22058_Erwin Mill_Asbestos O&M Plan_20200610

Asbestos -Containing Material
Operations and Maintenance Plan
Former Erwin Mills Site
200 N. 13t" Street
Erwin, North Carolina
H&H Job No. BRP-001
June 10, 2020
hart � hickman
2923 South Tryon Street, Suite 100 3921 Sunset Ridge Rd, Suite 301
Charlotte, NC 28203 Raleigh, NC 27607 www.harthickman.com
704.586.0007 main 919.847.4241 main

Asbestos -Containing Material
Operations and Maintenance Program
Former Erwin Mills Site
200 N. 13rh Street
Erwin, North Carolina
H&H Job No. BRP-001
Table of Contents
Section Page No.
1.0 Introduction and Purpose of O&M Plan.............................................................................1
2.0 Asbestos Background Information....................................................................................... 3
3.0 Identified ACMs and Response Actions.............................................................................. 3
4.0 Overview of Federal, State, and Local Asbestos Regulations ............................................ 7
4.1 Federal Regulations............................................................................................................. 7
4.2 North Carolina Regulations................................................................................................. 9
5.0 Responsibilities of the Asbestos Coordinator.................................................................... 11
6.0 Notification Requirements.................................................................................................. 15
7.0 Training and Responsibilities of Employees, Contractors, and Tenants ........................15
8.0 Surveillance and Periodic Inspections...............................................................................17
9.0 General Work Practices and Prohibited Activities...........................................................18
10.0 Emergency Response Procedures.....................................................................................19
11.0 Recordkeeping Requirements........................................................................................... 20
12.0 Specifications for Asbestos Abatement Contactors and Consultants ........................... 22
12.1 Asbestos Abatement Contractor's Requirements............................................................ 22
12.2 Specifications for Air Monitoring During Asbestos Abatement ..................................... 24
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l,ict of Tih]PF
Table 1 O&M Plan Buildings Summary
List of Figures
Figure 1 Site Location Map
Figure 2 Site and Building Location Map
Figures 3-22 Positive Asbestos Sample Location Maps
List of Appendices
Appendix A Building Re -Inspection Reports
Appendix B Glossary of Terms
Appendix C O&M Plan Forms
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Asbestos -Containing Material
Operations and Maintenance Program
Former Erwin Mills Site
200 N. 131" Street
Erwin, North Carolina
H&H Job No. BRP-001
1.0 Introduction and Purpose of O&M Plan
On behalf of Brooks Pierce, H&H has developed this Asbestos Operations and Maintenance
(O&M) Plan for implementation of sixteen (16) buildings and areas that comprise the former Erwin
Mills Site located at 200 N. 13th Street in Erwin, Harnett County, North Carolina (see Figure 1).
The O&M Plan was created for the use and protection of employees and sub -contractors working in
and around the Erwin Mills buildings. The O&M Plan includes an inventory of asbestos -containing
materials (ACMs) that were either sampled or presumed to contain asbestos during previous
asbestos surveys conducted on the Erwin Mills buildings by H&H between December 16th, 2019
and January 9, 2020. Identified ACMs should be inspected annually by a NC Accredited asbestos
inspector to evaluate the ACMs for damage and their current condition. The Erwin Mills buildings
included in the O&M Plan are summarized in Table 1 and are depicted on Figure 2.
The purpose of this O&M Plan is to develop procedures to minimize the potential exposure of Site
employees and contractors to airborne asbestos fibers at buildings while performing general
maintenance or custodial activities in the area of the ACMs, or to building tenants and visitors while
occupying the Site buildings. This will be accomplished by performing the following three tasks:
(1) minimize and/or prevent additional fiber releases;
(2) maintenance of ACMs to keep them in good condition; and
(3) periodic inspections and documentation of the condition of these materials.
These tasks are generally characterized under the Occupational Safety and Health Administration
(OSHA) Class IV work classification. Class IV work is generally characterized as maintenance and
custodial activities where employees contact but do not disturb ACMs. The Erwin Mills Asbestos
O&M Plan does not allow employees or contractors to remove, repair, or conduct maintenance
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operations that may disturb identified ACMs or presumed ACMs (PACMs), or cleanup of dust,
waste, or debris from ACMs or PACMs after renovation and/or repair activities. These activities
are generally characterized as Class I, II, III, and certain Class IV work. In accordance to with this
O&M Plan, these activities will be performed by a licensed asbestos abatement contractor.
This ACM O&M Plan includes pertinent information regarding the following asbestos -related
topics:
• background information;
• identified ACMs and response actions;
• an overview of federal, state, and local regulations;
• the responsibilities of the Asbestos Coordinator;
• notification requirements;
• training and the responsibilities of Site employees and contractors;
• surveillance and periodic inspections;
• general work practices and prohibited activities;
• emergency response procedures;
• record keeping requirements; and
• specifications for asbestos abatement contractors.
A summary of these activities is presented in the following sections.
Please note that this O&M Plan should be used in conjunction with the asbestos facility re -
inspection reports, which are included in Appendix A. A glossary of asbestos related terminology is
included in Appendix B, and additional O&M Plan forms are included in Appendix C.
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2.0 Asbestos Background Information
Asbestos is the name given to a group of naturally occurring minerals that are resistant to heat
and corrosion. Asbestos has been used in products, such as insulation for pipes (steam and water
lines), floor tile and associated mastics, roof materials, dry wall, plaster coatings, textured ceiling
materials, window glazing, transite siding, gaskets and seals, and other building materials. The
US Environmental Protection Agency (EPA) defines ACMs as any material or product
containing > 1% asbestos. Asbestos includes the following mineral fibers:
• chrysotile
• amosite,
• crocidolite,
• tremolite,
• anthophyllite,
• actinolite, and
• any of the minerals listed above that have been chemically treated or altered.
Historically, asbestos exposures have occurred in mining and shipbuilding industries. Exposures
may occur in the construction industry, during the removal of asbestos materials due to
renovation, repairs, or demolition. Workers may be exposed during the manufacture of asbestos
products (such as textiles, friction products, insulation, and other building materials).
Asbestos is recognized as a health hazard and its use is regulated by OSHA and the EPA.
Asbestos fibers associated with these health risks are too small to be seen with the naked eye.
Breathing asbestos fibers can cause a buildup of scar -like tissue in the lungs called asbestosis and
result in loss of lung function that can progress to disability or even death. Asbestos inhalation is
also linked to cancer of the lung and other diseases such as mesothelioma of the pleura which is a
fatal malignant tumor of the membrane lining the cavity of the lung or stomach.
Please note that the presence of ACMs within buildings does not necessarily constitute a health
hazard. ACMs are a potential health hazard if they are damaged or disturbed in a manner that
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renders the ACM friable and creates a release of fibers that can be inhaled or ingested. ACMs
that remain intact and in good non -friable condition have a low potential to create a fiber release
and generally are not considered to be a health hazard.
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3.0 Identified ACMs and Response Actions
Identified ACMs
During the initial asbestos surveys conducted between December 16, 2019 and January 9, 2020,
H&H identified the following types of ACMs located on or within the former Erwin Mills
buildings:
• floor tile and associated mastic;
• sheet flooring;
• wall mastic;
• waterproofing;
• wall surfacing;
• textured sink material;
• thermal system insulation (TSI) on piping;
• mastic on HVAC equipment and ducts;
• mastic on fan units;
• cementitious paneling;
• roof system materials (including flashing and silver coating);
• window glazing;
• tar on air handlers;
• door caulk; and
• gaskets on piping
The ACMs identified on and within the former Erwin Mills buildings are summarized in Table 1
and were assessed by H&H during our recent re -inspections conducted in June 2020. Copies of
the Re -inspection Reports for each Erwin Mills building or area are included in Appendix A.
Response Actions
Five response actions that can be selected by the Management Planner to address ACMs or
PACMs identified in the former Erwin Mills buildings are listed as follows:
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• Removal — take out ACMs or facility components that contain ACMs;
Encapsulation — coat an ACM with a sealant, encapsulant, or bonding agent to prevent
fiber release;
Repair — to fix or patch ACM with localized damage to prevent a fiber release;
• Enclose — construction of an air tight barrier around the ACM to prevent a future fiber
release; and
• Operations and Maintenance (O&M) — implement an O&M Plan to manage building
ACMs identified in good condition utilizing periodic inspections, training, engineering
controls and record keeping.
When damaged and friable ACMs or presumed ACMs (PACMs) are identified during
inspection/re-inspection, the recommended response action in this O&M Plan will consist of
removal, encapsulation, repair, or enclosure of the ACM(s) or PACM(s). If the ACM or PACM
is identified in good condition and the potential for its disturbance in the future is low, the
recommended response action will consist of maintaining the ACM or PACM in the facility's
O&M Plan. The appropriate response action for the ACMs identified during our recent re -
inspection as determined by the Management Planner are included in the Re -inspection Reports
found in Appendix A.
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4.0 Overview of Federal, State, and Local Asbestos Regulations
4.1 Federal Regulations
The two federal government agencies responsible for regulations regarding exposure to asbestos are
the EPA and OSHA. A summary of the regulations associated with these federal agencies is
presented below.
EPA
The following US EPA regulations were established to address asbestos in schools, in commercial
and public spaces, during demolition/renovation activities, and for protection of state and local
government workers:
• EPA Asbestos Hazard Emergency Response Act (AHERA) - 40 CFR Part 763 Subpart E.
• EPA Asbestos School Hazard Abatement Reauthorization Act (ASHARA) - 40 CFR 763
Appendix C to Subpart E
• EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) - 40 CFR
61.140 Subpart M
• EPA Asbestos Worker Protection Rule - 40 CFR Part 763 Subpart G
AHERA - In October 1987, the US EPA issued final regulations to carry out the Asbestos Hazard
Emergency Response Act of 1986 (AHERA). AHERA regulatory requirements address only with
public and private elementary and secondary school buildings. The regulations require schools to
conduct inspections, develop comprehensive asbestos management plans, and select asbestos
response actions to deal with asbestos hazards. The AHERA rules do not require schools to remove
ACMs. The AHERA rules are not enforceable upon industry; however, the elements of the
AHERA program have generally been utilized by industry as a standard when performing asbestos
surveys and developing operation and maintenance plans.
A key element of the AHERA regulation requires schools to develop an O&M Plan if friable ACM
is present. The AHERA O&M requirements also cover non -friable ACM which may become
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friable. Friable asbestos material is defined as material which is able to be crushed, pulverized or
reduced to powder by the exertion of hand pressure. Friable asbestos has the greatest chance of
becoming airborne, and airborne asbestos poses the greatest threat to human health. For example,
drilling through an ACM wall will likely render the ACM friable. Under AHERA O&M
provisions, schools must carry out specific O&M procedures which provide for the clean-up of any
ACM releases and ensure the general safety of school maintenance and custodial workers, as well as
all other school building occupants. The AHERA regulation's O&M requirements mandate that
schools employ specific work practices including wet wiping, HEPA vacuuming, proper waste
disposal procedures, and specific training for custodial and maintenance employees who work in
buildings with ACMs.
ASHARA - On November 28, 1990, the Asbestos School Hazard Abatement Reauthorization Act
(ASHARA) was enacted. The EPA regulations for implementing ASHARA are under the Model
Accreditation Plan (MAP) contained in the Federal Register, dated February 3, 1994 (40 CFR
763 Appendix C to Subpart E). The MAP went into effect October 4, 1994, and set standards for
training employees who work with asbestos (i.e., inspectors, management planners, supervisors,
workers, and project designers), and expanded the accreditation requirements to cover asbestos
abatement projects in all public and commercial buildings.
NESHAP - The asbestos NESHAP regulations specify work practices for asbestos to be followed
during demolition and renovation of all structures, installations, and buildings (excluding
residential buildings that have four or fewer dwelling units). The regulations require the owner
of the building or the operator to notify the appropriate state agency before demolition, or before
renovations of buildings that could contain a certain threshold amount of asbestos. In addition,
particular manufacturing and fabricating operations either cannot emit visible emissions into the
outside air or must follow air cleaning procedures, as well as follow certain requirements when
removing asbestos -containing waste. In Harnett County, NESHAP regulations are regulated by
the North Carolina Health Hazards Control Unit (HHCU).
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Asbestos Worker Protection Rule - The US EPA Asbestos Worker Protection Rule (40 CFR
Part 763 Subpart G) extends the OSHA asbestos protections to state and local government
workers not covered by OSHA laws. The law became effective December 15, 2000.
OSHA
OSHA has two standards associated with asbestos to address worker protection associated with
Site operations:
• General Industry Standard (29 CFR 1910.1001) - covers routine housekeeping activities
in buildings and automotive brake and clutch repair and applies to protection of office
workers, housekeeping staff, and service employees.
• Construction Standard (29 CFR 1926.1101) - covers work activities associated with
demolition and renovation operations and other activities where asbestos is removed or
encapsulated and applies to building maintenance and repair activities and emergency
cleanup of asbestos spills.
4.2 North Carolina Regulations
The two state government agencies responsible for regulations regarding exposure to asbestos are
the North Carolina Department of Health and Human Services (DHHS) Occupational and
Environmental Epidemiology HHCU and the North Carolina Department of Labor. A summary of
the regulations associated with these state agencies is presented below.
HHCU
• Asbestos Hazard Management Program (AHMP) is established under N.C. General
Statute § 130A-444 through 452 - Asbestos Hazard Management
The North Carolina Asbestos Hazard Management Program (AHMP), administered by
HHCU, provides information to the public, to schools, and to business and industry about this
health hazard and the proper ways to control or eliminate possible asbestos contamination and
exposure.
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The AHMP also accredits individuals performing asbestos management activities such as
inspection, design, and removal; approves asbestos training courses; issues permits for
asbestos removal projects; issues demolition notifications; inspects asbestos removal projects;
implements the management of ACMs in schools; and investigates citizens' complaints.
NC Department of Labor
The NC Department of Labor has adopted the federal OSHA General Industry Standard
(29 CFR 1910.1001) and the Construction Standard (29 CFR 1926.1101) regulations and is
responsible for their enforcement of worker protection in the State.
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5.0 Responsibilities of the Asbestos Coordinator
An individual shall be appointed to act as the Asbestos Coordinator to supervise the implementation
of this O&M Plan and serve as the Site representative on asbestos -related matters associated with
the Site buildings. The Asbestos Coordinator duties shall include:
• Coordinating maintenance, repair, renovation, or demolition activities to the extent that
they affect ACMs. The Asbestos Coordinator will be the project manager for asbestos
abatement projects performed in the Site buildings.
• Scheduling and documenting annual training required by OSHA for Site employees.
• Notifying contractors and tenants that perform work in the Site buildings covered by the
O&M Plan of the presence and location of ACMs within the buildings prior to proposing
the project, during pre -construction meetings, and prior to initiating work that could
potentially impact the ACMs. Notification should be documented and kept with O&M
records for the building.
• Scheduling and coordinating annual re -inspections for the Site buildings covered by the
O&M Plan.
• Coordinating emergency response to asbestos fiber release episodes with licensed
asbestos contractors.
• Recordkeeping requirements necessary for this O&M Plan including maintaining:
➢ updated facility re -inspection records;
➢ reports and documents from asbestos survey, abatement, and repair activities
conducted at the Site buildings included in the O&M Plan including permits,
notifications, contractor information, documentation of medical surveillance and
respiratory protection, daily logs, air monitoring data, waste manifests, and project
closure reports; and
➢ training records for Site maintenance employees including certificates indicating
successful completion of a 2-hr awareness training for Site maintenance employees
and the Asbestos Coordinator's successful completion of 16 hrs of O&M training (2
hrs awareness plus 14 hrs O&M -specific training).
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The Asbestos Coordinator will receive renovation and maintenance activity requests from
Building maintenance employees and /or contractors for planned, unplanned, and emergency
repair activities that will require removal, repair, maintenance, and cleanup of ACM. A
summary of the Asbestos Coordinators project coordination activities is presented as follows:
➢ Planned Renovation Requests - occur when building maintenance employees or
contractors submit a request within a timeframe that allow for the Asbestos Coordinator
to develop an appropriate plan to address the ACM, and obtain competitive bids from
multiple approved asbestos abatement contractors.
➢ Unplanned Renovation Requests — occur when building maintenance employees or
contractors submit a request within an expedited timeframe that will allow for the
Asbestos Coordinator to develop an appropriate plan to address the ACM; however, the
expedited timeframe may or may not be sufficient to obtain competitive bids from
multiple asbestos abatement contractors.
➢ Emergency Repairs — in response to an emergency fiber release event, the Asbestos
Coordinator selects an appropriate response action and selects an asbestos abatement
contractor from a pre -approved list of vendors.
The above activities will be conducted by approved and NC licensed asbestos abatement
contractors. Air monitoring and clearance testing may also be required by approved and NC -
Licensed asbestos air monitors. Specifications for asbestos abatement contractors and air
monitors are presented in Section 12.0.
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6.0 Notification Requirements
Once the presence of AGMs has been established in a facility, maintenance employees, contractors,
and building tenants should be notified of the presence of ACMs (if present in their building) and
provide them with basic information to avoid disturbing ACMs. Notification of building tenants
and visitors who are less likely to disturb the ACMs can be accomplished by distribution of notices,
posting of signage, and/or scheduling informational seminars. Notification to employees and
contractors will be managed via coordination with the Asbestos Coordinator and review of the
O&M Plan. Labels will be affixed to ACMs where practical. Labels will contain warning
statements about breathing asbestos fibers and will be printed in large bold letters on a contrasting
background. The labels will bear the following industry specific information:
DANGER
CONTAINS ASBESTOS FIBERS
AVOID CREATING DUST
CANCER AND LUNG DISEASE HAZARD
Warning signs may be posted in lieu of labels so long as they contain the required information.
Signs will also be posted at entrances to mechanical rooms and/or areas where employees may
contact surfacing or thermal system insulation.
Warning signs may also be used to demarcate regulated areas. Regulated areas are defined as areas
where Class I, II, and III asbestos work is conducted; any adjoining area where debris and waste
from asbestos work accumulates; and a work area within which airborne concentrations of asbestos
exceed, or there is a reasonable possibility that they may exceed, the permissible exposure limit
(PEL). The warning signs shall bear the following industry specific information to demark an
area if ACMs or PACMs have or will be disturbed:
DANGER
ASBESTOS
CANCER AND LUNG DISEASE HAZARD
AUTHORIZED PERSONNEL ONLY
RESPIRATORS AND PROTECTIVE CLOTHING ARE
REQUIRED IN THIS AREA
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If an outside contractor has the potential to directly contact ACM, the Asbestos Coordinator will
verify that the contractor is familiar with this O&M Plan and has experience and the appropriate
level of training for working with ACM. The Asbestos Coordinator will approve, schedule, and
oversee maintenance activities performed by outside contractors.
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7.0 Training and Responsibilities of Employees, Contractors, and Tenants
Tramm
Training for building maintenance employees who will perform renovation, repair, maintenance,
and custodial activities where the employees will contact but will not disturb ACMs (Class IV work
activities) will consist of 2-hr awareness training. Training for the Asbestos Coordinator
(component person) will consist of a 16-hr AHERA-OSHA O&M Class III Worker training class.
Responsibilities of Employees and Contractors
As stated previously in Section 1.0, the Asbestos O&M Plan does not allow building maintenance
employees to remove, repair, or conduct maintenance operations that will disturb identified ACMs
or PACMs, or cleanup of dust, waste, or debris from ACMs or PACMs. These activities are
generally characterized as Class I, II, III, and some Class IV work. In accordance with the O&M
Plan, these activities will be performed by a licensed asbestos abatement contractor. A summary of
OSHA classes of work, training requirements, and work activities allowed under the O&M Plan to
perform these activities is presented in the following table.
CLASS OF WORK DEFINED
TRAINING
WORK PERFORMED BY
REQUIREMENTS
Class I : Thermal/Surfacing ACMs
40-HR
LICENSED ASBESTOS
Removal
CONTRACTOR/
ABATEMENT CONTRACTOR
SUPERVISOR
32-HR WORKER
Class II: Removal of Dry Wall, Floor
40-HR
LICENSED ASBESTOS
Coverings, Transite, Construction
CONTRACTOR/
ABATEMENT CONTRACTOR
Mastics
SUPERVISOR
(i.e., Non Thermal/Surfacing
8-HR WORKER
ACMs
Class III: Repair/Maintenance Operations
16-HR O&M WORKER
LICENSED ASBESTOS
<_ one glove bag or disposal bag
ABATEMENT CONTRACTOR
60"
Class IV: Asbestos Dust, Waste, and Debris
2-HR AWARENESS
LICENSED ASBESTOS
Clean -Up
ABATEMENT CONTRACTOR
(for cleanup of ACM contaminated
dust, waste, or debris)
Routine Maintenance
2-HR AWARENESS
BUILDING MAINTENANCE
EMPLOYEES (for routine
maintenance where employee will
contact but will not disturb the
AC
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It is critical that employees, contractors, and tenants have adequate information regarding the
presence and location of ACMs in the buildings. Therefore, the Asbestos Coordinator will maintain
a copy of the updated O&M Plan manual with re -inspection records in his/her office, which will be
made readily available for review to employees, contractors, and tenants upon request.
It is important that the building maintenance employees, contractors, and tenants understand the
location of ACMs within the buildings where they are working and to protect themselves against
exposure to airborne asbestos fibers that could be disturbed during maintenance or renovation
activities. Therefore, building maintenance employees and contractors shall implement the
following protocols as part of the standard operating procedures.
1. Prior to initiating any renovation, maintenance, or housekeeping activity, the building
maintenance employee, contractor, or tenant will review the O&M Plan manual with the
Asbestos Coordinator for potential ACMs which may be disturbed by the scheduled
renovation/maintenance activity. If no ACMs will be impacted, the renovation or
maintenance activity can proceed.
2. If ACMs are present and will be impacted, the Asbestos Coordinator will plan a response
action prior to conducting the renovation or maintenance activity.
3. If it is not clear whether ACMs will be disturbed by scheduled renovation or maintenance
activity, the Asbestos Coordinator will contact H&H for clarification.
As discussed previously in Section 4.0, the Asbestos Coordinator will supervise the implementation
of this O&M Plan including coordination of asbestos removal, maintenance/repair, and cleanup
activities, and will serve as the representative on asbestos -related matters associated with the
buildings. The Asbestos Coordinator will also verify that employees performing the activities have
the proper training for the type of work being performed.
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8.0 Surveillance and Periodic Inspections
In the event that damage or deterioration to ACMs is identified during routine maintenance
activities, maintenance employees, contractors, and tenants should report this information to the
Asbestos Coordinator immediately.
Inspections
ACMs in the buildings and areas covered by this O&M Plan will be visually inspected for
damage and current condition on an annual basis by an independent NC -licensed asbestos
inspector designated by the Asbestos Coordinator. The annual assessment will consist of
1. visual inspection of the ACMs present in the buildings, and
2. documentation of the condition on the re -inspection reports that will be included in the
updated O&M Plan report maintained by the Asbestos Coordinator.
The re -inspection reports that document H&H's most recent re -inspection of the buildings are
attached to the back of this document in Appendix A.
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9.0 General Work Practices and Prohibited Activities
In accordance with the OSHA General Industry Standard 29 CFR 1910.1001, routine
maintenance and housekeeping activities in the area of ACMs or PACMs will include the
following work practices:
All surfaces shall be maintained as free as practicable of ACM waste and debris and
accompanying dust.
• All spills and sudden releases of material containing asbestos shall be isolated, the
Asbestos Coordinator should be notified, and the ACM shall be cleaned up by an
asbestos abatement contractor as soon as possible.
• Surfaces potentially contaminated with asbestos debris may not be cleaned by use of
compressed air.
• HEPA-filtered vacuuming equipment shall be used for vacuuming any potentially friable
building materials that contain asbestos. The equipment shall be used and emptied in a
manner which minimizes the reentry of asbestos into the workplace.
All vinyl and asphalt flooring material that contain asbestos must be maintained in accordance
with the following conditions:
• Sanding flooring material is prohibited.
• Employees stripping finishes must use wet methods and low abrasion pads at speeds
lower than 300 revolutions per minute (rpms).
Burnishing or dry buffing may be done only on flooring with enough finish that the pad
cannot contact the flooring material.
• Employees must not dust, dry sweep, or vacuum without a HEPA filter in an area
containing thermal system insulation or surfacing material or visibly deteriorated ACM.
18 ■
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SMARTER ENVIRONMENTAL 50LUT10H5

10.0 Emergency Response Procedures
Damage or rapid deterioration of ACMs and a fiber release may occur within the Site buildings as a
result of an emergency event such as a fire, water damage, unplanned construction/renovation
activities, or a natural/catastrophic disaster. In the event of an emergency occurrence and fiber
release episode, the following procedures must be implemented by the Asbestos Coordinator:
1. All employees, contractors, and visitors will be evacuated from the area.
2. Entry into the area will be restricted using a physical barrier; danger signs will be posted
to prevent entry into the area by unauthorized persons; and doors, windows, and
penetrations into the affected area will be sealed using plastic and duct tape.
3. The air handling system will be shut down or modified to prevent the distribution of
fibers to other areas of the building.
4. A licensed asbestos abatement contractor will be contacted by the Asbestos Coordinator
to perform cleanup, abatement, and/or repair as warranted. Air sampling will be
conducted, as required.
5. A written report will be prepared including date and time of fiber release, name of
person discovering debris and actions taken to will be given to and maintained by the
Asbestos Coordinator. A copy of a Fiber Release Episode/Response Action Report form
for use in the event of a fiber release incident is included in Appendix C.
All work carried out in response to the emergency occurrence will conform to the requirements set
forth in all applicable federal, state, and local regulations.
19 ■
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SMARTER ENVIRONMENTAL SOLUTIONS

11.0 Recordkeeping Requirements
The following section details the recordkeeping requirements necessary for this O&M Plan:
1. Training Records - A list of employees attending the 2-hr Awareness Training for
maintenance workers and the Asbestos Coordinator's successful completion of an
operations and maintenance training course will also be kept on file for a minimum of
one year from termination of employment. Asbestos contractors performing work at the
site shall also be required to maintain these records.
2. Emergency Fiber Release Episode Document - Should a fiber release episode occur, the
following information will be included in this Program:
- Date of episode;
- Location of episode;
- Method of repair;
- Response action taken;
- Name, address and telephone number of person/company perfonning work;
- Waste disposal site and manifest (if applicable); and
- Air sampling information (if applicable).
A copy of an Emergency Fiber Release Episode form is included in Appendix C.
3. Annual Inspection Records - A record of visual inspections performed during the annual
inspection and the Asbestos Coordinator will maintain the annual inspection records (see
Appendix A). During inspection, the following information will be recorded:
- Date of inspection;
- Name, address and telephone number of person performing inspection;
- Record of visual observations; and
- Record of appropriate response action.
20 ■
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SMARTER ENVIRONMENTAL SOLUTIONS

4. Asbestos Survey Reports — In the event that additional buildings or areas are added to
the O&M Plan, an asbestos survey will be completed on the buildings and the results
will be incorporated into the O&M Plan.
5. Asbestos Abatement Documents — The Asbestos Coordinator shall maintain documents
related to asbestos abatement activities performed by licensed asbestos abatement
contractors. Contractors will provide a report that documents asbestos abatement
activities, permits, worker and supervisor licenses, medical surveillance records, waste
manifests, and air monitoring data.
21 44
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SMARTER ENVIRONMENTAL SOLUTIONS

12.0 Specifications for Asbestos Abatement Contractors and Consultants
12.1 Asbestos Abatement Contractor's Requirements
1. The Abatement Contractor shall make all necessary written notifications to
appropriate regulatory agencies.
2. The Abatement Contractor shall perform asbestos abatement activities in accordance
with all applicable government regulations.
The above constitute the major specifications for abatement projects. The specifications outlined
below are included to ensure that the designated representative is provided with the minimum
necessary documentation for record keeping and to inform the Abatement Contractor of
additional work practices not previously detailed.
Prior to Project Start
1. The Abatement Contractor shall review the proposed abatement plan/project design
with the Asbestos Coordinator.
2. All workers performing asbestos abatement shall be thoroughly trained and licensed
in proper work practices for asbestos removal and respiratory protection
requirements. Proof of such training (including respirator fit and leak tests and
medical examination to ascertain physical fitness to wear respiratory protection) shall
be made available to the Asbestos Coordinator.
3. A written list of all Abatement Contractor's employees performing asbestos
abatement on a project shall be made available to the Asbestos Coordinator.
4. A copy of the Abatement Contractor's State of North Carolina license shall be made
available to the Asbestos Coordinator.
22 44
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SMARTER ENVIRONMENTAL SOLUTIONS

During Removal Activities
1. The Abatement Contractor shall have a supervisor (competent person) on duty at all
times while work is in progress.
2. The Abatement Contractor shall assume that all equipment and furniture observed
during the pre -bid inspection will still be in place during asbestos removal and will
first have to be completely wrapped and sealed with a minimum one (1) layer of 6-
mil polyethylene. The Abatement Contractor shall then construct double walled
containment area and shall provide his employees with necessary shower facilities
and clean rooms.
3. The Abatement Contractor shall provide his/her own HEPA wet/dry vacuums and
HEPA filtered negative air machines in sufficient quantity. Such equipment shall be
supplied with new filters prior to project commencement and inspected regularly each
day.
4. The Abatement Contractor shall ensure that his workers will wear appropriate
NIOSH-approved respiratory protection at all times while performing asbestos
abatement activities.
5. All asbestos waste materials shall be doubled bagged in 6-mil polyethylene bags and
properly disposed of in an approved landfill. All waste receipts of disposal shall be
made available to the building owner's representative.
6. Personal air monitoring of workers during abatement activities will be the Abatement
Contractor's responsibility. Air sampling results shall be made available to the
building owner's representative.
23 ■
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SMARTER ENVIRONMENTAL SOLUTIONS

Post -Removal Activities
1. The work area shall be thoroughly cleaned using a combination of wet wiping and
HEPA vacuuming to remove all visible accumulations of asbestos.
2. After cleaning, work surfaces from which asbestos is removed shall be sprayed with a
light coat of encapsulate to seal residual asbestos fibers.
3. The Air Monitor will conduct a visual site inspection and air clearance monitoring
(when required per NESHAP). The Asbestos Coordinator will not release the
Abatement Contractor until the Air Monitor accepts the cleaning as sufficient by
visual inspection and clearance monitoring indicates airborne asbestos concentrations
of less than 0.01 Pee. An independent third parry not associated with the Abatement
Contractor must conduct clearance monitoring.
Waste Disposal
The Abatement Contractor will be responsible for the transportation and disposal of asbestos
waste materials at an approved landfill.
12.2 Specifications for Air Monitoring During Asbestos Abatement
A licensed Air Monitor consultant (when required per NESHAP) will sample the air during the
abatement activities and to ensure compliance with applicable OSHA requirements. Specific
responsibilities shall also include:
1. Conduct background air monitoring in the removal area prior to the Abatement
Contractor's arrival at the work site.
2. Inspect the asbestos containment constructed by the Abatement Contractor prior to
the commencement of removal activities. Advise the Abatement Contractor of any
24 44
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SMARTER ENVIRONMENTAL 50LUT10H5

problems or deficiencies and ensure their correction before giving approval to the
Abatement Contractor to begin removal.
3. Observe the Abatement Contractor's work practices and procedures. The Air
Monitor will recommend that the job be stopped if, in their opinion, proper work
practices are not being followed or if the integrity of the regulated areas has been
compromised.
4. Monitor the air outside regulated areas during removal activities. The Air Monitor
will recommend that the job be stopped if the monitoring indicates airborne
concentrations of asbestos fibers exceed 0.05 fibers/cc outside the containment area.
All removal activities will cease until the problem is resolved to the satisfaction of the
Air Monitor.
5. Check the Contractor's monitoring of his own employees by conducting random
monitoring of the Abatement Contractor's employees inside the regulated areas
during removal activities. The Air Monitor will recommend that the job be stopped if
breathing zone samples are found to exceed the protection factor of the respirators
worn by the Abatement Contractor's employees. If such conditions should occur, it
will be the Abatement Contractor's responsibility to alter work practices and
procedures to reduce airborne concentrations to acceptable levels or else issue
employees' respirators with a sufficient protection factor.
6. Make a visual inspection of the work area after final cleaning and conduct clearance
air monitoring. The Air Monitor will recommend that the Abatement Contractor re-
clean the area if visual inspection is not satisfactory or if clearance air samples exceed
0.01 fibers/cc.
7. Provide the facility's Asbestos Coordinator with a written report upon completion of
the project. This report shall include results of all air sampling and a detailed
evaluation of the Abatement Contractor's work practices and overall performance.
25 44
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SMARTER ENVIRONMENTAL 50LUT10H5

Table 1
Former Erwin Mills Facility
200 N. 1311 Street
Erwin, North Carolina
H&H Job No. BRP-001
Approx. Size
ACMs Currently
Types of ACMs Currently Present in the Building
Building/Area
(square ft)
Present in the Building
(see Inspection Records -Appendix A)
Yes/No?
Building 1
238,000
Yes
wall mastic, waterproofing, wall surfacing, flooring,
and TSI
Building 2
113,000
Yes
flooring, textured sink material, TSI, HVAC mastic,
cementitious paneling, and roofing
Building 3
190,000
Yes
fan unit mastic, caulking, pipe mastic, TSI, HVAC
coating, cementitious paneling, and roofing
Building 4
167,000
Yes
flooring, textured sink material, window glazing,
TSI, cementitious paneling, and roofing
Building 5
200,000
Yes
flooring, TSI, air handler tar, cementitious paneling,
and roofing
Building 6
40,000
Yes
door caulk, window glazing, TSI, cementitious
paneling, and roofing
Building 7
32,000
Yes
TSI and roofing
Building 8
31,600
Yes
TSI and roofing
Building 9
27,600
Yes
flooring and roofing
Ammonia Storage Building
3,100
Yes
roofing
Boiler House
5,100
Yes
gasket, window glazing, TSI, and roofing
Debris Pile Adjacent to Boiler House
--
No
none (asbestos -containing roofing debris
removed May -June 2020
Fire Pump Room and Tank
350
No
none identified during initial asbestos survey
Pump House
650
No
none identified during initial asbestos survey
Guard House
100
No
none identified during initial asbestos survey
Coal Silos
--
No
none identified during initial asbestos survey
Notes:
• ACMs = Asbestos -Containing Materials
• TSI = Thermal System Insulation
• HVAC = Heating, Ventilation, and Air Conditioning
• H&H conducted the initial asbestos surveys of the Site buildings on December l 6-20, 2019 and January 6-9, 2020

APPROXIMATE TITLE
N 0 2000 4000 SITE LOCATION MAP
SCALE IN FEET PROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
U.S.G.S. QUADRANGLE MAP ' 3921 Sunset Ridge Road, Suite 301
hart '"e•l hickman Raleigh, North Carolina 27607
. 919-847-4241 (p) 919-847-4261 (f)
ERWIN, NORTH CAROLINA 1997 SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
QUADRANGLE DATE: 1-17-20 REVISION NO: 0
7.5 MINUTE SERIES (TOPOGRAPHIC)
JOB NO: BRP-001 FIGURE: 1

T
i
LEGEND
h--'1
11
--
:1BUILDING
1 INTERIOR AND EXTERIOR WALLS
-
-
©
POSITIVE ASBESTOS SAMPLE LOCATION
9 18
ASBESTOS -CONTAINING BLACK WALL MASTIC
ASBESTOS -CONTAINING BLACK WATERPROOFING
ASBESTOS -CONTAINING BLOCK SURFACING
ASBESTOS -CONTAINING 12" x 12", BLACK VINYL
FLOOR TILE AND ASSOCIATED BLACK MASTIC
ASBESTOS -CONTAINING 12-INCH PIPE ELBOW
JACKET
ASBESTOS -CONTAINING 4-INCH PIPE INSULATION
AND/OR JACKET
ASBESTOS -CONTAINING FIRE DOOR INSULATION
1 ST FLOOR i
I BASEMENT
FLOOR
T
APPROXIMATE
0 50 100
SCALE IN FEET
TITLPOSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 1 INTERIOR)
PROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
hart ■ 2923 South Tryon Street -Suite 100
h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f
SMARTER ENVIRONMENTAL SOLlMON5 License # C-1269 / #C-245 Geology
DATE: 1-17-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 3

LEGEND
BUILDING 2 INTERIOR AND EXTERIOR WALLS
Q POSITIVE ASBESTOS SAMPLE LOCATION
ASBESTOS -CONTAINING SHEET FLOORING
\ ASBESTOS -CONTAINING 12" x 12", RED VINYL
FLOOR TILES AND ASSOCIATED BLACK MASTIC
BENEATH NON -ASBESTOS CONTAINING 12" x 12"
DARK BLUE VINYL FLOOR TILES
ASBESTOS -CONTAINING 6-INCH PIPE INSULATION
ASBESTOS -CONTAINING 4-INCH PIPE INSULATION
AND/OR ELBOW
\\ ASBESTOS -CONTAINING 9" x 9", TAN VINYL FLOOR
TILE AND ASSOCIATED BLACK MASTIC
�D ASBESTOS -CONTAINING FIRE DOOR INSULATION
ASBESTOS -CONTAINING TAN MASTIC AND RED AND
YELLOW MOSAIC PATTERN SHEET FLOORING
ASBESTOS -CONTAINING BROWN DOOR TRANSITION
8
APPROXIMATE
0 50 100
SCALE IN FEET

LEGEND
BUILDING 3 INTERIOR AND EXTERIOR WALLS
ADJACENT BUILDING WALLS
D O POSITIVE ASBESTOS SAMPLE LOCATION
ASBESTOS -CONTAINING BLACK AND GRAY MASTIC
IDENTIFIED ON NON -ASBESTOS -CONTAINING 2-INCH
PIPE INSULATION
T ASBESTOS -CONTAINING 6-INCH PIPE ELBOW
�I JACKET
ASBESTOS -CONTAINING 12-INCH PIPE JACKET
1ST FLOOR ASBESTOS -CONTAINING 4-INCH STEAM PIPE
INSULATION
ASBESTOS -CONTAINING BLACK MASTIC ON
FANHOUSE EQUIPMENT
ASBESTOS -CONTAINING FIRE DOOR
I
2ND FLOOR
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 3 - NORTHERN INTERIOR)
FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
` hart h i c k ma n 2923 South Tryon Street -Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
SMARTER ENVIRONMENTAL SOLLMONS License # C-1269 / #C-245 Geology
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.004 FIGURE NO. 7

LEGEND
BUILDING 3 INTERIOR AND EXTERIOR
WALLS
© POSITIVE ASBESTOS SAMPLE LOCATION
ASBESTOS -CONTAINING FIRE DOOR
ASBESTOS -CONTAINING 6" MUDDED
ELBOW MATERIAL
ASBESTOS -CONTAINING 4-INCH STEAM
PIPE INSULATION
D
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 3 - SOUTHERN INTERIOR)
112,IF�T FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
` hart h i c k ma n 2923 South Tryon Street -Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
SMARTER ENVIRONMENTAL SOLLMONS License # C-1269 / #C-245 Geology
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 8

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LEGEND
1..� .
BUILDING 3 EXTERIOR WALLS
• �'�
© POSITIVE ASBESTOS SAMPLE LOCATION
.•
� •�
d ♦!
ASBESTOS —CONTAINING EQUIPMENT CAULK
J•t
APPROXIMATE LOCATION OF ASBESTOS -CONTAINING
N .
ROOF FLASHING, TAR, AND SILVER PAINT
• :' ",
APPROXIMATE LOCATION OF ASBESTOS —CONTAINING
CEMENTITIOUS PANELING
APPROXIMATE LOCATION OF ASBESTOS —CONTAINING
ROOF FLASHING FELT PAPER
•,�. 4
.+M1 ..
` ' •� �T '
APPROXIMATE LOCATION OF ASBESTOS —CONTAINING
HVAC DUCT COATING
• �.: tip.N!
APPROXIMATE LOCATION OF ASBESTOS —CONTAINING
CEMENTITOUS PANELS
, W"�f
s rl..N 6 m.
�r
T
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 3 EXTERIOR)
'ROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
■ 2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North CaroFina 28203
704-586-0007(p) 704-586-0373(f
SMARTER ENVIRONMENTAL SOLLMONS License # C-1269 / #C-245 Geology
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 9

L
LEGEND
BUILDING 4 INTERIOR AND EXTERIOR WALLS
O POSITIVE ASBESTOS SAMPLE LOCATION
ASBESTOS -CONTAINING 12" x 12", TAN VINYL FLOOR
TILES
ASBESTOS -CONTAINING WINDOW GLAZING
ASBESTOS -CONTAINING 6" MUDDED ELBOW
~� MATERIAL
ASBESTOS -CONTAINING 4-INCH STEAM PIPE
INSULATION
ASBESTOS -CONTAINING BLACK MASTIC IDENTIFIED
BENEATH NON -ASBESTOS -CONTAINING 12" x 12x,
BLUE VINYL FLOOR TILE
ASBESTOS CONTAINING WHITE TEXTURED SINK
MATERIAL
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 4 INTERIOR)
---- FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
` hart h i c k ma n 2923 South Tryon Street -Suite 100
Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
SMARTER ENVIRONMENTAL SOLLMONS License # C-1269 / #C-245 Geology
DATE: 2-7-20
REVISION NO. 0

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LEGEND
BUILDING 4 EXTERIOR WALLS
© POSITIVE ASBESTOS SAMPLE LOCATION
_ APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING ROOF FLASHING FELT
PAPER
APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING CORRUGATED
CEMENTITIOUS PANELING
APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING ROOF TAR
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 4 EXTERIOR)
I— IFC.T FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
It 2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f)
SMARTER ERVIRONMENTAL SOLlMCNS License # C-1269 / #C-245 Geology
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 11

2
H.
r
BUILDING 5 INTERIOR AND EXTERIOR WALLS
ADJACENT BUILDING WALLS
O
POSITIVE ASBESTOS SAMPLE LOCATION
ASBESTOS -CONTAINING 1-INCH PIPE ELBOW
ASBESTOS -CONTAINING 2-INCH PIPE INSULATION
AND/OR ELBOW
ASBESTOS -CONTAINING 6-INCH STEAM PIPE
INSULATION
ASBESTOS -CONTAINING 9-INCH STEAM PIPE
E----- i
INSULATION
ASBESTOS -CONTAINING BLACK MASTIC IDENTIFIED
BENEATH NON -ASBESTOS -CONTAINING 12" x 12",
TAN VINYL FLOOR TILES
ASBESTOS -CONTAINING 12" x 12", TAN VINYL FLOOR
TILES
BROWN, ASBESTOS -CONTAINING MOSAIC PATTERN
SHEET FLOORING
ASBESTOS -CONTAINING 12" x 12", TAN VINYL FLOOR
TILES AND ASSOCIATED BLACK MASTIC BENEATH
X
CARPET
ASBESTOS -CONTAINING TAN FELT BACKING
IDENTIFIED BENEATH NON -ASBESTOS CONTAINING
12" x 12", GRAY AND 12" x 12", TAN VINYL FLOOR
TILES AND ASSOCIATED BLACK AND TAN MASTIC
ASBESTOS -CONTAINING BLACK MASTIC IDENTIFIED
BENEATH NON -ASBESTOS -CONTAINING 12" x 12",
TAN VINYL FLOOR TILE
ASBESTOS -CONTAINING FIRE DOOR INSULATION
0
APPROXIMATE
0 50 100
SCALE IN FEET
TITLPOSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDING 5 INTERIOR)
PROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
darthickman 292dorte, Trvon ',hCar Carolina
L Charlotte, 1\arrh Carolina 28203
704-586-0007(p) 704-586-0373(fl
SMARTER ENVIRONMENTAL SCLlMCNS License # C-1269 / #C-245 Geologc
DATE: 1-17-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 12
a
a
a

BUILDING 8
. 2 T L
LEGEND
BUILDING 6 & 8 INTERIOR AND EXTERIOR WALLS
Q POSITIVE ASBESTOS SAMPLE LOCATION
BUILDING 6 MATERIAL:
ASBESTOS -CONTAINING DOOR CAULK
ASBESTOS -CONTAINING 1-INCH PIPE INSULATION
AND/OR ELBOW
ASBESTOS -CONTAINING WINDOW GLAZING
BUILDING 8 MATERIAL:
ASBESTOS -CONTAINING 1-INCH PIPE ELBOW JACKET
ASBESTOS -CONTAINING 2-INCH PIPE ELBOW JACKET
0
APPROXIMATE
50 100
SCALE IN FEET

I
I
1
BUILDING 6
�t
■
LEGEND
BUILDING 6 OR 8 EXTERIOR WALLS
O POSITIVE ASBESTOS SAMPLE LOCATION
APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING CEMENTITIOUS PANELING
APPROXIMATE EXTENT OF ASBESTOS -CONTAINING
ROOF TAR AND SILVER PAINT
APPROXIMATE EXTENT OF ASBESTOS -CONTAINING
ROOF FELT PAPER
APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING ROOF FLASHING FELT
PAPER
APPROXIMATE LOCATION OF
ASBESTOS -CONTAINING ROOF SEAM TAR
r, * BUILDI'NG8' ,
APPROXIMATE
�• a ��� =��`, �� " 0 50 100
1.f.. • J G - is _ - Lam" _ _ SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
�. (BUILDING 6&8 EXTERIOR)
A PROJECT FORMER ERWIN MILLS FACILITY
L } 200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
2923 South Tryon Street -Suite 100
\l� hart ",• h i c k m a n Charlotte, North Carolina 28203
■ 704-586-0007(p) 704-586-0373(f
_ ; ♦ SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
R
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 15

LEGEND
BUILDING 6 & 8 INTERIOR AND EXTERIOR WALLS
POSITIVE ASBESTOS SAMPLE LOCATION
BUILDING 7 MATERIAL:
ASBESTOS -CONTAINING 2-INCH PIPE ELBOW JACKET
BUILDING 9 MATERIAL:
ASBESTOS -CONTAINING 12" x 12", TAN VINYL FLOOR
TILE AND ASSOCIATED BLACK MASTIC
E:1
1
BUILDING 9
APPROXIMATE
0 50 100
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BUILDINGS 7 & 9 INTERIOR)
PROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
hart t h i c k ma n 2923 south Tryon Street -Suite 2 2 100
Charlotte, North Carolina 28203
3
704-586-0007(p) 704-586-0373(f)
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 1-17-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 1
BUI
DING 7

LEGEND
BOILER HOUSE INTERIOR AND EXTERIOR WALLS
O POSITIVE ASBESTOS SAMPLE LOCATION
DASBESTOS-CONTAINING BOILER PIPE GASKET
ASBESTOS -CONTAINING 4-INCH CONDENSATE PIPE
MUDDED ELBOW
1ST FLOOR
o a ® a
2ND FLOOR
APPROXIMATE
0 50 100
SCALE IN FEET
TITLPOSITIVE ASBESTOS SAMPLE LOCATION MAP
(BOILER HOUSE INTERIOR)
PROJECT FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
■ 2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p) 704-586-0373(f
SMARTER ENVIRONMENTAL SOLUTIONS License # C-1269 / #C-245 Geology
DATE: 1-17-20 REVISION NO. 0
JOB NO. BRP.001 FIGURE NO. 19

I
4
M
�
LEGEND
~
•
BOILER HOUSE EXTERIOR WALLS
POSITIVE ASBESTOS SAMPLE LOCATION
r- ,
APPROXIMATE LOCATION OF ASBESTOS -CONTAINING
•
ROOF FLASHING FELT PAPER
•
�w
APPROXIMATE LOCATION OF ASBESTOS -CONTAINING
`
ROOF FLASHING TAR AND FELT PAPER
APPROXIMATE LOCATION OF ASBESTOS -CONTAINING
WINDOW GLAZING
der.
4w * �
7-1
ate♦ •
fN t.M ev,
.,�.`_�► -rat
ti�+a
Fj
t
I
40
8
APPROXIMATE
0 20 40
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(BOILER HOUSE EXTERIOR)
`RWE`T FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
is2923 South Tryon Street -Suite 100
hart h i c k m a n Charlotte, North Carolina 28203
704-586-0007(p)704-586-0373(f
t ` SMARTER ENVIRONMENTAL SOLLMONS License # C-1269 / #C-245 Geology
d ' DATE: 2-7-20 REVISION NO. 0
1�
JOB NO. BRP.001 FIGURE NO. 20

i
w-0
. * ► Y LEGEND
FIRE PUMP HOUSE EXTERIOR WALLS
9
APPROXIMATE
0 20 40
SCALE IN FEET
POSITIVE ASBESTOS SAMPLE LOCATION MAP
(FIRE PUMP HOUSE EXTERIOR)
I- IFC.T FORMER ERWIN MILLS FACILITY
200 NORTH 13TH STREET
ERWIN, NORTH CAROLINA
hart h a c k m a n Char South Tryon Street -Stolen 282 100
Charlotte, North Carolina 28203
704-586-0007(p)704-586-0373(f)
SMARTER ERVIRONMENTAL SOLlMCNS License # C-1269 / #C-245 Geology
DATE: 2-7-20 REVISION NO. 0
JOB NO. BRP.001 I FIGURE NO. 21

Appendix A
Facility Re -Inspection Reports
■
hart F hickman
SMARTER ENVI RONMEWAL SOLLMONS

REINSPECTION REPORT
it
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 1
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
eastern building
entrance
Wall mastic (grey)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
eastern building
entrance breezeway
Waterproofing (black)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
_

REINSPECTION REPORT
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100
Charlotte, North Carolina 28203
Phone [phone]
Fax [phone]
Job Number:
BRP-001
Building:
Building 1
Address:
200 N. 13th Street Erwin, NC
Initial Inspection Date:
December 2019 - January 2020
Previous Reinspection Date:
Not Applicable
Reinspection Date:
June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
interior side of exterior
block wall surfacing
maintain ACM in
concrete block walls on
(white)
non -friable; good condition
O&M Program
not applicable
condition unchanged
a;
the ground floor
vinyl floor tile (12" x
maintain ACM in
northern office area
12", black) & mastic
non -friable; good condition
O&M Program
not applicable
condition unchanged
(black)

REINSPECTION REPORT
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100
Charlotte, North Carolina 28203
Phone [phone]
Fax [phone]
Job Number:
BRP-001
Building:
Building 1
Address:
200 N. 13th Street Erwin, NC
Initial Inspection Date:
December 2019 - January 2020
Previous Reinspection Date:
Not Applicable
Reinspection Date:
June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
ground floor fan
12-inch pipe elbow
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
0 ,
q
houses
jacket
O&M Program
northern fan houses on
1-inch pipe insulation
ACM TSI removed May
not applicable
not applicable
ACM TSI removed May
the ground floor
2020
2020
ti

REINSPECTION REPORT
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100
Charlotte, North Carolina 28203
Phone [phone]
Fax [phone]
Job Number:
BRP-001
Building:
Building 1
Address:
200 N. 13th Street Erwin, NC
Initial Inspection Date:
December 2019 - January 2020
Previous Reinspection Date:
Not Applicable
Reinspection Date:
June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
approximately 200 linear
overhead piping
friable; approximately 200
maintain ACM in
ft of damaged ACM TSI
throughout
4-inch pipe insulation
linear ft identified in
O&M Program
not applicable
removed May 2020;
damaged condition
remaining ACM TSI in
good condition
9
overhead piping
4-inch pipe insulation
ACM TSI removed May
not applicable
not applicable
ACM TSI removed Me
-
throughout
jacket
2020
2020
II
r

REINSPECTION REPORT
hart hickman
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100
Charlotte, North Carolina 28203
Phone [phone]
Fax [phone]
Job Number:
BRP-001
Building:
Building 1
Address:
200 N. 13th Street Erwin, NC
Initial Inspection Date:
December 2019 - January 2020
Previous Reinspection Date:
Not Applicable
Reinspection Date:
June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
basement
fire door insulation
friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
INSPECTOR:
Typed Name: Robert Sorgel
Signature: / G
NC Accreditation No: 13071
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: —
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
office in southeastern
portion of the building
sheet flooring (beige,
stone mosaic pattern)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
A
_ c.:c 3
on the ground floor
; AD
former laboratory area
in the southeastern
textured sink
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
portion of the building
material (black)
O&M Program
on the ground floor
.

REINSPECTION REPORT
hart � hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
southeastern office
vinyl floor tile (12" x
area beneath non -ACM
12", red) and mastic
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
`
12" x 12" dark blue
(black)
O&M Program
vinyl floor tiles
4� {;
L
overhead piping
maintain ACM in
ground floor and
6-inch pipe insulation
friable; good condition
O&M Program
not applicable
condition unchanged
IL11
basement

REINSPECTION REPORT
hart � hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
overhead piping
maintain ACM in
ground floor and
4-inch pipe insulation
friable; good condition
O&M Program
not applicable
condition unchanged
basement
overhead piping
maintain ACM in
ground floor and
4-inch pipe elbow
friable; good condition
O&M Program
not applicable
condition unchanged
bi
basement

REINSPECTION REPORT
hart � hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
.
southwestern portion of
vinyl floor tile (9" x 9",
maintain ACM in
r
the basement
tan) and mastic
non -friable; good condition
O&M Program
not applicable
condition unchanged
(black)
I
basement
fire door insulation
friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
` i

REINSPECTION REPORT
hart hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
office area in the
mastic (tan)
maintain ACM in
western portion of the
associated with non-
non -friable; good condition
O&M Program
not applicable
condition unchanged
ground floor
ACM brown cove base
office area in the
the
sheet flooring (red
maintain ACM in
v �r:� .•.: , .
C1
western portion of
and yellow mosaic
non -friable; good condition
O&M Program
not applicable
condition unchanged
;_ >
:�;
ground floor
pattern)

REINSPECTION REPORT
hart hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
office doorway in the
door transition
maintain ACM in
eastern portion of the
threshold (brown)
non -friable; good condition
O&M Program
not applicable
condition unchanged
ground floor
_
Zia
roof
HVAC equipment
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
mastic (black)
O&M Program
r

REINSPECTION REPORT
hart � hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof flashing (perimeter
roof flashing tar
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
and equipment)
O&M Program
.-
gravel roof connecting
Buildings 1 and 2
roof flashing tar/felt
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged

REINSPECTION REPORT
hart hickman 2
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 2
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
gravel roof connecting
Buildings 1 and 2
cementitious
paneling
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
INSPECTOR:
Typed Name: Robert Sorgel
Signature: / G
NC Accreditation No: 13071
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: —
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
fan house in the
mastic (black and
southeastern portion of
grey) associated with
non -friable; good condition
maintain ACM ins
not applicable
condition unchanged
the ground floor
non -ACM 2-inch pipe
O&M Program
insulation
fan houses on the
6-inch pipe elbow
maintain ACM in
ground floor and
jacket
non -friable; good condition
O&M Program
not applicable
condition unchanged
second floor

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
fan house in the
northeastern portion of
6-inch pipe elbow
ACM TSI removed May
not applicable
not applicable
ACM TSI removed May
the ground floor
jacket
2020
2020
fan house in the
maintain ACM in
southeastern portion of
12-inch pipe jacket
non -friable; good condition
O&M Program
not applicable
condition unchanged
the ground floor

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
behind panels on the
maintain ACM in
fan units within the fan
mastic (black)
non -friable; good condition
O&M Program
not applicable
condition unchanged
.;y...�
houses
fit!
exterior HVAC unit on
the western edge of
cementitious
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
�I
the building
paneling
O&M Program
��jj�]

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof fan house
caulking (white)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
rr
roof fan house
roof flashing silver
non -friable; damaged
maintain ACM in
not applicable
condition unchanged
paint
condition
O&M Program-
• -_

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof fan house
cementitious
paneling
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
i
northern gravel-
roof flashing tar and
non -friable; damaged
maintain ACM in
not applicable
condition unchanged
r
covered roof system
silver paint
condition
O&M Program

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
southern membrane-
roof flashing felt
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
covered roofs y stem
paper
O&M Program
roof HVAC ducts
HVAC duct coating
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
=

REINSPECTION REPORT
hart hickman 3
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 3
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof skylights
roof flashing felt
non -friable; damaged
maintain ACM in
not applicable
condition unchanged
~-
paper
condition
O&M Program
'^+�s ;•-•
INSPECTOR:
Typed Name: Robert Sorgel
Signature: / G
NC Accreditation No: 13071
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: —
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart � hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
former conference
4
room in the
moisture barrier
ACM moisture barrier
not applicable
not applicable
ACM moisture barrier
N'
northeastern portion of
removed May 2020
removed May 2020
the building_
_i
office in the
northeastern portion of
vinyl floor tile (12" x
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
the building
12", tan)
O&M Program
,s

REINSPECTION REPORT
hart hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
interior window in the
maintain ACM in
southeastern portion of
window glazing
non -friable; good condition
O&M Program
not applicable
condition unchanged
the building
overhead piping
throughout
4-inch elbow jacket
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged

REINSPECTION REPORT
hart hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
approximately 200 linear
I
overhead piping
4-inch steam pipe
friable; approximately 200
maintain ACM in
ft of damaged ACM TSI
throughout
insulation
linear ft identified in
O&M Program
not applicable
removed May 2020;
damaged condition
remaining ACM TSI in
good condition
office area in the
mastic (black)
southwestern portion of
associated with non-
ACM 12" x 12", blue
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
the building
vinyl floor tiles
y

REINSPECTION REPORT
hart hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
office area in the
southeastern portion of
textured sink
material
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
the building
roof -mounted fan
roof flashing felt
non -friable; damaged
maintain ACM in
not applicable
condition unchanged
houses
paper
condition
O&M Program

REINSPECTION REPORT
hart hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
northern built-up roof
roof flashing felt
non -friable; damaged
maintain ACM in
not applicable
condition unchanged
system
paper
condition
O&M Program
roof -mounted fan
corrugated
maintain ACM in
house
cementitious
non -friable; good condition
O&M Program
not applicable
condition unchanged
paneling

REINSPECTION REPORT
hart T hickman 4
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 4
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
eastern edge of the
maintain ACM in
building at a historical
roof tar
non -friable; good condition
O&M Program
not applicable
condition unchanged
__
roof seam
Y
INSPECTOR:
Typed Name: Robert Sorgel
Signature:
NC Accreditation No: 13071`
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: —
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart T hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
overhead piping
throughout
2-inch pipe insulation
friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
-
overhead piping
throughout
2-inch pipe elbow
friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
�,

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
overhead piping
1-inch pipe elbow
friable; good condition
maintain ACM in
not applicable
condition unchanged
orb
T
throughout
O&M Program
overhead piping
6-inch steam pipe
friable; good condition
maintain ACM in
not applicable
condition unchanged
lP
throughout
insulation
O&M Program

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
overhead piping
9-inch steam pipe
friable; good condition
maintain ACM in
not applicable
condition unchanged
throughout
insulation
O&M Program
office area in the north-
mastic (black)
associated with non-
maintain ACM in
,
central portion of the
ACM 12" x 12", tan
non -friable; good condition
O&M Program
not applicable
condition unchanged
rk
building
vinyl floor tiles
c m

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
office area in the north-
central portion of the
vinyl floor tile (12" x
12", tan)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
Nil
building
office area in the north-
central portion of the
sheet flooring (brown,
top layer) and vinyl
floor the (12" x 12"
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
- -
building
tan, bottom layer

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Material
Initial Assessment
Response
Previous Annual
2020 Annual
Functional Space
Description
(performed by H&H)
Action
Assessment
Assessment
Photograph
(performed by H&H)
felt backing layer
a
office area in the
(tan) associated with
maintain ACM in
r =-
\
southeastern portion of
non -ACM 12" x 12",
non -friable; good condition
O&M Program
not applicable
condition unchanged
•�
the building
grey and 12" x 12", tan
�t
_
vinyl floor tiles
-
office area in the+
mastic (black)
}
southeastern portion of
associated with non-
ACM 12" x 12", tan
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
the building
vinyl floor tiles

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
exterior walls of the
tar
maintain ACM in
~
roof air handler rooms
and silver paint
non -friable; good condition
O&M Program
not applicable
condition unchanged
northwestern
silver paint
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
membrane roof system
O&M Program

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Material
Initial Assessment
Response
Previous Annual
2020 Annual
Functional Space
Description
(performed by H&H)
Action
Assessment
Assessment
Photograph
(performed by H&H)
eastern roof system
roof -mounted fans
roof flashing tar and
felt paper
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
-
T
southwestern gravel
roof flashing tar and
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
roof system
felt paper
O&M Program
-

REINSPECTION REPORT
hart hickman 5
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 5
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
southwestern gravel
roof system wall
cementitious
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
between the higher
paneling
O&M Program
and lower levels
i
roof of the storage
building attached to the
roof tar and felt paper
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
of
western edge o
O&M Program
,r
Building 5
TW
INSPECTOR:
Typed Name: Robert Sorgel
Signature: C
NC Accreditation No: 13071G'�
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: -
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman s
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 6
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
door frame of unit 3-W
door caulk
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
'
Y
overhead piping
pipe insulation
friable; good condition
maintain ACM in
not applicable
condition unchanged
throughout
O&M Program

REINSPECTION REPORT
hart hickman s
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 6
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
southeastern portion of
the building
Pipe elbow insulation
friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
northern edge exterior
windows
window glazing
non -friable; good condition
maintain ACM in
O&M Programr'
not applicable
condition unchanged
�.._-_
X

REINSPECTION REPORT
hart hickman s
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 6
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
western -most super-
cementitious
maintain ACM in
structure located on
paneling
non -friable; good condition
O&M Program
not applicable
condition unchanged
the roof
western silver -painted
roof tar and silver
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
roofs y stem
paint
O&M Program
INSPECTOR:
Typed Name: Robert Sorgel
Signature: C
NC Accreditation No: 13071`'�
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: -
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman 7
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 7
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
northwestern portion of
the building
pipe elbow jacket
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
roof parapet walls
between the western
gravel -covered roof
roof flashing tar
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
systems
INSPECTOR:
Typed Name: Robert Sorge
Signature:
NC Accreditation No: 13071
Date: June 3. 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature:
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman $
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 8
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
overhead piping
1-inch pipe elbow
friable; good condition
maintain ACM in
not applicable
condition unchanged
IF
-.-
throu g
throughout
jacket
O&M Program
� f
4L -.
overhead piping
2-inch pipe elbow
friable; good condition
maintain ACM in
not applicable
condition unchanged
tiY
•-
p0�
throughout
jacket
O&M Program

REINSPECTION REPORT
hart hickman $
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 8
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof system
roof felt paper
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchangedr
P. v"
roof -mounted vent
roof flashing felt
maintain ACM in`�-
hoods on the western
paper
non -friable; good condition
O&M Program
not applicable
condition unchanged
,
roof system
4. ��

REINSPECTION REPORT
hart hickman $
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 8
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
eastern edge of the
maintain ACM in
.RwNi
building historic
roof seam tar
non -friable; good condition
O&M Program
not applicable
condition unchanged
*�
overhang seam
roof parapet walls
roof flashing felt
maintain ACM in
between warehouse
non -friable; good condition
O&M Program
not applicable
condition unchanged
_ z
suites
paper
INSPECTOR:
Typed Name: Robert
Signature:
NC Accreditation No: 13071
Date: June 3. 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ir
Signature:
NC Accreditation No: 20718
ails
Date: June 3. 2020

REINSPECTION REPORT
hart hickman s
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 9
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
northern portion of
vinyl floor tile (12" x
maintain ACM in
Suite H
12", tan) and mastic
non -friable; good condition
O&M Program
not applicable
condition unchanged
(black)
5
roof vent hood on the
maintain ACM in
=r _
westernmost roof
roof flashing tar
non -friable; good condition
O&M Program
not applicable
condition unchanged
system

REINSPECTION REPORT
hart hickman s
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Building 9
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
y
roof parapet walls on
maintain ACM in
the western painted
roof flashing tar
non -friable; good condition
O&M Program
not applicable
condition unchanged
`
roof system
fis
roof parapet walls on
the eastern gravel-
roof flashing tar
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
covered roof system
O&M Program
INSPECTOR:
Typed Name: Robert
Signature:
NC Accreditation No: 13071
Date: June 3. 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ir
Signature:
NC Accreditation No: 20718
alls
Date: June 3. 2020

REINSPECTION REPORT
hart hickman 10
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Ammonia Storage Building
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
t
.a
roof -mounted
equipment
roof flashing tar
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
-;
INSPECTOR:
Typed Name: Robert Sorgel
Signature: C
NC Accreditation No: 13071`'�
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature:
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart hickman 11
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Boiler House
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
second floor piping
boiler pipe gasket
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged
p . �
ground floor and near
4-inch condensate
friable; good condition
maintain ACM in
not applicable
condition unchanged_
the roof
pipe mudded elbow
O&M Program
rr.

REINSPECTION REPORT
hart hickman 11
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Boiler House
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
1 '
roof flashing felt
maintain ACM in
roof system
paper
non -friable; good condition
O&M Program
not applicable
condition unchanged
roof window
window glazing
(white, thin)
non -friable; good condition
maintain ACM in
O&M Program
not applicable
condition unchanged

REINSPECTION REPORT
hart hickman 11
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Boiler House
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
roof -mounted
roof flashing tar and
non -friable; good condition
maintain ACM in
not applicable
condition unchanged
equipment
felt paper
O&M Program
_
INSPECTOR:
Typed Name: Robert Sorgel
Signature: / G
NC Accreditation No: 13071
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature: —
NC Accreditation No: 20718
Date: June 3, 2020

REINSPECTION REPORT
hart � hickman 12
SMARTER ENVIRONMENTAL SOLUTIONS
2923 S. Tryon Street, Suite 100 Job Number: BRP-001
Charlotte, North Carolina 28203 Building: Debris Pile Adjacent to Boiler House
Phone [phone] Address: 200 N. 13th Street Erwin, NC
Fax [phone] Initial Inspection Date: December 2019 - January 2020
Previous Reinspection Date: Not Applicable
Reinspection Date: June 3, 2020
All previously identified asbestos containing building materials (ACBMs) have been reinspected/assessed and findings are specified below.
Building and
Functional Space
Material
Description
Initial Assessment
(performed by H&H)
Response
Action
Previous Annual
Assessment
2020 Annual
Assessment
(performed by H&H)
Photograph
debris
silver paint associated
non -friable; damaged
ACM removed May
ACM May 202(
pile
with non -ACM roofing
not applicable
removed
�
tar and felt paper
condition
2020
r
INSPECTOR:
Typed Name: Robert Sorgel
Signature:
NC Accreditation No: 13071 `
Date: June 3, 2020
MANAGEMENT PLANNER:
Typed Name: Matt Ingalls
Signature:
NC Accreditation No: 20718
Date: June 3, 2020

Appendix B
Glossary of Terms
■
hart F hickman
SMARTER ENVI RONMEWAL SOLLMONS

Asbestos Glossary
Abatement - Work that involves the physical removal of asbestos. Work must be performed by
trained personnel under the supervision of a competent person as defined by the Environmental
Protection Agency (EPA).
Aggressive Final Clearance Air Sampling - The act of aggressively agitating the air in an
asbestos removal area using fans and/or a leaf blower while final clearance air samples are being
taken.
Amended Water - Water that has been mixed (amended) with a chemical wetting agent, or
surfactant, to improve penetration and wetting ability.
Asbestos - A generic name given to a number of naturally occurring minerals that possess a
unique crystalline structure and are separable into fibers. Asbestos includes the asbestiform
varieties of chrysotile, crocidolite and amosite.
Asbestos -containing Material (ACNE - Any material containing more than 1.0% asbestos by
area as determined using Polarized Light Microscopy.
Asbestos Project - An activity involving job set-up for containment, removal, enclosure,
encasement, renovation, repair, demolition, construction or alteration of an asbestos -containing
material.
CFR - Code of Federal Regulations
Control Measure - A measure used to control the generation of airborne asbestos fibers until a
permanent solution can be implemented. These measures include encapsulation, repair,
encasement and enclosure.
Delamination - Physical separation of one layer from another.
Encapsulation - The application of a sealant over the surface of the asbestos -containing material
to prevent the release of asbestos fibers.
Enclosure - The construction or installation over or around the ACM of any solid or flexible
covering, which will not deteriorate or decompose for a period of time, so as to conceal the
ACM, contain ACM fibers, and render the ACM inaccessible.
EPA - The United States Environmental Protection Agency
Excursion Limit - The employer shall ensure that no employee is exposed to an airborne
asbestos fiber concentration in excess of 1.0 f/cc of air as averaged over a sampling period of
thirty (30) minutes; the concentration of 1.0 f/cc is defined as the excursion limit.

Fiber Release Episode - The unintentional disturbance of ACM resulting either from accidental
contact or that is a result of other factors, such as pipe leaks or roof leaks, where the ACM has
been physically dislodged and the potential for asbestos fibers to have become airborne as a
result of this disturbance is high.
Friable - Material which is capable of being crumbled, pulverized or reduced to powder by hand
pressure when dry, or which under normal use or maintenance emits or can be expected to emit
fibers into the air.
HEPA - High Efficiency Particulate Air (HEPA). HEPA filtered equipment must be capable of
trapping and retaining 99.97% of all particles larger than 0.3 microns.
Homogenous - Materials of the same age, physical appearance, texture and color, used for a
similar application. A separate homogenous sampling area shall be defined for each type of
homogenous material on each floor of a building.
Industrial Hygienist - A professional qualified by education, training and experience to
recognize, evaluate, and develop control measures for occupational health hazards.
Miscellaneous ACM - Interior ACM that is not surfacing or thermal system insulation, such as
some floor tile, ceiling tile, wire insulation, asbestos cement products and so forth.
Operations & Main-tenance Program - Specific procedures and practices developed for the
interim control of asbestos -containing materials in buildings until it is removed.
OSHA - Occupational Safety and Health Administration, administered in Virginia by the
Department of Labor and Industry (DLI).
Permissible Exposure Limit (PEL) - The highest allowable level of exposure to airborne
asbestos fibers that an employee may have, without using respiratory protection, as stated by the
Occupational Safety and Health Administration (OSHA).
Personal Protective Equipment - Any material or device worn to protect a worker from
exposure to, or contact with, any harmful material or force. PPE should be used only if
engineering or administrative controls are insufficient to protect against a hazard.
Regulated Area - An area established by the employer to demarcate areas where airborne
asbestos fiber concentrations exceed, or can reasonably be expected to exceed, the permissible
exposure limit.
Renovation - Altering, in any way, one or more facility components.
Repair - Returning damaged ACM to an undamaged condition or to an intact state so as to
prevent fiber release.

Respiratory Protection - A device worn to either purify the air, or that provides clean air from
another source to the wearer. All respirator users must be enrolled in Virginia Tech's Medical
Surveillance Program, and must have received appropriate training on respirator use, care, and
maintenance.
Response Action - Repair of damage or deterioration to asbestos materials, or the removal of
asbestos or asbestos debris, undertaken to alleviate a hazard to building occupants.
For the purposes of this document, in-house workers may only conduct small-scale, short -
duration removal or repair response actions, the cleaning/removal of asbestos debris, and
cleaning/removal operations associated with an asbestos fiber release episode.
Asbestos work other than small-scale, short duration must be performed by either an in-house
person who has Asbestos Worker equivalent training, or by a licensed asbestos removal
contractor.
Small-scale, Short -duration Asbestos Projects - Small-scale, short -duration (SS/SD) renovation
and maintenance activities include, but are not limited to: removal of ACM from pipes;
replacement of an ACM gasket on a valve; installation or removal of small sections of drywall;
installation or electrical conduit proximate to, or through, ACM; or the removal of small sections
of ceiling tile, friable (e.g. damaged) flooring, or unbonded ACM flooring where the work is
non -repetitive, and can be completed within an eight (8) hour work shift. The purpose of SS/SD
projects is maintenance, repair or renovation where the removal of ACM is not the primary goal
of the job. For additional information, see Section 4.1.
Asbestos Project Supervisor - A person with the training and experience required by the
Department of Commerce for licensing as an Asbestos Supervisor, and who meets the
qualifications of "competent person" as established by 40 CFR 761. An asbestos project
supervisor must be present on all asbestos projects which involve the removal of friable ACM.
Surfacing ACM - ACM sprayed or troweled on surfaces, such as some acoustical plasters, hard
wall or ceiling plasters, and fireproofing.
Thermal System Insulation - Thermal system insulation (TSI), is ACM applied to pipes, fittings,
boilers, breaching, tanks, ducts or other structural components to prevent heat loss or gain or
water condensation.

Appendix C
Fiber Release Episode / Response Action Report
hart hickman
SMAMIR ENVIRONMENTAL SOLLMONS

FIBER RELEASE EPISODE / RESPONSE ACTION REPORT
FIBER RELEASE EPISODE
Reported by: Date: / / Time
Building Name:
Address:
City: State: _
Building Number: Room:
Provide a brief description of the cause of the episode:
ZIP:
AM/PM
What area(s) were affected by the episode:
Was the area occupied at the time of the incident: Yes No
List occupants occupying the space or entering the space at the time of or after the episode (use
the back of the form if necessary):
RESPONSE ACTION / ROUTINE O&M ACTIVITY
Personnel (name and title) conducting the response action:
Method of Repair:
Response Action Taken:
Abatement Report Provided to Asbestos Coordinator:
Waste Disposal Site:
Air Sampling Information:
Additional Comments:
Yes No
Signature Date
Title