PRE-DEMOLITION INSPECTION FOR ASBESTOS-CONTAINING ...dnhiggins.com/docs/RFB 872 S41 Pre-Demo...

Eco Advisors, LLC | www.ecoadvisors.net | Engineering.CA28480 | Asbestos.ZA444 | Lead FL-F152099-1

3931 RCA Blvd., Suite 3114, Palm Beach Gardens, FL 33410 | Ph. 561-627-1810 | Fax 561-627-2270

PRE-DEMOLITION INSPECTION

FOR ASBESTOS-CONTAINING MATERIALS

S-41 Water Control Structure Building

C. Stanley Weaver Canal East of US-1

Boynton Beach, Florida

Prepared for: CDM Smith

2180 West First Street

Suite 400

Fort Myers, FL 33901

Contact: Mr. William T. Beeson

Telephone: 239-938-9608

South Florida Water Management District

23500 SW Kanner Highway

Canal Point, Florida 33438

Contact: Mr. Bob Kukleski

Telephone: 561-686-8800

Prepared by:

Eco Advisors, LLC

Contact: Rachael Rossmeissl-Stone

March 2017

Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017

Executive Summary

EXECUTIVE SUMMARY

Eco Advisors, LLC is pleased to present our pre-demolition inspection report for asbestos-

containing materials (ACM) within the S-41 water control structure building associated with the

C. Stanley Weaver Canal east of US-1 in Boynton Beach, Florida.

We do not suspect that the following building materials are asbestos-containing; therefore the

materials were not sampled: wood, metal, rubber, plastic, CBS wall (no fill) and cotton.

Material

Description Location(s) Amount

Asbestos Content

or Assumed

Cementitious Casing

NESHAP Category II

Stilling wells: above grade and

underground, N side of the structure > 30 LF

15% Chrysotile

3% Crocidolite

Core Insulation Fire door at west wall 1 Door Assumed

The stilling wells extend approximately three feet above ground and approximately 12 feet into

the ground. The casing to the stilling wells is constructed of an asbestos cementitious product

which is an NESHAP Category II material. NESHAP Category II, a non-friable ACM, may

remain in place if the probability is low that the material will become crumbled, pulverized, or

reduced to powder during the demolition. In our opinion there is a high probability that

demolition activities will damage the cementitious casing rendering it a regulated ACM.

It is Eco Advisors understanding that a decision has not yet been made whether the wells will be

closed in place or removed. If the stilling wells are to be removed, the demolition should be

coordinated with a Florida Licensed Asbestos Abatement Contractor to properly remove and

dispose of the asbestos cementitious casing. If the wells are to be closed in placed, prior to

demolition remove the aboveground section [three (3) feet] utilizing a Florida Licensed Asbestos

Abatement Contractor. The wells should be abandoned by a licensed well driller in accordance

with Palm Beach County requirements including permitting. Provide notification and maintain

records as to the location of the abandoned asbestos containing materials.

The fire door core insulation can be removed as asbestos-containing and disposed of by a Florida

Licensed Asbestos Abatement Contractor or tested for asbestos content prior to demolition.

General recommendations:

Meet demolition notification requirements specified in EPA NESHAP regulations (40

CFR 61) and OSHA Asbestos regulations (29 CFR 1926.1011).

After casing removal and/or well abandonment is complete and the fire door has been

removed proceed with a wet demolition of the control building in accordance to EPA

NESHAP to mitigate fugitive dust.

Make this report available to contractors and regulatory agencies and assume any

additional suspect material found during the demolition and not identified in this report

as asbestos-containing until testing determines otherwise.

Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017

Table of Contents

TABLE OF CONTENTS

1 Introduction ................................................................................................................. 1

2 Scope of Work ............................................................................................................ 1

3 Project Information ..................................................................................................... 1

4 Inspection .................................................................................................................... 2

4.1 Not suspected of containing asbestos .............................................................................. 2

4.2 Suspect asbestos-containing materials (ACM) ............................................................... 2

5 Results ......................................................................................................................... 2

5.1 No Asbestos Detected ..................................................................................................... 2

5.2 Asbestos Detected ........................................................................................................... 2

5.3 Assumed Asbestos .......................................................................................................... 2

6 Recommendations ....................................................................................................... 3

7 Regulatory Information ............................................................................................... 3

7.1 EPA NESHAP – Asbestos (40 CFR Part 61).................................................................. 3

7.2 OSHA - Asbestos (29 CFR Part 1926.1101 or 29 CFR Part 1910.1001) ....................... 4

7.3 Florida Department of Environmental Protection (FDEP) ............................................. 4

8 Document Content ...................................................................................................... 5

9 Document Use ............................................................................................................. 5

Appendices:

Appendix A - Certifications and Signatures

Appendix B - Table 1 - Summary of Inspection

Appendix C - Site Photographs

Appendix D - Bulk Sample Analysis Report

Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017 |

Page 1

1 Introduction

Eco Advisors, LLC is pleased to present this pre-demolition inspection report for asbestos-

containing materials (ACM) within the S-41 water control structure building on the C. Stanley

Weaver Canal east of US-1 in Boynton Beach, Florida.

2 Scope of Work

The scope of work for this project was as follows:

Site visit and inspection to locate, identify, assess, and quantify ACM or suspect ACM.

o Performed by an EPA accredited inspector working under the direction of a Florida

licensed Asbestos Consultant (Appendix A).

o The inspection included the S-41 water control structure

o Visual observation of accessible areas to determine location of suspect ACM.

Sampling and analysis of identified suspect materials for asbestos content and other major

components.

o Contracted with a laboratory, fully accredited by the National Voluntary Laboratory

Accreditation Program (NVLAP), for bulk sample asbestos analysis utilizing Polarized

Light Microscopy (PLM)

o The amount or area of each homogeneous material determined the number of samples.

Homogeneous material is similar in color and texture, and installed during the same

time. The number of random samples met or exceeded the EPA AHERA Rule.

3 Project Information

Donathan Buck, EPA Accredited Asbestos Inspector for Eco Advisors, LLC, conducted the

inspection for asbestos-containing materials, in accordance with the above Scope of Work on

February 7, 2017.

Facility Usage: Utility

Facility Construction Date: Unknown

Approximate Size: 150 SF


Page 2

4 Inspection

4.1 Not suspected of containing asbestos

Wood

Metal

Rubber

Plastic

CBS wall (no fill)

Cotton

4.2 Suspect asbestos-containing materials (ACM)

Concrete slab

Cementitious stilling well casing

Fire door core insulation

Vibration isolator

5 Results

Table 1, included as Appendix B, tabulates the results of our Inspection. Listed are the suspect

asbestos-containing materials with type and content of asbestos for those materials determined

by sampling to be asbestos containing and the quantity (square or linear footage) of all ACM.

Appendix C, attached, provides Site photographs. Appendix D, attached, presents the Bulk

Sample Analysis report.

5.1 No Asbestos Detected

Concrete slab

Vibration isolator

5.2 Asbestos Detected

Cementitious stilling well casing

5.3 Assumed Asbestos

Fire door core insulation

Survey Area Components:

Ceilings Concrete

Walls CBS (no fill)

Floors Concrete

Roof Concrete

Exterior CBS (no fill)

Other Well casing


Page 3

6 Recommendations

The stilling wells extend approximately three feet above ground and approximately 12 feet into

the ground. The casing to the stilling wells is constructed of an asbestos cementitious product

which is an NESHAP Category II material. NESHAP Category II, a non-friable ACM, may

remain in place if the probability is low that the material will become crumbled, pulverized, or

reduced to powder during the demolition. In our opinion there is a high probability that

demolition activities will damage the cementitious casing rendering it a regulated ACM.

It is Eco Advisors understanding that a decision has not yet been made whether the wells will be

closed in place or removed. If the stilling wells are to be removed, the demolition should be

coordinated with a Florida Licensed Asbestos Abatement Contractor to properly remove and

dispose of the asbestos cementitious casing. If the wells are to be closed in placed, prior to

demolition remove the aboveground section [three (3) feet] utilizing a Florida Licensed Asbestos

Abatement Contractor. The wells should be abandoned by a licensed well driller in accordance

with Palm Beach County requirements including permitting. Provide notification and maintain

records as to the location of the abandoned asbestos containing materials.

The fire door core insulation can be removed as asbestos-containing and disposed of by a Florida

Licensed Asbestos Abatement Contractor or tested for asbestos content prior to demolition.

General recommendations:

Meet demolition notification requirements specified in EPA NESHAP regulations (40

CFR 61) and OSHA Asbestos regulations (29 CFR 1926.1011).

After casing removal and/or well abandonment is complete and the fire door has been

removed proceed with a wet demolition of the control building in accordance to EPA

NESHAP to mitigate fugitive dust.

Make this report available to contractors and regulatory agencies and assume any

additional suspect material found during the demolition and not identified in this report

as asbestos-containing until testing determines otherwise.

7 Regulatory Information

7.1 EPA NESHAP – Asbestos (40 CFR Part 61)

Requirements cited for building owners and contractors concerning inspections,

renovations, demolitions, removal, and disposal of ACM. Alternatives depend on

categories of the ACM: friable, Category I non-friable ACM, Category II non-friable ACM,

and Regulated ACM.

Category I Non Friable ACM is packing, gaskets, resilient floor coverings and roofing

products that contain more than one percent asbestos.

Category II Non Friable ACM is any material, excluding Category I Non-Friable ACM

or Regulated ACM (friable) that contains more than one percent asbestos.

Regulated ACM (RACM) is:

o All friable ACM that contains more than one percent asbestos;

o Category I Non Friable ACM that will or has been subject to sanding, grinding

cutting or abrading;


Page 4

o Category II Non Friable ACM that has become friable; and

o Category II Non Friable ACM with a high probability of being or has become

crumbled, pulverized, or reduced to powder by forces expected to act on the

material in the course of demolition or renovation.

Friable materials containing less than 10% by PLM analysis are ACM unless the

percentage is verified by point counting.

Notification is required for all demolitions (includes renovations where a load bearing

member is removed) and removal of friable or regulated asbestos containing and

presumed asbestos-containing material. The Contractor must wait ten (10) days from

the postmarked date of mailing to commence demolition or removal.

o Changes in the start date of the demolition/removal require notification to the above

agencies by phone, followed by a written revision to the Notification Form.

o Send a courtesy notification for Category I or II Non-Friable materials removed in a

manner that maintains the material in a non-friable condition.

7.2 OSHA - Asbestos (29 CFR Part 1926.1101 or 29 CFR Part 1910.1001)

Regulates asbestos exposure in all work, including but not limited to: demolition or

salvage of structures where asbestos is present, construction, alteration, repair,

maintenance, or renovation of structures, substrates, or portions thereof that contains

asbestos

Applies to all assumed or asbestos-containing materials EXCEPT asbestos-containing

asphalt roof coatings, cements, and mastics

Coverage under this standard is dependent on the nature of the work operation

involving asbestos exposure and not the asbestos content within the building material,

including but not limited to methods of compliance, record keeping, and waste disposal,

regardless of the asbestos content or levels of exposure.

o Asbestos-containing materials are classified as: Class I, II, III or IV Work Activities

and each Class has specific requirements under the OSHA Construction

Regulations.

o Materials containing less than 1% asbestos require compliance with 1926.1101(g)

(1) (2) (3) as an Unclassified Work Activity.

7.3 Florida Department of Environmental Protection (FDEP)

The Florida Department of Environmental Protection (FDEP) has the responsibility

under Sections 403.061 and 376.60, F.S., to oversee the safe management and removal

of asbestos-containing materials within Florida. This responsibility is implemented

under Chapter 62-257, F. A. C., and Section 62-204.800, F. A. C., which adopts 40

CFR, Part 61.

FDEP or delegated local government agencies may charge a notification fee for any

asbestos removal project.

The Owner or Demolition Contractor must complete a Notice of Asbestos Renovation

or Demolition. Send Notification by mail or hand deliver to the Florida Department of

Health, 800 Clematis Street, 4th

Floor or P.O. Box 29, West Palm Beach, FL 33401.


Page 5

8 Document Content

Consultation provided as stated in Eco Advisors, LLC Scope of Services. If local knowledge

indicates error, omissions, or inaccuracy, notify the consultant. The information contained in

this report reflects the conditions present on the date of inspection. The knowledge of the

consultant, Eco Advisors, LLC, is current information and research. The status of said

information, research, and technology could change in the future, thus affecting the services

provided.

9 Document Use

The document and all Appendices provided by the consultant, Eco Advisors, LLC, are for the

exclusive use of the Client. The use of this document or any part of this document by others or

third parties is not authorized without the prior written consent of Eco Advisors.

APPENDIX A

CERTIFICATIONS AND SIGNATURES

Certifications & Signatures

SURVEY DATA:

Site Name: S-41 Water Control Structure Building

Site Address: C. Stanley Weaver Canal East of US-1, Boynton Beach, Fl.

FLORIDA CONSULTANT DATA:

Name: Eco Advisors, LLC

Address: 3931 RCA Boulevard, Suite 3114

Palm Beach Gardens, Florida 33410

Florida Business

License No.: ZA0000444

Consultant: Karen M. Meyer, CIH

Florida Consultant

License No. AX000033

Signature/Date: March 1, 2017

Inspector(s): Donathan Buck

EPA Certification(s): 72216434

Signature(s):

ANALYTICAL DATA:

Name: CEI Labs, Inc.

Address: 730 SE Maynard Road

Cary, NC 27511

Analyst: Samantha Card

Requirements: This laboratory meets the applicable requirements of 40 CFR Part

763, Section 763.90 and utilizes EPA Method 600/R-93/116

APPENDIX B

TABLE 1

Table 1 Asbestos Inspection Results

S-41 Water Control Structure, Boynton Beach, FL C. Stanley Weaver Canal East of US-1 February 7, 2017

Sample No.

Sample Location

Material Description

Asbestos Content1

Approx. Amount2

020717DB01 Slab Concrete (slab and roof) NAD N/A

020717DB 02 Roof

020717DB 03 North Brown Mastic Generator Fan Exhaust

NAD N/A 020717DB 04 South

020717DB05 West Cementitious Casing (wells)

15% Chrysotile 3% Crocidolite

16” diameter, 3’ above grade, and approximately 12’ deep

12”diameter, 2.5’ above grade, and approximately 12’ deep 020717DB 06 East 15% Chrysotile

1 Asbestos Content: No Asbestos Detected (NAD), Assumed ACM, or % and type of asbestos (Chrysotile or Crocidolite) 2 Approx. Amount: Approximate amount of asbestos-containing material in the building – not just sample location, square feet (SF) and linear feet (LF). Not applicable (NA) if not asbestos containing.

APPENDIX C

SITE PHOTOGRAPHS

Client : CDM Smith

Location: C. Stanley Weaver Canal East of US-1

Boynton Beach, FL

Date of photo: February 7, 2016

Outside View of the Water Control Structure

View of the Stilling Wells

15% Chrysotile & 3% Crocidolite

Client : CDM Smith


Boynton Beach, FL


Larger Stilling Well

Fire Door Label

Client : CDM Smith


Boynton Beach, FL


View of the Vibration Isolator

View of the Concrete Slab

Client : CDM Smith


Boynton Beach, FL


View Looking Through the CBS with No Fill

View of the Roof

APPENDIX D

BULK SAMPLE ANALYSIS REPORT

ASBESTOS ANALYTICAL REPORTBy: Polarized Light Microscopy

Prepared for

ECO Advisors LLC

TEL: 866-481-1412www.ceilabs.com

CLIENT PROJECT:

CEI LAB CODE:

TEST METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORT DATE:

TOTAL SAMPLES ANALYZED:

# SAMPLES >1% ASBESTOS:

5-41-5FWMD

A17-1963

6

2

Asbestos Report SummaryBy: POLARIZING LIGHT MICROSCOPY

PROJECT: 5-41-5FWMD CEI LAB CODE: A17-1963

Client ID Lab ID Color Sample DescriptionASBESTOS

%Layer

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

A2321412 Gray,Blue Concrete None Detected020717DB01

A2321413 Gray Concrete None Detected020717DB02

A2321414 Brown Mastic None Detected020717DB03

A2321415 Brown Mastic None Detected020717DB04

A2321416 Gray Transite Wall ChrysotileCrocidolite

020717DB05 15%3%

A2321417 Gray Transite Wall Chrysotile020717DB06 15%

Page 1 of 1

ASBESTOS BULK ANALYSISBy: POLARIZING LIGHT MICROSCOPY

CEI Lab Code: A17-1963Date Received: 02-08-17Date Analyzed: 02-13-17Date Reported:

Client IDLab ID

LabAttributes

LabDescription

ASBESTOS%

ASBESTOS BULK PLM, EPA 600 METHODNON-ASBESTOS COMPONENTS

Non-Fibrous

Client: ECO Advisors LLC3931 RCA Blvd. Suite 3114Palm Beach Gardens, FL 33410

Project: 5-41-5FWMD

Fibrous

Gray,BlueConcrete020717DB01

A2321412Heterogeneous

Non-fibrousBound

70%25%5%

SilicatesBinderPaint

None Detected

GrayConcrete020717DB02


Non-fibrousBound

70%30%

SilicatesBinder

None Detected

BrownMastic020717DB03

A232141410%5%

Heterogeneous

FibrousBound

85%FiberglassCellulose

Mastic None Detected

BrownMastic020717DB04

A232141510%5%

Heterogeneous

FibrousBound

85%FiberglassCellulose

Mastic None Detected

GrayTransite Wall020717DB05


FibrousBound

35%47%

SilicatesBinder

15%3%

ChrysotileCrocidolite

GrayTransite Wall020717DB06


FibrousBound

35%50%

SilicatesBinder

15% Chrysotile

Page 1 of 2

LEGEND: Non-Anth = Non-Asbestiform AnthophylliteNon-Trem = Non-Asbestiform TremoliteCalc Carb = Calcium Carbonate

METHOD: EPA 600 / R93 / 116 and EPA 600 / M4-82 / 020

REPORTING LIMIT: <1% by visual estimation

REGULATORY LIMIT: >1% by weight

Due to the limitations of the EPA 600 method, nonfriable organically bound materials (NOBs) such asvinyl floor tiles can be difficult to analyze via polarized light microscopy (PLM). EPA recommends thatall NOBs analyzed by PLM, and found not to contain asbestos, be further analyzed by TransmissionElectron Microscopy (TEM). Please note that PLM analysis of dust and soil samples for asbestos is notcovered under NVLAP accreditation. Estimated measurement of uncertainty is available on request.

This report relates only to the samples tested or analyzed and may not be reproduced, except in full,without written approval by CEI Labs, Inc. CEI Labs makes no warranty representation regarding theaccuracy of client submitted information in preparing and presenting analytical results. Interpretation ofthe analytical results is the sole responsibility of the client. Samples were received in acceptablecondition unless otherwise noted. This report may not be used by the client to claim productendorsement by NVLAP or any other agency of the U.S. Government.

Page 2 of 2

ANALYST: APPROVED BY:Tianbao Bai, Ph.D., CIHLaboratory Director

Samantha Card

PRE-DEMOLITION INSPECTION FOR ASBESTOS-CONTAINING ...dnhiggins.com/docs/RFB 872 S41 Pre-Demo...

Documents

Transcript of PRE-DEMOLITION INSPECTION FOR ASBESTOS-CONTAINING ...dnhiggins.com/docs/RFB 872 S41 Pre-Demo...