Jim Moore
From:
Sent:
To:
Cc:
Subject:
Attachments:
Jason Lafayette <[email protected]>
Thursday, April 03, 2014 11:50 AM
Jim Moore
Mark Halloway; Dan Roeser
Summary of Asbestos Assessment - Turtle Creek and Packard Creek Bridges, Ottawa
County, Michigan
328415.pdf; 328415r.pdf
Dear Mr. Moore,
SME prepared this email transmittal to summarize the results of our asbestos assessment services related to two
bridges in Ottawa County, Ohio. You requested that we visit the two sites and collect representative samples of
coating materials on the structural steel beams of the bridges to determine the asbestos content of the coatings
prior to the bridge construction activities. We understand the Ottawa County Engineer’s Office is planning to
perform rehabilitation of the bridge that crosses Turtle Creek (BEN-19-4.70), and the bridge that crosses Packer
Creek (BEN-19-3.54), on North Graytown Road. We completed the assessment to assist with identification of
asbestos-containing materials (ACMs) prior to the planned renovation of the two bridges. The assessment
services provide information to assist in complying with the United States Environmental Protection Agency
(USEPA) requirements for inspection of the structures prior to renovation under the National Emissions
Standards for Hazardous Air Pollutants (NESHAP 40 CFR Part 61 Subpart M) and also provide information to
assist in complying with the Occupational Safety and Health Administration (OSHA) Asbestos Construction
Standard (29 CFR 1926.1101) regarding communication of hazards.
On March 17, 2014, Mr. John Hall (Accreditation No. ES35706), trained in accordance with USEPA
regulations and accredited by the Ohio Department of Health (ODH) as Asbestos Hazard Evaluation Specialists,
conducted the asbestos assessment field activities. Mr. Hall conducted a visual assessment to identify and
estimate quantities of suspect ACMs associated with the bridges’ building materials. Mr. Hall assigned a
unique homogeneous area (HA) number to each suspect ACM observed during the assessment. A
homogeneous area, as defined by the USEPA Asbestos Hazard Emergency Response Act (AHERA, 40 CFR
Part 763), is an area of thermal system insulation, surfacing material, or miscellaneous material that appears
uniform in color and texture. According to the USEPA and the Occupational Safety and Health Administration
(OSHA) regulations, building materials that contain greater than one percent (1%) asbestos are considered
ACMs. Mr. Hall identified one bridge undercoating material (HA1) on the BEN-19-4.70 bridge, and one bridge
undercoating material (HA2) on the BEN-19-3.54 bridge that were suspected to contain asbestos. Following
the visual assessments, Mr. Hall collected samples of suspect ACMs in accordance with the USEPA AHERA
assessment protocol (40 CFR Part 763), which is also referenced by the OSHA regulations. Mr. Hall collected
a total of eight samples during the representing the two homogeneous areas. Mr. Hall observed approximately
1
300 square feet of bridge undercoating material on the BEN-19-3.54 bridge and approximately 1,500 square
feet of bridge undercoating material on the BEN-19-4.70 bridge.
We submitted the suspect ACM bulk samples to International Asbestos Testing Laboratories (IATL), a
laboratory accredited by the National Institute of Standards and Technology (NIST) under the requirements of
the National Voluntary Laboratory Accreditation Program (NVLAP), for asbestos analysis of the bulk samples
via Polarized Light Microscopy (PLM), a USEPA approved method for visual determination of asbestos fibers
in bulk samples. Copies of the chain of custody and Certificate of Analysis are appended to this
email. Samples found to contain less than ten percent (10%) asbestos via the visual estimation method of PLM
were further verified via the "Point Count Method" as defined by the USEPA AHERA regulations (40 CFR Part
763). PLM analysis of the samples indicated that the bridge undercoating from both bridges contained greater
than one percent asbestos, and are therefore considered ACMs. During the assessment, Mr. Hall evaluated the
condition of the suspect ACMs to determine if they meet the definition of a “friable asbestos material” as
defined by the USEPA. According to the USEPA, a friable asbestos material means any material containing
more than one percent asbestos, and that when dry, can be crumbled, pulverized or reduced to powder by hand
pressure. Although likely nonfriable in their original condition, due to weathering, the asbestos-containing
bridge undercoating materials have become damaged, and are likely to become friable if subjected to renovation
forces.
The USEPA classifies the undercoating materials on both bridges as surfacing materials and, according to the
asbestos NESHAP regulation, surfacing materials must be removed prior to renovation or demolition activities
that will impact them. According to the OSHA Asbestos Construction Standard removal of surfacing materials
is considered Class I asbestos work and must be conducted within a negative pressure enclosure. We
recommend that a licensed asbestos contractor remove the asbestos-containing undercoating materials from
both bridges prior to renovation activities that might disturb the coatings within a negative pressure enclosure
and in accordance with the OSHA Class I asbestos work requirements. If greater than 160 square feet, 260
linear feet, or 35 cubic feet of regulated asbestos materials will be removed, a ten working day (14 calendar
day) notification to the Ohio Environmental Protection Agency (OEPA) is required. The OEPA notification
form can be downloaded from the OEPA website. A ten working day notification to the ODH is required when
greater than 50 linear feet or 50 square feet of friable asbestos or nonfriable asbestos expected to become friable
will be removed during a renovation or demolition. The ODH notification form also can be downloaded from
the ODH website.
In accordance with EPA regulations (40 CFR 763), we recommend abatement project design by a Project
Designer that is trained in accordance with EPA requirements (40 CFR 763) and accredited by ODH under the
requirements of Ohio Administrative Code Chapter 3701-34. We also recommend monitoring asbestos removal
work or disturbance with air sampling, visual verification, and clearance air monitoring performed by an
independent third party (such as SME).
2
All ACM waste generated during asbestos abatement activities should be placed in doubled, appropriately
labeled waste bags, affixed with a waste generator location label, and disposed in a Type II landfill licensed to
accept asbestos waste. All ACM waste generated during asbestos abatement activities that is removed from the
site should be inventoried on a Waste Shipment Record that complies with NESHAP regulations, 40 CFR Part
61.
We appreciate the opportunity to assist you on this project. If you have any questions or concerns, please
contact me.
Thank you,
Jason C. Lafayette | Senior Environmental Specialist
43980 Plymouth Oaks Blvd. | Plymouth MI 48170-2584
734.454.9900 o |734.891.6277 c |[email protected]
Consultants in the Geosciences, Materials, and the Environment
Offices in Indiana, Michigan, and Ohio
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3
International Asbestos
Testing Laboratories
IATL
9000 Commerce Parkway Suite B Mt. Laurel, NJ 08054
Telephone: 856-231-9449 Fax: 856-231-9818
CERTIFICATE OF ANALYSIS
Client:
Soil & Materials Engineers Inc.
Report Date:
3/25/2014
43980 Plymouth Oaks Road
Report No.:
328415
Project:
OttawaCounty;Turtle&PackerCreekBr
Project No.:
069381.00
Plymouth
MI
48170
BULK SAMPLE ANALYSIS SUMMARY
Lab No.:
5262835
Client No.:
HA-1A
% Asbestos
PC 3.3
Lab No.:
5262836
Client No.:
HA-1B
% Asbestos
Black Tar
Description / Location:
Undercoating; BEN-19-4.70
Type
% Non-Asbestos Fibrous Material
Type
% Non-Fibrous Material
Chrysotile
None Detected
None Detected
PC 96.7
Sample Not Analyzed
Description / Location:
Type
% Non-Asbestos Fibrous Material
Sample Not Analyzed
Lab No.:
5262837
Client No.:
HA-1C
% Asbestos
Sample Not Analyzed
% Non-Asbestos Fibrous Material
Sample Not Analyzed
Lab No.:
5262838
Client No.:
HA-1D
% Asbestos
% Non-Fibrous Material
Sample Not Analyzed
% Non-Asbestos Fibrous Material
Sample Not Analyzed
Accreditations:
Type
Sample Not Analyzed
Description / Location:
Type
% Non-Fibrous Material
Sample Not Analyzed
Description / Location:
Type
Type
Type
% Non-Fibrous Material
Sample Not Analyzed
NIST-NVLAP No. 101165-0
NY-DOH No. 11021
AIHA-LAP, LLC No. 100188
This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA or any agency of the U.S. government
This report shall not be reproduced except in full, without written approval of the laboratory.
Analytical Method:
Comments:
Analysis Performed By:
Date:
US EPA 600/R-93/116 by Polarized Light Microscopy, (ELAP 198.1 where applicable)
Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not
quantifiable under the Point Counting regimen. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not
present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations
of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron
microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.
R. Caran
Approved By:
3/25/2014
Page 1 of 2
_____________________________
Frank E. Ehrenfeld, III
Laboratory Director
International Asbestos
Testing Laboratories
IATL
9000 Commerce Parkway Suite B Mt. Laurel, NJ 08054
Telephone: 856-231-9449 Fax: 856-231-9818
CERTIFICATE OF ANALYSIS
Client:
Soil & Materials Engineers Inc.
Report Date:
3/25/2014
43980 Plymouth Oaks Road
Report No.:
328415
Project:
OttawaCounty;Turtle&PackerCreekBr
Project No.:
069381.00
Plymouth
MI
48170
BULK SAMPLE ANALYSIS SUMMARY
Lab No.:
5262839
Client No.:
HA-1E
% Asbestos
Sample Not Analyzed
Description / Location:
Type
% Non-Asbestos Fibrous Material
Sample Not Analyzed
Lab No.:
5262840
Client No.:
HA-2A
% Asbestos
PC 3.6
Lab No.:
5262841
Client No.:
HA-2B
% Asbestos
Black Tar
Undercoating; BEN-19-3.54
Type
% Non-Asbestos Fibrous Material
Type
% Non-Fibrous Material
Chrysotile
None Detected
None Detected
PC 96.4
Sample Not Analyzed
Description / Location:
% Non-Asbestos Fibrous Material
Sample Not Analyzed
5262842
Client No.:
HA-2C
% Asbestos
Type
% Non-Fibrous Material
Sample Not Analyzed
Sample Not Analyzed
Description / Location:
Type
% Non-Asbestos Fibrous Material
Sample Not Analyzed
Accreditations:
% Non-Fibrous Material
Sample Not Analyzed
Description / Location:
Type
Lab No.:
Type
Type
% Non-Fibrous Material
Sample Not Analyzed
NIST-NVLAP No. 101165-0
NY-DOH No. 11021
AIHA-LAP, LLC No. 100188
This confidential report relates only to those item(s) tested and does not represent an endorsement by NIST-NVLAP, AIHA or any agency of the U.S. government
This report shall not be reproduced except in full, without written approval of the laboratory.
Analytical Method:
Comments:
Analysis Performed By:
Date:
US EPA 600/R-93/116 by Polarized Light Microscopy, (ELAP 198.1 where applicable)
Quantification at <0.25% by volume is possible with this method. (PC) Indicates Stratified Point Count Method performed. (PC-Trace) means that asbestos was detected but is not
quantifiable under the Point Counting regimen. Analysis includes all distinct separable layers in accordance with EPA 600 Method. If not reported or otherwise noted, layer is either not
present or the client has specifically requested that it not be analyzed (ex. analyze until positive instructions). Small asbestos fibers may be missed by PLM due to resolution limitations
of the optical microscope. Therefore, PLM is not consistently reliable in detecting asbestos in non-friable organically bound (NOB) materials. Quantitative transmission electron
microscopy (TEM) is currently the only method that can pronounce materials as non-asbestos containing.
R. Caran
3/25/2014
Page 2 of 2