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
Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017 |
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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
Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017 |
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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;
Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017 |
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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.
Pre-Demolition Asbestos Inspection | S-41 Water Control Structure, Boynton Beach, FL | March 2017 |
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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
Location: C. Stanley Weaver Canal East of US-1
Boynton Beach, FL
Date of photo: February 7, 2016
Larger Stilling Well
Fire Door Label
Client : CDM Smith
Location: C. Stanley Weaver Canal East of US-1
Boynton Beach, FL
Date of photo: February 7, 2016
View of the Vibration Isolator
View of the Concrete Slab
Client : CDM Smith
Location: C. Stanley Weaver Canal East of US-1
Boynton Beach, FL
Date of photo: February 7, 2016
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
A2321413Heterogeneous
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
A2321416Heterogeneous
FibrousBound
35%47%
SilicatesBinder
15%3%
ChrysotileCrocidolite
GrayTransite Wall020717DB06
A2321417Heterogeneous
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