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HomeMy WebLinkAboutFile Documents.601 E Hopkins Ave.0038-2023-BCOM (3) DS Environmental CONSULTING "The trusted choice for your environmental & industrial hygiene needs." ASBESTOS INSPECTION REPORT FirstBank - Aspen 601 E Hopkins Ave, Unit 1, Aspen, Colorado PRESENTED TO: INSPECTED BY: PROJECT DETAILS: Mr. Pete Whalen Mr.Thomas Holzfaster DS Job Number: 25570 Director, Real Estate and Facilities DS Environmental Date of Inspection: April 28, 2023 FirstBank Cell: (720) 955-1813 Work Order#: 17736FAC 12345 W Colfax Ave, Lakewood, CO 80215 O 303-231-2034 C 720-289-3849 /Pete.Whalen@efirstbank.com J ," /G`� Front Range 7555 W 10th Ave Mountains PO Box 6864 Western SI, '!•cE199 ED Suite A, Lakewood, CO 80214 Avon,CO 81620 Aspen, CO 81612 07/20/2023 Web dsconsultinginc.com Direct(303) 286-9094 Fax(303)986-0121 ASPEN BUILDING DEPARTMENT Table of Contents 1.0 Introduction 2.0 Limitations of Inspection 3.0 Conclusions & Summary of Findings 4.0 Material Information 5.0 Inspector & Firm Certifications 6.0 Inspection, Sampling & Analytical Procedures 7.0 Recommendations 8.0 Asbestos Abatement & Demolition Requirements 9.0 Major Asbestos Spills 10.0 Project Design & Project Manager Requirements 11.0 Disclaimer & Limitations 12.0 Copyright Notice APPENDIX A CERTIFICATIONS APPENDIX B SAMPLE LOCATIONS APPENDIX C LABORATORY REPORT RECEIVED 07/20/2023 2 ASPEN BUILDING DEPARTMENT 1.0 Introduction Mr. Thomas Holzfaster with DS Environmental Consulting (DS) conducted an asbestos inspection and collected bulk-samples of suspect asbestos-containing building materials within the commercial building detailed on the cover page of this report. The purpose of the inspection was to determine if any of the materials that may be impacted by the renovation activities contain asbestos. No suspect asbestos-containing materials that were within the scope of renovation work have been found to contain asbestos. 2.0 Limitations of Inspection This inspection was limited in its scope and only included specific areas and materials as defined by the client. The inspection did not constitute a full-building inspection and does not fulfill the asbestos inspection requirements for structures that are to be demolished. The table below, (Table 1.0), lists the suspect asbestos-containing materials included in the scope of the inspection. It identifies the specific areas that were included in the inspection as well descriptions of the suspect asbestos-containing materials in those areas that were sampled; or materials that were assumed to contain asbestos. The suspect asbestos-containing materials listed below may be found in other areas of the building that were outside of the scope of work for this inspection and sampling. Additionally, there may be other materials in other parts of the building that contain asbestos, which were not included in the scope of this inspection and sampling. Table 1.0 I Sampled or Assumed Suspect ACM within Scope of Work Materials in RED are materials that contain greater than 1% asbestos. Materials in BLUE are assumed to contain >1% asbestos Materials in GREEN contain 1% asbestos or less. Materials in BLACK are none-detected for asbestos. Suspect Asbestos-Containing Materials Sampled Material Locations **See Appendix B for I Sample Location Map Homogeneous Area 1 Smooth Drywall Texture (SM1) Homogeneous Area 2 Joint Compound Associated with SM1 (JC1) • Throughout areas of renovation Homogeneous Area 3 Gold Carpet Adhesive (CA1) Homogeneous Area 4 (BBA1) Tan Cove Base Adhesive 07/20/2023 3 ASPEN BUILDING DEPARTMENT 3.0 Conclusions & Summary of Findings ACRONYMS ACM ASSESSMENT CATEGORIES CHRY—Chrysotile 1—damaged/significantly damaged thermal system insulation ACM SUMMARY ACT—Actinolite 2—damaged friable surfacing material ACM OF TR—Trace;Assumed >1%Asbestos 3—significantly damaged friable surfacing material ACM ND—None-detected FINDINGS 4—damaged or significantly damaged friable miscellaneous material ACM ACM—Asbestos Containing 5—ACM with the potential for damage Material (>1%asbestos) 6—ACM with the potential for significant damage BRL—Below Reporting Limit; 7—any remaining friable ACM or friable suspected ACM Assumed>1%Asbestos Materials in RED are materials that contain greater than 1% asbestos. Materials in BLUE are assumed to contain >1% asbestos Materials in GREEN contain 1% asbestos or less. Materials in BLACK are none-detected for asbestos. Sample Information Asbestos **See Appendix B for Sample Location Map Material Information Content Sample ID: SM1-1 Sample Location: Far N center office/supply area -S wall -center-<1' < from floor Description: Smooth Drywall Texture ceClassification: Surfacing Material 0 Sample ID: SM1-2 Condition: Good pSample Location: Accounts office- N wall 2 Z W side <1'from floor Quantity: ^ 250 ft ND w Friability: Friable w O Assessment Category: No Category(Non-ACM) = Sample ID: SM1-3 Sample Location: Lobby-S side -at customer counter opposite teller line - S wall below counter edge N a Sample ID:JC1-1 Description:Joint Compound Associated w/SM1 QSample Location: Far N center storage Classification: Miscellaneous Material O area -SE corner Condition: Good m z Sample ID:JC1 2 Quantity: 50 ft2 ND w Friability: Friable w Sample Location: Lobby-S side -at customer counter SW corner above Assessment Category: No Category(Non-ACM) O counter I gPr'IPVEr 07/20/2023 4 ASPEN BUILDING DEPARTMENT M ,a Sample ID: CA1 1 Description: Gold Carpet Adhesive Q Sample Location: Far N center storage Classification: Miscellaneous Material n area -floor at S wall - E end Condition: Good O Quantity: "'50 ft2 ND W Sample ID: CA1-2 Friability: Friable p Sample Location: Far N center storage Assessment Category: No Category(Non-ACM) 2 area -floor at S wall - E end -side by side x Tr Q Sample ID: BBA1-1 Description:Tan Cove Base Adhesive c`cc Sample Location: Far N center storage Classification: Miscellaneous Material Q area -S wall - E end � Condition: Good m O Quantity: ^' 10 ft2 ND z Sample ID: BBA1-2 w Friability: Friable w Sample Location: Far N center storage area S wall Wend Assessment Category: No Category(Non-ACM) 0 I 4.0 Material Information A Homogeneous Area (HA) means an area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture. The asbestos content of the bulk-samples collected within a homogeneous area can be applied to the entire homogenous area, if they conform to the above characteristics and the regulated minimum sample quantities of each type of material have been collected and analyzed. An Asbestos Containing Material (ACM) is a material that contains more than 1% asbestos. Any material can be assumed to be an ACM, but not the contrary. 4.1 Material Friability A material can either be friable or non friable. A friable material is one that, when dry, can be pulverized, or reduced to powder by hand pressure, a non-friable material cannot. A non-friable material may become friable if its condition had deteriorated or has been impacted by forces that have rendered it friable. 4.2 Material Classifications Sampled materials are divided into one of the following three categories: RECEIVED • Surfacing Material: sprayed or troweled onto structural building members 07/20/2023 5 ASPEN BUILDING DEPARTMENT • Thermal System Insulation (TSI): any type of pipe, boiler, tank, or duct insulation • Miscellaneous Material: all other materials not classified in the above two categories 4.3 Material Conditions Sampled materials are placed into one of the following three categories of conditions: • Good: none to very little visible damage or deterioration • Damaged:the surface is crumbling, blistered,water-stained,gouged, marred, or otherwise abraded over less than one-tenth of the surface if the damage is evenly distributed, or one-quarter if the damage is localized • Significantly Damaged: the surface is crumbling, blistered, water-stained, gouged, marred, or otherwise abraded over greater than one-tenth of the surface if the damage is evenly distributed, or one-quarter if the damage is localized 4.4 Sample Quantities DS collected at least the minimum number of samples from each homogeneous area necessary to meet all regulatory requirements for the quantity of material to be disturbed in the scope of work as defined by the client. The quantities listed in this report are approximate and on-site verification of the exact quantity of each material is required for permitting, estimating, and billing purposes. The following outlines the minimum sample quantities required per homogeneous area for a regulatory compliant inspection; however, in the event of a due diligence inspection, these sample minimums may not have been met: • Surfacing Materials: up to 1,000 ft2 of material requires a minimum of three (3) samples; between 1,000 ft2 and 5,000 ft2 of material requires a minimum of five (5) samples; over 5,000 ft2 of material requires a minimum of seven (7) samples; one (1) sample of each patch • Thermal System Insulation (TSI): each homogeneous area requires a minimum of three (3) samples; at least one (1) sample must be collected from each patch; and collect enough samples sufficient to adequately assess the material and determine the asbestos content for TSI fittings such as pipe elbows or T's, which a minimum of two (2) samples of each • Miscellaneous Materials: collect enough samples sufficient to determine the asbestos content with a minimum of two (2) samples of each 4.5 Materials Reporting "TRACE" Results Any sample reporting a "TRACE" amount of asbestos shall be considered to contain greater than 1% asbestos unless it is further analyzed utilizing the point-count method and verified to be less than or equal to 1% asbestos content, and therefore not an ACM. TRACE does not mean it contains less than or equal to 1%. 4.6 Materials Containing 1%Asbestos or Less Materials containing less than or equal to 1%asbestos are not regulated by the Colorado Department of Public Health and Environment (CDPHE) Regulation 8, Part B — Asbestos. However, all demolition/abatement activities should be performed following the applicable Occupational Safety and Health Administration (OSHA) regulations. This includes, but is not limited to, the appropriate asbestos training for the type of material being removed/disturbed as well as having a properly trained supervisor onsite, using wet removal methods, wearing adequate personal protective equipment (HEPA-filtered particulate respirators), medical surveillance of workers, personal-exposure air monitoring, area air monitoring in occupied buildings, etc. There may also be landfill disposal requirements for these materials, depending on the facility. DS recommends • t� r demolition/renovation projects involving the disturbance of any amount of asbestos be subjected to post-'— y Y work visual inspections and a final clearance air testing by a CDPHE-certified Asbestos Air Monitobrai$2 cidljti23 6 // �� �� ASPEN BUILDING DEPARTMENT (AMS) after the work has been completed, but before any containments are dismantled, the contractor demobilizes, and the area is reoccupied. 4.7 Overspray Any surfacing material indicated in this report also includes any associated overspray of that material, e.g., under carpet, above suspended ceilings, on studs and structural members, etc. 5.0 Inspector & Firm Certifications The inspection detailed within this report was conducted by Mr. Thomas Holzfaster with DS. DS is a CDPHE certified Asbestos Consulting Firm, Registration No. 14912. Mr. Holzfaster is a CDPHE certified Building Inspector; having certification number 15626 (see Appendix A for certificates). 6.0 Inspection, Sampling & Analytical Procedures 6.1 Inspection Procedures The asbestos inspection detailed in this report was conducted by an Environmental Protection Agency (EPA) and CDPHE certified asbestos Building Inspector. The inspection procedures included identifying and sampling suspect ACM within the pre-defined areas that were within the scope of work, submitting samples to an accredited laboratory for analysis, classifying the materials and assessing their condition, and compiling a final report detailing the inspection and the analytical results of the bulk-samples. 6.2 Sampling Procedures Statistically random bulk-samples representative of the suspect ACM of each homogeneous area were collected according to the guidelines published in the Environmental Protection Agency's October 1985 publication, "Asbestos in Building: Simplified Sampling Scheme for Friable Surfacing Materials", commonly known as the "Pink Book." DS has collected the appropriate number of bulk-samples to meet all regulatory requirements for the classification and quantity of each homogeneous area. All reasonable efforts were made to identify homogeneous areas and to sample or assume suspect materials. Destructive investigation was conducted whenever feasible, and every effort was made to locate and quantify suspect ACM within the scope of work. Any material not identified and sampled in this report shall be assumed to be an ACM or shall be sampled by an EPA-trained and CDPHE-certified inspector and submitted for analysis. 6.3 Analytical Procedures All asbestos bulk-samples were analyzed by a third party, National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory via Polarized Light Microscopy (PLM) for asbestos content per CDPHE Regulation 8 (see Appendix C for laboratory report). 7.0 Recommendations The asbestos inspection detailed in this report did not identify ACM(s); therefore, professional abatement activities are not required to remove or disturb the above-referenced sampled materials. RECEIVED 07/20/2023 7 ASPEN BUILDING DEPARTMENT 8.0 Asbestos Abatement & Demolition Requirements If ACM is to be removed or disturbed in a single-family residence, and the total quantity exceeds any of the regulatory trigger levels of 50 linear ft. on pipes, 32 ft2 on other surfaces, or the volume equivalent of a 55-gallon drum, a CDPHE-certified General Abatement Contractor (GAC) is required to perform the work. The regulatory trigger levels within a commercial building are 260 linear ft. on pipes, 160 ft2 on other surfaces, or the volume equivalent of a 55-gallon drum. In addition,formal notification to CDPHE prior to the abatement of ACM as well as air monitoring,visual inspections, and final air clearances by a CDPHE-certified Asbestos AMS is required. DS can provide the client or building owner with a proposal for project design, abatement oversight and air monitoring upon request. CDPHE regulations allow for the demolition of a building that contains certain non-friable asbestos-containing materials,such as caulking, tars, and mastics; however, demolition must be completed without causing the non- friable ACM to be rendered friable. Certain other non-friable materials, such as cementitious siding (Transite) and resilient floor tiles must be abated prior to demolition. DS recommends abating all ACM prior to abatement, regardless of friability. Burning a building with any ACM is prohibited. Operations such as sanding, cutting, crushing, grinding, pneumatic jacking, etc. of ACM are not permitted. Recycling of building materials such as concrete, metal, or wood that are bonded or contaminated with ACM, e.g., glue, caulking, or mastic is also prohibited. If any of the non-friable asbestos containing materials are to be recycled and rendered friable after demolition (i.e., crushing mastic-coated concrete), these materials must be abated of all ACM prior to shipping offsite for recycling. OSHA regulations regarding occupational exposure during demolition activities is still mandatory. OSHA 29 CFR 1926.1101 requires that workers performing construction-related activities be protected from asbestos fibers more than the permissible exposure limit of 0.1 f/cc of air. Contractors must comply with applicable provisions of OSHA 29 CFR 1926.1101 during demolition and renovation activities. These OSHA provisions include, but are not limited to, PPE and respirators, personnel training, personal-exposure air monitoring, employee medical surveillance, wet removal methods, signage for regulated areas, etc. 9.0 Major Asbestos Spills If ACM is significantly damaged and the total quantity exceeds the regulatory trigger levels, the area is deemed a "Major Asbestos Spill." The area is consequently subject to the requirements in Reg. 8, Section III.T.2.—Major Asbestos Spills. Unless the entire facility is to be treated as a major asbestos spill, a Colorado-certified Air Monitoring Specialist (AMS) must determine the extent of the spill area. This may be done using visual examination, air samples, micro-vacuum dust samples, wipe samples or a combination thereof. If visible dust or debris is observed, directly related to or resulting from the known or assumed ACM which created the major asbestos spill, areas where it is observed must be included in the abatement of the spill. Samples must be collected and analyzed quantitatively by Transmission Electron Microscopy (TEM.) The General Abatement Contractor (GAC) selected to perform the cleanup of the spill must: • Submit notification in accordance with subsection III.E. (Notifications) or subsection III.G. (Permits), whichever is applicable to the Division for approval. • Using certified Workers and Supervisors, in accordance with Section II. (Certification Requirements), construct a containment in accordance with the requirements of the regulation. • HEPA vacuum then steam clean all carpets, drapes upholstery and other non-clothing fabrics in,.4 contaminated area or discard these materials in accordance with subsection III.R. (Waste Handling) 0,,; • Launder or discard all contaminated clothing in accordance with subsection III.R. (Waste I- r}tA'iggj/2023 8 ASPEN BUILDING DEPARTMENT • HEPA vacuum or wet wipe with clean amended water all hard surfaces in the contaminated area. • Discard all waste in accordance with subsection III.R. (Waste Handling) All persons must comply with any other measures, provided in writing by the Division, which are deemed necessary to protect public health. Following completion of Sections III.T.2.d.(i) through III.T.2.e., the AMS must comply with air monitoring requirements as described in Section III.P. (Clearing Abatement Projects); air samples must be collected aggressively as described in 40 C.F.R. Part 763, Appendix A to Subpart E (EPA 2010), except that the air stream of the leaf blower must not be directed at any friable ACM that remains in the area. Gross removal of additional ACM may not be conducted under Section III.T.2. Any remaining gross removal of ACM must be abated in accordance with Section III.H. (Abatement Sequence). If additional ACM is to be removed, the final air sampling required in Section III.T.2.f. is not required to be conducted until after the additional removal is completed. 10.0 Project Design & Project Manager Requirements DS can provide an Asbestos Abatement Project Design as well as fulfill the Colorado Asbestos Abatement Project Manager requirements for any asbestos abatement project, as applicable below. Project Design An abatement Project Design is an accurate and detailed scope of work, which includes project specifications and procedures, containment design/equipment placement, and descriptions of engineering controls and work practices for an asbestos abatement project or response action that is required by CDPHE Regulation Number 8, Part B -Asbestos (Reg. 8) on large asbestos abatement projects. Prior to the start of any asbestos abatement project in a non-school building, where the amount of asbestos-containing material (ACM) to be removed or disturbed exceeds 1,000 linear feet on pipes, or 3,000 square feet on surfaces, or in a school building in which the amount of friable ACM to be abated exceeds 3 linear feet on pipes, or 3 square feet on surfaces, a written Project Design must be developed by a State of Colorado certified Project Designer in accordance with subsection IV.G.7 of Regulation 8. A signed copy shall be posted on-site prior to commencing any abatement activities,shall be always available on-site, and shall remain onsite until final air clearances have been completed by a State of Colorado-certified Air Monitoring Specialist (AMS). Project Manager A Project Manager shall be used on all asbestos abatement projects in which the amount of friable asbestos- containing material to be abated exceeds 1,000 linear feet on pipes, or 3,000 square feet on other surfaces per CDPHE Regulation Number 8, Part B — Section 111.6.6. An asbestos Project Manager on an abatement project shall be responsible for assessing that the project is conducted in accordance with Regulation 8, assessing that the Project Design is followed, assessing that the abatement project is cleared in accordance with Regulation 8, assessing that the asbestos waste generated on the project is properly manifested and disposed of in accordance with Regulation 8, and communicating these assessments to the building owner or GAC. The GAC shall notify the building owner during the bid process as to whether a Project Manager is required. Project Managers shall be independent of the asbestos abatement contractor and work strictly on behalf of the building owner to the extent feasible unless the abatement is being performed in-house. Project Managers must sign the original copy of the abatement permit for the permit to be valid, and before any abatement can take place. RECEIVED 07/20/2023 9 ASPEN BUILDING DEPARTMENT 11.0 Disclaimer & Limitations The activities outlined in this report were conducted in a manner consistent with a level of care and expertise exercised by members of the environmental consulting and industrial hygiene profession. All activities were performed in accordance with all applicable federal, state, and local regulations as well as generally accepted standards and professional practice. No warranty is either expressed or implied. DS assumes no responsibility or liability for error in public information utilized, statements from sources other than DS, or developments resulting from situations outside the scope of work for this project. The details provided within this report outline the inspection activities on the date(s) indicated and should not be relied upon to represent conditions later. The laboratory results contained in this report apply specifically to the materials in which bulk-samples were collected. The results do not include or apply to any other materials within the structure that were not sampled but may contain asbestos; including materials that may be hidden or inaccessible. Additional inspection and bulk-sampling activities by a certified inspector would be required to determine whether any other materials contain asbestos. This report has been prepared on behalf of and exclusively for use by the DS's client, with specific application to their project as discussed in the scope of work. The information contained in this report is intended as supplementary material for abatement design and is not to be used as the sole means to develop the scope of abatement activities, bidding, or billing purposes. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. DS can provide a full scope of work for abatement upon request. DS does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. 12.0 Copyright Notice © DS Environmental 2023. All Rights Reserved. This document contains material protected under Federal Copyright Laws. No part of this document or any of its contents may be reproduced, copied, modified, or adapted, without the prior written consent of the author and DS Environmental. RECEIVED 07/20/2023 10 ASPEN BUILDING DEPARTMENT APPENDIX A: CERTIFICATIONS RECEIVED 07/20/2023 11 ASPEN BUILDING DEPARTMENT 1 vy t -. sSi x 1'i,4i iilrr'm, u�lr�t l"t Y'4'k �ttrr v? " i1 h 11 Rt :,i 1�'rX A's°1 P;t+,• ,, .$0/#.. ,s+ ?f..•'.,i„•,,��.3-o,J t d C., „etr, But 9r�7,�'.4 n y t. �4'. L o, '�' ° ,� .,,b,:4,:re":, J-, n.;,.U:f,•. 4,}y^r, :,tr;,s. t / ,ti:, ,�. t1�/i ✓s i '�w`a Q M t S6t �'" 4t �, i " � �- Si �. d $ ,�� � "µ, ,Mt"� y� ,�r t � ,�'� �' .� 3 �,. mm� ‘', '"°wS'- ✓ 4 ✓J . 1 h � � �.c6 tj � �' ,iy yr� � F F .lay y{� ula y� A y� �r ,1� 4y 2 / A_` 4,t311'�i, �;�im. ', Ibt,ia4.4b1,4 f wo- u_n- r, :it4)i'`:owsi gt '' kk git ti°' /i q[ I f -2 i } Colorado l ��, !. 1 ' - i,/N �.i, of Public Health '+ a 't--g , , ,,,, a J }ti---eit,, fA. and Environment 1 _ z:- ASBESTOS e a C �' , ‘ ,,, ,.„ N' ; CERTIFICATION* i' I n o rn �, ' ry V= < 1 r This certifies that 1e lit;.;') • .o- �• i , Thomas M.Holzfaster „ „ s. 3 -i n , �' �` - t t* Certification No.:15626 ir; 1 _' ° O ry ° g'?o o ' has met the requirements of 25-7-507,C.R.S.and Air Quality Control :w-�`-\ , Z V' U1 a T'o S°f ,' F.,...?,-.4;:l.,-..;'1 0 Commission Regulation No.8,Part B,and is hereby certified by the ' t 0 0 o ::,. 0 S 3 +oa"° ,�, .N - state of Colorado in the following discipline: r♦ , �„x a.,Building Inspector* 1As a r ? Z !�` y, ::.;!-;:.i-.,'!". .- N 4 a s n ,-k ;i.--,.:' a Issued: May 05,2022 j4, ! i 0 r, `, -p.• 1' P. 4 (� '�,g Expires: .Tune IQ 2023 1 S '.,,i,i44.;,,,, ,, 't ems •rxo+mrlw ,,Wae„ +,n„e. �+io j - 1 i 't' ' g}9 grF frail'#�rW+i imp' �a t NPw rr�0 h �ar�i 'g�flP r , ,' I i i' ) ,.. . mayJ xd{��/r f''`te "It` ^r*- Of* ko, , ,' t � " ' e it jrivi ,... `........ il i t '<� Q ' ' V _ ,' . 91 , ra..F„ Y. ,. ts, -%i?, .n ysv !0} y A '' t� -, fP V. ' ,V -- ✓e , ^ �..� ' . 94 tl , 7 l i \'1.... y '.» Z ,,4,7°4?ee..4.. . .A4 , k. , A.f*;a+47tq, � P: �� w1m bVyM� :� � � �4y^Nht gi? ,`;!> ) Inspector Certification: 15626 Firm Certification: 14912 RECEIVED 07/20/2023 12 ASPEN BUILDING DEPARTMENT APPENDIX B: SAMPLE LOCATIONS RECEIVED 07/20/2023 13 ASPEN BUILDING DEPARTMENT -- N LI I o — u h I I Y , C ' } � � — —1 _ I� J I r- ,-,- _ = ` � o 1 9 _ cor 11111 F 1 1 T ii nl r11./.--------------'-'------*,--t--,„_ COell . II ---,. (i)/ :- -,.... 1 __ I: I I Tom^ .6.R I ' 1 u c I, rli t ii r . r 1 l 1 1,1 1 C (13 o I cc ' o v) v) 0 c Y Q O 2 w 0 in RECEIVE D 07/20/2023 14 ASPEN BUILDING DEPARTMENT APPENDIX C: LABORATORY REPORT RECEIVED 07/20/2023 15 ASPEN BUILDING DEPARTMENT