 98% NON FIBROUS MATERIAL RM-6 Layer 1: Floor Tile None Detected 100% NON FIBROUS MATERIAL Brown, Organically Bound Layer 2: Mastic None Detected 3% CELLULOSE FIBER Yellow, Soft 97% NON FIBROUS MATERIAL Exterior Layer 1: Mortar None Detected 100% NON FIBROUS MATERIAL White/Gray, Granular Exterior Layer 1: Mortar None Detected 100% NON FIBROUS MATERIAL White/Gray, Granular Exterior Layer 1: Mortar None Detected 100% NON FIBROUS MATERIAL White/Gray, Granular Total Number of Pages in Report: 4 Results relate only to samples as received by the laboratory. Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the limitations of light microscopy including matrix interference. Gravimetric reduction and correlative analyses are recommended for all non-friable, organically bound materials. This method has a reporting limit of 1% or greater. Visual estimation contains an inherent range of uncertainty. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other gov't agency endorsement.

15 Account - Workorder (Continued) Page 4 (Continued) Client SLI Sample Sample Sample/ Identification/ PLM Analysis Results No. Layer ID Layer Name Asbestos Fibers Other Materials Exterior Layer 1: Concrete None Detected 100% NON FIBROUS MATERIAL Gray, Hard Exterior Layer 1: Concrete None Detected 100% NON FIBROUS MATERIAL Gray, Hard Exterior Layer 1: Concrete None Detected 100% NON FIBROUS MATERIAL Gray, Hard Analyst: Total Number of Pages in Report: 4 HALA A. OSMAN Results relate only to samples as received by the laboratory. Reviewed By: Susan L. Childress, Analyst Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the limitations of light microscopy including matrix interference. Gravimetric reduction and correlative analyses are recommended for all non-friable, organically bound materials. This method has a reporting limit of 1% or greater. Visual estimation contains an inherent range of uncertainty. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other gov't agency endorsement.

16 SCHNEIDER LABORATORIES I N C O R P O R A T E D 2512 W. Cary Street Richmond, Virginia LABS (5227) (FAX) Excellence in Service and Technology AIHA/ELLAP , NVLAP , NYELAP/NELAC 11413, CAELAP 2078, NC 593, SC LABORATORY ANALYSIS REPORT Asbestos Identification by Polarized Light Microscopy with EPA Point Count¹ ACCOUNT #: CLIENT: PbO3 ENV TESTING & SERVICES INC ADDRESS: 473 N PINE MEADOW DR DEBARY, FL PROJECT NAME: Crescent City JOB LOCATION: 315 Central Ave PROJECT NO.: Demo PO NO.: Using SLI A6 DATE COLLECTED: 8/18/2010 DATE RECEIVED: 8/27/2010 DATE ANALYZED: 8/30/2010 DATE REPORTED: 9/3/2010 SampleType: BULK Client SLI Sample Sample Sample/ Identification/ PLM Analysis Results No. Layer ID Layer Name Asbestos Fibers Other Materials Rm 10 Layer 1: Drywall/Joint Cmpd None Detected 5.50% CELLULOSE FIBER White, Powdery/Granular, Homogenous 94.50% NON FIBROUS MATERIAL Analyst: Total Number of Pages in Report: 1 HALA A. OSMAN Results relate only to samples as received by the laboratory. Reviewed By: Susan L. Childress, Analyst Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the inherent limitations of light microscopy including interference by matrix components. This method has a reporting limit of 0.25% or greater. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other government agency endorsement.

17 SCHNEIDER LABORATORIES I N C O R P O R A T E D 2512 W. Cary Street Richmond, Virginia LABS (5227) (FAX) Excellence in Service and Technology AIHA/ELLAP , NVLAP , NYELAP/NELAC 11413, CAELAP 2078, NC 593, SC LABORATORY ANALYSIS REPORT Asbestos Identification by Polarized Light Microscopy with EPA Point Count¹ ACCOUNT #: CLIENT: PbO3 ENV TESTING & SERVICES INC ADDRESS: 473 N PINE MEADOW DR DEBARY, FL PROJECT NAME: Crescent City JOB LOCATION: 315 Central Avenue PROJECT NO.: Demo PO NO.: Using SLI A6 DATE COLLECTED: 8/18/2010 DATE RECEIVED: 9/13/2010 DATE ANALYZED: 9/16/2010 DATE REPORTED: 9/16/2010 SampleType: BULK Client SLI Sample Sample No. Sample/ Layer ID Identification/ Layer Name 3LS Drywall,Joint Cmpd.Rm1 Asbestos Fibers PLM Analysis Results Other Materials Layer 1: Drywall/Joint Cmpd 0.50% CHRYSOTILE 99.50% NON FIBROUS MATERIAL White, Powdery/Granular, Homogenous 3LS Drywall,Joint Cmpd.Rm11 Layer 1: Drywall/Joint Cmpd 0.50% CHRYSOTILE 99.50% NON FIBROUS MATERIAL White, Powdery/Granular, Homogenous Analyst: Total Number of Pages in Report: 1 HALA A. OSMAN Results relate only to samples as received by the laboratory. Reviewed By: Hind Eldanaf, Asbestos Area Supervisor Visit for current certifications. Samples analyzed by the EPA Test Method are subject to the inherent limitations of light microscopy including interference by matrix components. This method has a reporting limit of 0.25% or greater. This report must not be reproduced except in full with the approval of the lab, and must not be used to claim NVLAP or other government agency endorsement.

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20 APPENDIX B DRAWINGS

21 315 Central Ave C Loading Dock D B A PbO3 ENVIRONMENTAL TESTING & SVC. CO., INC. DeBary, Florida Drawing # Not To Scale Asbestos Sampling Locations 315 Central Ave.

22 APPENDIX C PHOTOGRAPHS

23 1 S. Summit Street 301 Central Avenue 315 Central Avenue 315 Central Out Building 29 S. Summit Street 29 S. Summit St.-Garage 40 S. Prospect Street N PbO3 ENVIRONMENTAL TESTING & SVC. CO., INC. DeBary, Florida Drawing # Not To Scale Site Plan Crescent City, FL.

24 Asbestos-315 Central Ave., Crescent City Drywall, Joint Compound Plaster w/ Skim Coat 1x1 Ceiling Tile-Rough 2x2 Ceiling Tile-Snowflake 2x2 Ceiling Tile-Smooth 12x12 Floor Tile-Brown

25 Asbestos-315 Central Ave., Crescent City Mortar Concrete Slab

26 APPENDIX D SPECIFICATIONS

27 STANDARD SPECIFICATIONS For ASBESTOS-CONTAINING MATERIAL (ACM) Project: Crescent City Demolition of Multiple Sites Prepared for: Mr. Patrick Kennedy, City Manager Cresent City 3 N. Summit Street Cresent City, FL Prepared by: PbO3 Environmental Testing & Service Co., Inc. 473 North Pine Meadow Drive DeBary, Florida (386) Project No September 10, 2010 These specifications were prepared in conformance with all applicable state and federal regulations in effect on the date of this submittal and were completed under the direction of PbO3 s Licensed Asbestos Consultant, Peter Swarr, P.E. #55159 LAC # 00063, in conformance with the Florida Statutes, Sections as signed and sealed in this survey.

28 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES ASBESTOS TABLE OF CONTENTS PART 1 GENERAL 1.01 Summary 1.02 References 1.03 Submittals 1.04 Quality Assurance 1.05 Qualifications 1.06 Contractor Responsibilities 1.07 Coordination PART 2 PRODUCTS 2.01 Materials 2.02 Equipment PART 3 EXECUTION 3.01 Examination 3.02 Temporary Utilities and Services 3.03 Work Areas and Work Practices 3.04 Waste Load Out Unit 3.05 Respiratory Protection 3.06 Removal of Asbestos 3.07 Daily Housekeeping 3.08 Cleaning Procedures 3.09 Inspection 3.10 Asbestos Waste and Contaminated Materials 3.11 Asbestos Abatement Notice and Checklist 3.12 Final Acceptance PART 4 DEMOLITION PRACTICES FOR CATEGORY I NON-FRIABLE MATERIALS End- PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 2

29 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES ASBESTOS PART 1 - GENERAL 1.01 SUMMARY A. Document Includes: 1. Part 1 and Part 2 are general provisions for Asbestos Abatement. 2. Part 3 of this document addresses demolition where Asbestos Containing Material (ACM) is present; removal of ACM; ACM emergency cleanup; and, transportation, disposal, storage, containment of, and housekeeping activities involving, regulated asbestos or potentially regulated ACM products, any of which take place on the site or location at which construction activities are performed. 3. Part 4 of this document is for the demolition in place of all Category I Non-friable Materials (roofing material, vinyl flooring, mastics, etc.) identified in this project. If at any time the Category I Non-friable is deemed by manner of process or handling to become regulated material than the appropriate sections of this document shall govern. 4. These specifications, in whole or in part, form the requirements for conducting ACM removal or abatement work. Provisions not expressed herein shall be at the discretion of PbO3 Environmental the Owner Consultant and shall not be implemented unless approved in writing REFERENCES A. 29 CFR Occupation Safety and Health (OSHA) Standards 1. ANSI Z , Local Exhaust Ventilation Requirements 2. ASTM E , Standard Practice for Visual Inspection of Asbestos Abatement Projects 3. Code of Federal Regulations (CFR) a. 29 CFR 1910, Occupational Safety and Health Standards b. 29 CFR 1926, Safety and Health Regulations for Construction c. 40 CFR 61, National Emission Standards for Hazardous Air Pollutants d. 40 CFR 763, Asbestos e. 49 CFR 171, General Information, Regulations, and Definitions f. 49 CFR 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information and Training Requirements 4. Environmental Protection Agency guidance document EPA 560/ , Guidance for Controlling Asbestos Containing Materials in Buildings 5. Florida Statutes 469, Asbestos Abatement PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 3

30 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 6. Florida Administrative Code (FAC) a. FAC Chapter , Asbestos Fee b. FAC Chapter 61E1-1, Asbestos Consultants/Contractors 7. National Institute For Occupational Safety And Health (NIOSH) , NIOSH Manual of Analytical Methods, and in particular Method SUBMITTALS A. Section 01000, Part 2 - Submittals and Contractor Furnished Items. B. Incomplete, partial, illegible, or poorly reproduced photocopies of submittals shall not be reviewed but shall be returned for correction and re-submittal. Re-submittals or submittal of corrected or deficient information shall be presented as a part of another entire submittal (marked as a revision) with the corrections or additional information clearly marked as newly submitted. When personnel are added, the entire submittal need not be duplicated; however, the submittal shall include the training, medicals and fit-testing for each person in order to be considered complete. C. Submittal Accuracy - The Contractor is solely responsible for the accuracy and completeness of the data submitted, regardless of corrections made in, or approvals given to such submittals. The Contractor is cautioned to check his personnel's training and medical records. Falsification of information may be grounds for breach of contract. D. Abatement Plan (for Regulated ACM and Category II non-friable materials) and a Work Plan for all Category I non-friable demolition. The contractor shall submit a detailed, job specific plan that addresses how the contractor will execute the requirements specified here in. The plan shall be prepared under the direction of an individual certified in accordance with F.S. 469, 29 CFR 1926, and 40 CFR 763 to prepare abatement plans. The Contractor shall Tab each section of the plan as follows: a. Signature page - include a signature page certifying that the abatement plan was prepared under the direction of an asbestos professional certified to prepare such plans in accordance with federal, state and local regulations including F.S. 469, 29 CFR 1926, and 40 CFR 763 signed and dated by the abatement planner. b. Project information - include: i. Contract number, project number, project name and facility number (if not included in project name) ii. Company name, address, phone number and Florida Asbestos Contractor license number (attach copy) iii. Name of owner or principle in charge iv. Name, daytime and emergency phone number of project manager v. Name, daytime and emergency phone number of competent person if different than Item c vi. Name and phone number of Contracting Administrator vii. Name and phone number of facility manager and project inspector viii. Specify if a Notification of Asbestos Demolition is required to be submitted to the Florida Department of Environmental Protection (attach copy of DEP FORM (1) and certification of receipt if required) c. Coordination drawings - include site specific drawings for each phase of proposed work (on multi-phase projects) and worker-used areas including, but not limited to: delineation of regulated and controlled areas, location of decontamination units, waste loading/staging areas, waste haul-out routes, location of disposal containers, locations of HEPA filtered diminished air pressure devices and exhaust points, proposed air flow directions, locations of water and PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 4

31 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES electrical connections and wastewater discharge points, equipment storage, emergency routing and exits, and areas to be modified. d. Execution plan - for each phase of work, provide: i. Description of each material, NESHAP classification (friable, Category I nonfriable, Category II non-friable), and quantity to be removed. ii. OSHA abatement classification (I, II, III or IV) to be used in determining level of engineering controls and work practices. iii. Lockout / tag-out procedures for electrical and HVAC systems. Identify which portions of the facility systems will need to be shutdown during the abatement and the methods to be used to isolate these systems. Discuss requirements for utility outages in support of operations. iv. Proposed procedures are to be used to protect the surrounding residential neighborhood, the Crescent City personnel and visitors to the site including the description and location of critical barriers and containment systems to be used to control fiber release (identify surfaces and equipment to be covered and thickness of protection), the use of portable HEPA diminished air pressure or ventilation systems (include calculations used to determine air changes and the number of ventilation units required), and other engineering controls to be used to minimize fiber release. v. Sequence of asbestos abatement work, the methods to be used to remove each material and minimize fiber release, and the interface of trades involved in the performance of work directly involved or in proximity to the abatement work. vi. Disposal plan including waste containerization methods and load out procedures, site storage, and disposal site offloading methods (include disposal site name, address, owner, phone number and permit number). vii. Equipment owner's acknowledgment of intended asbestos use for all rented equipment to be used to remove, handle or dispose of asbestos containing materials. e. Hazardous Material Management Plan shall be prepared and included by the contractor to address the management and storage of hazardous materials. The plan shall include a list of all hazardous materials to be used or encountered on the project (i.e. asbestos, surfactants, solvents, coatings, encapsulants, etc,) intended usage, quantities, Material Safety Data Sheets, and a description of the procedures for material storage and spill prevention. f. A Contingency Plan shall be prepared and included by the Contractor for emergencies including fire, accident, hazardous material spills, power failure, heating or cooling, diminished air pressure system failure, respirator supplied air system failure, or any other event that may require modification of the work area isolation procedures. Include in the plan specific procedures for decontamination or work area isolation, safe exiting and the need for medical attention in the event of an emergency. g. Health & Safety Plan. h. Product Data - Material, equipment, and fixture lists shall be submitted for all major components proposed to be furnished and used under this section, to include but not be limited to: manufacturer and specifications of diminished pressure and air purifying equipment (provide manufacturers literature indicating usable air handling capacity for various static pressure readings), HEPA vacuums, air filtration equipment, water filtration equipment, personal protective equipment, and air monitoring equipment. i. Certifications i. Provide relevant work experience, training and certifications of individual preparing the abatement plan. ii. Provide relevant work experience of the competent person. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 5

32 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES iii. For each employee and the competent person, provide: 1. Training certificates certifying that training required by federal, state and local regulations as set forth in F.S. 469 and in accordance with 29 CFR 1926, and 40 CFR 763 is current and appropriate for the level of work being performed. 2. Submit documentation indicating successful fit check of respirators within the previous six months and certification of worker training in the care, use, and maintenance of respirators. 3. Certification by a licensed physician that annual medical examinations have been provided in accordance with 29 CFR to include the physician's written opinion regarding the results of the medical examination E. Work Schedules shall be submitted indicating the work days and hours to include as a minimum the number of workers per shift. Include a bar chart to identify the individual milestones through to the completion of the project (e.g., mobilization, number of days to complete work site preparation, number of days to complete ACM removal, number of days to complete final cleaning and lockdown, etc.). F. Project Log Book 1. The contractor shall maintain the following records at the work site in an accessible location for PbO3 s review. All records shall be updated daily. a. Work-site Entry Logs (Attachment 1) of all personnel entering and leaving the regulated work area shall be maintained by the on-site competent person. The Logs shall indicate all pertinent information such as individual s name, social security number, date and time of entry and egress, and the type of respiratory protection worn. b. Daily Site Inspection/Activity Logs (Attachment 2) shall be maintained by the on-site competent person indicating the date, time and results of the work area daily site inspections. The contractor shall log diminished air pressure machine strip charts daily (record date and start time for each day). The Contractor shall use printout paper that indicates elapsed time in intervals no greater than hours. The Contractor shall explain any abnormal fluctuations observed on the recordings in the daily activity logs. c. Air Monitor Reports for OSHA Personal Samples- listing the airborne fiber concentration in fibers/cc. At a minimum, the Air Monitor Reports shall include the following information for each sample: Sample identification, employee name, social security number, sample location, description of task being monitored, exposure level results in (f/cc), monitoring instrument identification number, pre-calibration, post calibration and average flow rate of each sample, sample date, start and stop times, type of protective devices worn (if any), project identification number, facility number and name, sampling and analytical methods used, contact name and company, and name of individual performing the sampling. d. Waste Drum Inventory of all generated waste drums or containers shall be maintained indicating the location and approximate quantity of material in each container. Copies of waste manifests, signed by the landfill, showing disposition of the waste shall be included in the inventory. e. Inspection Reports including initial inspection; final inspection; clearance air sampling report; re-occupancy inspection; and, punch lists. G. Close Out Documents PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 6

33 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 1. Project Log Book - submit (3) bound copies of the Project Log Book within ten days of the completion of the work. 2. As-built drawings - submit five copies of as-built drawings showing location and description of materials removed. Identify location of asbestos materials located in the work area that were not removed under this requirement QUALITY ASSURANCE A. The Contractor shall assume full responsibility and liability for compliance with all applicable Federal, State, and local regulations pertaining to the protection of workers, visitors to the site, and persons occupying areas adjacent to the site. B. The Contractor is responsible for providing medical examinations and maintaining medical records of ACM abatement personnel as required by the applicable Federal, State, and local regulations. The Contractor shall hold the Client-Crescent City and the Owner s Consultant PbO3 Environmental harmless for failure to comply with any applicable safety and health regulation on the part of himself, his employees, and/or his Subcontractors. A Physician's certification that medical examinations have been provided in compliance with 29 CFR 1926 for each employee shall be maintained on site. C. ACM abatement work shall be conducted in accordance with the Class I, II, III, or IV Methods of Compliance as required by 29 CFR 1910, especially ; 29 CFR 1926, especially , applicable statutes, regulations, and standards and, good, prudent, or typical work practices common to the ACM abatement industry. D. Compliance monitoring shall be performed by an independent monitoring agency in accordance with NIOSH , NIOSH Manual of Analytical Methods, and in particular Method A copy of all monitoring records shall be maintained on site. 1. The Contractor shall be responsible for conducting personnel air sampling. The individual performing the personnel monitoring shall meet the requirements as set forth in F.S. 469 and 40 CFR 763 and perform sample collections in accordance with an approved Air Monitoring Plan. 2. The Contractor is solely responsible for the implementation of any inspection and monitoring procedures necessary to ensure the integrity of their containment systems and the adequacy of engineering controls being used to ensure compliance with 40 CFR 61 and 29 CFR The Owner will conduct air sampling in and adjacent to the Contractor s containment to ensure compliance with the requirements of this specification and the Contractor s work plan. The Contractor shall make electrical outlets available to the Owner s representative for this purpose. 4. Airborne fiber sampling and analytical procedures shall be by Phase Contrast Microscopy (PCM) in accordance with 29 CFR 1926 or the most current version of the NIOSH , Method The Contractor shall conduct daily monitoring utilizing sample rates, volumes and frequency in accordance with 29 CFR At no time shall the minimum, number of samples or sample volumes be less than those specified below when performing Class I work: Type of Sample Volume Minimum # Samples Location Personal, during work 400L 2 Personal B.Z QUALIFICATIONS PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 7

34 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES A. Work under this section shall be preformed by a contractor licensed by the State of Florida Department of Professional Regulation (FDPR) in accordance with Florida Statute (FS) 469. A copy of required licenses and certificates shall be maintained on site. B. Work under this section shall be performed by persons knowledgeable, qualified, trained, and certified in the removal, treatment, handling, and disposal of ACM, and the subsequent cleaning of the affected environment in accordance with all applicable federal, state and local regulations including 29 CFR , 40 CFR 763 and FS 469 as specified herein. A copy of the training records for each employee shall be maintained on site. C. The independent agency performing compliance sampling shall be trained and certified in accordance with all applicable federal, state and local regulations including 29 CFR , 40 CFR 763 and FS 469 as specified herein. In addition the agency shall be participating in a Proficiency Analytical Test (PAT) program such as or equivalent to the American Industrial Hygiene Association PAT or Asbestos Analytical Registry (AAR). Accreditation certificate and Interlab QA/QC Program CONTRACTOR RESPONSIBLITIES 1. The Contractor shall assume full responsibility and liability for compliance with all applicable federal, state, and local regulations pertaining to the protection of workers, visitors to the site, and persons occupying areas adjacent to the site. The Contractor is responsible for providing medical examinations and maintaining medical records of ACM abatement personnel as required by the applicable federal, state, and local regulations. The Contractor shall hold the Client and their consultant harmless for failure to comply with any applicable safety and health regulation on the part of himself, his employees, and/or his subcontractors. 2. During ACM abatement activities the Contractor shall be responsible for security, fire safety and damage to equipment and other property losses incurred by the Contractor and his labor force. 3. The Contractor shall act as the Owner's Agent for purposes of preparing and submitting all required notifications, obtaining required permits, and paying all fees associated therein with the project. 4. Methods defined in these specifications are in accordance with the EPA and OSHA Guidelines. Alternate methods of containment or removals that will provide the same or better results may be submitted for approval; however, any deviation must be approved by PbO3 Environmental prior to implementation COORDINATION i. At least 10 working days prior to the start of abatement activities, the Contractor shall submit written notification of demolition of regulated asbestos (DEP FORM (1)) in accordance with FAC Chapter via certified mail to: Florida Department of Environmental Protection Air Program 3319 Maguire Blvd., Suite 232 PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 8

35 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES Orlando, FL A copy of the notification and proof of certification shall be provided to the Consultant as part of the Abatement Plan. ii. iii. Notification to Facility Occupants - upon approval of the Abatement Plan, the contractor shall schedule a meeting with the facility manager and any interested personnel to notify them of the proposed asbestos abatement activities, site signage and demarcation, alternate entry and egress, utility outages, project points of contact and any other pertinent information affecting building operations. The contractor shall ensure that PbO3 s Representative is present at the meeting. The contractor shall record the names of all attendees and the minutes of the meeting. Copies of these minutes shall be included as part of the Contractor's daily activity log. The Contractor shall inform other Contractor employers, on the site of the abatement work, of the nature of the Contractor's work with ACM and/or PACM, of the existence of and requirements pertaining to regulated areas, and the measures taken to ensure that employees of such other Contractor employers are not exposed to asbestos in accordance with 29 CFR PART 2 - PRODUCTS 2.01 MATERIALS A. Tarps and Drapes: Impermeable, woven material free of holes or openings, of sufficient thickness and reinforced to perform the work. B. Plastic Sheeting: Impermeable, double ply, 6-mil heavy wall construction, of sufficient thickness and reinforcement to perform the work. Plastic sheeting shall be fire resistant. C. Panels: Plywood, aluminum, corrugated plastic, metal or other rigid materials of sufficient strength to perform the work. D. Tape: Glass fiber or other type capable of sealing joints and attach to finish and unfinished surfaces under both wet and dry conditions. E. Impermeable Containers: All waste shall be placed in either doubled 6-mil polyethylene bags, a leak proof container intended to transport asbestos waste, or wrapped in double 6 mil polyethylene sheeting to retain debris or contaminated materials until disposed of at an approved landfill. F. Warning Labels and Signs: Provide and post warning signs in accordance with 29 CFR and 40 CFR 61. Provide appropriate labels and markings for hazardous waste in accordance with DOT 49 CFR & 400 and 40 CFR G. Provide an amended water solution with a detergent containing at least five (5) percent trisodium phosphate (TSP) or an equivalent solution. Ensure that workers carefully follow the specific manufacturer's instructions for the proper use of the product, especially the recommended dilution ratio. H. Provide waterproof gloves for workers to wear when applying the solution. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 9

36 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 2.02 EQUIPMENT A. Scaffolding: Self supporting as specified in Criteria for Containment Systems, and as required to accomplish the work and meet all applicable safety and OSHA regulations. B. Transportation: Utilize appropriately placarded equipment (DOT) for the loading, temporary storage, transit, and unloading of asbestos waste without exposure to persons or property. C. Respiratory Equipment: Shall be NIOSH/MSHA approved and satisfy the requirements of 29 CFR 1910 and 29 CFR Personal protection - provide workers with proper protection in accordance with all applicable Federal, State, and local standards. 2. Provide workers with protective full body clothing. A sufficient number of disposable coveralls should be available to provide each worker a clean suit upon each entry into the regulated area. 3. Diminished air pressure ventilation units equipped with HEPA filters shall meet the requirements of ANSI Z and be fitted with a monitoring device incorporating a continuous recording capability (e.g. strip-chart). PART 3 - EXECUTION 3.01 EXAMINATION A. Administrative Requirements: Verification of existing conditions before starting work. B. The Contractor shall be responsible for verifying the quantities and the removal of all materials identified in the plans and/or specifications and other contract documents. When removals are indicated, the requirement is to remove all ACM from the locations and systems noted on the plans and identified in the specifications. The requirement is also to include incidental accessories that are a part of the system. C. Prior to beginning any aspect of the abatement work, the Contractor's competent person shall ensure that the negative exposure assessment provided in the Contractor's Abatement Plan is appropriate for the existing site conditions. The Contractor shall not reduce worker protection levels from those identified in the Abatement Plan without notifying PbO3 Environmental TEMPORARY UTILITIES AND SERVICES A. The Contractor shall be responsible for determining the adequacy of the available utilities. Where utilities are not available or are not adequate at the job site, the Contractor shall provide, all necessary temporary utilities required for the abatement work. Water-proof safety lighting shall be provided by the Contractor where necessary for safe, adequate illumination. B. Any temporary utilities and connections or lines that may be required shall be installed, maintained, and removed by the Contractor at his sole expense and in a manner PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 10

37 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES satisfactory to PbO3 Environmental. All utility connections shall be performed by certified craftsmen and shall be coordinated with the Owner s operations personnel. B. All electrical equipment to be used inside the work areas should be powered from a UL approved Ground Fault Circuit Interrupter (GFCI). The Contractor shall not exceed the manufacturers limits per GFCI. The Contractor shall make all necessary connections and shall restore the site connections to their original condition or better prior to project completion. C. The Contractor shall ensure all energized or pressurized systems inside the work area have been locked out, tagged out or otherwise rendered safe. D. The Contractor shall provide temporary water from the existing building water source to control the generation of airborne dust, to allow for area, personnel, and equipment decontamination, and to supply decontamination unit needs. The Contractor shall provide a backflow preventer at the source WORK AREAS and WORK PRACTICES A. The Contractor shall use engineering controls and work practice methods in accordance with 29 CFR Daily site inspection logs shall be posted at the jobsite by the on-site competent person. B. Preparation: 1. During ACM removal, the Contractor shall confine equipment and employees to thdesignated work area(s).unless otherwise directed by PbO3 Environmental, the Contractor shall establish and maintain a 25-foot [8-meter] access control barrier zone around the designated work area(s). Interference with the functional operation of the building occupants outside these areas will not be permitted. The Contractor shall shut down HVAC systems and seal all critical barriers prior to initiating precleaning actions. Openings including but not limited to: windows, corridors, doorways, elevator openings, skylights, ducts, grilles, diffusers, and any other penetrations between the contaminated work areas and uncontaminated areas, shall be sealed with plastic sheeting with a minimum thickness of 6 mil. 2. Signs and Markings a. Signs shall be posted prior to asbestos work as required in 29 CFR These signs shall be posted near the perimeter of the asbestos work areas, along the route to the temporary waste material holding (Drum Staging) area, around the perimeter of the temporary holding area, and at all entrances to areas containing asbestos fibers. Signs shall be conspicuous and legible. b. Telephone numbers and locations of emergency services including but not limited to fire, ambulance, doctor, and hospital, shall be posted at a designated telephone located near the regulated area. The job-site superintendent s 24-7 telephone numbers shall also be posted. c. One copy of all permits shall be posted at the work site perimeter in an accessible location outside the regulated area. d. One copy of the Abatement Contractors current license shall be posted at the work site perimeter in an accessible location outside the regulated area. e. One copy of a completed Pre-Work Inspection form (Attachment 4) shall be posted at the work site perimeter in an accessible location outside the regulated area. C. Removal of Floor Systems PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 11

38 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 1. These procedures shall include the removal of floor systems, vinyl flooring, base molding, asbestos tile flooring, tile mastic and similar floor coverings. 2. If the material is currently non-friable and after review of the Contractor's work plan it is determined that the material is likely to remain non-friable, then the minimum requirement for containment shall be critical barriers and HEPA filtered exhaust units. Decontamination units and partial polyethylene sheeting for the walls may be required by the Owner s Consultant depending on the work plan and the friability of the material. 3. Arrange the pressure differential system such that air flow is from the entrance toward the work area farthest from the point of entry. 4. Inspect for and seal any floor penetrations to avoid the contaminated water leaking below the floor level. 5. Proceed as follows: a. Saturate the carpet with amended water and remove as ACM waste. Cutting the material in strips prior to removal should facilitate removal and bagging operations. b. Saturate the floor area (e.g.: mastic, backing material, and tile) with a removal solvent and allow to penetrate in accordance with manufacturer's instructions. The Contractor shall provide and use respirator filters that are compatible with any solvents that are used. c. Start removal from the starting point and work systematically away from the entrance of the work area. Mist the surface with amended water or removal encapsulant and begin scraping the material from the floor surface. The material should be kept damp at all times during removal. d. All material and debris found in the work area shall be processed as ACM waste. e. The Contractor shall remove the flooring system. D. Removal of Asbestos-Containing Transite Panels. 1. Proceed as follows: a. Develop a daily removal plan indicating the square footage of panel material that will be removed during the abatement working day. b. Establish a regulated area by posting necessary barricades and warning signs to isolate the abatement work area. c. Prior to commencing work, establish a regulated area by covering the surface with plastic sheeting a minimum of 4.5 m from the panels being removed. d. At all times, keep the panels misted with water. e. Remove the panels individually and minimize breakage. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 12

39 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES f. Gently place the panels in bags or wrap the panels in two layers of 0.15 mm plastic sheeting. g. Collect and dispose of any debris that falls on the plastic sheeting as asbestoscontaining material. h. Wet-clean all surfaces of the structure which secured the panels to remove residual ACM. i. Encapsulate the structure surfaces wet-cleaned in (h) above. j. Wet wipe the plastic sheeting prior to disestablishing the regulated area and dispose of the sheeting as contaminated waste. A. Removal of Asbestos-Containing Roofing Material 1. This section covers the removal of asbestos containing bituminous resinous roofing material and associated insulation which has been identified as asbestos-containing material. 2. Hoists or enclosed chutes used to remove the ACM from elevated areas shall be erected at locations away from any entrances to the building and shall be identified as a controlled area with barrier tape and signs. 3. The general method strategy is to cut sections of the built-up roofing system and bag the material for disposal. 4 To ensure control of fibers, the material shall be maintained in a wetted state the wetting material shall be cutback petroleum-based primers. No water shall be used on the roof if the building is occupied and not scheduled for demolition. 5. The removals shall be systematic and shall start on the area farthest from the access/load-out area. After the roofing resins and felts are removed, the underlying insulation shall be cleaned using HEPA vacuums and wet wiping techniques, then protected from the elements until new resins/felts are installed. B. Membrane Removal 1. Prior to cutting of roofing composite material (built-up roof), all loose gravel and accumulated debris, which is free from visible ACM, shall be washed from the cutting surface. This work will not be classified as being ACM related. 2. ACM related work begins with the cutting of the membrane containing asbestos into manageable segments. Engineering controls shall be used to prevent the emitting of visible dust from the cutting operation. a. Physical barriers, such as a hood over a saw blade, shall be used to control dust. b. Use of hand tools, in lieu of power saws is preferred. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 13

40 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES c. Wetting of the roofing material shall occur immediately prior to the cutting operation. d. The Contractor shall provide HEPA vacuuming during a cutting operation providing suction of dust from within the blade hood. e. The Contractor shall use a sealant to capture dust and fix raw edges on all materials which will not be removed. f. The depth of the cutting blade shall be adjusted to prevent any contact and subsequent damage to the underlying insulation or roof deck. If required to be removed, the insulation beneath the roofing material may be removed as non- ACM if it is cleaned and decontaminated. 3. A powered saw, one normally used in the roofing industry to cut roofing membranes, may be made acceptable by use of the above control methods. Any such saw used within this procedure shall be of an enhanced design, one modified for asbestos related work. a. The blade hood (or shroud) shall provide for the complete enclosure of the cutting operation with such materials as needed to withstand its environmental conditions. The hood shall accommodate the connection for and use of a HEPA vacuum system or airless sprayer and extend as close to the deck as possible for operating purposes. b. Cutting operations shall stop and a flexible skirt shall be attached to the cutting blade hood to further control emissions from around the cutting surface, if visible dust is not controlled by the above methods. This flexible material may require replacement frequently, due to the very rough surface against which it may be rubbed. c. If at any time visible emissions are observed, the work shall stop immediately and the Contractor shall make adjustments in the procedures to eliminate further emissions prior to commencing work WASTE LOAD-OUT UNIT A. This procedure addressed removing containerized debris from building roofs and other similar locations outside of a building after the material has already been removed from the work area as defined in other sections. The following methods are defined, however the Contractor may submit an alternate method for approval by the Owner s Consultant which provides the same or better protection. B. Free Fall Chute 1. An air tight chute shall be constructed extending from the elevated location to the ground. An enclosure shall be constructed at the top and bottom of the chute. The lower enclosure shall be constructed to maintain the work area isolation similar to the waste container pass-out identified in this document. This containment shall consist of a waste container pass-out with airlock, a container staging area and another airlock with access to outside the work area. A HEPA filtered exhaust system shall be installed in the lower enclosure so as to provide a pressure differential of inches PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 14

41 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES of water. The exhaust system shall be operated at all times during the transfer of the containerized debris. 2. All personnel shall wear protective clothing and respirators. As the bagged debris is dropped through the chutes, it is collected and inspected in the lower enclosure. If any bags are broken, debris transfer shall be stopped and the debris shall immediately be cleaned up and put in a new bags. The exterior of each unbroken bag shall be cleaned prior to being handed out. If bags continue to break using the chute method, the Contractor shall modify the chute and or the transfer method so additional bags are transferred intact. When the transfer is complete, the enclosures shall be cleaned and visually inspected. When they pass visual inspection, they shall be dismantled and disposed of as ACM waste. B. Controlled Lift 1. A pulley system and lanyard shall be constructed to permit the controlled decent of the containerized debris without scraping or bumping the building or other structures. The containers shall be strapped in a cargo net for the transfer. The workers shall be dressed in protective clothing and shall wear respirators. The containers shall be carefully lowered to the ground. If any containers are broken using this method, the transfer shall stop immediately and the area cleaned up. Cleanup shall proceed as follows: a. Mist the area with amended water or removal encapsulant prior to cleanup and mist with same during removal. b. Pick up, by hand, larger pieces of material and place in bags for disposal. c. For smaller pieces use a shovel, with material well saturated, and a HEPA vacuum system. d. Upon completion or removal of all visible materials dispose of all material and debris as ACM waste. C. All asbestos-containing waste material shall be sealed in leak-tight disposal containers. D. The Contractor shall maintain proper labeling protocols and shall keep a running and final inventory of all filled disposal containers RESPIRATORY PROTECTION A. All personnel engaged in the asbestos removal work in the Work Area shall at all times wear respirators in accordance with 29 CFR The Contractor shall instruct and train each worker involved in asbestos abatement in proper respirator use, and shall require that each worker in the work area always wear a respirator from the start of any operation which may cause airborne asbestos fibers until the Work Area is released for re-occupancy. All respirators shall be fitted by approved qualitative or quantitative test. Use respiratory protection appropriate for the fiber level encountered in the Work Area and as specified herein, or as required for other situations encountered. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 15

42 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES B. Air Quality for Supplied Air Respiratory Systems - the Contractor shall provide air used for breathing in Type "C" supplied air respiratory systems that meets or exceeds CGA G- 7.1, standards for Grade D air COMPETENT PERSON A. The Contractor shall use engineering controls and work practices for all operations in accordance with 29 CFR 1926 Methods of Compliance for Class I, II, III, or IV asbestos work. B. All work shall be supervised by an on-site Competent Person at all times that work is in progress DAILY HOUSEKEEPING A. The Contractor shall maintain a clean work area in accordance with 29 CFR The Contractor shall perform the following housekeeping functions at the end of each shift or prior to leaving the work site unattended. B. Prepare contaminated waste for disposal by packaging the waste and removing it from the work area. Ensure no visible debris is left inside the work area. 1. HEPA vacuum the work area. 2. Visually inspect polyethylene in the work area and other high traffic areas. 3. Inspect the HEPA ventilation units and filters CLEANING PROCEDURES A. The Contractor shall clean the work area at the end of each day's abatement activities. All visible debris shall be properly containerized prior to leaving the work area. The work area shall be secured after termination of the workday to prevent entry. Disposable supplies, such as mop heads, sponges, and rags shall be replaced regularly and properly disposed of. All equipment shall be cleaned by HEPA vacuuming and wet wiping. B. Work areas in which abatement operations have been completed shall be cleaned, starting at the ceiling and working down to the floors, by HEPA vacuuming and wet wiping. Upon satisfactory final clearance air sampling, and removal of polyethylene sheeting has been completed, a final cleaning (wet wipe) of all surfaces within the work area shall performed by the Contractor prior to removal of work site access controls and re-occupancy inspection by PbO3 Environmental INSPECTION A. The Contractor shall not commence removal of asbestos materials prior to satisfactory completion of the pre-work inspection. The Contractor shall post a copy of the completed pre-work inspection form (Attachment 4) at the jobsite. B. Initial Inspection PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 16

43 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 1. The Contractor and the client (including client s representative PbO3) shall conduct a walk-through of the work area prior to beginning the abatement work to review existing conditions and ensure safe and practical conditions for the work to be implemented. Any damage to structures, surfaces, and equipment, which could be misconstrued as damage resulting from work shall be documented by the Contractor and submitted to PbO3 Environmental at least one day prior to start of work. 2. Background samples shall be taken for work areas in accordance with 29 CFR 1926 prior to beginning the abatement work. C. Daily Inspection 1. The Contractor shall maintain an access log of all personnel who enter the regulated work area. Through continuous surveillance and inspections of the work site the Contractor shall ensure the integrity of containment, proper function of the diminished air pressure system, and posting of signs and labels. The Contractor shall also ensure, through frequent inspections during each work shift, that diminished air pressure is maintained, appropriate work practices are followed, appropriate protective clothing and equipment are used, and worker decontamination procedures are being followed. 2. Details of the inspections are to be included in the Contractor's daily inspection log and posted in an accessible location outside the regulated area. 3. The Contractor shall provide updated copies of the Air Monitor Report Entry Logs, Daily Site Inspection Logs, and Waste Inventory to PbO3 Environmental at the end of each week of the abatement work. 4. The client reserves the right to conduct periodic inspections and air monitoring in the work areas. If the work area is unsafe as determined by PbO3 Environmental, the client will require the Contractor to stop work until the unsafe conditions are corrected. D. Final Inspection 1. The thoroughness of asbestos removal shall be evaluated by visually inspecting the affected surfaces for residual asbestos material and accumulated dust, and by air sampling. There shall be no evidence of residual asbestos or asbestos debris on any adjacent surfaces upon completion of the work. 2. Upon completion of the work, a thorough visual inspection of the work area will be conducted by PbO3 and the Contractor to make certain there are no signs of residual asbestos material and accumulated dust. The final visual inspection shall be in accordance with ASTM E Final inspections shall be documented on a Clearance Inspection form (Attachment 5) which will be provided by the Consultant. The Contractor shall schedule final inspection with PbO3 Environmental 48 hours in advance ASBESTOS WASTE AND CONTAMINATED MATERIALS A. Removal of Asbestos Waste Materials 1. For purposes of this paragraph, asbestos waste materials shall be defined as those materials, which contain or have been contaminated by asbestos and are not planned to be encapsulated and remain at the job site. They are primarily PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 17

44 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES removed asbestos and ACM, disposable clothing and safety equipment, masking sheets, contaminated amended water, vacuum cleaner contents and filters. 2. Asbestos waste material shall be contained in sealed leak-tight containers. At a minimum, all waste shall be placed in two 6-mil polyethylene disposal bags, or wrapped in two layers of 6-mil polyethylene sheeting. The asbestos waste material shall be packed while still wet. Excess air shall be removed from bags by means of a HEPA vacuum to eliminate "ballooning" and reduce the risk of rupturing. The external surface of the waste containers shall be cleaned by HEPA vacuuming and wet wiping before moving from the work area. By the end of each workday, all waste shall be placed in a closed, lockable truck or dumpster protected with two layers of polyethylene sheeting. 3. The Contractor shall handle waste bags in such a manner as to avoid rupturing the containers. If ruptured bags are found in the storage container, the Contractor shall stop work, repackage the material, and decontaminate the affected area of the container. 4. All disposal containers, dumpsters, and trucks, including the inside bags must be labeled and marked in accordance with 40 CFR 61, 29 CFR 1910 of OSHA's Hazard Communications Standard, and 49 CFR 171 and 49 CFR 172, Hazardous Substances. 5. The labels must be conspicuous and legible and shall be affixed to plastic bags and drums indicating the name of the waste generator and the location (facility name & number) where the waste was generated. 6. A waste shipment record (WSR) shall also be provided to the waste site owner in accordance with the instructions in "Figure 4" of 40 CFR 61. B. Work Area Disposal - After final inspection has been completed and the work area is released for occupancy, the diminished air pressure system units shall be shut off and removed. All entrances and exits shall be unsealed and the plastic sheeting, tape, and any other trash and debris, except for critical barriers, shall be disposed of in sealable plastic bags, or disposed of in drums and moved to the staging area. After final wet wipe of the work area and satisfactory clearance air sampling, critical barriers and the decontamination unit shall be dismantled. C. Decontamination Area and Support Area Disposal - The decontamination area shall be dismantled after the work area is released by PbO3 Environmental for re-occupancy. Vacuum all surfaces of the decontamination unit before it is disassembled. D. Waste Transportation and Disposal 1. The Contractor shall transport and dispose of asbestos waste in full compliance with 40 CFR 61, SUBPART A, 49 CFR 171 and 49 CFR 172. All ACM waste shall be disposed at an EPA approved landfill. 2. Contractor shall contact the landfill of shipments at least 24 hours prior to delivery. (weather permitting). 3. Container tipping is not permitted at landfills. Trained personnel wearing appropriate worker protection must unload all waste containers at the landfill. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 18

45 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES 3.11 ASBESTOS ABATEMENT NOTICE AND CHECKLIST A. A Pre-Work Inspection form and a Clearance Inspection form will be provided by the PbO3 Environmental. The completed forms shall be used to establish approval of the containment, work practices and final acceptance/re-occupancy of the work areas FINAL ACCEPTANCE A. The work shall not be considered complete until the ACM identified herein has been abated, the areas cleaned, satisfactory final inspections are completed, all ACM waste has been properly disposed of, and all project close out documents have been received and approved PbO3 Environmental. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 19

46 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES PART 4 DEMOLITION PRACTICES for CATEGORY I NON-FRIABLE MATERIALS SECTION 1 DEMOLITION PRACTICES for CATEGORY I NON-FRIABLE MATERIALS INTRODUCTION EPA revised the asbestos NESHAP regulations on November 20, 1990 (see 40 CFR Part 61 Subpart M). Although the NESHAP has not been revised to alter its applicability to friable and non-friable asbestoscontaining materials (ACM), non-friable asbestos materials are now classified as either Category I or Category II material. Category I material is defined as asbestos-containing resilient floor covering, asphalt roofing products, packings and gaskets. Asbestos-containing mastic is also considered a Category I material (EPA determination - April 9, 1991). Category II material is defined as all remaining types of non-friable ACM not included in Category I that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable asbestos-cement products such as transite are an example of Category II material. The asbestos NESHAP specifies that Category I materials which are not in poor condition and not friable prior to demolition do not have to be removed, except where demolition will be by intentional burning. However, regulated asbestos-containing materials (RACM) and Category II materials that have a high probability of being crumbled, pulverized, or reduced to powderas part of demolition must be removed before demolition begins. PURPOSE This document is intended to apply primarily to demolition and cleanup activities for buildings that contain Category I non-friable ACM. Although references will be made to Category II non-friable ACM, for the purposes of this document, it and all other RACM will be assumed to have been removed prior to the start of actual demolition activities. Work practices associated solely with building renovations will not be addressed. Activities associated with site cleanup such as segregation, reduction, and on and offsite disposal of ACM are discussed because they may take place during or after the major demolition activities at a site and consequently may influence a demolition contractor's choice of methods. DEFINITIONS The following definitions taken from the November 20, 1990 revision of the asbestos NESHAP regulation are provided for ease of reference. Adequately wet means sufficiently mix or penetrate with liquid to prevent the release of particulates. If visible emissions are observed coming from asbestos-containing material, then that material has not been adequately wetted. However, the absence of visible emissions is not sufficient evidence of being adequately wet. Asbestos-containing waste materials means mill tailings or any waste that contains commercial asbestos and is generated by a source subject to the provisions of this subpart. This term includes filters from control devices, friable asbestos waste material, and bags or other similar packaging contaminated with commercial asbestos. As applied to demolition and renovations operations, this term also includes regulated asbestos-containing material waste and materials contaminated with asbestos including disposable equipment and clothing. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 20

47 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES Category I non-friable asbestos-containing material (ACM) means asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products containing more than one percent asbestos as determined using the method specified in appendix A, subpart F, 40 CFR part 763, section 1, Polarized Light Microscopy. Category II non-friable ACM means any material, excluding Category I non-friable ACM, containing more than one percent asbestos as determined 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. Cutting means to penetrate with a sharp-edged instrument and includes sawing, but does not include shearing, slicing, or punching. Demolition means the wrecking or taking out of any load-supporting structural member of a facility together with any related handling operations or the intentional burning of any facility. Facility means any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site. For purposes of this definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential structure, installation, or building. Any structure, installation or building that was previously subject to this subpart is not excluded, regardless of its current use or function. Facility component means any part of a facility including equipment. Friable asbestos material means any material containing more than one percent asbestos as determined using the method specified in appendix A, subpart F, 40 CFR part 763 section 1, 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. Grinding means to reduce to powder or small fragments and includes mechanical chipping or drilling. In poor condition means the binding of the material is losing its integrity as indicated by peeling, cracking, or crumbling of the material. Inactive waste disposal site means any disposal site or portion of it where additional asbestos-containing waste material has not been deposited within the past year. Installation means 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). Non-friable asbestos-containing material means any material containing more than one percent asbestos as determined using the method 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. Owner or operator of a demolition or renovation activity means any person who owns, leases, operates, controls, or supervises the facility being demolished or renovated or any person who owns, leases, operates, controls, or supervises the demolition or renovation operation, or both. Planned renovation operations means a renovation operation, or a number of such operations, in which some RACM will be removed or stripped within a given period of time and that can be predicted. Individual nonscheduled operations are included if a number of such operations can be predicted to occur during a given period of time based on operating experience. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 21

48 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b) Category I nonfriable 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 regulated by this subpart. Remove means to take out RACM or facility components that contain or are covered with RACM from any facility. Renovation means altering a facility or one or more facility components in any way, including the stripping or removal of RACM from a facility component. Operations in which load-supporting structural members are wrecked or taken out are demolitions. Resilient floor covering means asbestos-containing floor tile, including asphalt and vinyl floor tile, and sheet vinyl floor covering containing more than one percent asbestos as determined using polarized light microscopy according to the method specified in appendix A, subpart F, 40 CFR part 763, Section 1, Polarized Light Microscopy. Strip means to take off RACM from any part of a facility or facility components. Visible emissions means any emissions, which are visually detectable without the aid of instruments, coming from RACM or asbestos-containing waste material, or from any asbestos milling, manufacturing, or fabricating operation. This does not include condensed, uncombined water vapor. Waste generator means any owner or operator of a source covered by this subpart whose act or process produces asbestos-containing waste material. Waste shipment record means the shipping document, required to be originated and signed by the waste generator, used to track and substantiate the disposition of asbestos-containing waste material. SECTION 2 DEMOLITION PRACTICES BY TYPE OF ACM INTRODUCTION Since significant amounts of airborne asbestos fibers are not believed to be produced from such materials during normal demolition activities, the asbestos NESHAP, in most cases, does not require their removal prior to demolition. Category I materials are considered RACM only when they "will be or have been subjected to sanding, grinding, cutting, or abrading", they are in "poor condition" and "friable", or the structure in which they are located will be demolished by burning. (Definitions for these terms and additional information concerning Category I non-friable ACM can be found in the preamble to the November 1990 revised asbestos NESHAP (SUPPLEMENTARY INFORMATION, Section IV - Significant Comments..., Demolition and Renovation, Non-friable ACM and Broken ACM). The following information details specific pre-demolition and demolition practices and their impact on Category I non-friable ACM. The information has been compiled from telephone surveys of demolition contractors, the viewing of activities at a number of demolition sites, and formal and informal EPA applicability determinations. Many of the various demolition techniques described do not, by themselves, cause Category I non-friable ACM to become RACM. However, in many cases, post-demolition waste consolidation, cleanup, and recycling efforts can cause both Category I non-friable ACM to become RACM. If that is likely to happen, PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 22

49 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES such materials must be considered RACM and be treated as such. Post-demolition activities which can affect Category I and II materials will be detailed later in this document. Demolition with Floor Tiles in Place Since ordinary demolition activities do not include the sanding, grinding, cutting and abrading of floor tiles, floor tiles and associated mastic that are not in poor condition and not friable are not considered RACM and are allowed to remain in place during demolition. ASPHALT ROOFING PRODUCTS Demolition with Roofing Materials in Place Since demolition activities do not include sanding, grinding, cutting, or abrading, Category I asbestoscontaining roofing materials not in poor condition and not friable are not considered. SECTION 3 DEMOLITION PRACTICES BY METHOD Methods of destruction employed at demolition sites include the use of heavy machines, explosions/implosions, and hand methods. Category I non-friable ACM (packings, gaskets, resilient floor coverings, asphaltic roofing materials, mastic) that is not in poor condition and not friable prior to the demolition operation may be subjected to most of these techniques without becoming RACM. The following describes various demolition techniques and their effects on non-friable materials. All Category I non-friable ACM referenced is presumed not to be in poor condition and not friable prior to the demolition operation. HEAVY MACHINERY RAZING OPERATIONS For the purposes of this document heavy machinery (or equipment) includes large motorized vehicles such as bulldozers with rakes, top loaders, backhoes, skid loaders/bobcats, hydraulic excavators, and other similar machinery used for transporting, moving, or dislodging of materials at a demolition site. Cranes equipped with wrecking balls, clamshells, or buckets are also considered heavy machinery. Heavy machinery is used at demolition sites for both razing operations and post-demolition activities. "Razing", the process which reduces a building's structural skeleton to rubble, typically occurs after the building's interior has been gutted by hand. Bulldozers and Similar Machinery Included in this grouping of heavy machinery are all types of bulldozers, backhoes, top loaders and skid loaders/bobcats commonly used in conjunction with hand methods to raze buildings. Bulldozers move on tracks whereas backhoes, top loaders, and skid loaders operate on rubber tires. Only if a great deal of working space exists at a site, and a precisely-controlled demolition is not necessary, can bulldozers such as 977 loaders and D-9s be used to demolish a building. These bulldozers are typically equipped with giant rakes designed to ram building walls and move debris. 977's or D-9s may be used to undermine a building, but hydraulic excavators (discussed later in this section) are usually used for this purpose. Backhoes and top loaders are mainly used for moving debris and tearing off sections of walls and other building components. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 23

50 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES Skid loaders, machines commonly used to load skids or pallets onto trucks, may be specially equipped with a type of ram for use during demolitions and are usually of the "bobcat" type. Hydraulic Excavators Hydraulic excavators, such as EL-300s, 225s or 215s, resemble a combination bulldozer/backhoe and operate on tracks. They are easier to use and provide greater control during demolition than the bulldozers described above. However, since they too raze buildings by ramming and tearing, like bulldozers, their use in congested areas is limited. Nearby buildings must be protected from the falling debris; plywood may be applied over the windows and rubber tires may be used to cushion and prevent damage to walls of adjacent structures. On rare occasions, hydraulic excavators may be used to topple one-or two-story buildings by means of an undermining process. The strategy is to undermine the building while controlling the manner and direction in which it falls. The demolition project manager (who in many jurisdictions must be licensed by the city or state) must determine where undermining is necessary so that a building falls in the desired manner and direction. The walls are typically undermined at a building's base, but this is not always the case as building designs may dictate otherwise. Safety and cleanup considerations are also taken into account in determining the methods to be used. Since the toppling of a building constitutes a safety hazard and generates enormous quantities of dust, many cities and towns will not approve of this method of demolition. Where the practice is allowed, the contractor may be required to keep the structure wet during demolition. Hydrant permits may be required and, because of the wetting restrictions, such demolitions may be impossible to accomplish during the winter. Hydraulic excavators are also used to conduct cleanup activities such as excavation, fill burial, material reduction, and material load-out. The use of hydraulic excavators during the razing process causes Category II non-friable ACM, but not Category I non-friable ACM to become RACM. Cranes (Wrecking Ball, Clamshell, Bucket) Although often employed in the past, particularly during demolitions of high-rise structures, cranes are now rarely used. They are expensive to operate and usually not necessary, since renovation has displaced demolition as the method of choice in dealing with many out-of-date structures. Cranes are currently used only in situations where other equipment cannot be employed. Cranes may be equipped with wrecking balls, clamshells or buckets, which are used in a variety of ways. All three may be dropped or swung against the structure to demolish it. When employed in this manner, clamshells provide the greatest force of the three and result in the fastest, most efficient demolition projects. Buckets and clamshells allow a greater degree of control than wrecking balls. Buckets may be raised to the level where internal demolition of the building is taking place and be used merely to transport and segregate hand-loaded demolition materials collected from within. Clamshells can take big bites out of the structure and facilitate the segregation of demolition debris. When demolition is accomplished by crane, the process can begin at the roof and progress continually downward, or alternate up and down. Materials are segregated to the greatest degree possible as the PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 24

51 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES demolition progresses so that the need for post-demolition handling is minimized. In the case of high-rise structures, the interiors are usually gutted by hand prior to razing. Effect on Category I Materials The use of cranes during the razing process does not cause Category I non-friable ACM to become RACM; therefore, Category I materials which are not in poor condition and not friable may remain in the building during such demolition. EPA does not consider Category I material to be RACM as a result of building implosions. If, however, Category I materials are to be subjected to sanding, grinding, cutting, or abrading after demolition, they must be treated as RACM and be removed from the building before demolition. Where demolition debris will be recycled, any asbestos remaining on the debris must be removed prior to any recycling that will sand, grind, cut, or abrade the asbestos or otherwise cause it to become RACM. Roof Removal and Disposition On occasion one may find that the roof of a building being demolished is removed before the building is razed. Such removal may be required when buildings are very close to one another, or when the roofing contains asbestos-containing materials. There are two major types of roofing: "built-up roofing" and "sheet goods". Built-up roofing contains multiple layers of felt and asphalt. Sheet goods typically consist of a single layer of material. Roofs are often taken out by hand, typically by using pry bars, sledge hammers, axes, adzes, bolt cutters, ice chippers, shovels and roof-cutting saws. If the roof contains asbestos materials (felt, cork, etc.), an asbestos removal contractor may be employed to remove it. Some abatement contractors wet the roof with plain or amended water and then use shrouded power saws whose exhaust is HEPA-filtered to cut the roofing into manageable (often 2' x 3') pieces. After the pieces are lifted, the edges may be encapsulated. Other abatement contractors may build a full containment and establish a reduced pressure environment prior to removing the roofing materials. Depending upon the contractors involved and the condition of the asbestos-containing roof debris, the debris may or may not be segregated from other demolition debris. Abatement contractors may store roof debris in lined dumpsters onsite and dispose of it at an asbestos landfill; if the asbestos-containing roofing material is not in poor condition and is not friable however, it may be disposed of in a landfill which accepts ordinary demolition waste. Asbestos-containing roofing material may not be ground up for recycling into other products. Work Progression Demolition crews typically work downward, floor by floor. Materials such as doors, windows, electrical and other fixtures which can be salvaged are removed first. Interior partitions are then ripped, cut, or knocked out using various hand-held tools including sledge hammers, axes, adzes and pry bars. Brick is generally segregated immediately after being knocked out of walls so it can be examined at the site by potential buyers. Ceilings are also ripped out using pry bars, axes and sledge hammers. Steel and other metal materials are typically placed in separate debris piles from other materials. Work proceeds in a similar floor/wall, floor/wall pattern until the first floor is once again reached. Sawing/Cutting Operations PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 25

52 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES In order to raze a building by hand, load-bearing members must be cut. Based upon the composition, thickness, and condition of the structural member being cut, saws selected range from hand saws to Sawz-alls and gas-driven carbide blade hand saws. Large bolt cutters are also used to cut steel members. Category I materials subjected to sawing or cutting are subject to the provisions of the asbestos NESHAP; however, typical demolition sawing/cutting operations rarely involve such materials. Grinding Operations Grinding operations are not common occurrences at most demolition sites. On occasion, however, asbestos-containing mastic and remaining pieces of floor tile may be ground off concrete destined for recycling. Category I material so treated is RACM and is subject to the provisions of the asbestos NESHAP. Pulverizing Operations On occasion, asbestos-containing floor tiles are removed from their substrate by hand, using either handheld ice choppers or electrically- or gas-powered mechanical chippers. If use of such methods pulverizes, crumbles or reduces the floor tiles to powder, the tiles must be considered RACM and must be handled in accordance with the requirements of the asbestos NESHAP. ONSITE WASTE HANDLING PROCEDURES INTRODUCTION At the present time it is not demolition operations and ordinary cleanup activities but the post-demolition activities involving waste consolidation and recycling of Category I and II materials which are of greater concern. If such activities subject either Category I ACM to sanding, grinding, cutting or abrading, the materials become RACM and are then subject to the provisions of the asbestos NESHAP. In general, since cleanup activities such as loading waste debris onto trucks for disposal do not subject non-friable materials to sanding, grinding, cutting or abrading, such materials are not considered asbestos-containing waste materials and are not regulated by the asbestos NESHAP. However, waste consolidation efforts which involve the use of jack hammers or other mechanical devices such as grinders to break up asbestos-containing concrete or other materials covered or coated with Category I non-friable ACM, are subject to the regulation. In addition, operations such as waste recycling which sand, grind, cut, or abrade Category I or II non-friable ACM are subject to the asbestos NESHAP. When these types of activities are performed, Category I and II non-friable ACM become RACM. The following details the post-demolition activities of waste consolidation (segregation and reduction), waste load-out and onsite waste disposal and their effects on non-friable ACM. WASTE CONSOLIDATION Waste consolidation operations involve segregation and reduction activities that have as their ultimate goal the resale, recycling, and disposal of demolition debris. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 26

53 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES Material Transport Since heavy equipment is often used to move and segregate demolition debris, questions have been raised concerning the effect of such transport particularly on Category I non-friable ACM. If Category I non-friable ACM is transported across a demolition site in the bucket of a top loader, backhoe, hydraulic excavator or other similar vehicle, it is not considered RACM since it is not subjected to sanding, grinding, cutting or abrading during this activity. Use of bulldozers, on the other hand, is expected to have a greater impact on Category I materials. However, EPA has stated that "...if the bulldozer is moving the debris or picking it up to be put in a vehicle and inadvertently runs over Category I material, then it is not subject to the NESHAP standard" (see Appendix I). Consequently, the moving of debris by bulldozers, whether by carrying it in a bucket or pushing it along the ground does not in itself cause Category I non-friable ACM to become RACM. Vehicular Traffic Impact Rubber-tired Vehicles If non-friable ACM is intentionally run over by rubber-tired vehicles as a means of segregation, it does not automatically become RACM but must be examined for damage. If it has become extensively damaged, i.e., it was sanded, ground, cut or abraded during segregation, it becomes RACM and is subject to the NESHAP regulation. Tracked Vehicles Although tractor treads present greater risks of causing extensive damage to non-friable ACM, limiting their use at demolition sites is not considered practical. Intentionally running over non-friable ACM with tractor treads as a means of segregation is considered grinding; material thus treated becomes RACM. Intentional segregation in this manner is addressed in the preamble to the revised asbestos NESHAP (SUPPLEMENTARY INFORMATION, Section IV, Significant Comments and Changes to the Proposed Revisions, Demolition and Renovation, Non-friable ACM): "Examples of practices...included the breaking of non-friable insulation from steel beams by repeatedly running over the beams with a crawler tractor...these and other similar practices involving non-friable asbestos material were considered to render non-friable ACM into dust capable of becoming airborne." Reduction of Demolition Debris Reduction activities are of the greatest concern to EPA, since they are most likely to cause both Category I and Category II non-friable ACM to become RACM. Category I Reduction The use of bulldozers to reduce the volume of Category I materials causes them to become RACM as discussed elsewhere in this document and in the following EPA correspondence: "If, after a demolition, material left in the facility... is intentionally ground up (such as repeatedly running over the debris with a bulldozer to compact the material), then (a)(3) applies. The material must be adequately wetted and kept adequately wet during collection and transport to a site or facility operated in accordance with or Reduction by the use of sledgehammers does not normally cause Category I non-friable ACM to become RACM. The use of pneumatic hammers, however, whether hand-operated or attached to heavy PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 27

54 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES machinery, does cause these materials to become RACM. The use of cranes with clamshells or other heavy machinery with rakes or buckets to partially reduce Category I non-friable ACM is permissible if the material is left recognizable in its original form. Extensively damaged Category I ACM (that which has been sanded, ground, cut, or abraded) becomes RACM. Consolidating waste materials containing Category I non-friable ACM in the hole (basement) of a building and subsequently grinding or crushing it via bulldozer subjects the operation to the asbestos NESHAP. For wood/tile debris, demolition crews sometimes use tree chippers to grind the material up. Any Category I non-friable ACM subjected to this treatment becomes RACM. Concrete At certain demolition sites demolition contractors may rent and operate large concrete-pulverizing machines called PC-400s. Under no circumstances should asbestos-containing concrete, or concrete to which asbestos-containing resilient flooring is attached, be subjected to such treatment unless the concrete has been abated, sampled and verified by the owners consultant as asbestos free. Onsite Waste Disposal As mentioned in other sections of this document, using heavy machinery to crush demolition debris containing Category I non-friable ACM in place prior to or during burial, can cause the ACM to become RACM subject to the provisions of sections (waste disposal) and (inactive waste disposal sites) or (active waste disposal sites). If Category I materials are not rendered friable, they are not subject to the asbestos NESHAP. Waste Load Out As mentioned previously, waste load out activities generally do not cause Category I non-friable ACM to become RACM. Top loaders are typically used to deposit demolition debris containing Category I nonfriable ACM into trucks for hauling to landfills that accept construction debris. Recent EPA correspondence discusses the hauling and ultimate disposal of both Category I and Category II ACM as follows: It is required under (a)(3) that asbestos-containing waste material be kept adequately wet. Asbestos-containing waste material as applied to demolitions and renovations includes RACM waste and materials contaminated with asbestos including disposable equipment and clothing. Category I nonfriable ACM that has been contaminated by RACM, and cannot be decontaminated (e.g., building debris in a pile contaminated with RACM) must be treated as asbestos-containing waste material. Category I or Category II ACM that does not meet the definition of RACM after a demolition or renovation, and is not contaminated with RACM, is not asbestos-containing waste material and is not subject to the wetting requirement of (a)(3). Category I non-friable ACM that is not subject to (a)(3) would still have to be disposed of in a landfill that accepts building debris, in a landfill that operates in accordance with , or at a facility that operates in accordance with This waste material would not be allowed to go to any facility that would sand, grind, cut or abrade the non-racm waste or otherwise turn it into RACM waste (such as a cement recycling facility). In addition, if Category I or II non-friable ACM is sanded, ground, cut or abraded during disposal at a landfill, before it is buried, it is subject to the NESHAP. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 28

55 Asbestos Specification CRESCENT CITY DEMOLITION OF MULTIPLE SITES SECTION 4 OFFSITE WASTE HANDLING PROCEDURES Landfills Category I ACM that has become RACM must be disposed of in a landfill that operates in accordance with and , or in an EPA-approved conversion facility described in of the asbestos NESHAP. Category I non-friable ACM which has not become RACM during demolition may be disposed of in a landfill that normally accepts this type of construction debris. However, if Category I non-friable ACM is sanded, ground, cut or abraded before it is buried at the landfill, it is subject to the asbestos NESHAP. Recycling Centers At the present time, EPA does not allow either Category I or II non-friable demolition debris to go to any facility (e.g., a cement recycling facility) that will sand, grind, cut or abrade it or otherwise turn it into RACM waste. Recycling facilities which cause non-racm waste to become RACM waste are subject to the provisions of the asbestos NESHAP. PbO3 Environmental Testing and Service Co., Inc. Asbestos License # ZA Page 29

56 APPENDIX E CERTIFICATIONS

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