Limited Renovation Asbestos Survey · ACM, PACM or asbestos materials at the subject site that are...

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Limited Renovation Asbestos Survey ABC Electric Company Building 1 1 of 33 5.30.2012 XYZ Consultants Inc. Project Number 12-012 Limited Renovation Asbestos Survey Conducted At: ABC Electric Company Building 1 555 Park Avenue Rochester, New York Prepared For: Acme General Contractors 1 Elm Street Pittsford, New York 14534 Prepared & Performed By: XYZ Consultants Inc 123 Main Street Rochester, New York 14610

Transcript of Limited Renovation Asbestos Survey · ACM, PACM or asbestos materials at the subject site that are...

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Limited Renovation Asbestos Survey ABC Electric Company Building 1

1 of 33 5.30.2012 XYZ Consultants Inc. Project Number 12-012

Limited Renovation Asbestos Survey Conducted At: ABC Electric Company Building 1 555 Park Avenue Rochester, New York

Prepared For: Acme General Contractors 1 Elm Street Pittsford, New York 14534

Prepared & Performed By: XYZ Consultants Inc 123 Main Street Rochester, New York 14610

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Table of Contents___________________________________

Project Fact Sheet Page 4 Survey Introduction Page 5 Renovation Survey Scope Page 5 Renovation Scope Page 5 Inspection/Survey Page 6 Inspector Training & Certification Page 6 Asbestos Bulk Sampling Page 6 Asbestos Bulk Analysis Page 7 Limitations Page 7 Survey Description Page 9 Conclusions Page 10 Appendix A Code Rule 56 Subpart 56-5 Page 11

EPA AHERA Regulation 40 CFR Part 763.86 Page 16 OSHA Construction Standard 1926.1101 Page 18

Appendix B Definitions Page 20 Appendix C Certifications & Licenses Page 25 Appendix D Homogeneous Areas Summary Table Page 33 Appendix E Sample Prefix Identification Table Page 35 Appendix F Room Survey Quantity Summary Table Page 36 Appendix G Sample Location Map Page 37 Appendix H Analytical Results Page 38

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Project Fact Sheet_____________________________ Project Number: 12-012 Project Title: Limited Renovation Asbestos Survey Project Dates: May 16, 2012 to May 20, 2012 Project Location: ABC Electric Company Building 1 555 Park Avenue Rochester, New York Prepared For: Acme General Contractors

1 Elm Street Pittsford, New York 14534

Contact: John Doe 585-555-5555 Prepared By: XYZ Consultants Inc 123 Main Street Rochester, New York 14610 585-555-4444 Performed By: John Smith

XYZ Consultants 123 Main Street Rochester, New York 14610 Asbestos Survey and Report Asbestos Survey Report Reviewed By: Prepared By: _________________ _________________ John Smith Jack Inthebox XYZ Consultants Inc XYZ Consultants Inc NYSDOL Inspector Project Manager

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Introduction_______________________________________ XYZ Consultants Inc. was retained by Acme General Contractors to perform a limited renovation asbestos survey of Building 1 at ABC Electric Company prior to the scheduled renovation. The renovation survey for asbestos containing materials was conducted on May 16, 2012 to May 20, 2012 at ABC Electric Company, located at 555 Park Avenue in Rochester, New York. Building 1 is a two story, 6,000 square foot power house that was built over 100 years ago. Its current and past primary function is a power house. The building is constructed of brick, and concrete with metal I-beams and supports. This asbestos survey report is not intended to be a bid document for a scope of work for the asbestos abatement contractor. The survey report only identifies and assesses the location, quantity and condition of ACM, PACM or asbestos materials at the subject site that are expected to be impacted by the renovation. The asbestos survey report is intended to be used as an integral part in the development of an asbestos abatement project design or work scope. Under the Code Rule Regulation this task can only be performed by a Certified Project Designer. This Survey report is a multi page document and must be viewed in its entirety. In the event that this survey report is used as part of the bidding process for the purposes of asbestos abatement or project design of the areas indicated within the survey report, it is recommended that this survey report is submitted to the bidding contractors in its entirety. Immediate transmittal of the building survey to the commissioner is the responsibility of the building owner or his/her agent as defined by 12 NYCRR Part 56.5.1(g). Renovation Survey Scope______________________________ As required by the 12 NYCRR Part 56 the asbestos survey shall include a thorough inspection for and identification of all PACM (Presumed Asbestos Containing Materials), suspect miscellaneous ACM (Asbestos Containing Materials), or asbestos material throughout the building or portion of the building to be renovated. The inspection/survey shall be performed with due diligence to identify and assess the locations, quantities, friability, and conditions of all types of installations (materials) at the effected portion of the building and expected to be impacted by renovation at the above referenced location. The scope of the renovation asbestos survey is dictated by the scope of the renovation that the client is proposing to perform. Below is the client’s scope and intentions as described by the client and understood by the inspectors. Several components are essential in determining the scope of the renovation survey. The inspectors and/or project manager shall determine the scope of the renovation survey through an understanding of building owner’s or the building owner’s representative description of the renovation, any building or demolition/renovation drawings provided by the building owner or the building owner’s representative and interviews with knowledgeable building personnel with an intimate understanding of the building’s components. Any changes in circumstances or fact that the scope of the survey is based upon can affect the findings, conclusions and recommendations presented in the survey report.

Renovation Scope___________________________________ The scope of the renovation project as defined by Acme General Contractors is a complete interior demolition of the building. The renovation scope will include the following;

1. Complete interior demolition 2. Window and door replacement throughout the building.

Demolition drawings were not provided to the inspectors by the client. All information pertaining to the scope of the renovation was provided through interviewing the project manager, John Doe of Acme General Contractors throughout the course of the inspection. As built drawings were not provided to the inspector, as built drawings are essential parts of the survey process. Often these as built drawings will provide the inspector with information related to hidden suspect materials that may have been installed in the building

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during the original construction. Please refer to the conclusion section for materials that were discovered as a result of this as built drawing. Inspection/Survey___________________________________ Asbestos surveys conducted in New York State are regulated by the NYS Department of Labor’s Code Rule 56. For the purpose of this report 12 NYCRR Part 56 (Code Rule 56) will be referred to as Code Rule 56 or The Code Rule. A copy of the applicable Code Rule Subpart is provided in Appendix A. Code Rule 56 provides specific guidelines for the survey (inspection) process. The Code Rule states that the inspection shall be conducted using standard EPA and OSHA accepted methods. The accepted EPA method of asbestos surveys (inspections) is the AHERA protocol (EPA 40 CFR Part 763, subpart E). Since its development the AHERA sampling and inspection protocol has become the standard for which all asbestos surveys are performed. This survey was performed consistent with the requirements of the AHERA protocol. The Code Rule also indicates OSHA accepted methods. Under the OSHA Construction Standard asbestos surveys are considered Class III asbestos work. What the OSHA Standard states is that the building owner shall notify prospective employers, employees of the owner, employers of employees working on or adjacent to the site and tenants, the presence, location and quantity of ACM and/or PACM present within their worksite. And prior to demolition, renovation or repair work must supply any contractor performing work within the building with an asbestos survey identifying the presence, location and quantity of ACM and/or PACM. This survey shall identify with due diligence the presence, locations, and quantities of PACM and/or ACM present at the worksite prior to the scheduled work. 1926.1101(k)(5)(ii)(b) of the OSHA Construction Standard indicates that the samples shall be collected in a manner consistent with 40CFR 763.86 (The AHERA sampling protocol). Inspector Training & Certification________________________ XYZ Consultants inspector John Smith conducted the inspection. XYZ Consultants inspectors are fully trained by an approved New York State Department of Health (NYSDOH) training provider prior to certification. Per the AHERA Regulation (40 CFR Part 763 Subpart E) inspections shall be performed by an accredited inspector. Accredited inspectors are required to receive their accreditation consistent with section 206 of Title II of the Toxic Substance Control Act (TSCA). The Toxic Substance Control Act (TSCA) mandates that training shall meet the requirements of the Model Accreditation Plan (40 CFR Part 763, Subpart E, Appendix (C). The established New York State Department of Health (NYSDOH) training program meets the requirements of the EPA Model Accreditation Plan. Mr. Smith is a New York State Department of Labor (NYSDOL) certified inspector working for XYZ Consultants Inc. which is a New York State Department of Labor (NYSDOL) licensed asbestos contractor. Inspector certifications and the company’s asbestos handling license are provided in Appendix C.

Asbestos Bulk Sampling_______________________________ XYZ Consultants inspectors selected Homogeneous areas (materials) within each functional space for inclusion in the inspection. Homogeneous areas were selected through an understanding of the scope of the renovation as described by the client, the scope of the renovation survey as defined by the contract, and the historical uses of asbestos in building materials. Bulk samples were then collected from each homogenous area. “Homogenous area” is an EPA AHREA term which means; an area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture. Please keep in mind that the word “area” does not refer to a space or room, it refers to a material. For reference a listing definitions related to asbestos surveys has been provided in Appendix B of this report. A listing of homogeneous areas that were sampled as part of the survey/inspection can be found in Appendix D of this report. Bulk samples were collected consistent with the AHERA Sampling protocol (40 CFR Part 763.86 Subpart E). Bulk samples consist of a small amount of the suspect material that is collected and containerized consistent with EPA and OSHA accepted methods. Each bulk sample was assigned a six digit alphanumeric identification number by the inspector. A listing of the sample identification number prefix is provided in Appendix E of this report for reference. Bulk samples are then recorded on the inspector’s documentation which includes; field notes, room survey sheets, drawings and a chain of custody document.

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All bulk samples are recorded on the chain of custody prior to delivery to the analytical laboratory. The chain of custody document accompanies all bulk samples from the point of collection until they reach the laboratory.

Asbestos Bulk Analysis________________________________ Ronco Environmental performed all sample analysis and analytical reports for this project. The Ronco laboratory is accredited through NYSDOH/ELAP (Lab ID# 111111) for Solid and Hazardous Waste, Air and Emissions for Bulk Asbestos Fiber Analysis. Samples are stored at the laboratory for 90 days then disposed of according to authoritative regulations. The following analysis methodology was used for suspect asbestos bulk samples:

• New York State Department of Health, ELAP Method 198.1 (Polarized Light Microscopy Methods for Identifying and Quantitating Asbestos in Bulk Samples)

• New York State Department of Health, ELAP Method 198.6 (Polarized Light Microscopy Method for Identifying and Quantitating Asbestos in Non-Friable Organically Bound Bulk Samples).

• New York State Department of Health, ELAP Method 198.4 (Transmission Electron Microscopy Method for Identifying and Quantitating Asbestos in Non-Friable Organically Bound Bulk Samples).

Limitations________________________________________ The information provided in this report was compiled from field and laboratory data and was prepared for and referenced to ACB Electric Company, Building 1. Materials noted and recorded are intended to represent the subject site at the time and date that the observations were made. Determinations of suspect asbestos containing materials within the building were subject to the accessibility of each individual area or space. Determinations of asbestos containing materials were made by means of bulk sampling and analysis, physical assessment and/or visual assessment if the materials were not accessible. XYZ Consultants Inc accepts no responsibility for the content of building materials within areas or spaces that were unknown to us, not reasonably accessible, or not part of the scope of the project as defined by the client. XYZ Consultants Inc assumes no liability for any buildings or areas that were not identified by the client that may fall under state or federal regulations. Conclusions and recommendations provided in this report are based on the assumption that homogeneous areas (materials) identified are homogenous throughout their application. Energized mechanical or electrical systems were not sampled as part of the survey, and were visually assessed as ACM (Asbestos Containing Material). Suspect materials that are visually assessed by the inspector as ACM shall be treated as ACM, unless bulk sampling is conducted consistent with EPA and OSHA accepted methods, and the analysis meets the requirements of Code Rule 56 and the suspect material is found not to be asbestos containing. These systems may contain one or more of the following components, but are not limited to these components: brakes, clutches, gaskets, insulating panels, blocks or backer boards, wire insulation, explosion proof lighting gaskets and fitting packings, insulating papers, pipe sleeve packings, fire stops, caulks, paints and coatings. Areas that were inaccessible at the time that the survey was performed will be noted on the survey. If areas that were inaccessible were determined homogeneous to the surrounding areas by visual assessment, quantification by means of a visual assessment was performed and will be noted on the survey report. Access to the space should be provided to the inspector prior to renovation to confirm the homogeneous classification. Bulk sampling and analysis was limited to materials that are expected to be impacted by the renovation, this includes but not limited to materials that may be necessary to move, demolish or penetrate to access suspect materials. Due to the age of construction, some suspect materials were not analyzed for asbestos at the clients request and will be assumed to be ACM. All materials assumed to be ACM shall be treated as

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ACM, unless bulk sampling is conducted consistent with EPA and OSHA accepted methods, and the analysis meets the requirements of Code Rule 56 and the suspect material is found not to be asbestos containing. Assumptions made on materials that were not sampled and analyzed or inaccessible for assessment during the inspection are based on historical application of a suspect material based on the inspector’s experience and training and may not actually represent the color, quantity, friability or condition of the material. All quantities are approximations and must be field verified by the contractor prior to the submittal of bids. Contractor bids are expected to be based on their own determination of quantities and not the quantities stated in this report. All quantifications were made by means of tape measurements and should be field verified by the contractor. These quantifications may have changed from the time of the survey due to a change in the scope. Consistent with Code Rule 56 subpart 56-5.1(j), when unidentified and unassessed Asbestos is discovered during any construction activity, such as demolition, remodeling, renovation or repair work and reveals PACM or suspect miscellaneous ACM that has not been identified by the asbestos survey consistent with the requirements of the Code Rule, or has not been identified by other inspections as per current OSHA or EPA requirements, all activities shall cease in the area where the PACM or suspect miscellaneous ACM is found and the Asbestos Control Bureau shall be notified by telephone by the building/structure owner or their representative, followed with a written notice in accordance with the notification requirements of the Code Rule. Unassessed PACM or suspect miscellaneous ACM shall be treated and handled as ACM and assumed to be ACM, unless proven otherwise by standard EPA and OSHA accepted methods, including multi-layered systems sampling protocols; subsequent analyses performed by a laboratory that meets the requirements of Section 56-4.2 of the Code Rule; and the analyses satisfies both NYS ELAP and federal requirements, including multi-layered sample analyses, to document non-asbestos containing material. In addition to this requirement the property owner is required to follow provisions indicated in Code Rule 56 subpart 56-1.5.

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Survey Description__________________________________ The following is a brief description of the space by space survey located in Appendix G.

Column 1

Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10

Room #

Sample #'s

taken in

space

Positive Sample ID #

Positive Material

Description Location of

Material Type of Material

Friable Non-Friable NOB Condition SQ FT Lin. FT

1. Column 1; indicates the room or space number, functional space description and estimated square

footage of the room or functional space referenced to the attached map/drawing. 2. Column 2; indicates the bulk sample numbers that were taken in the room or functional space

indicated in column 1. I.e. 001-007 means samples one through seven were sampled in the room or space, none would indicate that no samples were taken in the room or space. You will not see the first three letters of the sample in this column. If you would like to know the materials that were tested in the room please refer to the analytical results which are documented in numerical order.

3. Column 3; indicates the sample number that proves the material is positive for asbestos content. This sample may have taken in the room or space in column 1 or determined a homogeneous area (material) by the inspector to a sample that was taken in another room or space. For the purpose of this report all samples are assigned a six digit alphanumeric sample identification number. The first three letters indicate the material, found in column 4. The last three numbers indicate the sample number in the sequence in which it was taken. If there is a letter after the last three numbers, this indicates that the laboratory or the inspector determines that there were multiple layers within the same sample, requiring additional analysis under EPA protocols. Materials that were assumed to be asbestos containing materials by the inspector or at the request of the client will be indicated by “Assume” in this column.

4. Column 4; gives a brief description of the asbestos containing material or the material that is to be treated as asbestos containing as determined by the inspector. At times non-asbestos materials are contaminated with asbestos, therefore must be treated as asbestos.

5. Column 5; indicates a brief description of the location of the material in the room and not the location where the sample was taken from. You will find locations of where each sample was taken from on the analytical sampling results.

6. Column 6; indicates classification of material, according to EPA (AHERA) protocols. 7. Column 7; indicates the friability of the material in that space as determined by the inspector and

the analytical laboratory consistent with Code Rule 56 and EPA regulations. 8. Column 8; indicates the physical condition of the material as assessed by the inspector in the

space indicated in column 1, according to the condition description described below. For the purpose of this report, the condition of the ACM will be reported in good, fair or poor condition. Conditions listed in column 8 of the survey report will be as follows; a. Good; means material is intact with no visible damage. b. Fair; means material contains fewer than 10% distributed damage or 25% localized damage. c. Poor; means material contains over 10% distributed damage or 25% localized damage. Conditions listed in column 8 of the space by space survey report are only related to the specific material for the specific space.

9. Column 9; indicates the square footage of ACM material found in the space. 10. Column 10; indicates the linear footage of ACM material found in the space. Pipe insulation that is

two feet or greater in diameter is required to be reported in square feet according to code Rule 56.

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Conclusions_______________________________________ Conclusions and recommendations made are based upon the subject site at the time and date that the observations were made. The renovation survey was conducted on May 16, 2012 through May 30, 2012. Refer to the attached space by space spreadsheet in Appendix G indicating the materials that were identified to contain asbestos. Any changes in circumstances or fact that the scope of the survey is based upon can affect the findings, conclusions and recommendations presented in the survey report. The asbestos survey included the bulk sampling of 61 homogeneous areas (materials), identification of the 61 homogeneous areas are indicated in Appendix D of this survey report. 220 bulk samples were submitted to a state and federal accredited laboratory for analysis to determine the presence of asbestos. Of the 220 bulk samples that were collected representing the 61 homogeneous areas submitted for analysis, 10 materials (homogeneous areas) were found to contain asbestos greater than one percent. Analytical results and chain of custody documentation are provided in Appendix I of this report. In addition 7 homogeneous areas were identified and will be assumed to be ACM at the client’s request. Due to the energized boilers, interior components of the buildings boiler system were not tested as part of the inspection. Bulk sampling of suspect materials on the boilers were limited to accessible materials on the exterior of the boilers. Boilers may contain the following materials but are not limited to these components; Fire Brick, Refractory, Gaskets and insulating blocks or panels. These materials shall be assumed to be ACM and shall be treated as ACM, unless bulk sampling is conducted consistent with EPA and OSHA accepted methods, and the analysis meets the requirements of Code Rule 56 and the suspect material is found not to be asbestos containing. The inspector noted that the structure had been renovated several times over the years and separated the building into several different homogeneous areas, combining homogeneous areas that appeared to be renovated at the same time period considering the type and application of building materials that were used in the specific spaces and/or areas of the building. At the costumers request some suspect materials were not analyzed using TEM analysis as required by state regulations. Therefore these materials shall be assumed to be ACM (Asbestos Containing Materials) and are subject to state and federal regulations governing asbestos abatement practices.

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Appendix A_______________________________________ Code Rule 56 Subpart 56-5

SUBPART 56-5

PHASE IA: ASBESTOS SURVEY PLANNING AND DESIGN 56-5.1 Asbestos Survey Requirements for Building/Structure Demolition, Renovation, Remodeling and Repair (a) Asbestos Survey Required. An owner or an owner’s agent, except the owner of one and two-family

dwellings who contracts for, but does not direct or control the work, shall cause to be conducted, an asbestos survey completed by a licensed asbestos contractor using inspectors certified in compliance with Section 56-3.2(d), to determine whether or not the building or structure, or portion(s) thereof to be demolished, renovated, remodeled, or have repair work, contains ACM, PACM or asbestos material. This asbestos survey shall be completed and submitted as indicated in Subdivision (g) of this Section, prior to commencing work. All such asbestos surveys shall be conducted in conformance with the requirements of Subdivision (e) of this Section.

(b) Exemptions To Asbestos Survey Requirements: The asbestos survey required by this Subdivision

(a) of this Section shall not be required for the following classes of buildings or structures:

(1) an agricultural building; (2) buildings or structures for which original construction commenced on or after January 1, 1974; (3) A structure certified in writing to be structurally unsound by a licensed Professional Engineer,

Registered Architect, Building Inspector, Fire Inspector or other official of competent jurisdiction. (See Section 56-11.5)

(c) Building/Structure Demolition. If a building/structure asbestos survey is not required or performed

per Subdivision (b) of this Section, and the building/structure is certified to be unsound or slated for contracted demolition, the building/structure shall be assumed to contain asbestos, and shall be demolished per this Part, unless the building/structure is adequately certified to be free of asbestos containing material. Acceptable documentation for certification shall be a previous thorough building/structure asbestos survey, abatement records or other documentation acceptable to the Commissioner or his or her representative.

(d) Responsibility To Comply. No exemption to the requirement to conduct an asbestos survey shall

exempt any person, asbestos contractor, property owner or business entity from the inspection or asbestos survey requirements of EPA, OSHA, and any other applicable section of this Part.

(e) Building/Structure Asbestos Survey Requirements. The asbestos survey shall include a thorough

inspection for and identification of all PACM, suspect miscellaneous ACM, or asbestos material throughout the building/structure or portion thereof to be demolished, renovated, remodeled, or to have repair work. The required inspection shall be performed by a certified asbestos inspector, and, at a minimum, shall include identification of PACM, suspect miscellaneous ACM or asbestos material by all of the following methods:

(1) The review of building/structure plans and records, if available, for references to asbestos,

ACM, PACM, suspect miscellaneous ACM or asbestos material used in construction, renovation or repair; and

(2) A visual inspection for PACM and suspect miscellaneous ACM throughout the

building/structure or portion thereof to be demolished, renovated, remodeled, or repaired. For the purpose of this Part, all PACM and suspect miscellaneous ACM visually assessed

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shall be treated and handled as ACM and shall be assumed to be ACM, unless bulk sampling is conducted as per this Section, standard EPA and OSHA accepted methods, including multi-layered systems sampling protocols; the subsequent analyses are performed by a laboratory that meets the requirements of Section 56-4.2 of this Part; and the analyses satisfies both ELAP and federal requirements, including multi-layered sample analyses, to document non-asbestos containing material.

(f) Building/Structure Asbestos Survey Information.

(1) The asbestos survey shall, at a minimum, identify and assess with due diligence, the locations, quantities, friability and conditions of all types of installations at the affected portion of the building/structure relative to the ACM, suspect miscellaneous ACM, PACM or asbestos material contained therein. The following list is not inclusive of all types of ACMs, it only summarizes typical ACMs. The certified asbestos inspector is responsible for identification and assessment of all types ACM, PACM, suspect miscellaneous ACM and asbestos material within the affected portion of the building/structure:

(i) PACM

(a) Surfacing Treatments:

(1) Fireproofing; (2) Acoustical Plaster; (3) Finish Plasters; and (4) Skim Coats of Joint Compound.

(b) Thermal System Insulation:

(1) Equipment Insulation; (2) Boiler, Breeching, Duct, or Tank Insulation, Cement or Mortar Used

for Boilers and Refractory Brick; (3) Piping and Fitting Insulations including but not limited to, Wrapped

Paper, Aircell, Millboard, Rope, Cork, Preformed Plaster, Job Molded Plaster and coverings over fibrous glass insulation.

(ii) SUSPECT MISCELLANEOUS ACM

(a) Roofing and Siding Miscellaneous Materials:

(1) Insulation Board; (2) Vapor Barriers; (3) Coatings; (4) Non-Metallic or Non-Wood Roof Decking (5) Felts; (6) Cementitious Board (Transite); (7) Flashing;

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(8) Shingles; and (9) Galbestos.

(b) Other Miscellaneous Materials:

(1) Dust and Debris; (2) Floor Tile; (3) Cove Base; (4) Floor Leveler Compound; (5) Ceiling Tile; (6) Vermiculite Insulation

(7) Gaskets, Seals, Sealants (including for condensate control); (8) Vibration Isolators; (9) Laboratory Tables and Hoods; (10) Chalkboards; (11) Pipe Penetration Packing or Other Fire stopping Materials (12) Cementitious Pipe (Transite) (13) Cementitious Board (Transite); (14) Electrical Wire Insulation; (15) Fire Curtains; (16) Fire Blankets; (17) Fire Doors; (18) Brakes and Clutches; (19) Mastics, Adhesives and Glues; (20) Caulks; (21) Sheet Flooring (Linoleum); (22) Wallpaper; (23) Drywall; (24) Plasterboard (25) Spackling/Joint Compound; (26) Textured Paint;

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(27) Grout; (28) Glazing Compound; and (29) Terrazzo; and (30) Boiler Rope.

(2) All ACM, PACM, suspect miscellaneous ACM, or asbestos material reported under

Paragraph (1) of this Subdivision shall include the location of the materials, an estimate of the quantities, types, friability and condition of the identified materials to be treated and handled as ACM. For the purpose of this Part, all PACM and suspect miscellaneous ACM visually assessed shall be treated and handled as ACM and shall be assumed to be ACM, unless bulk sampling is conducted as per this Section, standard EPA and OSHA accepted methods, including multi-layered systems sampling protocols; the subsequent analyses are performed by a laboratory that meets the requirements of Section 56-4.2 of this Part; and the analyses satisfies both ELAP and federal requirements, including multi-layered sample analyses, to document non-asbestos containing material.

(3) The building/structure asbestos survey shall also include the building/structure name,

address, the building/structure owner’s name and address, the name and address of the owner's agent, the name of the firm performing the asbestos survey and a copy of the firm’s current asbestos handling license, the names of the certified inspector(s) performing the survey and a copy of the current asbestos handling certificate for each inspector utilized, the dates of the asbestos survey, a listing of homogeneous areas identifying which ones are ACM, all laboratory analyses reports for bulk samples collected, and copies of the appropriate certifications for the laboratory used for analysis of samples taken during the asbestos survey.

(g) Transmittal of Building/Structure Asbestos Survey Information. One (1) copy of the results of

the building/structure asbestos survey shall be immediately transmitted by the building/structure owner as follows:

(1) One (1) copy of the completed asbestos survey shall be sent by the owner or their agent

to the local government entity charged with issuing a permit for such demolition, renovation, remodeling or repair work under applicable State or local laws.

(2) The completed asbestos survey for controlled demolition (as per Subpart 56-11.5) or pre-

demolition asbestos projects shall also be submitted to the appropriate Asbestos Control Bureau district office.

(3) The completed asbestos survey shall be kept on the construction site with the asbestos

notification and variance, if required, throughout the duration of the asbestos project and any associated demolition, renovation, remodeling or repair project.

(h) Removal Required. If the building/structure asbestos survey finds that the portion of the

building/structure to be demolished, renovated, remodeled, or have repair work contains ACM, PACM, suspect miscellaneous ACM assumed to be ACM, or asbestos material, which is impacted by the work, the owner or the owner’s agent shall conduct, or cause to have conducted, asbestos removal performed by a licensed asbestos abatement contractor in conformance with all standards set forth in this Part. All ACM, PACM, suspect miscellaneous ACM assumed to be ACM, or asbestos material impacted by the demolition, renovation, remodeling or repair project shall be removed as per this Part, prior to access or disturbance by other uncertified trades or personnel. No demolition, renovation, remodeling or repair work shall be commenced by any owner or the owner’s agent prior to the completion of the asbestos abatement in accordance with the notification requirements of this Part. For multi-phased work, the access restriction for uncertified trades or personnel applies to each intermediate portion of the entire project. Upon completion of the intermediate portion of the asbestos project, other trades or personnel may access that portion of the work site.

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For demolition projects that are exempt from asbestos survey requirements due to being structurally unsound, the demolition is considered an asbestos project and shall proceed as per Section 56-11.5.

(1) All building/structure owners and asbestos abatement contractors on a demolition,

renovation, remodeling, or repair project, which includes work covered by this Part, shall inform all trades on the work site about PACM, ACM, asbestos material and suspect miscellaneous ACM assumed to be ACM at the work site.

(i) Bidding. Bids may be advertised and contracts awarded for demolition, remodeling, renovation, or repair

work, but no work on the current intermediate portion of the project shall commence on the demolition, renovation, remodeling or repair work by any owner or agent prior to completion of all necessary asbestos abatement work for the current intermediate portion of the entire project, in conformance with all standards set forth in this Part.

(j) Unidentified and Unassessed Asbestos. When any construction activity, such as demolition,

remodeling, renovation or repair work, reveals PACM or suspect miscellaneous ACM that has not been identified by the asbestos survey per this Part, or has not been identified by other inspections as per current OSHA or EPA requirements, all activities shall cease in the area where the PACM or suspect miscellaneous ACM is found and the Asbestos Control Bureau shall be notified by telephone by the building/structure owner or their representative, followed with a written notice in accordance with the notification requirements of this Part. Unassessed PACM or suspect miscellaneous ACM shall be treated and handled as ACM and assumed to be ACM, unless proven otherwise by standard EPA and OSHA accepted methods, including multi-layered systems sampling protocols; subsequent analyses performed by a laboratory that meets the requirements of Section 56-4.2 of this Part; and the analyses satisfies both NYS ELAP and federal requirements, including multi-layered sample analyses, to document non-asbestos containing material.

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Appendix A_______________________________________ EPA AHERA 40 CFR Part 763 Samples were collected in the following manner consistent with EPA 40 CFR Part 763.86 Subpart E. (a) Surfacing material. An accredited inspector shall collect, in a statistically random manner that is

representative of the homogeneous area, bulk samples from each homogeneous area of friable surfacing material that is not assumed to be ACM, and shall collect the samples as follows: (1) At least three bulk samples shall be collected from each homogeneous area that is 1,000 ft2 or

less, except as provided in § 763.87(c)(2). (2) At least five bulk samples shall be collected from each homogeneous area that is greater than

1,000 ft2 but less than or equal to 5,000 ft2, except as provided in § 763.87(c)(2). (3) At least seven bulk samples shall be collected from each homogeneous area that is greater than

5,000 ft2, except as provided in § 763.87(c)(2). (b) Thermal system insulation.

(1) Except as provided in paragraphs (b) (2) through (4) of this section and § 763.87(c), an accredited inspector shall collect, in a randomly distributed manner, at least three bulk samples from each homogeneous area of thermal system insulation that is not assumed to be ACM.

(2) Collect at least one bulk sample from each homogeneous area of patched thermal system insulation that is not assumed to be ACM if the patched section is less than 6 linear or square feet.

(3) In a manner sufficient to determine whether the material is ACM or not ACM, collect bulk samples from each insulated mechanical system that is not assumed to be ACM where cement or plaster is used on fittings such as tees, elbows, or valves, except as provided under § 763.87(c)(2).

(4) Bulk samples are not required to be collected from any homogeneous area where the accredited inspector has determined that the thermal system insulation is fiberglass, foam glass, rubber, or other non-ACBM.

(c) Miscellaneous material. In a manner sufficient to determine whether material is ACM or not ACM, an accredited inspector shall collect bulk samples from each homogeneous area of friable miscellaneous material that is not assumed to be ACM.

(d) Non-friable suspected ACBM. If any homogeneous area of nonfriable suspected ACBM is not assumed to be ACM, then an accredited inspector shall collect, in a manner sufficient to determine whether the material is ACM or not ACM, bulk samples from the homogeneous area of nonfriable suspected ACBM that is not assumed to be ACM.

According to an EPA clarification letter issued to the New York State Department of Labor Engineering Services Unit on May 31, 2007 regarding the bulk sampling of miscellaneous materials and non-friable suspect ACBM the following was determined by the EPA; New York State Department of Labor Question The New York State Dept. of Labor asbestos regulation (ICR 56) requires surveys/inspections of buildings/structures to identify the presence of ACM prior to demolition, renovation, remodeling or repair project. For the minimum number of samples necessary per homogeneous area, ICR 56 defers to AHERA requirements. 763.86(c) Miscellaneous material. In a manner sufficient to determine whether material is ACM or not ACM, an accredited inspector shall collect bulk samples from each homogeneous area of friable miscellaneous material that is not assumed to be ACM. 763.86(d) Nonfriable suspected ACBM. If any homogeneous area of nonfriable suspected ACBM is not assumed to be ACM, then an accredited inspector shall collect, in a manner sufficient to determine whether the material is ACM or not ACM, bulk samples from the homogeneous area of nonfriable suspected ACBM that is not assumed to be ACM. Thus the question that has been submitted to the department; Is two samples the minimum number of bulk samples per homogeneous area for both miscellaneous materials and non-friable suspect ACBM, to show that a homogeneous area is not ACM? As the terminology “bulk samples” is used in both definitions, one bulk sample per homogeneous area would not seem to meet the minimum requirement in the definitions.

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EPA Response After consultation with our office of General Counsel, EPA agrees that the regulations cited above use the plural word “samples” and, therefore, two samples are the minimum number of samples for miscellaneous material and non-friable suspect ACBM.

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Appendix A_______________________________________ OSHA Construction Standard 1926.1101 Subpart Z 1926.1101(k) Communication of hazards (1) This section applies to the communication of information concerning asbestos hazards in construction

activities to facilitate compliance with this standard. Most asbestos-related construction activities involve previously installed building materials. Building owners often are the only and/or best sources of information concerning them. Therefore, they, along with employers of potentially exposed employees, are assigned specific information conveying and retention duties under this section. Installed Asbestos Containing Building Material. Employers and building owners shall identify TSI and sprayed or troweled on surfacing materials in buildings as asbestos-containing, unless they determine in compliance with paragraph (k)(5) of this section that the material is not asbestos- containing. Asphalt and vinyl flooring material installed no later than 1980 must also be considered as asbestos containing unless the employer, pursuant to paragraph (g)(8)(i)(I) of this section determines that it is not asbestos-containing. If the employer/ building owner has actual knowledge, or should have known through the exercise of due diligence, that other materials are asbestos-containing, they too must be treated as such. When communicating information to employees pursuant to this standard, owners and employers shall identify ‘‘PACM’’ as ACM. Additional requirements relating to communication of asbestos work on multi-employer worksites are set out in paragraph (d) of this section.

(2) Duties of building and facility owners (i) Before work subject to this standard is begun, building and facility owners shall determine the

presence, location, and quantity of ACM and/or PACM at the work site pursuant to paragraph (k)(1) of this section.

(ii) Building and/or facility owners shall notify the following persons of the presence, location and quantity of ACM or PACM, at the work sites in their buildings and facilities. Notification either shall be in writing, or shall consist of a personal communication between the owner and the person to whom notification must be given or their authorized representatives: (A) Prospective employers applying or bidding for work whose employees reasonably can be

expected to work in or adjacent to areas containing such material; (B) Employees of the owner who will work in or adjacent to areas containing such material: (C) On multi-employer worksites, all employers of employees who will be performing work within

or adjacent to areas containing such materials; (D) Tenants who will occupy areas containing such material.

(3) Duties of employers whose employees perform work subject to this standard in or adjacent to areas containing ACM and PACM. Building/facility owners whose employees perform such work shall comply with these provisions to the extent applicable. (i) Before work in areas containing ACM and PACM is begun; employers shall identify the presence,

location, and quantity of ACM, and/or PACM therein pursuant to paragraph (k)(1) of this section. (ii) Before work under this standard is performed employers of employees who will perform such work

shall inform the following persons of the location and quantity of ACM and/or PACM present in the area and the precautions to be taken to insure that airborne asbestos is confined to the area. (A) Owners of the building/facility; (B) Employees who will perform such work and employers of employees who work and/or will be

working in adjacent areas. (iii) Within 10 days of the completion of such work, the employer whose employees have performed

work subject to this standard, shall inform the building/ facility owner and employers of employees who will be working in the area of the current location and quantity of PACM and/or ACM remaining in the area and final monitoring results, if any.

(4) In addition to the above requirements, all employers who discover ACM and/or PACM on a worksite shall convey information concerning the presence, location and quantity of such newly discovered ACM and/or PACM to the owner and to other employers of employees working at the work site, within 24 hours of the discovery.

(5) Criteria to rebut the designation of installed material as PACM. (i) At any time, an employer and/or building owner may demonstrate, for purposes of this standard,

that PACM does not contain asbestos. Building owners and/ or employers are not required to communicate information about the presence of building material for which such a demonstration pursuant to the requirements of paragraph (k)(5)(ii) of this section has been made. However, in all

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such cases, the information, data and analysis supporting the determination that PACM does not contain asbestos, shall be retained pursuant to paragraph (n) of this section.

(ii) An employer or owner may demonstrate that PACM does not contain more than 1% asbestos by the following: (A) Having a completed inspection conducted pursuant to the requirements of AHERA (40 CFR

Part 763, subpart E) which demonstrates that the material is not ACM; or (B) Performing tests of the material containing PACM which demonstrate that no ACM is present in

the material. Such tests shall include analysis of bulk samples collected in the manner described in 40 CFR 763.86. The tests, evaluation and sample collection shall be conducted by an accredited inspector or by a CIH. Analysis of samples shall be performed by persons or laboratories with proficiency demonstrated by current successful participation in a nationally recognized testing program such as the National Voluntary Laboratory Accreditation Program (NVLAP) or the National Institute for Standards and Technology (NIST) or the Round Robin for bulk samples administered by the American Industrial Hygiene Association (AIHA) or an equivalent nationally-recognized round robin testing program.

(iii) The employer and/or building owner may demonstrate that flooring material including associated mastic and backing does not contain asbestos, by a determination of an industrial hygienist based upon recognized analytical techniques showing that the material is not ACM.

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Appendix B_______________________________________ Definitions All definitions are from the following regulations; 12 NYCRR Part 56 (DOL), EPA (AHERA) 40 CFR Part 763 Subpart E, (OSHA) 29CFR1926.1101 Subpart Z and EPA (NESHAP) 40 CFR Part 61 Subpart M. Abatement. Any portion of an asbestos project that includes procedures to control fiber release from

asbestos containing material. This includes removal, encapsulation, enclosure, repair, or handling of asbestos material that may result in the release of asbestos fiber. (DOL)

Accepted Methods/Methodologies, Procedures, regulations, or standards, which are published by

recognized standards organizations (e.g. NIOSH, ASTM, ANSI), or are included within federal, state or local governmental regulations (e.g. OSHA, USEPA). (DOL)

Accredited or accreditation when referring to a person or laboratory means that such person or

laboratory is accredited in accordance with section 206 of Title II of the Act. (AHERA) Asbestos. Any naturally occurring hydrated mineral silicate separable into commercially usable fibers,

including chrysotile (serpentine), amosite (cumingtonitegrunerite), crocidolite (riebeckite), tremolite, anthophyllite and actinolite. (DOL)

Asbestos Containing Material (ACM). Any material containing greater than one percent (1%) of

asbestos, also known as Asbestos Material. (DOL) Asbestos-containing building material (ACBM) means surfacing ACM, thermal system insulation ACM,

or miscellaneous ACM that is found in or on interior structural members or other parts of a school building. (AHERA)

Asbestos debris means pieces of ACBM that can be identified by color, texture, or composition, or means

dust, if the dust is determined by an accredited inspector to be ACM. (AHERA) Asbestos Material Any material containing greater than one percent (1%) of asbestos, also known as

Asbestos Containing Material (ACM). (DOL) Asbestos Survey A thorough inspection for and identification of all PACM, suspect ACM, or asbestos

material throughout the building/structure or portion thereof to be demolished, renovated, remodeled, or repaired. (DOL)

Building/Structure A structure wholly or partially enclosed within exterior walls and a roof, intended to

afford shelter to persons, animals or property; or a structure used as a conveyance for utilities, vehicular traffic or pedestrians (e.g. bridge, tunnel, manhole, subsurface conduits). (DOL)

Building/Structure Owner The State, any political subdivision of the State, a public authority or any

other governmental agency or instrumentality thereof, person, company, unincorporated association, firm, partnership or corporation in whom legal title to the premises is vested unless the premises are held in land trust, in which instance building/structure owner means the person in whom beneficial title is vested. (DOL)

Building/facility owner is the legal entity, including a lessee, which exercises control over management

and record keeping functions relating to a building and/or facility in which activities covered by this standard take place. (OHSA)

Building/Structure Owner’s Authorized Representative. A licensed asbestos contractor firm

contractually responsible for execution of any building owner’s responsibility, as required by this Part, during any phase of an asbestos project at the building owner’s building/structure. (DOL)

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Bulk Sampling Accepted methods for collecting samples of suspect materials for appropriate analyses by NYS ELAP approved laboratories, to determine asbestos content. (DOL)

Category I Non-Friable ACM NESHAP classification - Asbestos-containing packings, gaskets, resilient

floor covering, and asphalt roofing products, containing more than one percent (1%) asbestos that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (DOL)

Category I non-friable asbestos-containing material (ACM) means asbestos containing packings,

gaskets, resilient floor covering, and asphalt roofing products containing more than 1 percent asbestos as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy. (NESHAP)

Category II Non-Friable ACM NESHAP classification - Any material, excluding Category I Non-Friable

ACM, containing more than one percent (1%) asbestos, that when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (DOL)

Category II non-friable ACM means any material, excluding Category I nonfriable ACM, containing more

than 1 percent asbestos as determined using the methods specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (NESHAP)

Class I Asbestos Work OSHA term meaning activities involving the abatement of Thermal Systems

Insulation (TSI), and surfacing ACM and PACM. (DOL) Class II Asbestos Work OSHA term meaning activities involving the abatement of ACM which is not TSI

or surfacing material. This includes, but is not limited to, the removal of asbestos-containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. (DOL)

Class II Asbestos Work means activities involving the removal of ACM which is not thermal system

insulation or surfacing material. This includes, but is not limited to, the removal of asbestos containing wallboard, floor tile and sheeting, roofing and siding shingles, and construction mastics. (OHSA)

Class III Asbestos Work OSHA term meaning Repair and Maintenance operations, where no more than a

minor quantity of ACM, including TSI and surfacing ACM and PACM, is likely to be disturbed. (DOL) Class III asbestos work means repair and maintenance operations, where ‘‘ACM’’, including TSI and

surfacing ACM and PACM, is likely to be disturbed. (OHSA) Class IV Asbestos Work OSHA term meaning Maintenance and Custodial Activities during which

employees contact but do not disturb ACM or PACM and activities to clean up non-ACM dust, waste and debris resulting from Class I, II and III activities. (DOL)

Class IV Asbestos Work means maintenance and custodial activities during which employees contact but

do not disturb ACM or PACM and activities to clean up dust, waste and debris resulting from Class I, II, and III activities. (OHSA)

Demolition The wrecking or removal of any load-supporting structural member of a building or structure.

(DOL) Demolition means the wrecking or taking out of any load-supporting structural member and any related

razing, removing, or stripping of asbestos products. (OHSA) 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. (NESHAP)

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Disturbance Any activities that disrupt the matrix of ACM or PACM, or generate debris, visible emissions or airborne asbestos fibers from ACM or PACM. This includes moving of friable asbestos containing material from one place to another. (DOL)

Disturbance means activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM,

or generate visible debris from ACM or PACM. In no event shall the amount of ACM or PACM so disturbed exceed that which can be contained in one glove bag or waste bag which shall not exceed 60 inches in length and width. (OHSA)

Emergency An unexpected, unanticipated or unforeseen occurrence, including but not limited to, a steam,

chemical, gas or water line rupture, a boiler failure, a building/structure collapse, or act of nature which may pose: (DOL)

(1) an imminent danger to the health and safety of the public; or (2) an asbestos-related risk to the health and safety of the public from release of asbestos fibers.

Emergency renovation operation means a renovation operation that was not planned but results from a

sudden, unexpected event that, if not immediately attended to, presents a safety or public health hazard, is necessary to protect equipment from damage, or is necessary to avoid imposing an unreasonable financial burden. This term includes operations necessitated by non-routine failures of equipment. (NESHAP)

Emergency Asbestos Project An asbestos project which is necessary to respond to an emergency. (DOL) EPA The United States Environmental Protection Agency. (DOL) Friable Any material that when dry, can be crumbled, pulverized, or reduced to powder by hand pressure,

or is capable of being released into the air by hand pressure. (DOL) Friable asbestos material means any material containing more than 1 percent asbestos as determined

using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy, which, 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. (NESHAP)

Functional space means a room, group of rooms, or homogeneous area (including crawl spaces or the

space between a dropped ceiling and the floor or roof deck above), such as classroom(s), a cafeteria, gymnasium, hallway(s), designated by a person accredited to prepare management plans, design abatement projects, or conduct response actions. (AHERA)

Homogeneous area means an area of surfacing material, thermal system insulation material, or

miscellaneous material that is uniform in color and texture. (AHERA) Homogeneous area means an area of surfacing material or thermal system insulation that is uniform in

color and texture. (OHSA) Incidental Disturbance The unintentional disturbance of, ACM, PACM, or asbestos material. (DOL) Incidental Disturbance Asbestos Project The cleanup, repair or encapsulation of less than 10 square

feet or less than 25 linear feet of incidentally disturbed ACM, PACM or asbestos material. (DOL) Inspector Any person who performs the duties described at Section 56-3.2(d)(4) of this Part. (DOL) Intact Asbestos material that has not crumbled, been pulverized, or otherwise been damaged or disturbed,

and the material’s matrix has not noticeably deteriorated. (DOL)

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Intact means that the ACM has not crumbled, been pulverized, or otherwise deteriorated so that the asbestos is no longer likely to be bound with its matrix. (OHSA)

Miscellaneous material means interior building material on structural components, structural members or

fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation. (AHERA)

NESHAP. National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61). (DOL) NIOSH. The National Institute for Occupational Safety and Health. (DOL) Non-Asbestos Material Any material documented to contain one percent (1%) or less of asbestos. (DOL) Non-Friable Any material that when dry, cannot be crumbled, pulverized, or reduced to powder by hand

pressure, and is not capable of being released into the air by hand pressure. (DOL) Non-friable means material in a school building which when dry may not be crumbled, pulverized, or

reduced to powder by hand pressure. (AHERA) Non-friable asbestos-containing material means any material containing more than 1 percent asbestos

as determined using the method specified in appendix E, subpart E, 40 CFR part 763, section 1, Polarized Light Microscopy, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. (NESHAP)

Non-Friable Organically Bound (NOB) Asbestos Material. Non-friable asbestos materials embedded in

flexible-to-rigid asphalt or vinyl matrices, including but not limited to flooring materials, adhesives, mastics, asphalt shingles, roofing materials and caulks. (DOL)

OSHA The Occupational Safety and Health Administration. (DOL) PACM means ‘‘presumed asbestos containing material’’. (OHSA) Presumed Asbestos Containing Material (PACM) All Thermal System Insulations and Surfacing

Materials found in buildings constructed no later than 1980. PACM is considered to be ACM unless proven otherwise by appropriate bulk sampling and laboratory analyses. (DOL)

Presumed Asbestos Containing Material means thermal system insulation and surfacing material found

in buildings constructed no later than 1980. The designation of a material as ‘‘PACM’’ may be rebutted pursuant to paragraph (k)(5) of this section. (OHSA)

Project Designer Any person who performs the duties described at Section 56-3.2(d)(7) of this Part.

(DOL) Project Designer means a person who has successfully completed the training requirements for an

abatement project designer established by 40 U.S.C. 763.90(g). (OHSA) Regulated Asbestos-Containing Material (RACM) Friable ACM or PACM, Category I Non-friable ACM

that has become friable or has been or will be subjected to sanding, grinding, cutting or abrading, or 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. (DOL)

Regulated asbestos-containing material (RACM) means (a) Friable asbestos material, (b) Category I

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

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Removal Abatement, consisting of operations where ACM, PACM or asbestos material is removed or

stripped from structures or substrates. This includes demolition operations. (DOL) Renovation The altering of an existing building/structure, or a portion of building/structure components or

systems, including the stripping, removal or abatement of ACM from a building or structure. Operations in which load-supporting structural members are wrecked or taken out are demolitions. (DOL)

Repair (Asbestos). Abatement, consisting of corrective action for a Minor Asbestos Project using required

work practices to control fiber release from damaged ACM, PACM or asbestos material. (DOL) Repair The replacement, overhaul, rebuilding, reconstructing or reconditioning of any part of a

building/structure component or system with like or similar material or parts, due to damage or excessive wear. (DOL)

Repair means returning damaged ACBM to an undamaged condition or to an intact state so as to prevent

fiber release. (AHERA) Repair means overhauling, rebuilding, reconstructing, or reconditioning of structures or substrates,

including encapsulation or other repair of ACM or PACM attached to structures or substrates. (OHSA)

Strip means to take off RACM from any part of a facility or facility components. (NESHAP) Suspect Miscellaneous ACM. Any suspect asbestos-containing material that is not PACM, such as floor

tiles, ceiling tiles, mastics/adhesives, sealants, roofing materials, cementitous materials, etc. A listing of typical suspect miscellaneous ACM can be found in Subpart 56-5. All suspect miscellaneous ACM must be assumed to be ACM, unless proven otherwise by appropriate bulk sampling and laboratory analyses. (DOL)

Surfacing ACM means surfacing material that is ACM. (AHERA) Surfacing ACM means surfacing material which contains more than 1% asbestos. (OHSA) Surfacing Material, Material that is sprayed-on, troweled-on, or otherwise applied to surfaces (such as

acoustical or finish plaster on ceilings and walls, and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes). (DOL)

Thermal System Insulation, Insulation material applied to pipes, fittings, boilers, breeching, tanks, ducts

or other structural components to prevent heat gain or loss. (DOL) Thermal system insulation (TSI) means ACM applied to pipes, fittings, boilers, breeching, tanks, ducts or

other structural components to prevent heat loss or gain. (OHSA) Thermal system insulation ACM means thermal system insulation that is ACM. (AHERA)

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Appendix C_______________________________________ Inspector Certifications New York State Department of Labor Asbestos Handling Certification

Insert Hard Card here

Legend- Designation of Letter Identification A Asbestos Handler D Asbestos Inspector G Asbestos Supervisor B Allied Trades E Management Planner H Asbestos Project Monitor C Air Sampling Technician F Operations & Maintenance I Asbestos Project Designer

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Appendix C_______________________________________ Company Asbestos Handling License New York State Department of Labor Asbestos Handling Certification

Insert license here

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Appendix C_______________________________________ ELAP Certification

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Appendix C_______________________________________ NVLAP Certification

Insert Certification here

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Appendix D_______________________________________ Homogeneous Area Summary Table

The Following is a list of homogeneous areas (materials) that were identified, sampled and analyzed for asbestos as part of the inspection and found to be non-asbestos.

1. White Joint Compound Negative 2. Gray 2x4 Suspended Ceiling Tile Negative 3. Gray 2x4 Suspended Ceiling Tile Negative 4. White 2x4 Suspended Ceiling Tile Negative 5. Tan 1x2 Suspended Ceiling Tile Negative 6. White 2x2 Suspended Ceiling Tile Negative 7. Gray 2x2 Suspended Ceiling Tile Negative 8. Gray 2x4 Suspended Ceiling Tile Negative 9. Tan 1x1 Adhered Ceiling Tile Negative 10. Gray Wall Plaster Negative 11. White Wall Plaster Negative 12. White Ceiling Plaster Negative 13. Gray Ceiling Plaster Negative 14. Tan Cove Molding Mastic Negative 15. Gray Cove Molding Mastic Negative 16. Tan Carpet Mastic Floor Negative 17. Tan Carpet Mastic Wall Negative 18. White Wall Caulk Negative 19. White/Gray Sheet Vinyl Negative 20. Gray Sheet Vinyl Backing Negative 21. Tan Sheet Vinyl Mastic Negative 22. White/Green Sheet Vinyl Negative 23. Blue/White Sheet Vinyl Negative 24. Green Sheet Vinyl Negative 25. Gray Sheet Vinyl Negative 26. Gray Sheet Vinyl Mastic Negative 27. White Drywall Negative 28. White Floor Leveler Negative 29. Tan Fiber Board Negative 30. Tan Floor Covering Negative 31. Tan Floor Covering Mastic Negative 32. Tan Sheet Vinyl Negative 33. White Ceramic Tile Grout Negative 34. Black Tar Paper Negative 35. Tan Floor Tile Mastic Negative 36. Brown Floor Covering Negative 37. Gray Ceramic Tile Cement Negative 38. Gray Ceramic Tile Grout Negative 39. Tan Ceramic Tile Mastic Negative 40. Gray Blown-in Insulation Negative 41. Gray Window Caulk Negative 42. Brown Wall Caulk Negative 43. Gray Fireproofing Negative 44. White Cove Molding Mastic Negative

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The Following is a list of homogeneous areas (materials) that were identified, sampled and analyzed for asbestos as part of the inspection and found to contain greater than 1% asbestos.

1. White Joint Compound Positive 2. Tan Ceiling Tile Mastic Positive 3. Tan Window Caulk Positive 4. Black Window Glaze Positive 5. White Duct insulation Positive 6. Brown Mastic Positive 7. Black Floor Tile Mastic Positive 8. Tan 12x12 Floor Tile Positive 9. Gray 12x12 Floor Tile Positive 10. Black Mastic Positive

The Following is a list of homogeneous areas (materials) that were identified, and assumed to be ACM as part of the inspection.

1. Brown Cove Molding Mastic 2. Tan Sheet Vinyl 3. White Sheet Vinyl Mastic 4. White/Green Sheet Vinyl 5. Tan Sheet Vinyl Mastic 6. Tan Mastic 7. Brown Mastic

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Appendix E_______________________________________ Sample Prefix Identification Table

APL Acoustical Plaster EPX Epoxy Flooring FLA Roof Flashing

ABC Acid Brick Cement EXJ Expansion Joint RMB Roof Membrane

ABM Acid Brick Membrane EPF Explosion Proof Fittings ROF Roofing

ARC Arc Tape EPG Explosion Proof Gasket ROS Roofing Shingles

BBR Boiler Breeching FBR Fiber Board RTR Roofing Cement/Tar

BOI Boiler Insulation FCU Fire Curtain SVL Sheet Vinyl

CAN Canvas Cloth FDI Fire Door SVB Sheet Vinyl Backing

CMF Carpet Mastic Floor FPR Fireproofing SVM Sheet Vinyl Mastic

CMW Carpet Mastic Wall FSP Fire Stop SPK Spackle/Joint Compound

CMW Carpet Mastic Wall Col. FLL Floor Leveler TKI Tank Insulation

CLK Caulk/General FMB Floor Membrane TAR Tar

CPL Ceiling Plaster FT1 Floor Tile 12x12 TRP Tar Paper

MCT Suspended Metal Pan Ceiling FT9 Floor Tile 9x9 TER Terrazzo Floor

ACT Adhered Ceiling Tile FTM Floor Tile Mastic SPK Top fill/Joint Compound

CTM Ceiling Tile Mastic FTP Floor Topping TRN Elevator Panel Box

SCT Suspended Ceiling Tile FGM Foam Glass Mastic TRN Transite Wall

COR Cement Core FOM Foam Mastic TRN Transite/General

CEM Cement General FHD Fume Hood DEB Unknown Debris

CEM Cement Pier GAL Galbestos Siding VPB Vapor Barrier

CTC Ceramic Tile Cement GAS Gasket VER Vermiculite Insulation

GRT Ceramic Tile Grout GAR Gasket (rope) VBC Vibration Cloth

CRM Ceramic Tile Mastic INM Insulation Mastic WLB Wall Board

CFM Computer room Fl Mastic INS Insulation (TSI) WAC Wall Caulk

CVM Cove Molding MAS Mastic/General WAI Wall Insulation

CMM Cove Molding Mastic MJP Mud Joint Packing WLP Wall Paper

CTG Coating PNT Paint WPL Wall Plaster

DWL Dry Wall PIC Pipe Covering WMB Waterproof Membrane

DUC Duct Caulk PIN Pipe Insulation WIC Window Caulk

DUI Duct Insulation PIT Pipe Insulation/Cork & Tar WIG Window Glaze

DIM Duct Insulation Mastic PIW Pipe Wrap WGH Window Glaze/Hauserman

EPB Electrical Panel Box REF Boiler Refractory WGD Window Glaze/Door The sample prefix identification table indicates the first three letters of the sample identification number which represents the material that was sampled and the assigned number by the inspector, the identification numbers are also indicated in Appendix E “Sample Identification Table” which represents all the samples that were collected as part of the renovation inspection/survey.

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Appendix F_______________________________________ Room Survey Quantity Summary Table All quantities are approximations and must be field verified by the contractor prior to the submittal of bids. Contractor bids are expected to be based on their own determination of quantities and not the quantities stated in this report. Quantities of materials listed in the following tables indicate materials that were sampled and analyzed for asbestos and found to contain greater than 1% asbestos or were assumed the be asbestos containing materials at the request of the client or at the inspector’s discretion. The following tables indicate materials that are expected to be impacted by the renovation as determined by the demolition and renovation drawings and interviews with the client and may not represent all materials in the space or area. Please carefully review the limitations and conclusions sections of this report for materials that were not tested as part of the inspection. These sections will contain general limitations or conclusions that were determined as a result of the inspector’s observations or testing limitations and/or assumptions that were determined by the client and the contract documents.

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Appendix G_______________________________________ Sample Location Maps The attached sample location maps will give you the exact location where the samples were taken from. Due to the limited space of the chain of custody and analytical report these map were provided to indicate sample location points.

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Appendix H_______________________________________ Analytical Results Insert analytical results here