1120001832 25 Colonial Rd., ACM PCB Svy 7/13/20-compressedPre-Demolition Asbestos and PCB Survey Services
Admin Building
25 Colonial Road
Salem, Massachusetts
EBI Project No. 1120001832
July 13, 2020
Prepared for:
R.J. Kelly Co., Inc.
55 Cambridge Street
Burlington, MA 01803
Prepared by:
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................... 1
2.0 BACKGROUND ............................................................................................................................ 1
3.0 ASBESTOS CONTAINING BUILDING MATERIALS (ACBM) SURVEY ...................... 1
3.1 METHODOLOGIES ........................................................................................................................ 1
3.2 SCOPE OF WORK ......................................................................................................................... 5
3.3 ASBESTOS-CONTAINING BUILDING MATERIAL FINDINGS .................................................... 5
4.0 POLYCHLORINATED BIPHENYL (PCB) SCREENING .................................................. 12
4.1 METHODOLOGIES ...................................................................................................................... 12
5.0 RECOMMENDATIONS ............................................................................................................. 13
5.1 ASBESTOS CONTAINING BUILDING MATERIALS ................................................................... 13
5.2 POLYCHLORINATED BIPHENYLS .............................................................................................. 13
6.0 GENERAL LIMITATIONS ........................................................................................................ 14
APPENDIX A – PHOTOGRAPHS
APPENDIX B – ASBESTOS SAMPLING TABLE
APPENDIX C – ASBESTOS LABORATORY RESULTS AND CHAIN OF CUSTODY
APPENDIX D – PCB (“EOX”) LABORATORY RESULTS AND CHAIN OF CUSTODY
APPENDIX E – CERTIFICATIONS
APPENDIX F – GLOSSARY
APPENDIX G – LIMITED PRE-DEMOLITION HAZARDOUS MATERIALS SURVEY, MAY 7, 2020
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 1
1.0 INTRODUCTION
Envirobusiness, Inc. (dba EBI Consulting hereinafter “EBI”) of Burlington, Massachusetts was retained by
R.J. Kelly Co., Inc. to perform a pre-demolition asbestos and Polychlorinated Biphenyls (PCB) survey for
the Admin Building located at 25 Colonial Road in Salem, Massachusetts (Subject Property). This Report
has been completed in general conformance with EBI’s proposal entitled Pre-Demolition Asbestos and
PCB Survey Services and dated June 24, 2020 between R.J. Kelly Co., Inc. and EnviroBusiness, Inc.
EBI’s scope of work did not include extensive exploratory demolition of building/structural components
or physical or invasive testing, or dismantling of operating equipment or appliances to access potential
hidden ACBM and PCBs.
Field reconnaissance was conducted by Commonwealth of Massachusetts-certified Asbestos Inspector
Mr. Donn LaFlamme (AI #041142) on June 30, 2020.
2.0 BACKGROUND
EBI understands that the Subject Property is currently improved with a vacant former brick
Administration building, with a gross area of approximately 3,500± square feet, total. The date of
construction is unknown.
EBI previously conducted a Limited Pre-Demolition Hazardous Materials Survey of the Subject Property
(EBI Project No. 1120001832, “Limited Pre-Demolition Hazardous Materials Survey Report, May 7,
2020”). The findings of this report supplement the previous survey report findings.
3.0 ASBESTOS CONTAINING BUILDING MATERIALS (ACBM) SURVEY
3.1 METHODOLOGIES
Inspection, Identification of Homogeneous Areas and Sampling
An inspector (accredited and certified/licensed in accordance with all applicable Federal, State and local
requirements) performed the survey and sampling. Survey to identify ACBM began with locating and
listing the “homogeneous areas” of materials that were suspected to contain asbestos. A
“homogeneous area” is a material application that is uniform in color and texture. Typically, date and/or
occasion of material application are also considered in determining homogeneous areas. Materials of
similar color and texture, but installed in different buildings or during different construction events, are
typically considered different homogeneous areas. Homogenous areas of building materials exist in the
form of surfacing materials, thermal systems insulation (TSI), and miscellaneous materials.
SURFACING MATERIALS – Surfacing materials include sprayed or troweled-on applications of
materials such as fireproofing, acoustical or decorative ceiling materials, or plaster.
THERMAL SYSTEM INSULATION (TSI) – TSI materials include materials applied to pipes, fittings,
boilers, ducts, or other interior structural components to prevent heat loss or gain, water
condensation, or other such purposes.
MISCELLANEOUS MATERIALS – Miscellaneous materials include any building material on structural
components or fixtures such as floor and ceiling tiles, which do not include surfacing material or TSI.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 2
Suspect ACBMs were sampled to obtain a representative analysis of the material type throughout each
homogeneous area. Bulk samples, representing individual homogenous areas of suspect ACBM, were
collected in a randomly distributed manner. Samples were collected with a retractable knife that was
driven through the suspect material to the substrate to obtain a sample containing each discrete layer.
The samples were then placed in sterilized tight-sealing plastic bags and assigned unique identifiers,
which were recorded on the bags and the bulk sampling survey sheets.
Locations to collect bulk samples were determined based on the locations of observed suspect ACBMs
identified during the assessment phase of the survey, and samples were randomly distributed throughout
the area of ACBM application. The number of samples collected was based on the material classification
and quantity of each homogeneous area observed during the survey. The following illustrates the
sampling strategy employed by EBI:
• Surfacing materials:
A minimum of three (3) bulk samples are collected from each homogeneous area that was
less than or equal to 1,000 ft2.
A minimum of five (5) bulk samples are collected from each homogeneous area that was
greater than 1,000 ft2, but less than or equal to 5,000 ft2.
A minimum of seven (7) bulk samples are collected from each homogeneous area that was
greater than 5,000 ft2.
• Thermal systems insulation (TSI):
A minimum of three (3) bulk samples were collected from each homogeneous area of TSI.
A minimum of one (1) bulk sample was collected from each patch of TSI, providing the
section of patch was less than six (6) linear or square feet.
A minimum of three (3) bulk samples were collected of each insulated mechanical system
including, but not limited to: cementitious material used on pipe fittings such as tees, elbows,
or valves. A sufficient number of samples were collected to determine whether each
homogenous area was ACBM or non-ACBM.
Bulk samples were not required to be collected from materials that the accredited asbestos
inspector has determined that the TSI is a non-suspect ACBM (i.e., fiberglass, foam glass,
rubber, or any other non-ACBM).
• Miscellaneous materials:
A minimum of two (2) representative bulk samples were collected of each miscellaneous
material. A sufficient number of samples were collected to determine whether each
homogenous area was ACBM or non-ACBM.
ACBM Condition Assessment
Once the inspector identifies the suspect ACBMs in the building(s), they performed a physical
assessment of the suspect ACBMs. The physical assessment may have included the following
considerations:;
• Location and amount of the material
• Condition of the material, specifying:
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 3
Type of damage or significant damage
Severity of damage
Extent or spread of damage
• Whether the material was accessible;
• Materials potential for disturbance;
• Known or suspected causes of damage or significant damage; and,
• Preventive measures that might eliminate the reasonable likelihood of undamaged ACBM from
becoming significantly damaged.
EBI classified the ACBMs as being in Good, Fair or Poor condition. The following are the general
definitions of each category:
• Good Condition - Any material which is intact with no noticeable damage.
• Fair Condition - Any material with a small amount of damage (generally less than 10% of the
entire area, or 25% localized).
• Poor Condition - Any material with a large amount of damage (generally greater than 10% of
the entire surface area, or 25% localized).
NESHAP Categories of ACBMs
ACBM, as defined by the United States Environmental Protection Agency (EPA) and the Occupational
Safety and Health Administration (OSHA), are materials with an asbestos concentration of greater than
one percent (> 1%). The EPA further defines friable and non-friable ACM as follows:
• Friable ACBM is defined by the EPA Asbestos National Emission Standard for Hazardous Air
Pollutants (NESHAP) as any material containing more than one percent (1%) asbestos as
determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1
(i.e., the PLM method), that, when dry, can be crumbled, pulverized or reduced to powder by
hand pressure. The term includes non-friable ACM after such previously non-friable material
becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to
powder by hand pressure.
• Non-friable ACBM is any material containing more than one percent (1%) asbestos that,
when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. The EPA
further defines two categories of non-friable ACBM:
Category I non-friable ACBM is any asbestos-containing packing, gasket, resilient floor
covering or asphalt roofing product, which contains more than one percent (1%) asbestos;
and,
Category II non-friable ACBM is any material, excluding Category I non-friable ACBM,
containing more than one percent (1%) asbestos that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.
Identified friable and non-friable ACBMs are categorized into the appropriate NESHAP Classification. If
an ACBM is assessed as non-friable and does not meet the standards of one of the four (4) listed
Regulated Asbestos-Containing Material (RACM) categories, it is considered a non-RACM.
• Regulated Asbestos-Containing Material (RACM)
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 4
Friable ACM
Category I non-friable ACM that has become friable;
Category I non-friable ACM that will be or has been 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.
Analytical Procedures
Environmental Hazards Services, L.L.C. (EHS) of Richmond, Virginia is an accredited laboratory by the
EPA for "Interim Asbestos Bulk Sample Analysis Quality Assurance Program". EHS is also accredited by
the U.S. Department of Commerce, National Institute of Standards and Technology through the
National Voluntary Laboratory Accreditation Program (NVLAP) for Bulk Asbestos Analysis. The
polarized light microscopy with dispersion staining (PLM/DS) analytical method is modeled after 40 CFR
Part 763, Subpart F, Appendix A: "Interim Method for the Determination of Asbestos in Bulk Insulation
Samples". PLM/DS is an optical microscopic technique used to distinguish the different types of asbestos
fibers by their shape and unique optical properties. The technique is based on the refraction of light
from the various crystalline asbestos structures and observing the corresponding color changes through
a microscope. By using the PLM/DS method, a trained microscopist is able to identify and distinguish
between asbestos group minerals and other fibrous materials such as cellulose (paper), mineral (rock),
wood, or glass fiber. The quantity of each of these substances is estimated on a weight basis and
recorded as a percent.
Collected samples of the suspect ACBM were submitted, along with a chain of custody, to EHS and
analyzed using the approved PLM/DS method.
The EPA considers various building materials, typically non-friable materials, to be very difficult to
analyze by PLM/DS such as vinyl materials (i.e., floor tiles, sheetings), viscous matrix products (i.e.,
caulks/sealants, adhesives, coatings, joint compound/spackle), cementitious materials (i.e., pipes,
sheetings), asphaltic roofing materials (i.e., shingles, roof rollings), and miscellaneous products (i.e.,
frictions plates, gaskets). Asbestos fibers can be too small to be seen by PLM/DS methods or may be
obscured by binders or other matrix interference. The EPA recommends, but does not require, that
these materials be analyzed by TEM. Upon client request, follow-up TEM analysis can be performed for
these materials to verify the presence/absence of asbestos and/or asbestos concentration.
Interpretation of Analytical Results
To determine asbestos content, EBI’s laboratory performed the EPA-required PLM/DS visual estimation
analytical method, which does not include the Point Count Method by PLM. Utilizing this method, non-
friable materials containing >1.0% asbestos by weight were considered ACBM, and non-friable materials
containing ≤1.0% by weight were considered non-ACBM. When the asbestos content of a friable
suspect ACBM was determined to be <10% (including ≤1.0%) as determined by a method other than the
Point Count Method by PLM, the material was assumed to be ACBM. As such, friable materials with an
asbestos concentration of ≥10% were considered ACBM and <10% (including ≤1.0%) were considered
assumed ACBM.
Federal OSHA and NESHAP define an ACBM as any material containing greater than one percent
(>1.0%) asbestos. Handling, disturbance, removal and disposal of ACBM is required to be performed by
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 5
licensed contractors utilizing protective work practices as prescribed by these regulatory agencies. If a
material contains <1% asbestos, it is considered to be an asbestos containing waste material (ACWM)
by the Massachusetts Department of Environmental Protection (MassDEP), which necessitates similar
licensure and work practices as required for ACBM.
If asbestos content of a material was “<1%”, the material is still regulated by OSHA as the airborne
asbestos concentrations may exceed the OSHA Permissible Exposure Limit (PEL), depending on the
work activity. OSHA states that employers performing construction activities on materials containing
any detectable asbestos must comply with all applicable provisions of OSHA Asbestos Construction
Standard 29 CFR, Part 1926.1101. OSHA requires worker training, exposure monitoring/protection,
safe work practices and engineering controls. Therefore, materials which contain any detectable
asbestos are still regulated, and should be handled by qualified personnel.
Materials having all laboratory results of “No Asbestos Detected” or “NAD” are not subject to asbestos
regulatory requirements.
3.2 SCOPE OF WORK
An Asbestos Containing Building Material (ACBM) pre-demolition survey of the Subject Property
building was performed. The survey involved locating and assessing the condition of accessible suspect
ACBM using sampling and visual inspection techniques, to develop a report, which identifies the extent
of the materials present within the areas surveyed.
3.3 ASBESTOS-CONTAINING BUILDING MATERIAL FINDINGS
Fifty-six (56) representative samples of suspect ACBM were collected at the time of the survey and
were submitted to EHS. Fifty-two (52) total samples were analyzed were performed due to material
layers and first positive stop analysis.
The following table lists the materials that were identified as non-ACBM via sample analysis:
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
1
HA-1A 1’x1’ White Ceiling Tiles Room 10 Good NAD F NQ
HA-1B 1’x1’ White Ceiling Tiles Hall Good NAD F NQ
2 HA-2A 2’x2’ White Ceiling Tiles Room 5 Good NAD F NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 6
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
HA-2B 2’x2’ White Ceiling Tiles Room 6 Good NAD F NQ
4
HA-4A White Wall Board Room 13 Good NAD F NQ
HA-4B White Wall Board Room 4 Good NAD F NQ
5
HA-5A Wood Wall Panel Brown
Adhesive Hall Good NAD NF NQ
HA-5B Wood Wall Panel Brown
Adhesive Room 2 Good NAD NF NQ
6
HA-6A 4” Brown Vinyl Cove Base Entry Good NAD NF NQ
HA-6B 4” Brown Vinyl Cove Base Room 9 Good NAD NF NQ
7
HA-7A Brown Cove Base Glue Entry Good NAD NF NQ
HA-7B Brown Cove Base Glue Room 9 Good NAD NF NQ
8 HA-8A White Ceiling Plaster Room 12 Good NAD F NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 7
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
HA-8B White Ceiling Plaster Boiler
Room Good NAD F NQ
HA-8C White Ceiling Plaster Boiler
Room Good NAD F NQ
10
HA-
10A White 12”x12” Floor Tile Hall Good NAD NF NQ
HA-
10B White 12”x12” Floor Tile Room 10 Good NAD NF NQ
11
HA-
11A Yellow Mastic under HA 10 Hall Good NAD NF NQ
HA-
11B Yellow Mastic under HA 10 Room 10 Good NAD NF NQ
14
HA-
14A Yellow Carpet Mastic Room 13 Good NAD NF NQ
HA-
14B Yellow Carpet Mastic Room 5 Good NAD NF NQ
15
HA-
15A
Yellow Ceramic Wall Tile
Adhesive (Ceramic Tile) Bath 1 Good NAD NF NQ
HA-
15B
Yellow Ceramic Wall Tile
Adhesive (Ceramic Tile) Bath 2 Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 8
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
HA-
15A
Yellow Ceramic Wall Tile
Adhesive (Mastic ) Bath 1 Good NAD NF NQ
HA-
15B
Yellow Ceramic Wall Tile
Adhesive (Mastic) Bath2 Good NAD NF NQ
17
HA-
17A Blue Stone Pattern Vinyl Floor Entry Good NAD NF NQ
HA-
17B Blue Stone Pattern Vinyl Floor Entry Good NAD NF NQ
18
HA-
18A Black Mastic Under HA 17 Entry Good NAD NF NQ
HA-
18B Black Mastic Under HA 17 Entry Good NAD NF NQ
19
HA-
19A
White Exterior Window
Caulking New on Metal
Exterior
Front Good NAD NF NQ
HA-
19B
White Exterior Window
Caulking New on Metal
Exterior
Rear Good NAD NF NQ
20
HA-
20A
Exterior Window Caulking
Old Brown under Metal
Frame
Exterior
Front Good NAD NF NQ
HA-
20B
Exterior Window Caulking
Old Brown under Metal
Frame
Exterior
Rear Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 9
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
21
HA-
21A Exterior Grey Caulking Exterior
on Brick Good NAD NF NQ
HA-
21B Exterior Grey Caulking
Exterior
Rear on
Window
Good NAD NF NQ
23
HA-
23A Black Roof Tar
Roof
Parapet
Wall
Flashing
Good NAD NF NQ
HA-
23B Black Roof Tar
Roof
Parapet
Wall
Flashing
Good NAD NF NQ
24
HA-
24A Black Asphalt
Roof
Parapet
Wall
Flashing
Good NAD NF NQ
HA-
24B Black Asphalt
Roof
Parapet
Wall
Flashing
Good NAD NF NQ
25
HA-
25A Black Felt Roof Field Good NAD NF NQ
HA-
25B Black Felt Roof Field Good NAD NF NQ
26
HA-
26A Black Tar Roof Field Good NAD NF NQ
HA-
26B Black Tar Roof Field Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 10
Non-ACBM Sampling Summary Table
HA
No.
Sample
# Suspect Material Description Location Condition Result Friability Estimated
Quantity
27
HA-
27A Tan Window Glazing Rear Door Good NAD NF NQ
HA-
27B Tan Window Glazing Rear Door Good NAD NF NQ
HA – Homogeneous Area
NAD – No Asbestos Detected
NA/PS – Not Analyzed/Positive Stop
NQ – Not Quantified
F – Friable
NF – Non-Friable
The following table lists the materials that were identified as ACBM or ACWM via sample analysis
including material location, asbestos content, friability, general condition, and estimated quantity:
Identified ACBM Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
3
HA-3A Tan Joint Compound Room 13
(Throughout) Good 2%
Chrysotile F 8,000 SF
HA-3B Tan Joint Compound Room 4
(Throughout) Good NA/PS F Same As
Above
9
HA-9A White Pipe Insulation Room 1 Good 18%
Chrysotile F 50 LF
HA-9B White Pipe Insulation Room 1 Good NA/PS F Same As
Above
HA-9C White Pipe Insulation Room 1 Good NA/PS F Same As
Above
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 11
Identified ACBM Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
12
HA-
12A Tan 9”x9” Floor Tile Hall
(Throughout) Good 3%
Chrysotile NF 2,800 SF
HA-
12B Tan 9”x9” Floor Tile Room 10
(Throughout) Good NA/PS NF Same As
Above
13
HA-
13A Black Mastic under HA 12 Hall
(Throughout) Good 7%
Chrysotile NF 2,800 SF
HA-
13B Black Mastic under HA 12 Room 10
(Throughout) Good NA/PS NF Same As
Above
16
HA-
16A
White Ceramic Wall Tile
Grout Bath 1 Good Trace <1%
Chrysotile NF 400 SF
HA-
16B
White Ceramic Wall Tile
Grout Bath 2 Good NAD NF Same As
Above
22
HA-
22A
Exterior Tan Door Caulk on
Brick Front Door Good 3%
Chrysotile NF 40 LF
HA-
22B
Exterior Tan Door Caulk on
Brick Rear Door Good NA/PS NF Same As
Above
HA – Homogeneous Area
NAD – No Asbestos Detected
NA/PS – Not Analyzed/Positive Stop
NQ – Not Quantified
F – Friable
NF – Non-Friable
SF – Square Feet
LF – Linear Feet
* Materials containing <1% asbestos by weight are regulated by OSHA Asbestos Construction Standard 29 CFR
1926.1101, and friable materials are assumed ACBM (≥1%) unless advanced laboratory analyses are performed.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 12
Laboratory analytical results indicate that six (6) homogenous areas sampled at the Subject Property
contain >1% asbestos and are considered ACBMs or ACWMs. Representative photographs of the
sampling locations are located in Appendix A. A tabulation of all suspect ACBM sampled as part of
the inspection (Asbestos Sampling Table) are located in Appendix B. Laboratory results and Chain of
Custody are located in Appendix C.
4.0 POLYCHLORINATED BIPHENYL (PCB) SCREENING
Polychlorinated biphenyls (PCBs) are man-made chemicals that persist in the environment and were
widely used in construction materials and electrical products prior to 1978. PCBs may be present in the
caulk used in windows, door frames, louvers/vents, masonry columns and other masonry building
materials in buildings built or renovated between 1950 and 1978. Because PCBs can migrate from the
caulk into air, dust, surrounding materials and soil, EPA is concerned about potential PCB exposure to
school children and other building occupants.
4.1 METHODOLOGIES
EBI’s visual inspection for suspect PCB-containing sealant applications was limited to the building
exterior. EBI’s inspector visually assessed exterior sealant applications. Visually-distinct sealant
applications were sampled separately. Four (4) samples were collected from the building and submitted
for laboratory analysis.
EBI inspected a representative number of sealants from the Subject Property for Extractable Organic
Halogens to determine the presence of Chlorine, which may act as an indicator for determining the
likelihood of PCBs to exist within these materials. The analytical results indicated levels of Chlorine
were below the method detection limit (< 50 milligrams per kilogram (mg/Kg)) in all of the samples. The
laboratory results and Chain of Custody are located in Attachment D.
EBI renders no opinion as to the property condition with respect to any potential PCB-containing
materials, including without limitation, PCB-caulkings/glazings/sealants, as well as PCB-containing roofing
materials in areas of the building that are not assessed or accessible at the time of EBI’s inspection.
Suspect PCB building sealant materials were sampled and are included in this inspection, but other
suspect PCB-containing building materials and applications were excluded from this inspection, including
without limitation PCB-containing roofing materials.
The following table presents the results of the EOX sampling:
Polychlorinated Biphenyl (PCB) Sampling
Sample No. Suspect Material Location Condition PCB Content*
(mg/Kg)
PCB-1 Exterior White Window
Caulk Exterior Windows Intact < 50
PCB-2 Exterior Gray Caulk Building Exterior Intact < 50
PCB-3 Exterior Tan Window
Caulk (Old) Exterior Windows Not Intact < 50
PCB-4 Exterior Door Caulk Exterior Doors Intact < 50
*- mg/Kg – milligrams per kilogram
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 13
Laboratory analytical results indicate that all of the suspect materials sampled at the Subject Property
contain EOX concentrations less than the method detection limit (<50 mg/Kg).
Laboratory analytical results and Chain of Custody are located in Appendix D.
5.0 RECOMMENDATIONS
5.1 ASBESTOS CONTAINING BUILDING MATERIALS
The EPA NESHAP regulations require removal of ACBM prior to renovation or demolition including
Regulated Asbestos-Containing Material (RACM). RACM includes Friable ACBM; Category I non-friable
ACBM that has become friable; Category I non-friable ACBM that will be or has been subjected to
sanding, grinding, cutting or abrading; or Category II non-friable ACBM 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 during demolition or renovation operations. The survey results identified RACM in the
form of:
• Tan joint compound associated with wall board;
• White pipe insulation;
• Tan 9”x9” floor tile and associated black mastic (beneath 12”x12” floor tile/carpet);
• White ceramic wall tile grout (ACWM); and,
• Exterior tan door caulk on brick.
EBI recommends that any and all quantities and locations of these ACBMs that will be disturbed as part
of planned renovations or demolition, be removed in advance by a licensed asbestos abatement
contractor and appropriately disposed in accordance with local, state and federal regulations.
The OSHA Asbestos Construction Standard 29 CFR, Part 1926.1101 also requires protection of
workers from asbestos exposure associated with all work activities: not limited to renovation and
demolition work, and not limited to ACBM and assumed ACBM. OSHA requires protection
procedures associated with materials containing any detectable concentration of asbestos including <1%
or “Trace” concentrations; protective measures include worker protection, training, and medical
surveillance portions, wet methods, prompt cleanup and proper disposal, prohibited
procedures/equipment/methods, and exposure-dependent engineering controls. EBI recommends that
any disturbance of identified ACBM, as well as materials containing <1% or “Trace” concentrations of
asbestos be performed by a licensed asbestos contractor in accordance with local, state and federal
regulations.
When an asbestos removal contractor is engaged for work involving disturbance of ACBMs, assumed
ACBMs, or materials with “Trace” concentrations of asbestos, EBI recommends that a qualified
independent third-party Industrial Hygiene technician provide abatement oversight and final visual and
air clearance services on behalf of the building owner.
5.2 POLYCHLORINATED BIPHENYLS
Laboratory analytical results indicate that all of the caulk samples collected contain concentrations of
EOX below the method detection limit (<50 mg/Kg). Based on these results, no further action is
recommended with regard to PCB sealants at this time.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting Page 14
6.0 GENERAL LIMITATIONS
Report information was obtained through sources deemed reliable (i.e., interviews with owners, agents,
occupants or other appropriate persons involved with the subject property). Findings, conclusions
and/or recommendations are based on our visual observations, the information provided to or obtained
by EBI, or provided by the Client or property contact, and/or a review of readily available and supplied
documents and drawings. EBI renders no opinion as to the property condition at un-surveyed and/or
inaccessible portions of the subject property.
This Report presents the findings of a limited investigation but does not constitute a complete
determination of whether past or present owners or occupants of the Subject Property have been in
compliance with all applicable local, state, and federal environmental regulations. The information
contained herein is based on on-site observations and on a limited investigation involving site
observations. The investigative methods applied to this assessment are consistent with current industry
standards for the performance of investigation within the limits of the scope of work, budget, and
schedule. Survey evaluations are limited in the sense that conclusions and recommendations are
developed from personal interviews and information obtained from limited research, site observations
and secondary informational sources. Except as set forth in this report, EBI has made no independent
investigations as to the accuracy or completeness of the information derived from the secondary
sources and personal interviews and has assumed that such information was accurate and complete. It
should be noted that no conclusions can be drawn regarding the existence of conditions that were not
addressed by the scope of work.
This assessment and Report were prepared by EBI solely for the use of R.J. Kelly Co., Inc.. The scope of
services performed in execution of this evaluation may not be appropriate to satisfy the needs of other
users, and use or re-use of this document or the findings, conclusions, or recommendations, is at risk of
said user. Third party use of this Report is prohibited without the prior written consent of EBI and use
thereof is at the risk of the user. The observations and results presented in this Report are believed to
be representative of site conditions prevailing at the time of the assessment in the areas explored.
Changes in site conditions or in the availability of information regarding past or current site conditions
should be brought to EBI’s attention so that they can be addressed and EBI’s conclusions verified or
modified as appropriate. This report does not warrant against future operations or conditions, nor
does it warrant against operations or conditions present of a type or at a location not investigated. This
document is not designed for bidding purposes. This report is not to be provided to potential bidders
for the purpose of soliciting proposals for abatement.
It has been a pleasure to prepare this Report for you. Please contact Tim Downey at (617) 877-6524 if
you have any questions, comments, or if I can be of further assistance in any way.
Respectfully Submitted,
Timothy M. Downey
Senior Project Manager
Asbestos and Lead Programs
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX A
PHOTOGRAPHS
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
1. Building Exterior
2. Non-ACBM Black Asphalt
Roofing Materials.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
3. Non-ACBM Blue Stone
Flooring, Vestibule.
4. ACBM Carpet/Double
Layer Floor Tile and
Associated ACBM
Adhesive, Throughout.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
5. ACBM White Pipe
Insulation Above
Conference Room
Ceiling.
6. ACBM Joint Compound
and Associated Gypsum
Wallboard, Throughout.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
7. Non-ACBM White1’x1’
Spline Ceiling Tiles, Front
Office Areas, Kitchen,
Restrooms, Corridor and
Copy Room.
8. Non-ACBM White
Caulking Associated with
Newer Aluminum
Windows, Throughout.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
9. ACWM Ceramic Wall
Tile Grout and Adhesive,
Restrooms.
10. Non-ACBM Wall Base
Molding and Associated
Adhesive, and Wood
Paneling Adhesive,
Throughout.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
11. Non-ACBM 2’x2’ Ceiling
Tile, Rear Offices.
12. Non-ACBM Carpet
Adhesive, Offices.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
13. ACBM Front Exterior
Door Caulking.
14. Non-ACBM Unfinished
Ceiling Plaster, Boiler
Room.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
15. Non-ACBM Steel-Framed
Window Glazing, Boiler
Room.
16. Non-ACBM Caulking at
CMU and Brick Wall
Junction, Boiler Room.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX B
ASBESTOS SAMPLING TABLE
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
1
HA-1A 1’x1’ White Ceiling Tiles Room 10 Good NAD F NQ
HA-1B 1’x1’ White Ceiling Tiles Hall Good NAD F NQ
2
HA-2A 2’x2’ White Ceiling Tiles Room 5 Good NAD F NQ
HA-2B 2’x2’ White Ceiling Tiles Room 6 Good NAD F NQ
3
HA-3A Tan Joint Compound Room 13
(Throughout) Good 2%
Chrysotile F 8,000 SF
HA-3B Tan Joint Compound Room 4
(Throughout) Good NA/PS F Same As
Above
4
HA-4A White Wall Board Room 13 Good NAD F NQ
HA-4B White Wall Board Room 4 Good NAD F NQ
5
HA-5A Wood Wall Panel Brown
Adhesive Hall Good NAD NF NQ
HA-5B Wood Wall Panel Brown
Adhesive Room 2 Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
6
HA-6A 4” Vinyl Cove Base Brown Entry Good NAD NF NQ
HA-6B 4” Vinyl Cove Base Brown Room 9 Good NAD NF NQ
7
HA-7A Brown Cove Base Glue Entry Good NAD NF NQ
HA-7B Brown Cove Base Glue Room 9 Good NAD NF NQ
8
HA-8A White Ceiling Plaster Room 12 Good NAD F NQ
HA-8B White Ceiling Plaster Boiler Room Good NAD F NQ
HA-8C White Ceiling Plaster Boiler Room Good NAD F NQ
9
HA-9A White Pipe Insulation Room 1 Good 18%
Chrysotile F 50 LF
HA-9B White Pipe Insulation Room 1 Good NA/PS F Same As
Above
HA-9C White Pipe Insulation Room 1 Good NA/PS F Same As
Above
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
10
HA-
10A White 12”x12” Floor Tile Hall Good NAD NF NQ
HA-
10B White 12”x12” Floor Tile Room 10 Good NAD NF NQ
11
HA-
11A Yellow Mastic under HA 10 Hall Good NAD NF NQ
HA-
11B Yellow Mastic under HA 10 Room 10 Good NAD NF NQ
12
HA-
12A Tan 9”x9” Floor Tile Hall
(Throughout) Good 3%
Chrysotile NF 2,800 SF
HA-
12B Tan 9”x9” Floor Tile Room 10
(Throughout) Good NA/PS NF Same As
Above
13
HA-
13A Black Mastic under HA 12 Hall
(Throughout) Good 7%
Chrysotile NF 2,800 SF
HA-
13B Black Mastic under HA 12 Room 10
(Throughout) Good NA/PS NF Same As
Above
14
HA-
14A Yellow Carpet Mastic Room 13 Good NAD NF NQ
HA-
14B Yellow Carpet Mastic Room 5 Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
15
HA-
15A
Yellow Ceramic Wall Tile
Adhesive (Ceramic Tile) Bath 1 Good NAD NF NQ
HA-
15B
Yellow Ceramic Wall Tile
Adhesive (Ceramic Tile) Bath 2 Good NAD NF NQ
HA-
15A
Yellow Ceramic Wall Tile
Adhesive (Mastic ) Bath 1 Good NAD NF NQ
HA-
15B
Yellow Ceramic Wall Tile
Adhesive (Mastic) Bath2 Good NAD NF NQ
16
HA-
16A
White Ceramic Wall Tile
Grout Bath 1 Good Trace <1%
Chrysotile NF 400 SF
HA-
16B
White Ceramic Wall Tile
Grout Bath 2 Good NAD NF Same As
Above
17
HA-
17A
Blue Stone Pattern Vinyl
Floor Entry Good NAD NF NQ
HA-
17B
Blue Stone Pattern Vinyl
Floor Entry Good NAD NF NQ
18
HA-
18A Black Mastic Under HA 17 Entry Good NAD NF NQ
HA-
18B Black Mastic Under HA 17 Entry Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
19
HA-
19A
White Exterior Window
Caulking New on Metal
Exterior
Front Good NAD NF NQ
HA-
19B
White Exterior Window
Caulking New on Metal
Exterior
Rear Good NAD NF NQ
20
HA-
20A
Exterior Window Caulking
Old Brown under Metal
Frame
Exterior
Front Good NAD NF NQ
HA-
20B
Exterior Window Caulking
Old Brown under Metal
Frame
Exterior
Rear Good NAD NF NQ
21
HA-
21A Exterior Grey Caulking Exterior on
Brick Good NAD NF NQ
HA-
21B Exterior Grey Caulking
Exterior
Rear on
Window
Good NAD NF NQ
22
HA-
22A
Exterior Tan Door Caulk on
Brick Front Door Good 3%
Chrysotile NF 40 LF
HA-
22B
Exterior Tan Door Caulk on
Brick Rear Door Good NA/PS NF Same As
Above
23
HA-
23A Black Roof Tar Roof Parapet
Wall Flashing Good NAD NF NQ
HA-
23B Black Roof Tar Roof Parapet
Wall Flashing Good NAD NF NQ
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Asbestos Sampling Summary Table
HA
No.
Sample
#
Suspect Material
Description Location Condition Result Friability Estimated
Quantity
24
HA-
24A Black Asphalt Roof Parapet
Wall Flashing Good NAD NF NQ
HA-
24B Black Asphalt Roof Parapet
Wall Flashing Good NAD NF NQ
25
HA-
25A Black Felt Roof Field Good NAD NF NQ
HA-
25B Black Felt Roof Field Good NAD NF NQ
26
HA-
26A Black Tar Roof Field Good NAD NF NQ
HA-
26B Black Tar Roof Field Good NAD NF NQ
27
HA-
27A Tan Window Glazing Rear Door Good NAD NF NQ
HA-
27B Tan Window Glazing Rear Door Good NAD NF NQ
HA – Homogeneous Area
NAD – No Asbestos Detected
NA/PS – Not Analyzed/Positive Stop
NQ – Not Quantified
F – Friable
NF – Non-Friable
SF – Square Feet
LF – Linear Feet
* Materials containing <1% asbestos by weight are regulated by OSHA Asbestos Construction Standard 29 CFR,
Part 1926.1101, and friable materials are assumed ACBM (≥1%) unless advanced laboratory analyses are
performed.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX C
ASBESTOS LABORATORY RESULTS AND CHAIN OF CUSTODY
Asbestos Bulk
Analysis Report
Client:
Report Number:
Project/Test Address:
Client Number:
Reported Date:
Received Date:
Analyzed Date:
Enviro Business Inc.07/01/2020
22-4564
07/02/2020
20-07-00057
7469 Whitepine Rd
Telephone: 800.347.4010
Richmond, VA 23237
Environmental Hazards Services, L.L.C.
1120001832; ACM Survey; 25 Colonial Dr.; Salem, MA
Laboratory Results Fax Number:
845-498-9075
21 B Street
Burlington, MA 01803
07/01/2020
Layer Type AsbestosClient Sample
Number
Other
Materials
Lab Gross DescriptionLab Sample
Number
Gray Fibrous; White Paint;
Inhomogeneous
20-07-00057-001 HA-1A 3% Cellulose
70% Fibrous Glass
27% Non-Fibrous
NAD
Brown Fibrous; White
Paint; Inhomogeneous
20-07-00057-002 HA-1B 65% Cellulose
5% Fibrous Glass
30% Non-Fibrous
NAD
Brown Fibrous; White
Paint; Inhomogeneous
20-07-00057-003 HA-2A 65% Cellulose
5% Fibrous Glass
30% Non-Fibrous
NAD
Brown Fibrous; White
Paint; Inhomogeneous
20-07-00057-004 HA-2B 65% Cellulose
5% Fibrous Glass
30% Non-Fibrous
NAD
Tan Granular;
Homogeneous
20-07-00057-005 HA-3A 98% Non-Fibrous2% Chrysotile
2%Total Asbestos:
1 of 8Page
20-07-00057-006 HA-3B Did Not Analyze (Positive Stop)
White Powder; Brown
Fibrous; Inhomogeneous
20-07-00057-007 HA-4A 20% Cellulose
80% Non-Fibrous
NAD
White Powder; Brown
Fibrous; Inhomogeneous
20-07-00057-008 HA-4B 20% Cellulose
80% Non-Fibrous
NAD
Brown Adhesive;
Homogeneous
20-07-00057-009 HA-5A 11% Cellulose
89% Non-Fibrous
NAD
Brown Adhesive;
Homogeneous
20-07-00057-010 HA-5B 11% Cellulose
89% Non-Fibrous
NAD
Brown Vinyl;
Homogeneous
20-07-00057-011 HA-6A 100% Non-FibrousNAD
Brown Vinyl;
Homogeneous
20-07-00057-012 HA-6B 100% Non-FibrousNAD
Brown Adhesive;
Homogeneous
20-07-00057-013 HA-7A 100% Non-FibrousNAD
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
2 of 8Page
Brown Adhesive;
Homogeneous
20-07-00057-014 HA-7B 100% Non-FibrousNAD
Brown Granular;
Homogeneous
20-07-00057-015 HA-8A 100% Non-FibrousNAD
Brown Granular;
Homogeneous
20-07-00057-016 HA-8B 100% Non-FibrousNAD
Brown Granular;
Homogeneous
20-07-00057-017 HA-8C 100% Non-FibrousNAD
Tan Fibrous;
Homogeneous
20-07-00057-018 HA-9A 76% Cellulose
6% Non-Fibrous
18% Chrysotile
18%Total Asbestos:
20-07-00057-019 HA-9B Did Not Analyze (Positive Stop)
20-07-00057-020 HA-9C Did Not Analyze (Positive Stop)
Tan Vinyl; Homogeneous20-07-00057-021 HA-10A 100% Non-FibrousNAD
Tan Vinyl; Homogeneous20-07-00057-022 HA-10B 100% Non-FibrousNAD
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
3 of 8Page
Yellow Adhesive; Brown
Granular; Inhomogeneous
20-07-00057-023 HA-11A 11% Cellulose
89% Non-Fibrous
NAD
Yellow Adhesive; Brown
Granular; Inhomogeneous
20-07-00057-024 HA-11B 11% Cellulose
89% Non-Fibrous
NAD
Gray Vinyl; Homogeneous20-07-00057-025 HA-12A 97% Non-Fibrous3% Chrysotile
3%Total Asbestos:
20-07-00057-026 HA-12B Did Not Analyze (Positive Stop)
Black Tar-Like;
Homogeneous
20-07-00057-027 HA-13A 4% Cellulose
89% Non-Fibrous
7% Chrysotile
7%Total Asbestos:
20-07-00057-028 HA-13B Did Not Analyze (Positive Stop)
Yellow Adhesive;
Homogeneous
20-07-00057-029 HA-14A 2% Cellulose
98% Non-Fibrous
NAD
Yellow Adhesive;
Homogeneous
20-07-00057-030 HA-14B 2% Cellulose
98% Non-Fibrous
NAD
Green Cementitious;
Homogeneous
20-07-00057-031A HA-15A 100% Non-FibrousCeramic
Tile
NAD
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
4 of 8Page
Tan Adhesive; Brown
Fibrous; Inhomogeneous
20-07-00057-031B HA-15A 18% Cellulose
82% Non-Fibrous
Mastic NAD
Green Cementitious;
Homogeneous
20-07-00057-032A HA-15B 100% Non-FibrousCeramic
Tile
NAD
Tan Adhesive; Brown
Fibrous; Inhomogeneous
20-07-00057-032B HA-15B 20% Cellulose
80% Non-Fibrous
Mastic NAD
Tan Brittle; Homogeneous20-07-00057-033 HA-16A 100% Non-FibrousTrace <1% Chrysotile
Trace <1%Total Asbestos:
Tan Brittle; Homogeneous20-07-00057-034 HA-16B 100% Non-FibrousNAD
Blue Vinyl; Homogeneous20-07-00057-035 HA-17A 100% Non-FibrousNAD
Blue Vinyl; Homogeneous20-07-00057-036 HA-17B 100% Non-FibrousNAD
Brown Adhesive;
Homogeneous
20-07-00057-037 HA-18A 2% Cellulose
98% Non-Fibrous
NAD
Brown Adhesive;
Homogeneous
20-07-00057-038 HA-18B 2% Cellulose
98% Non-Fibrous
NAD
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
5 of 8Page
White Pliable;
Homogeneous
20-07-00057-039 HA-19A 100% Non-FibrousNAD
White Pliable;
Homogeneous
20-07-00057-040 HA-19B 100% Non-FibrousNAD
Tan Pliable;
Homogeneous
20-07-00057-041 HA-20A 1% Cellulose
99% Non-Fibrous
NAD
Tan Pliable;
Homogeneous
20-07-00057-042 HA-20B 1% Cellulose
99% Non-Fibrous
NAD
Gray Pliable;
Homogeneous
20-07-00057-043 HA-21A 100% Non-FibrousNAD
Gray Pliable;
Homogeneous
20-07-00057-044 HA-21B 100% Non-FibrousNAD
Tan Pliable;
Homogeneous
20-07-00057-045 HA-22A 97% Non-Fibrous3% Chrysotile
3%Total Asbestos:
20-07-00057-046 HA-22B Did Not Analyze (Positive Stop)
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
6 of 8Page
Black Tar-Like; Black
Granular; Inhomogeneous
20-07-00057-047 HA-23A 23% Cellulose
77% Non-Fibrous
NAD
Black Tar-Like; Black
Granular; Inhomogeneous
20-07-00057-048 HA-23B 23% Cellulose
77% Non-Fibrous
NAD
Black Tar-Like; Black
Pliable; Inhomogeneous
20-07-00057-049 HA-24A 12% Cellulose
88% Non-Fibrous
NAD
Black Tar-Like; Black
Pliable; Inhomogeneous
20-07-00057-050 HA-24B 12% Cellulose
88% Non-Fibrous
NAD
Black Fibrous;
Homogeneous
20-07-00057-051 HA-25A 95% Cellulose
5% Non-Fibrous
NAD
Black Fibrous;
Homogeneous
20-07-00057-052 HA-25B 95% Cellulose
5% Non-Fibrous
NAD
Black Tar-Like;
Homogeneous
20-07-00057-053 HA-26A 8% Cellulose
92% Non-Fibrous
NAD
Black Tar-Like;
Homogeneous
20-07-00057-054 HA-26B 8% Cellulose
92% Non-Fibrous
NAD
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
7 of 8Page
Tan Brittle; Homogeneous20-07-00057-055 HA-27A 100% Non-FibrousNAD
Tan Brittle; Homogeneous20-07-00057-056 HA-27B 100% Non-FibrousNAD
Tasha Eaddy
1% Asbestos
Analyst:
Reporting Limit:
Method:
QC Blank:
QC Sample:
Christian H. Schaible
EPA Method 600/R-93/116, EPA Method 600/M4-82-020
QA/QC Clerk
Reviewed By Authorized Signatory:
46-M12019-1
SRM 1866 Fiberglass
NAD = no asbestos detectedLEGEND:
The condition of the samples analyzed was acceptable upon receipt per laboratory protocol unless otherwise noted on this report. Each distinct
component in an inhomogeneous sample was analyzed separately and reported as a composite. Results represent the analysis of samples submitted
by the client. Sample location, description, area, volume, etc., was provided by the client. This report cannot be used by the client to claim product
endorsement by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without the written consent of the
Environmental Hazards Service, L.L.C. California Certification #2319 NY ELAP #11714 NVLAP #101882-0 VELAP 460172. All information concerning
sampling location, date, and time can be found on Chain-of-Custody. Environmental Hazards Services, L.L.C. does not perform any sample collection.
Environmental Hazards Services, L.L.C. recommends reanalysis by point count (for more accurate quantification) or Transmission Electron Microscopy
(TEM), (for enhanced detection capabilities) for materials regulated by EPA NESHAP (National Emission Standards for Hazardous Air Pollutants) and
found to contain less than ten percent (<10%) asbestos by polarized light microscopy (PLM). Both services are available for an additional fee.
400 Point Count Analysis, where noted, performed per EPA Method 600/R-93/116 with a Reporting Limit of 0.25%.
* All California samples analyzed by Polarized Light Microscopy, EPA Method 600/M4-82-020, Dec. 1982.
Environmental Hazards Services, L.L.C
Project/Test Address:
Client Number:Report Number:22-4564 20-07-00057
1120001832; ACM Survey; 25 Colonial
Dr.; Salem, MA
Other
Materials
AsbestosLab Sample
Number
Layer Type Lab Gross DescriptionClient Sample
Number
8 of 8Page
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX D
PCB (“EOX”) LABORATORY RESULTS AND CHAIN OF CUSTODY
Mass Certification - MA-00071
Conn Certification - PH-0520
Sterling Analytical, Inc.
15 Agawam Avenue
West Springfield, MA 01089
Phone (413) 214-6541 Fax (413) 214-6842
email-madhu@sterlinganalytical.com
July 2, 2020
T. Downey
Analysis of Caulk Samples
Enclosed are Report No(s): 70987 to 70990
Samples Analyzed
Customer
Sample Description
Laboratory Supervisor
Madhu Shah customerservice@sterlinganalytical.com
eMail
Report Date
Thank you for your business
Madhu Shah, Laboratory Supervisor Date
EBI Consulting
Contact
ALL the information contained in this report has been reviewed for accuracy and checked against all quality control requirements
outlined in each applicable method.
This report may not be reproduced, except in full, without written approval from Sterling Analytical, Inc.
Visit our website: www.sterlinganalytical.com
7/2/2020
20-0623Work OrderSample AnalysisVisit our website: www.sterlinganalytical.com
50.0Extractable Organic Halides Less Than mg/kg SW846 902350.00 07/02/20 sjr
Parameter Results MethodRDL Analyzed/Time
70987 6/30/20Exterior Window Caulk White PCB1 EBI Consulting 7/1/20
Source Taken/Time ReceivedSampleDescription
Tech
50.0Extractable Organic Halides Less Than mg/kg SW846 902350.00 07/02/20 sjr
Parameter Results MethodRDL Analyzed/Time
70988 6/30/20Exterior Caulk Gray PCB2 EBI Consulting 7/1/20
Source Taken/Time ReceivedSampleDescription
Tech
50.0Extractable Organic Halides Less Than mg/kg SW846 902350.00 07/02/20 sjr
Parameter Results MethodRDL Analyzed/Time
70989 6/30/20Exterior Window Caulk Tan Old PCB3 EBI Consulting 7/1/20
Source Taken/Time ReceivedSampleDescription
Tech
50.0Extractable Organic Halides Less Than mg/kg SW846 902350.00 07/02/20 sjr
Parameter Results MethodRDL Analyzed/Time
70990 6/30/20Exterior Caulk Door PCB4 EBI Consulting 7/1/20
Source Taken/Time ReceivedSampleDescription
Tech
2Page of 2Sterling Analytical, Inc.(1) MA & CT do not certify this parameter
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX E
CERTIFICATIONS
Course presented by the Training and Education Division of
TRC Environmental
814 Broad Street, Weymouth, MA 02189
781-337-0016 Email: mmccaffrey@trcsolutions.com
Certificate of Completion
Donn LaFlamme
has attended and successfully completed the course and examination requirements of:
Asbestos Inspector Refresher (4 hours)
In Compliance with MA 453CMR 6.10 and USEPA AHERA 40 CFR 763 which meets the
requirements of TSCA Title II MAP.
Exam Date:__3/12/20 Exam Grade: _88_____
Start of Course: _3/12/20______ Conclusion of Course: _3/12/20_________
Course Instructor: Michael McCaffrey
Expiration Date:__ 3/12/21____ Certificate Number: MA031220-0006
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX F
GLOSSARY
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
GLOSSARY
Air Cell: Insulation normally used on pipes and ductwork that is comprised of corrugated cardboard
which is frequently comprised of asbestos combined with cellulose or refractory binders.
Air Monitoring: The process of measuring the fiber content of a specific volume of air.
Amosite - An asbestiform mineral of the amphibole group. It is the second most commonly used form of
asbestos in the U.S. (brown asbestos).
Amphibole - One of the two major groups of minerals from which the asbestiform minerals are derived;
distinguished by their chain-like crystal structure and chemical composition. Amosite and crocidoIite are
examples of amphibole minerals.
Anthophyllite - One of six naturally-occurring asbestos minerals. It is of limited commercial value.
Asbestos: The asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), cummingtonite-
grunerite, amosite, anthophylite, and actinolite-tremolite. For purposes of determining respiratory and
worker protection both the asbestiform and non-asbestiform varieties of the above minerals and any of
these materials that have been chemically treated and/or altered shall be considered as asbestos.
Asbestos-Containing Material (ACM): Any material containing more than 1% of asbestos of any type or
mixture of types.
Asbestos-Containing Building Material (ACBM): 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 definition).
Assumed Asbestos-Containing Material: Any suspect ACM that has not been appropriately tested to
confirm whether or not it contains asbestos.
Bulk Samples - Samples of bulk material, in the case of asbestos, suspect material
Certified Industrial Hygienist (C.I.H.): An industrial hygienist certified in Comprehensive Practice by the
American Board of Industrial Hygiene.
Class I Work (OSHA): Work activities, performed by an outside licensed abatement contractor, that
involve the removal of boiler, pipe and duct insulation, and surfacing material such as spray-applied
fireproofing.
Class II Work (OSHA): Work activities, performed by an outside licensed abatement contractor, that
involve the removal of asbestos-containing materials other than boiler, pipe and duct insulation, and
surfacing material such as spray-applied fireproofing.
Class III Work (OSHA): Work activities that involve the repair of minor amounts of damaged asbestos-
containing materials.
Class IV Work (OSHA): Work activities that involve the maintenance and custodial activities during
which tenants and employees contact but do not disturb asbestos-containing materials or presumed
ACM. Class IV work may involve the clean-up of dusts, wastes and debris in areas where asbestos is,
was or may be located.
Crocidolite - Strongest of asbestos minerals. An asbestiform mineral of the amphibole group. It is of
minor commercial value In the U.S. (blue asbestos).
Chrysotile - The only asbestiform mineral of the serpentine group, it is the most common form of
asbestos used in buildings (white asbestos).
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Damaged Friable Surfacing Miscellaneous) Material - Friable surfacing (miscellaneous) ACM which has
deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is
inadequate or, if applicable, which has delaminated such that the bond to the substrate (adhesion) is
inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or
deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the
substrate; flaking, blistering, or crumbling of ACM surface; water damage; significant or repeated water
stains, scrapes, gauges, mars or other signs of physical injury on the ACM. Asbestos debris originating
from the ACBM in question may also indicate damage (AHERA definition)
Damaged or Significantly Damaged Thermal System Insulation - Thermal system insulation on pipes,
boilers, tanks, ducts, and other thermal system insulation equipment which the insulation has lost its
structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured,
missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by
occasional punctures, gouges, or other signs of physical injury to ACM; occasional water damage on the
protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris, originating from the
ACBM in question may also indicate damage (AHERA definition).
Demolition: The wrecking or taking out of any building component, system, finish or assembly of a
facility together with any related handling operations.
Encapsulant: A material that surrounds or embeds asbestos fibers in an adhesive matrix, to prevent
release of fibers.
Bridging encapsulant: an encapsulant that forms a discrete layer on the surface of an in situ asbestos
matrix.
Penetrating encapsulant: an encapsulant that is absorbed by the in situ asbestos matrix without
leaving a discrete surface layer.
Removal encapsulant: a penetrating encapsulant specifically designed for removal of asbestos-
containing materials rather that for in situ encapsulation.
Encapsulation - The use of an agent to seal the surface (budging encapsulant) or penetrate the bulk
(penetrating encapsulant) of ACM.
Enclosure: The construction of an airtight, impermeable, permanent barrier around asbestos-containing
material to control the release of asbestos fibers into the air.
Fiber Release: Any uncontrolled or unintentional disturbance of ACBM resulting in visible emission.
Fitting: Within any piping system, any valve, tee, elbow, 45o, flange, union, reducer, or other piping
connector which may be insulated with asbestos.
Friable Asbestos Material: Material that contains more than 1.0% asbestos by weight, and that can be
crumbled, pulverized, or reduced to powder by hand pressure when dry.
HEPA Filter: A High Efficiency Particulate Air (HEPA) filter capable of trapping and retaining 99.97% of
asbestos fibers greater than 0.3 microns in length.
HEPA Filter Vacuum Collection Equipment (or vacuum cleaner): High efficiency particulate air filtered
vacuum collection equipment with a filter system capable of collecting and retaining asbestos fibers.
Filters should be 99.97% efficient for retaining fibers of 0.3 microns or larger.
High-Efficiency Particulate Air Filter (HEPA): A filter which removes from air 99.97% or more of
monodisperse dioctyl phthalate (DOP) particles having a mean particle diameter of 0.3 micrometer.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
Miscellaneous Material - 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 definition).
NESHAP: National Emission Standard for Hazardous Air Pollutants, 40 CFR Part 61 Subpart M.
Operations and Maintenance (O & M) Plan - A plan for an O & M program, which is designed to clean
up asbestos contamination, minimize future fiber release, and maintain ACM in good condition.
Phase Contrast Microscopy (PCM) - A method of analyzing air samples for fibers using a light
microscope.
Physical Assessment - Assessing suspect material to determine the current condition of the material and
the potential for future disturbance.
Polarized Light Microscopy (PLM) - A method of analyzing bulk samples for asbestos in which the sample
is illuminated with polarized light (light which vibrates in only one plane) and viewed under a light
microscope.
Presumed Asbestos-Containing Material (PACM): Thermal systems insulation, surfacing material or
miscellaneous materials found in buildings constructed prior to 1980 that has not been appropriately
tested to confirm whether or not it contains asbestos.
Repair: Returning damaged ACM to an undamaged condition to prevent fiber release.
Response Actions - Actions specified in the management plan to control ACM; includes repair, O & M,
and the various methods of abatement.
Serpentine - One of the two major groups of minerals from which the asbestiform minerals are derived;
distinguished by their tubular structure and chemical composition. Chrysotile is a serpentine mineral.
Significantly Damaged Friable Surfacing (Miscellaneous) Material - Friable surfacing (miscellaneous) ACM
in a functional space where damage is extensive and severe (AHERA definition).
Surfacing Material - Material in a school building that is sprayed on, troweled on, or otherwise applied to
surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or
other materials on surfaces for acoustical, fireproofing, or other purposes (AHERA definition).
Suspect Asbestos-Containing Material (Suspect ACM): The term "suspect ACM" is used by the asbestos
industry to refer to any building material that is suspected of being asbestos-containing (based on
appearance, usage, age of building, etc.), but has not been proven conclusively to be ACM (based on
sampling and analysis). Suspect material would include any material that a building owner suspects of
containing asbestos and is found in a building of any age or construction date. Refer to section 2.1 for a
list of typical suspect ACMs.
Thermal System Insulation (TSI) - Material applied to pipes, fittings, boilers, breeching, tanks, ducts, or
other interior structural components to prevent heat loss or gain, or water condensation, or for other
purposes.
Transmission Electron Microscopy - A method of analyzing air samples for asbestos fibers using a
transmission electron microscope and, possibly, associated instruments for further identifying asbestos.
Tremolite - One of six naturally-occurring asbestos minerals. Tremolite has few commercial uses.
Pre-Demolition Asbestos and PCB Survey Services Admin Building
EBI Project No. 1120001832 25 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX G
Pre-Demolition Hazardous Materials Survey Report, May 7,
2020
Limited Pre-Demolition Hazardous Materials Survey
Report
Colonial Road
25, 30 & 40 Colonial Road
Salem, Massachusetts
EBI Project No. 1120001832
May 7, 2020
Prepared for:
R.J. Kelly Co., Inc.
55 Cambridge Street
Burlington, MA 01803
Prepared by:
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
TABLE OF CONTENTS
1.0 INTRODUCTION ......................................................................................................................... 1
2.0 BACKGROUND ............................................................................................................................ 1
3.0 ASBESTOS CONTAINING BUILDING MATERIALS (ACBM) SURVEY ...................... 1
3.1 METHODOLOGIES ........................................................................................................................ 1
3.2 SCOPE OF WORK ......................................................................................................................... 3
3.3 ASBESTOS-CONTAINING BUILDING MATERIAL VISUAL FINDINGS ...................................... 3
4.0 LEAD-CONTAINING PAINT (LCP) SURVEY ...................................................................... 7
4.1 METHODOLOGIES ........................................................................................................................ 7
4.2 SCOPE OF WORK ....................................................................................................................... 10
4.3 LEAD-CONTAINING PAINT FINDINGS ..................................................................................... 10
5.0 POLYCHLORINATED BIPHENYL (PCB) VISUAL SCREENING .................................. 11
5.1 METHODOLOGIES ...................................................................................................................... 11
5.2 SCOPE OF WORK ....................................................................................................................... 11
5.3 POLYCHLORINATED BIPHENYL FINDINGS ............................................................................. 12
6.0 UNIVERSAL WASTE INVENTORY ...................................................................................... 12
6.1 METHODOLOGIES ...................................................................................................................... 12
6.2 SCOPE OF WORK ....................................................................................................................... 13
6.3 UNIVERSAL WASTE FINDINGS ................................................................................................. 13
7.0 RECOMMENDATIONS ............................................................................................................. 14
7.1 ASBESTOS CONTAINING BUILDING MATERIALS ................................................................... 14
7.2 LEAD-CONTAINING PAINT ....................................................................................................... 15
7.3 POLYCHLORINATED BIPHENYLS .............................................................................................. 15
7.4 UNIVERSAL WASTES ................................................................................................................. 16
8.0 GENERAL LIMITATIONS ........................................................................................................ 16
APPENDIX A – PHOTOGRAPHS
APPENDIX B – XRF LEAD TESTING TABLE
APPENDIX C – CERTIFICATIONS
APPENDIX D – GLOSSARY
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 1
1.0 INTRODUCTION
Envirobusiness, Inc. (dba EBI Consulting hereinafter “EBI”) of Burlington, Massachusetts was retained by
R.J. Kelly Co., Inc. to perform a limited pre-demolition visual asbestos-containing building materials
(ACBMs), suspect lead-containing paint (LCP), visual suspect Polychlorinated Biphenyls (PCB) Caulk and
a visual survey for other regulated wastes for the Colonial Road site located at 25, 30 & 40 Colonial
Road in Salem, Massachusetts (Subject Property). This Report has been completed in general
conformance with EBI’s proposal entitled Revised Limited Pre-Demolition Hazardous Materials Survey
Services and dated 4/22/2020 between R.J. Kelly Co., Inc. and EnviroBusiness, Inc.
The inspection was limited to areas of the Subject Property building where building demolitions are
planned. Accessible areas throughout Subject Property were visually inspected. At the request of the
current building owner, no sampling was conducted as part of the ACBM or PCB (“EOX”) surveys.
Field reconnaissance was conducted by state-certified asbestos inspector Mr. Rob Thomson (AI031431)
on April 29, 2020.
As there were no address numbers on these buildings, for the purposes of labeling buildings for this
survey report, the site buildings were identified as:
• L Building – 30 Colonial Road
• Admin Building – 25 Colonial Road
• Scale Shack – border of 25 & 30 Colonial Road
• Storage Shed – border of 25 & 30 Colonial Road
2.0 BACKGROUND
EBI understands that the Subject Property is currently improved with three vacant former garage/shed
buildings, with a gross area of approximately 6,700± square feet, total. The dates of construction are
unknown.
3.0 ASBESTOS CONTAINING BUILDING MATERIALS (ACBM) SURVEY
3.1 METHODOLOGIES
Inspection, Identification of Homogeneous Areas and Sampling
An inspector (accredited and certified/licensed in accordance with all applicable Federal, State and local
requirements) performed the visual survey. Survey to identify ACBM began with locating and listing the
“homogeneous areas” of materials that were suspected to contain asbestos. A “homogeneous area” is a
material application that is uniform in color and texture. Typically, date and/or occasion of material
application are also considered in determining homogeneous areas. Materials of similar color and
texture, but installed in different buildings or during different construction events, are typically
considered different homogeneous areas. Homogenous areas of building materials exist in the form of
surfacing materials, thermal systems insulation (TSI), and miscellaneous materials.
SURFACING MATERIALS – Surfacing materials include sprayed or troweled-on applications of
materials such as fireproofing, acoustical or decorative ceiling materials, or plaster.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 2
THERMAL SYSTEM INSULATION (TSI) – TSI materials include materials applied to pipes, fittings,
boilers, ducts, or other interior structural components to prevent heat loss or gain, water
condensation, or other such purposes.
MISCELLANEOUS MATERIALS – Miscellaneous materials include any building material on structural
components or fixtures such as floor and ceiling tiles, which do not include surfacing material or TSI.
Suspect ACBMs were documented including type, general locations, condition and approximate
quantities.
ACBM Condition Assessment
Once the inspector identified the suspect ACBMs in the buildings, they performed a physical assessment
of the suspect ACBMs. The physical assessment may have included the following considerations:
• Location and amount of the material
• Condition of the material, specifying:
Type of damage or significant damage
Severity of damage
Extent or spread of damage
• Whether the material was accessible;
• Materials potential for disturbance;
• Known or suspected causes of damage or significant damage; and,
• Preventive measures that might eliminate the reasonable likelihood of undamaged ACBM from
becoming significantly damaged.
EBI classified the ACBMs as being in Good, Fair or Poor condition. The following are the general
definitions of each category:
• Good Condition - Any material which is intact with no noticeable damage.
• Fair Condition - Any material with a small amount of damage (generally less than 10% of the
entire area, or 25% localized).
• Poor Condition - Any material with a large amount of damage (generally greater than 10% of
the entire surface area, or 25% localized).
NESHAP Categories of ACBMs
ACBM, as defined by the United States Environmental Protection Agency (EPA) and the Occupational
Safety and Health Administration (OSHA), are materials with an asbestos concentration of greater than
one percent (> 1%). The EPA further defines friable and non-friable ACM as follows:
• Friable ACBM is defined by the EPA Asbestos National Emission Standard for Hazardous Air
Pollutants (NESHAP) as any material containing more than one percent (1%) asbestos as
determined using the method specified in Appendix A, Subpart F, 40 CFR Part 763, Section 1
(i.e., the PLM method), that, when dry, can be crumbled, pulverized or reduced to powder by
hand pressure. The term includes non-friable ACM after such previously non-friable material
becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to
powder by hand pressure.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 3
• Non-friable ACBM is any material containing more than one percent (1%) asbestos that,
when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure. The EPA
further defines two categories of non-friable ACBM:
Category I non-friable ACBM is any asbestos-containing packing, gasket, resilient floor
covering or asphalt roofing product, which contains more than one percent (1%) asbestos;
and,
Category II non-friable ACBM is any material, excluding Category I non-friable ACBM,
containing more than one percent (1%) asbestos that, when dry, cannot be crumbled,
pulverized, or reduced to powder by hand pressure.
Identified friable and non-friable ACBMs are categorized into the appropriate NESHAP Classification. If
an ACBM is assessed as non-friable and does not meet the standards of one of the four (4) listed
Regulated Asbestos-Containing Material (RACM) categories, it is considered a non-RACM.
• Regulated Asbestos-Containing Material (RACM)
Friable ACM
Category I non-friable ACM that has become friable;
Category I non-friable ACM that will be or has been 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.
3.2 SCOPE OF WORK
An Asbestos Containing Building Material (ACBM) visual survey of the Subject Property buildings was
performed. The survey involved locating and assessing the condition of accessible suspect/assumed
ACBM using visual inspection techniques, to develop a report, which identified the extent of the
materials present within the areas surveyed.
3.3 ASBESTOS-CONTAINING BUILDING MATERIAL VISUAL FINDINGS
EBI observed the following suspect/assumed ACBMS at the Subject Property:
Assumed ACBM Summary Table
HA
No. Suspect Material Description Location Condition Friability Estimated
Quantity
1 Rolled Asphalt Roofing L Building Exterior Shed
Section Good NF 65 SF
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 4
Assumed ACBM Summary Table
HA
No. Suspect Material Description Location Condition Friability Estimated
Quantity
2 Flashing Cement L Building Exterior Shed Good NF 8 LF
3 White Sheet Flooring Interior of Scale Shack Good NF 40 SF
4 Mastic Associated with Sheet
Flooring Interior of Scale Shack Good NF 40 SF
5 Exterior Caulking at Base of Wall
Panel
Exterior Scale Shack
Walls Good NF 25 LF
6 Adhesive Associated with
Fiberglass Roofing Panels Scale Shack Roof Good NF 50 SF
7 Metal Door Insulation Scale Shack Entry Door Poor NF 1 Door
8 Asphalt Roofing Admin Building Roof Poor NF 3,000 SF
9 Blue Stone Floor Grout and
Bedding Mortar Admin Building Vestibule Good NF 95 SF
10 Double Layer Floor Tile
Throughout Admin
Building and Assumed
Beneath Office Carpet
Poor NF 2,800 SF
11 Mastic Associated with Floor Tile
Throughout Admin
Building and Assumed
Beneath Office Carpet
Poor NF 2,800 SF
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 5
Assumed ACBM Summary Table
HA
No. Suspect Material Description Location Condition Friability Estimated
Quantity
12 Corrugated Paper Pipe Insulation
Admin Building Above
Ceiling in Conference
Room
Good F 50 LF
13 Gypsum Wallboard Admin Building
Throughout Poor F 8,000 SF
14 Joint Compound Admin Building
Throughout Poor F 8,000 SF
15 1’x1’ Spline Ceiling
Admin Building Front
Office Areas, Kitchen,
Restrooms, Corridor and
Copy Room
Poor F 1,500 SF
16 Textured Ceiling on Gypsum
Board
Admin Building Small
Utility Room Poor F 70 SF
17 Ceramic Wall Tile Grout Admin Building
Restrooms Good
NF
400 SF
18 Ceramic Wall Tile Adhesive Admin Building
Restrooms Poor
NF
400 SF
19 Wall Base Molding Admin Building
Throughout Poor
NF
400 LF
20 Wall Base Adhesive Admin Building
Throughout Poor
NF
400 LF
21 White 2’x2’ Suspended Ceiling Tile Admin Building Rear
Offices Poor F 1,300 SF
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 6
Assumed ACBM Summary Table
HA
No. Suspect Material Description Location Condition Friability Estimated
Quantity
21 Carpet Adhesive Admin Building Offices Poor NF 1,700 SF
22 Wood Wall Paneling Adhesive Admin Building Offices Poor NF 4,000 SF
23 Gray Caulking Admin Building Front and
Rear Doors Poor NF 30 LF
24 Unfinished Plaster Ceiling Admin Building Boiler
Room Poor F 120 SF
25 Glazing Compound
Admin Building Boiler
Room Steel Framed
Window
Poor NF 1
Window
26 Gray Caulking
Admin Building at CMU
and Brick Wall Junction
at Boiler Room
Good NF 10 LF
27 Black Patching Material Exterior Admin Building
Rear Brick Wall Good NF 1 SF
28 White Caulking
Admin Building
Associated with Newer
Aluminum Windows
Good NF 17
Windows
29 Rolled Asphalt Roofing Storage Building Roof N/A NF 250 SF
HA – Homogeneous Area
NA – Not Accessible
F – Friable
NF – Non-Friable
SF – Square feet
LF – Linear feet
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 7
Photographs of the assumed ACBM locations are located in Appendix A.
4.0 LEAD-CONTAINING PAINT (LCP) SURVEY
4.1 METHODOLOGIES
Inspection and Identification of Homogeneous Areas
Lead-based paint (LBP) is defined by the EPA as paint or other surface coatings that contain lead
concentrations equal to or exceeding 1.0 milligram per square centimeter(mg/cm2), 0.5% by total weight
or 5,000 parts per million (ppm) by weight. Use of LBP was banned for consumer applications and
products in 1978. After the 1978 ban, LBP was still available for select commercial and industrial
applications, and paints and coating with lesser concentrations of lead are still available. Paints and
coatings containing any detectable concentration of lead, including concentrations less-than or equal-to
1.0 mg/cm2, 0.5% by total weight or 5,000 ppm are referred to as Lead-Containing Paint (LCP).
An LCP inspection is a surface-by-surface investigation to determine the presence of LCP applications
and other surface applications and materials that contain lead. Lead may be present in paint applications,
as well as surface coatings, ceramic and other materials glazing applications, and other building materials.
Identification of surfaces and materials that require sampling as part of the inspection is not limited to
paint applications. Painted applications (and other surfaces) that appear similar in color, texture and
substrate are considered to be a homogeneous material for the purpose of sample collection.
Paint applications and other surface coatings and materials were visually assessed for evidence of
distress, flaking, and/or peeling as well as substrate deterioration. Where no evidence of observed
distress, flaking and/or peeling paint, or substrate deterioration, the condition was assessed to be
“intact”. Where evidence was observed of distress, flaking and/or peeling paint, or substrate
deterioration, the condition was assessed to be “non-intact”.
Testing and Analysis
XRF Testing
Based on results of the visual observation, homogeneous paint applications, surface coatings and
materials are sample utilizing methods included in EPA 40 CFR, Part 745. Testing was conducted using
an X-Ray Fluorescence (XRF) Analyzer Lead Detector to determine lead content in a non-destructive
fashion. XRF quantitatively measures the concentration of the lead elements in solid materials by
exciting the atoms with X-rays and reading the characteristics of the return X-ray emittance.
Calibration checks were performed prior to the start of testing in the morning, at mid-day, and again
following the completion of testing for the day. Calibration checks were performed by using a painted
block or film of known lead content, as close to 1.0 mg/cm2 as possible. Data was recorded at each
sample location (such as sample number, paint/material description/condition, location and date) and
was recorded either on a field form, within the instrument, or as a combination of the two recording
methods. Federal and State regulations define LBP as paints and other coatings that contain lead at or
above 1.0 (mg/cm2). Since LCP includes any identified concentration of lead, LCP includes paints and
surface coatings with “negative” XRF measurements i.e., those below the HUD/EPA definition of what
constitutes LBP (1.0 mg/cm2), but with results that are greater than 0.0 mg/cm2 or greater than the
lower limit of detection for the XRF instrument.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 8
Interpretation of Analytical Results and Regulatory Requirements
Interpretation of Analytical Results
Results of XRF testing are typically reported as “negative” if they are below the HUD/EPA definition of
what constitutes Lead-Based Paint (LBP) (1.0 mg/cm2) However, an XRF measurement of any
concentration above 0.0 mg/cm2 represents an identified concentration of lead in the tested surface, and
the tested surface was considered LCP. Therefore, “negative” XRF measurements (unless the reported
result is 0.0 mg/cm2) do not relieve the owner/operator from regulatory requirements, worker
protection, work site preparation, and waste disposal requirements pertaining to LCP as discussed
below.
Regulatory Requirements
(OSHA provides the governing regulations (Safety and Health Regulations for Lead in Construction
Standard, 29 CFR, Part 1926.62) for occupational exposure to lead including exposure received during
construction, maintenance activities, painting, alteration and repairs. OSHA regulates activities that
disturb LCP regardless of the detected lead concentration; an allowable concentration of lead-in-paint is
not defined. Rather, OSHA sets limits on the concentration of lead-in-air that a worker can breathe
during a normal workday. OSHA does not consider any method that relies solely on the analysis of bulk
materials (i.e., paint chips) or surface content of lead to be acceptable for safely predicting employee
exposure to airborne lead. Without air monitoring results or without the benefit of historical or
objective data (including air sampling that clearly demonstrates employee cannot be exposed above the
action level during any process, operation, or activity), bulk or surface sample analysis cannot be used to
determine employee exposure. When disturbed, detectable lead content in paint may be released into
the air in the form of dust or fumes. To minimize exposure, workers that perform activities that may
disturb painted surfaces (containing any detectable concentration of lead) shall conduct all work in
compliance with all OSHA 29 CFR, Part 1926.62; contractors and employers are required to assure
compliance.
Worker Protection
A direct correlation cannot be drawn between the concentration of lead in a material and the expected
worker exposure upon material disturbance. A wide variety of means and methods may be used for
material disturbance, which may result in an equal range of worker exposure. The concentration of lead
in the material, the condition of the material, the extent of non-intact paint, and the work means and
methods used to disturb the material will affect the worker’s lead exposure.
Per OSHA, until an employer performs an exposure assessment and documents that employees are not
exposed above the Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter (µg/m3)
averaged over an eight-hour period, the employer must treat employees as if they were exposed above
the PEL for the following operations:
• Manual demolition of structures, manual scraping, manual sanding, and use of heat gun where
lead-containing coatings or paints are present;
• Abrasive blasting;
• Power tool cleaning;
• Lead burning;
• Using lead-containing mortar or spray-painting with lead-containing paint;
• Abrasive blasting, rivet busting, or welding, cutting, or burning on any structure where lead-
containing coatings or paint are present;
• Cleanup activities where dry expendable abrasives are used; and
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 9
• Any other task the employer believes may cause exposure in excess of the PEL.
Until an exposure assessment is performed that demonstrates exposure below the PEL, worker
protective procedures shall be employed such as providing respiratory protection, protective work
clothing and equipment, change areas, hand washing facilities, biological monitoring, and training. OSHA
requirements include work practice and administrative controls. A written compliance program and
record-keeping are also required. Special work practices are to be used to reduce worker exposure to
lead, and respirators may be used to supplement other controls.
Employers must also provide medical monitoring and training to employees exposed to lead above the
Action Level (AL) of 30 µg/m3. Air monitoring to assess lead exposures should be performed for all
personnel with potential exposure equal to or greater than the AL (or PEL). A Negative Exposure
Assessment (NEA) is required per work task to determine that these exposure thresholds are not
reached.
Work Site Protection
Prior to the start of work that may cause lead exposure or lead hazard, the owner/operator is
responsible for notifying all direct employees as well as contractors or general contractors of the
presence of lead in the building. General Contractors are responsible for informing all subcontractors
under their direction.
Frequent and regular jobsite inspections are required and must be performed by persons who are
capable of identifying lead hazards and have authorization to take prompt corrective measures.
Engineering controls (such as HEPA-filtered vacuum-equipped tools, wet methods, localized exhaust)
shall be used to reduce worker exposure to lead.
Waste Disposal
Disposal of wastes containing LCP are governed by the regulatory requirements of the EPA Resource
Conservation and Recovery Act (RCRA). Characterization of waste is required to determine whether
waste must be disposed of as hazardous waste. Lead containing wastes are considered hazardous waste
if Toxic Characteristic Leaching Procedures (TCLP) analytical results are equal to or exceed five
milligrams per liter (≥5.0 mg/L). Without the benefit of historical or objective data that demonstrates
that the waste cannot equal or exceed five 5.0 mg/L, TCLP testing is required to characterize the waste.
The TCLP analytical method mimics conditions that wastes area exposed to in a landfill and measures
the lead content of the leachate. TCLP testing is to be performed on the actual wastes generated at the
work site using a small representative sample of the entire waste pile. EPA exempts from most RCRA
requirements those generators whose combined hazardous waste generation is less than 100 kilograms
(kg) per month. Metal that contains LCP is also exempt from RCRA requirements provided it is
appropriately recycled.
If determined to be lead hazardous waste, testing, notification, transportation, treatment, storage and
disposal must be performed in accordance with RCRA requirements. Contractors must maintain
current licenses as required by applicable state or local jurisdictions for handling and disposal of lead
hazardous waste.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 10
4.2 SCOPE OF WORK
EBI conducted a limited LCP paint survey to determine the lead content of representative surfaces and
materials. The survey was designed to facilitate compliance with OSHA Lead-in-Construction regulatory
requirements pertaining to worker protection and RCRA regulatory requirements pertaining to waste
disposal. The survey was not designed to meet HUD requirements or other federal, state or local
regulatory requirements pertaining to Lead-Based Paint in residential housing or child-occupied facilities,
or other state, county or local Health Department or Housing Authority regulatory requirements.
The scope of services presented herein include steps necessary to characterize representative painted
surfaces and components for lead content. Inspection activities were limited to accessible areas of the
buildings with no destructive investigation of hidden spaces (inside wall cavities, hard deck ceilings, etc.),
at this time. Accessible components were visually inspected for the presence of paint. There was no
demolition of components to access hidden painted materials. EBI makes no guarantee as to the
possible existence or absence of lead in inaccessible locations. The objective of the survey was to
provide documentation to the Client consisting of a listing of the findings of lead bearing components
that are anticipated to be disturbed by planned building demolition activities.
Sample locations for this survey were selected with an emphasis on random distribution throughout the
survey area, while attempting to obtain samples of representative homogeneous types of suspect LCP
applications or surfaces or lead materials that are anticipated to be disturbed by planned building
demolition activities.
The LCP survey was conducted via X-ray fluorescence (XRF) methods. Individuals who conducted the
survey have been trained in the use, calibration and maintenance of the XRF, along with the principles of
radiation safety. Select painted and/or finished components were tested according to the specifications
described in the protocols for Lead-Based Paint testing in the HUD Guidelines Chapter 7 (revised 1997)
for use of XRF instrumentation.
4.3 LEAD-CONTAINING PAINT FINDINGS
XRF analyzer tests were performed on representative painted surfaces throughout the Subject Property.
XRF analyzer results identified the following painted surfaces exhibiting a detectable lead concentration:
Location/Component Substrate Result
(mg/cm2)
Paint
Condition
Admin Building Exterior Rear/Door Frame
White Wood 0.7 L
Admin Building Exterior Rear/Door Frame
White
Wood 0.9 L
Admin Building Exterior Rear/Door Frame
White
Wood 0.8 L
Admin Building Exterior Boiler Room/Wall
Beige
CMU 0.17 L
Scale Shack Driveway/Bollard Yellow Metal 1.8 L
Scale Shack Driveway/Bollard Yellow Metal 5.7 L
Scale Shack Driveway/Bollard Yellow Metal 2.6 L
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 11
Location/Component Substrate Result
(mg/cm2)
Paint
Condition
L Building Exterior Parking Lot/Bollard Yellow Metal 3.2 L
L Building Exterior Parking Lot/Bollard Yellow Metal 2.6 L
L Building Interior/Structural Steel Brown Metal 0.05 L
L Building Interior/Duct Gray Metal 2.1 L
mg/cm2 – milligrams per square centimeter
< 0.05 mg/cm2 – XRF detection limit
A full list of suspect XRF testing results are located in Appendix B.
5.0 POLYCHLORINATED BIPHENYL (PCB) VISUAL SCREENING
Polychlorinated biphenyls (PCBs) are man-made chemicals that persist in the environment and were
widely used in construction materials and electrical products prior to 1978. PCBs may be present in the
caulk used in windows, door frames, louvers/vents, masonry columns and other masonry building
materials in buildings built or renovated between 1950 and 1978. Because PCBs can migrate from the
caulk into air, dust, surrounding materials and soil, EPA is concerned about potential PCB exposure to
school children and other building occupants.
5.1 METHODOLOGIES
EBI’s visual inspection for suspect PCB-containing caulking/glazing/sealant applications was limited to the
building exterior. EBI’s inspector visually assessed exterior caulking/glazing/sealant applications
associated with the building exterior.
5.2 SCOPE OF WORK
EBI’s visual inspection for suspect PCB-containing caulking/glazing/sealant applications was limited to
exterior building areas. EBI’s inspector visually assessed exterior caulking/glazing/sealant applications
associated with windows, doors, louvers / vents, and expansion joints, and roofing materials. Visually-
distinct caulking/glazing/sealant applications were documented, separately.
EBI renders no opinion as to the property condition with respect to any potential PCB-containing
materials, including without limitation, PCB-caulkings/glazings/sealants as well as PCB-containing roofing
materials in areas of the building that are not assessed or accessible at the time of EBI’s inspection.
Other suspect PCB-containing building materials and applications were excluded from this inspection,
including without limitation, PCB-containing roofing materials.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 12
5.3 POLYCHLORINATED BIPHENYL FINDINGS
The following suspect PCB-containing caulks/sealants were observed:
Suspect Polychlorinated Biphenyl (PCB) Inventory
Suspect Material Location Condition Estimated Quantity
Exterior Base Wall Caulking Scale Shack Intact 25 LF
Gray Exterior Door
Caulking
Admin Building, Front & Rear
Doors Not Intact 30 LF
Window Glazing
Compound
Admin Building Boiler Room
Steel-Framed Window Not Intact 1 Window
Gray Building Caulking
Admin Building at CMU and
Brick Wall Junction at Boiler
Room
Intact 10 LF
Exterior White Window
Caulking
Admin Building Associated with
Newer Aluminum Windows Intact 17 Windows
LF – Linear Feet
6.0 UNIVERSAL WASTE INVENTORY
6.1 METHODOLOGIES
EBI’s inspector visually inspected the building(s) to identify and quantify miscellaneous universal and
regulated wastes that may require special handling prior to renovation or demolition as follows.
• Fluorescent light tubes (potentially mercury-containing)
• High Intensity Discharge lamps (potentially mercury-containing)
• Fluorescent/HID light fixture ballasts (potentially PCB-containing)
• Thermostats (potentially mercury-containing)
• Refrigerators, freezers, AC units, water fountains, coolers, dehumidifier
(Refrigerants (i.e. Freon/Halon))
• Miscellaneous controlled products: fire extinguishers, stored liquids (bleach,
cleaning solvents, gasoline, chemicals, paints, oils, etc.)
• Motors / pumps (potentially contain lubricating oils)
• Rechargeable batteries (all types, primarily emergency lights / exit
signs)(potentially lead and cadmium containing)
• Microwave ovens, white goods
• Switches, thermometers, pressure gauges (potentially mercury-containing)
• Compressed gas cylinders, propane tanks
• Electronic Devices (computers, monitors, TV, printers, scanners etc.)
• EXIT signs (potentially containing radioactive material – tritium gas)
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 13
6.2 SCOPE OF WORK
EBI’s inspection for miscellaneous regulated wastes was limited to areas of the buildings where
demolitions are planned.
EBI renders no opinion as to the property condition with respect to any miscellaneous regulated wastes
other than specifically listed in the above Universal Waste Inventory, Methodologies section. Further, EBI
renders no opinion as to the property condition with respect to the listed miscellaneous regulated
wastes in areas of the building that are not assessed or accessible at the time of EBI’s inspection.
6.3 UNIVERSAL WASTE FINDINGS
The following is an inventory of the identified miscellaneous regulated wastes:
Regulated Building Materials Inventory
Building/Waste Material Type Estimated Quantity
Admin Building- 4’ Fluorescent Light Tubes 77
Admin Building - Circular Fluorescent Light Tubes 1
Admin Building - PCB Ballasts 136
Admin Building – HF Thermostats 4
Admin Building – Hydraulic Door Stops 1
Admin Building – Emergency Lights 1
Admin Building – Fire Alarm Panel 1
Admin Building – Fire Extinguisher 5
Admin Building – Computer Monitor 2
Admin Building – Oil Burner (Buderus G215) 1
Admin Building – Oil Tank 275 Gal (1/4 full) 1
Admin Building – Bleach 3
Admin Building – Lysol 2
Admin Building – Household Cleaner 3
Admin Building – Oil Absorbent 1 Bag
Admin Building – Various Small Containers of
Chemicals 13
Scale Shack- 4’ Fluorescent Light Tubes 1
Scale Shack- PCB Ballasts 2
Scale Shack – Electric Baseboard Heater 1
Storage Building - 4’ Fluorescent Light Tubes 2
Storage Building - PCB Ballasts 4
Storage Building – HG Vapor Lamps 3
Storage Building – Exterior Light 1
Storage Building – Electric Motor 1
Storage Building – Oil Dry 10-Gal Bucket 1
L Building – HG Vapor Lamps 14
L Building – Fire Alarm Panel 1
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 14
Regulated Building Materials Inventory
Building/Waste Material Type Estimated Quantity
L Building – 5-Gal Compressor Fluid 1
L Building – Fire Extinguishers 4
L Building – 2-Gal Bucket (unknown) 1
L Building – Smoke Detector 2
L Building – Aerosol Paint Can 2
7.0 RECOMMENDATIONS
7.1 ASBESTOS CONTAINING BUILDING MATERIALS
The EPA NESHAP regulations require removal of ACBM prior to renovation or demolition including
Regulated Asbestos-Containing Material (RACM). RACM includes Friable ACBM; Category I non-friable
ACBM that has become friable; Category I non-friable ACBM that will be or has been subjected to
sanding, grinding, cutting or abrading; or Category II non-friable ACBM 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 during demolition or renovation operations. The survey results identified assumed ACBM
in the form of:
• Rolled asphalt roofing;
• Roof flashing cement;
• White sheet flooring and mastic;
• Exterior wall base caulking;
• Fiberglass roofing panel adhesive;
• Metal interior door insulation;
• Blue stone floor tile grout and mortar;
• Floor tile and mastic;
• Corrugated paper pipe insulation;
• Gypsum wallboard and joint compound;
• 1’x1’ Spline ceiling tile;
• Textured ceiling on gypsum board;
• Ceramic wall tile grout and adhesive;
• Wall base molding and adhesive;
• White 2’x2’ suspended ceiling tile;
• Carpet adhesive;
• Wood wall paneling adhesive;
• Gray door caulking;
• Unfinished plaster ceiling;
• Window glazing compound;
• Exterior black wall patching material; and,
• White window caulking.
EBI recommends future sample collection and laboratory analysis of these suspect/assumed ACBMs in
conjunction with supplemental inspection by an Commonwealth of Massachusetts-certified asbestos
inspector identify to identify the actual content of these materials prior to disturbance.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 15
The OSHA Asbestos Construction Standard 29 CFR, Part 1926.1101 also requires protection of
workers from asbestos exposure associated with all work activities: not limited to renovation and
demolition work, and not limited to ACBM, ACWM and assumed ACBM. OSHA requires protection
procedures associated with materials containing any detectable concentration of asbestos including <1%
or “Trace” concentrations; protective measures include worker protection, training, and medical
surveillance portions, wet methods, prompt cleanup and proper disposal, prohibited
procedures/equipment/methods, and exposure-dependent engineering controls. EBI recommends that
any disturbance of assumed ACBM be performed by a Commonwealth of Massachusetts-licensed
asbestos contractor in accordance with local, state and federal regulations.
When an asbestos removal contractor is engaged for work involving disturbance of ACBMs, assumed
ACBMs, or materials with “Trace” concentrations of asbestos, EBI recommends that a qualified
independent third-party Industrial Hygiene technician provide abatement oversight and final visual and
air clearance services on behalf of the building owner.
Additional suspect ACBMs may be present at the Subject Property in areas that were not inspected or
due to access limitation within inspected areas. If additional suspect or assumed ACBMs are identified in
the future (that were observed as part of this inspection), they must be treated as ACBMs unless future
laboratory analytical results in conjunction with inspection by an appropriately accredited and/or
licensed inspector identify the material(s) as non-ACBM. Based on the limitations of this inspection, EBI
recommends that a supplemental asbestos inspection be performed in accordance with all applicable
federal, state, and local regulatory requirements prior to building demolitions, or other activities that
could cause a material disturbance.
7.2 LEAD-CONTAINING PAINT
Results of testing via XRF analysis identified detectable concentrations of lead in paint applied to the
following surfaces:
• Exterior White Wood Door Frame;
• Exterior Beige CMU Boiler Room Wall;
• Exterior Yellow Metal Bollard; and,
• Interior Brown Structural Steel.
EBI recommends that all work performed in the buildings that will potentially disturb these materials and
surfaces be performed in full compliance with OSHA standard 29 CFR, Part 1926. Construction work
that may cause occupational exposed to lead in any amount is subject to the OSHA requirements. Initial
employee exposure monitoring is required to evaluate worker exposure to lead. Engineering controls,
respiratory protection, and personal protective equipment must be employed.
7.3 POLYCHLORINATED BIPHENYLS
EBI visually identified the following suspect PCB-containing caulk/sealants at the buildings:
• Exterior wall base caulking, Scale Shack;
• Gray door caulking, Admin Building;
• Window glazing compound, Admin Building;
• Gray building caulking Admin Building; and,
• White window caulking, Admin Building.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 16
Prior to building demolitions, samples of these suspect PCB-containing materials should be collected and
analyzed to determine actual PCB content.
7.4 UNIVERSAL WASTES
Miscellaneous regulated wastes were identified including fluorescent light tubes, light fixture ballasts,
suspect mercury thermostats, hydraulic door stops, emergency lights, fire extinguishers, computer
monitors, oil burner, aboveground oil storage tank, mercury vapor lamps, exterior street light, fire alarm
panel, motors, electric baseboard heaters, compressor oil, “Oil Dry”, fire alarm panel, unlabeled
containers, aerosol paint cans, miscellaneous household cleaners. EBI recommends that any of these
materials that will be disturbed during building demolition activities be properly handled, removed,
recycled and/or disposed by appropriately qualified and trained personnel, and in accordance with all
applicable regulations and standards.
8.0 GENERAL LIMITATIONS
Report information was obtained through sources deemed reliable (i.e., interviews with owners, agents,
occupants or other appropriate persons involved with the subject property). Findings, conclusions
and/or recommendations are based on our visual observations, the information provided to or obtained
by EBI, or provided by the Client or property contact, and/or a review of readily available and supplied
documents and drawings. EBI renders no opinion as to the property condition at un-surveyed and/or
inaccessible portions of the subject property.
This Report presents the findings of a limited investigation but does not constitute a complete
determination of whether past or present owners or occupants of the Subject Property have been in
compliance with all applicable local, state, and federal environmental regulations. The information
contained herein is based on on-site observations and on a limited investigation involving site
observations. The investigative methods applied to this assessment are consistent with current industry
standards for the performance of investigation within the limits of the scope of work, budget, and
schedule. Survey evaluations are limited in the sense that conclusions and recommendations are
developed from personal interviews and information obtained from limited research, site observations
and secondary informational sources. Except as set forth in this report, EBI has made no independent
investigations as to the accuracy or completeness of the information derived from the secondary
sources and personal interviews and has assumed that such information was accurate and complete. It
should be noted that no conclusions can be drawn regarding the existence of conditions that were not
addressed by the scope of work.
This assessment and Report were prepared by EBI solely for the use of R.J. Kelly Co., Inc.. The scope of
services performed in execution of this evaluation may not be appropriate to satisfy the needs of other
users, and use or re-use of this document or the findings, conclusions, or recommendations, is at risk of
said user. Third party use of this Report is prohibited without the prior written consent of EBI and use
thereof is at the risk of the user. The observations and results presented in this Report are believed to
be representative of site conditions prevailing at the time of the assessment in the areas explored.
Changes in site conditions or in the availability of information regarding past or current site conditions
should be brought to EBI’s attention so that they can be addressed and EBI’s conclusions verified or
modified as appropriate. This report does not warrant against future operations or conditions, nor
does it warrant against operations or conditions present of a type or at a location not investigated. This
document is not designed for bidding purposes. This report is not to be provided to potential bidders
for the purpose of soliciting proposals for abatement.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting Page 17
It has been a pleasure to prepare this Report for you. Please contact Tim Downey at (617) 877-6245 if
you should have any questions, comments, or if I can be of further assistance in any way.
Respectfully Submitted,
Timothy M. Downey
Senior Project Manager
Asbestos and Lead Programs
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX A
PHOTOGRAPHS
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
1. L Building Exterior Shed
Section; Black Rolled
Asphalt Roofing.
2. L Building Exterior Shed;
Black Flashing Cement at
Roof/Wall Junction.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
3. Storage Building; Black
Rolled Roofing.
4. Scale Shack; White Sheet
Flooring and Associated
Mastic.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
5. Scale Shack; Exterior
Caulking at Base of Wall
Panel.
6. Scale Shack Roof;
Adhesive Associated with
Fiberglass Roofing.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
7. Scale Shack; Metal Door
Insulation.
8. Admin Building; Black
Asphalt Roofing.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
9. Admin Building Vestibule;
Blue Stone Floor Grout
and Bedding Mortar.
10. Admin Building;
Throughout and Assumed
- Beneath Office
Carpet/Double Layer
Floor Tile and Associated
Adhesive.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
11. Admin Building; Above
Conference Room
Ceiling/Corrugated Paper
Pipe Insulation.
12. Admin Building;
Throughout - Gypsum
Wallboard and Associated
Joint Compound.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
13. Admin Building; Front
Office Areas, Kitchen,
Restrooms, Corridor and
Copy Room - White1’x1’
Spline Ceiling Tiles.
14. Admin Building; Small
Utility Room – White
Textured Ceiling on
Gypsum Board
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
15. Admin Building;
Restrooms - Ceramic
Wall Tile Grout and
Adhesive.
16. Admin Building;
Throughout - Wall Base
Molding and Associated
Adhesive.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
17. Admin Building Rear
Offices - 2’x2’ Ceiling Tile.
18. Admin Building; Offices -
Carpet Adhesive.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
19. Admin Building;
Throughout - Wood Wall
Paneling Adhesive.
20. Admin Building; Front
Door – Caulking.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
21. Admin Building; Boiler
Room Ceiling - Unfinished
Plaster.
22. Admin Building; Boiler
Room - Steel-Framed
Window Glazing.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
23. Admin Building; at CMU
and Brick Wall Junction at
Boiler Room – Caulking.
24. Admin Building; Rear
Brick Wall - Black
Patching Material.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
25. Admin Building;
Throughout - White
Caulking Associated with
Newer Aluminum
Windows.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX B
XRF LEAD TESTING TABLE
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
Location/Component Substrate Result
(mg/cm2)
Paint
Condition
Admin Building Exterior Rear/Door Frame
White Wood 0.7 L
Admin Building Exterior Rear/Door Frame
White
Wood 0.9 L
Admin Building Exterior Rear/Door Frame
White
Wood 0.8 L
Admin Building Exterior Rear/Door White Metal 0.00 L
Admin Building Exterior Rear/Door White Metal 0.00 L
Admin Building Exterior Rear/Door White Metal 0.00 L
Admin Building Exterior Boiler Room/Wall
Beige CMU 0.08 L
Admin Building Exterior Boiler Room/Wall
Beige
CMU 0.00 L
Admin Building Exterior Boiler Room/Wall
Beige
CMU 0.17 L
Admin Building Interior Boiler
Room/Incinerator Beige
Brick 0.00 L
Admin Building Interior Boiler
Room/Incinerator Beige
Brick 0.00 L
Admin Building Interior Boiler
Room/Incinerator Beige
Brick 0.00 L
Admin Building Exterior Front/Railing Black Metal 0.01 L
Admin Building Exterior Front/Railing Black Metal 0.01 L
Admin Building Exterior Front/Railing Black Metal 0.00 L
Admin Building Exterior Boiler Room/Door
Beige
Metal 0.00 I
Admin Building Exterior Boiler Room/Door
Beige
Metal 0.00 I
Admin Building Exterior Boiler Room/Door
Beige
Metal 0.00 I
Admin Building Interior Office Space/Wall
White Gypsum 0.00 I
Admin Building Interior Office Space/Wall
White
Gypsum 0.00 I
Admin Building Interior Kitchen/Wall White Gypsum 0.01 I
Admin Building Interior Utility Room/Wall
White Gypsum 0.03 L
Admin Building Interior/Door Trim White Wood 0.01 L
Admin Building Interior/Door Trim White Wood 0.01 L
Admin Building Interior/Door Trim White Wood 0.01 L
Admin Building Interior/Chair Rail White Wood 0.00 L
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
Location/Component Substrate Result
(mg/cm2)
Paint
Condition
Admin Building Interior/Chair Rail White Wood 0.01 L
Admin Building Interior/Chair Rail White Wood 0.00 L
Admin Building Interior/Wall Paneling Brown Wood 0.01 I
Admin Building Interior/Wall Paneling Brown Wood 0.00 I
Admin Building Interior/Wall Paneling Brown Wood 0.00 I
Scale Shack Exterior/Siding Beige Metal 0.00 I
Scale Shack Exterior/Siding Beige Metal 0.01 I
Scale Shack Exterior/Siding Beige Metal 0.00 I
Scale Shack Exterior/Interior/ Door Beige Metal 0.00 I
Scale Shack Exterior/Interior/ Door Beige Metal 0.00 I
Scale Shack Exterior/Interior/ Door Beige Metal 0.00 I
Scale Shack Truck Scale/Platform Red Metal 0.00 L
Scale Shack Truck Scale/Platform Red Metal 0.00 L
Scale Shack Truck Scale/Platform Red Metal 0.00 L
Scale Shack Driveway/Bollard Yellow Metal 1.8 L
Scale Shack Driveway/Bollard Yellow Metal 5.7 L
Scale Shack Driveway/Bollard Yellow Metal 2.6 L
Scale Shack Interior/Walls Beige Metal 0.00 I
Scale Shack Interior/Walls Beige Metal 0.00 I
Scale Shack Interior/Walls Beige Metal 0.00 I
Storage Building Exterior/Siding Gray Wood 0.00 L
Storage Building Exterior/Siding Gray Wood 0.00 L
Storage Building Exterior/Siding Gray Wood 0.00 L
Storage Building Exterior/Door Red Metal 0.00 I
Storage Building Exterior/Door Red Metal 0.00 I
Storage Building Exterior/Door Red Metal 0.00 I
Storage Building Interior/Door Gray Metal 0.00 I
Storage Building Interior/Door Gray Metal 0.00 I
Storage Building Interior/Door Gray Metal 0.00 I
Storage Building Interior Tank/Motor Gray Metal 0.01 I
Storage Building Interior Tank/Motor Gray Metal 0.01 I
Storage Building Interior Tank/Motor Gray Metal 0.00 I
Storage Building Interior Tank/Motor Support
Brown
Metal 0.00 L
Storage Building Interior Tank/Motor Support
Brown
Metal 0.00 L
Storage Building Interior Tank/Motor Support
Brown Metal 0.00 L
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
Location/Component Substrate Result
(mg/cm2)
Paint
Condition
L Building Exterior/Siding Tan Metal 0.04 I
L Building Exterior/Siding Tan Metal 0.04 I
L Building Exterior/Siding Tan Metal 0.03 I
L Building Exterior Rear/Stair Blue Metal 0.02 L
L Building Exterior Rear/Stair Blue Metal 0.01 L
L Building Exterior Rear/Stair Blue Metal 0.01 L
L Building Exterior Rear/Wall Panel Black Wood 0.00 I
L Building Exterior Rear/Wall Panel Black Wood 0.00 I
L Building Exterior Rear/Wall Panel Black Wood 0.00 I
L Building Attached Shed/Wall Tan Wood 0.00 I
L Building Attached Shed/Wall Tan Wood 0.00 I
L Building Attached Shed/Wall Tan Wood 0.00 I
L Building Garage/Door Brown Metal 0.00 L
L Building Garage/Door Brown Metal 0.00 L
L Building Garage/Door Brown Metal 0.00 L
L Building Exterior Parking Lot/Bollard Yellow Metal 0.00 L
L Building Exterior Parking Lot/Bollard Yellow Metal 3.2 L
L Building Exterior Parking Lot/Bollard Yellow Metal 2.6 L
L Building Interior/Wall Gray Metal 0.00 I
L Building Interior/Wall Gray Metal 0.01 I
L Building Interior/Wall Gray Metal 0.00 I
L Building Interior/Structural Steel Brown Metal 0.05 L
L Building Interior/Structural Steel Brown Metal 0.04 L
L Building Interior/Structural Steel Brown Metal 0.00 L
L Building Interior/Duct Gray Metal 2.1 L
L Building Interior/Duct Gray Metal 0.00 L
L Building Interior/Duct Gray Metal 0.00 L
• mg/cm2 = milligrams of lead per square centimeter of sampled surface area.
• < 0.05 = less than the limit of quantification of the XRF.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX C
CERTIFICATIONS
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
APPENDIX D
GLOSSARY
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
GLOSSARY
Air Cell: Insulation normally used on pipes and ductwork that is comprised of corrugated cardboard
which is frequently comprised of asbestos combined with cellulose or refractory binders.
Air Monitoring: The process of measuring the fiber content of a specific volume of air.
Amosite - An asbestiform mineral of the amphibole group. It is the second most commonly used form of
asbestos in the U.S. (brown asbestos).
Amphibole - One of the two major groups of minerals from which the asbestiform minerals are derived;
distinguished by their chain-like crystal structure and chemical composition. Amosite and crocidoIite are
examples of amphibole minerals.
Anthophyllite - One of six naturally-occurring asbestos minerals. It is of limited commercial value.
Asbestos: The asbestiform varieties of serpentinite (chrysotile), riebeckite (crocidolite), cummingtonite-
grunerite, amosite, anthophylite, and actinolite-tremolite. For purposes of determining respiratory and
worker protection both the asbestiform and non-asbestiform varieties of the above minerals and any of
these materials that have been chemically treated and/or altered shall be considered as asbestos.
Asbestos-Containing Material (ACM): Any material containing more than 1% of asbestos of any type or
mixture of types.
Asbestos-Containing Building Material (ACBM): 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 definition).
Assumed Asbestos-Containing Material: Any suspect ACM that has not been appropriately tested to
confirm whether or not it contains asbestos.
Bulk Samples - Samples of bulk material, in the case of asbestos, suspect material
Certified Industrial Hygienist (C.I.H.): An industrial hygienist certified in Comprehensive Practice by the
American Board of Industrial Hygiene.
Class I Work (OSHA): Work activities, performed by an outside licensed abatement contractor, that
involve the removal of boiler, pipe and duct insulation, and surfacing material such as spray-applied
fireproofing.
Class II Work (OSHA): Work activities, performed by an outside licensed abatement contractor, that
involve the removal of asbestos-containing materials other than boiler, pipe and duct insulation, and
surfacing material such as spray-applied fireproofing.
Class III Work (OSHA): Work activities that involve the repair of minor amounts of damaged asbestos-
containing materials.
Class IV Work (OSHA): Work activities that involve the maintenance and custodial activities during
which tenants and employees contact but do not disturb asbestos-containing materials or presumed
ACM. Class IV work may involve the clean-up of dusts, wastes and debris in areas where asbestos is,
was or may be located.
Crocidolite - Strongest of asbestos minerals. An asbestiform mineral of the amphibole group. It is of
minor commercial value In the U.S. (blue asbestos).
Chrysotile - The only asbestiform mineral of the serpentine group, it is the most common form of
asbestos used in buildings (white asbestos).
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
Damaged Friable Surfacing Miscellaneous) Material - Friable surfacing (miscellaneous) ACM which has
deteriorated or sustained physical injury such that the internal structure (cohesion) of the material is
inadequate or, if applicable, which has delaminated such that the bond to the substrate (adhesion) is
inadequate or which for any other reason lacks fiber cohesion or adhesion qualities. Such damage or
deterioration may be illustrated by the separation of ACM into layers; separation of ACM from the
substrate; flaking, blistering, or crumbling of ACM surface; water damage; significant or repeated water
stains, scrapes, gauges, mars or other signs of physical injury on the ACM. Asbestos debris originating
from the ACBM in question may also indicate damage (AHERA definition)
Damaged or Significantly Damaged Thermal System Insulation - Thermal system insulation on pipes,
boilers, tanks, ducts, and other thermal system insulation equipment which the insulation has lost its
structural integrity, or its covering, in whole or in part, is crushed, water-stained, gouged, punctured,
missing, or not intact such that it is not able to contain fibers. Damage may be further illustrated by
occasional punctures, gouges, or other signs of physical injury to ACM; occasional water damage on the
protective coverings/jackets; or exposed ACM ends or joints. Asbestos debris, originating from the
ACBM in question may also indicate damage (AHERA definition).
Demolition: The wrecking or taking out of any building component, system, finish or assembly of a
facility together with any related handling operations.
Encapsulant: A material that surrounds or embeds asbestos fibers in an adhesive matrix, to prevent
release of fibers.
Bridging encapsulant: an encapsulant that forms a discrete layer on the surface of an in situ asbestos
matrix.
Penetrating encapsulant: an encapsulant that is absorbed by the in situ asbestos matrix without
leaving a discrete surface layer.
Removal encapsulant: a penetrating encapsulant specifically designed for removal of asbestos-
containing materials rather that for in situ encapsulation.
Encapsulation - The use of an agent to seal the surface (budging encapsulant) or penetrate the bulk
(penetrating encapsulant) of ACM.
Enclosure: The construction of an airtight, impermeable, permanent barrier around asbestos-containing
material to control the release of asbestos fibers into the air.
Fiber Release: Any uncontrolled or unintentional disturbance of ACBM resulting in visible emission.
Fitting: Within any piping system, any valve, tee, elbow, 45o, flange, union, reducer, or other piping
connector which may be insulated with asbestos.
Friable Asbestos Material: Material that contains more than 1.0% asbestos by weight, and that can be
crumbled, pulverized, or reduced to powder by hand pressure when dry.
HEPA Filter: A High Efficiency Particulate Air (HEPA) filter capable of trapping and retaining 99.97% of
asbestos fibers greater than 0.3 microns in length.
HEPA Filter Vacuum Collection Equipment (or vacuum cleaner): High efficiency particulate air filtered
vacuum collection equipment with a filter system capable of collecting and retaining asbestos fibers.
Filters should be 99.97% efficient for retaining fibers of 0.3 microns or larger.
High-Efficiency Particulate Air Filter (HEPA): A filter which removes from air 99.97% or more of
monodisperse dioctyl phthalate (DOP) particles having a mean particle diameter of 0.3 micrometer.
Limited Pre-Demolition Hazardous Materials Survey Report Colonial Road
EBI Project No. 1120001832 25, 30 & 40 Colonial Road, Salem, Massachusetts
EBI Consulting
Miscellaneous Material - 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 definition).
NESHAP: National Emission Standard for Hazardous Air Pollutants, 40 CFR Part 61 Subpart M.
Operations and Maintenance (O & M) Plan - A plan for an O & M program, which is designed to clean
up asbestos contamination, minimize future fiber release, and maintain ACM in good condition.
Phase Contrast Microscopy (PCM) - A method of analyzing air samples for fibers using a light
microscope.
Physical Assessment - Assessing suspect material to determine the current condition of the material and
the potential for future disturbance.
Polarized Light Microscopy (PLM) - A method of analyzing bulk samples for asbestos in which the sample
is illuminated with polarized light (light which vibrates in only one plane) and viewed under a light
microscope.
Presumed Asbestos-Containing Material (PACM): Thermal systems insulation, surfacing material or
miscellaneous materials found in buildings constructed prior to 1980 that has not been appropriately
tested to confirm whether or not it contains asbestos.
Repair: Returning damaged ACM to an undamaged condition to prevent fiber release.
Response Actions - Actions specified in the management plan to control ACM; includes repair, O & M,
and the various methods of abatement.
Serpentine - One of the two major groups of minerals from which the asbestiform minerals are derived;
distinguished by their tubular structure and chemical composition. Chrysotile is a serpentine mineral.
Significantly Damaged Friable Surfacing (Miscellaneous) Material - Friable surfacing (miscellaneous) ACM
in a functional space where damage is extensive and severe (AHERA definition).
Surfacing Material - Material in a school building that is sprayed on, troweled on, or otherwise applied to
surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or
other materials on surfaces for acoustical, fireproofing, or other purposes (AHERA definition).
Suspect Asbestos-Containing Material (Suspect ACM): The term "suspect ACM" is used by the asbestos
industry to refer to any building material that is suspected of being asbestos-containing (based on
appearance, usage, age of building, etc.), but has not been proven conclusively to be ACM (based on
sampling and analysis). Suspect material would include any material that a building owner suspects of
containing asbestos and is found in a building of any age or construction date. Refer to section 2.1 for a
list of typical suspect ACMs.
Thermal System Insulation (TSI) - Material applied to pipes, fittings, boilers, breeching, tanks, ducts, or
other interior structural components to prevent heat loss or gain, or water condensation, or for other
purposes.
Transmission Electron Microscopy - A method of analyzing air samples for asbestos fibers using a
transmission electron microscope and, possibly, associated instruments for further identifying asbestos.
Tremolite - One of six naturally-occurring asbestos minerals. Tremolite has few commercial uses.