2024_06_City_of_Urbana_205_N_Race_St_Asbestos_Inspection_Demo_J25693A1.pdf

Asbestos Program

Asbestos Inspection Report – Prior to Demolition

Supplemental Report to IDEAL Number 25693, September 2023

Site:

Commercial Building

205 N. Race Street

Urbana, IL 61801

Client:

City of Urbana

400 S. Vine Street

Urbana, IL 61801

Completion Date:

June 19-22, 2024

IDEAL Number:

25693A1

City of Urbana Commercial Building, 205 N. Race Street, Urbana, IL

June 19-22, 2024 / IDEAL Number 25693A1

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Limited Asbestos Inspection Introduction

Project Name: Commercial Building

Project Location: 205 N. Race Street

Urbana, IL 61801

Client: City of Urbana

Address: 400 S. Vine Street

City, State Zip: Urbana, IL 61801

Contact Name: Mr. Ray Garcia

Ideal Job Number: 25693A1

Inspection Company: Ideal Environmental Engineering, Inc. (IDEAL)

Inspector Name: Jerry L. Wilson

Inspector ID#: 100-01338

Inspection Date: June 19-22, 2024

Purpose of Inspection: X Demolition Renovation Other

Scope of Work & Comments:

The purpose of the inspection was to sample the drywall and drywall joint compound system throughout the building to verify asbestos content.

Refer to the Drywall/Drywall Joint Compound System Diagram for a summary of the inspection.

After reviewing laboratory results, it was determined that the drywall and joint compound system throughout the building should be treated as asbestos containing material.

Note: Rooms where samples were taken are denoted by the sample ID (example: samples 21-

1,2,3 were taken from room 21).

Refer to inspection report dated September 2023, IDEAL Number 25693 for the main inspection.

Asbestos containing materials may be discovered during demolition that were not found during the asbestos inspection. This should be taken into consideration during the demolition phase. If materials other than those inspected and/or identified in this report are discovered, additional inspection is necessary.

This inspection was performed to help comply with the following rules governing asbestos: EPA NESHAP 40CFR Part 61, Subpart M and IDPH Part 855 Asbestos Abatement for Public and Private Schools and Commercial and Public Buildings in Illinois.

This report is intended to be read in whole and not in part. The General Definitions and General Comments are an integral part of this report.

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Drywall/Drywall Joint Compound System Diagram

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Laboratory Results

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Accreditation

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General Definitions

Asbestos Containing Material (ACM): Material containing greater than 1% asbestos as determined by Polarized Light Microscopy (PLM). [Refer also to General Comments paragraph about qualitative analysis.]

Homogeneous Area: An area of material that appears uniform in texture, size, color and apparent or known date of installation.

Area ID/Sample Area & Sample ID: The alpha-numeric code given to each sampled homogenous area and each sample taken.

Area Name & Area Description: The name and a description of each homogenous area.

Area Estimate: The estimated quantity of accessible material. Additional quantities may be present in inaccessible areas.

Area Location: The area location as noted in written text and on diagram(s) (if provided) may be a general description and may not include all locations.

Friable Material: Any material that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

Non-Friable Material: Any material that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

Non-Friable Organically Bound Material (NOB): Material where the asbestos (if present) is tightly bound to the matrix material (generally asphalt- or vinyl-based). Examples include flooring, mastics, caulks, and roofing materials.

Category I Non-Friable ACM: Non-friable asbestos containing packing, gaskets, resilient floor covering and asphalt roofing products.

Category II Non-Friable ACM: Non-friable asbestos containing materials other than Category I.

Poor Condition: The binding of the material is losing its integrity as indicated by peeling, cracking, or crumbling of the material.

All materials in poor condition are Regulated Asbestos Containing Materials (RACM).

Surfacing Material: Material that is sprayed-on, troweled-on or otherwise applied to surfaces, such as acoustical plaster on ceilings, fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, and other purposes.

Thermal System Insulation (TSI): Insulation applied to pipes, fittings, boilers, breeching, tanks, ducts and other structural components to prevent heat loss or gain.

Miscellaneous Material: Any material not classified as surfacing or TSI.

Condition of Material: The condition of a material is classified into three categories.

Not Damaged – Material that has <1% localized or distributed damage as determined by an asbestos inspector (aka good condition).

Damaged – Material that has 1-25% localized damage or 1-10% distributed damage as determined by an asbestos inspector.

Significantly Damaged – Material that has >25% localized damage or >10% distributed damage as determined by an asbestos inspector.

Response Action: Identifies appropriate remediation for a material. A response action is assigned by an asbestos management planner. In schools, it is required for all thermal system insulation materials and for all friable surfacing and miscellaneous materials.

O&M: Operations and maintenance

Regulated Asbestos Containing Material (RACM): 1). Friable ACM. 2). Category I non-friable ACM that has become friable.

3). Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, abrading or pulverized.

4). Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material during demolition operations.

[Materials may be reported as regulated ACM if qualitative analysis indicates that asbestos is present, even though it is not quantified.]

Trace Amounts of Asbestos: According to laboratory results, sample found to contain less than or equal to 1% asbestos.

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Demolition: The wrecking or extracting of any load-supporting structural member of a facility along with any related handling operations or the intentional burning of any facility.

Renovation: Altering a facility of one or more of its components by any means, including stripping or removal of RACM from a facility component. A component is any part of a facility including equipment.

Accessible: AHERA defines “accessible” as a material subject to disturbance by school building occupants or custodial or maintenance personnel in the course of their normal activities. For the purposes of this report, “accessible” materials, spaces or areas shall also mean those materials, spaces or areas for which nothing is required to be removed in order to access the material, space or area (i.e. no walls, ceilings, floors, outlet covers, etc. are required to be removed).

Inaccessible: For the purposes of this report, “inaccessible” materials, spaces or areas mean those materials, spaces or areas for which something is required to be removed in order to access the material, space or area (i.e. a wall, ceiling, floor, outlet cover, etc. is required to be removed).

Federal Agencies Governing Asbestos

EPA Environmental Protection Agency OSHA Occupational Safety and Health Administration

State of Illinois Agencies Governing Asbestos

ILEPA Illinois Environmental Protection Agency IDPH Illinois Department of Public Heath

Regulations Governing Asbestos

EPA regulations:

NESHAP National Emission Standard for Hazardous Air Pollutants

The regulation governs storage, transportation and disposal of asbestos.

[Any references to NESHAP in this report shall mean the asbestos portion of NESHAP.]

AHERA Asbestos Hazard Emergency Response Act

The regulation governs asbestos containing material in schools. It also regulates minimum training requirements for asbestos abatement personnel under the “Model Accreditation Plan”.

ASHARA Asbestos School Hazard Abatement Re-Authorization Act

The regulation extends the AHERA regulation to Public and commercial buildings in that if any action is taken in a Public or commercial building, it must be performed by accredited personnel.

IL EPA regulations:

Illinois Environmental Protection Act The act establishes a unified, state-wide program supplemented by private remedies to restore, protect and enhance the quality of the environment, and to assure that adverse effects upon the environment are fully considered and borne by those who cause them.

OSHA standards:

Occupational Exposure to Asbestos Final Rule The standard limits exposure to asbestos in the workplace.

IDPH regulations:

Asbestos Abatement Code for Public and Private Schools The code establishes regulations for asbestos abatement in Public and private schools.

Commercial and Public Building Asbestos Abatement Act The act requires licensure by the Illinois Department of Public Health for persons designing or conducting asbestos response actions or inspecting for asbestos in Public and commercial buildings. It also gives IDPH the authority to approve training courses for persons engaged in these activities.

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General Comments

Asbestos Survey Accessible building areas were visually inspected for suspect asbestos containing materials within the scope of this inspection.

Materials suspected to contain asbestos are determined by EPA guidance materials, industry standards, and the inspector’s experience and training. Suspect asbestos containing materials are generally any materials which are not metal, concrete, rubber, fiberglass, PVC, black foam glass, Armaflex, silicone or wood. However, the inspector ultimately determines what is suspected to contain asbestos, and, based on their own discretion, may include any of these materials in certain situations.

A thorough inspection was completed, including, where applicable, checking above ceiling panels, behind walls, below carpet, etc., to attempt to locate hidden materials. This was conducted within reason, within time constraints, in line with inspector safety and building occupancy constraints, and adhering to any desires of the client to avoid damage. Any suspect asbestos containing materials not found in the survey must be assumed to be ACM until sampled. Additional suspect asbestos containing materials may be found in pipe chases, hidden building cavities, behind walls, under floors, inside duct work, behind existing finishes or other similar areas. Materials may be misidentified if covered by paint, wallpaper, carpet, etc. The inspection did not include removal, dismantling or demolition of building components, unless otherwise noted. Unless specifically included in this report, mechanical equipment, electrical systems, elevators and confined spaces are excluded from the inspection. A return visit can always be requested for additional inspection service of opened wall cavities, discovered hidden spaces, HVAC systems, etc., to access previously excluded areas.

This survey was completed with generally accepted industry standard AHERA and/or NESHAP inspection practices within the constraints of the client’s directive and time frame. EPA-NESHAP asbestos inspections are completed for compliance commonly associated with public and commercial buildings prior to renovation or demolition work. To help comply with the OSHA asbestos general industry standard 29 CFR 1910.1001 and the OSHA asbestos construction standard 29 CFR 1926.1101, the results of this report should be communicated to employees and other employers at the project site. For residences, the inspection was completed using NESHAP rules as guidelines.

This inspection was prepared for the building owner or client as noted. If plans for the building change, additional inspection service may be necessary. It was not prepared for others. Any reliance on or use of this report by any third party is done at the risk of the third party. Reliance on this report by any third party does not make the third party a beneficiary to IDEAL’s contract with the building owner or client as noted.

The inspection was completed by EPA/AHERA-accredited, IDPH-licensed inspector(s) whose training is refreshed annually by an EPA-approved training course provider. Though thorough, the inspection is limited, as training is not guaranteed to encompass all clarifications, determinations, and amendments to regulations, nor is training guaranteed to cover all guidance publications.

PLM is the standard analysis method specified in NESHAP and AHERA regulations for determining if a material is asbestos containing, and unless otherwise noted, it was used as the standard analysis method for this inspection.

Unless otherwise noted, three (3) samples were collected per homogeneous building material, and this is the industry standard to determine if a material is asbestos containing. AHERA requires additional samples of surfacing materials based on the quantity of material. Based on established guidelines, the inspector determines how many samples are appropriate to achieve sufficient sampling for the quantity of each material present.

Samples of friable materials are collected using random sampling. During random sampling, the Grid Method may not be used to avoid destructive sampling in visible areas.

The inspector’s determination of homogeneous areas and inferences for friability, damage condition, and whether a material is regulated, category I or category II are guided by regulations but remain subjective and may differ from another inspector.

The inspection service excludes providing to any party suggested/required demolition contractor work practices, including but not limited to NESHAP and OSHA regulations.

Sometimes, materials may appear to be homogeneous but may not be. While care has been taken to accurately determine homogeneous materials, installation dates may differ unbeknownst to the inspector, different product brands may have been used, or manufacturers may produce batches with different sources for raw materials. Determining homogeneity of drywall systems (i.e. drywall, joint compound, tape) is especially difficult due to possible multiple installations, renovations, repairs and since drywall systems are intentionally finished so these occurrences are not noticeable. In addition, replacement materials are often purchased to match original materials. When replacement materials are near-identical to original materials or if their presence is very localized or sporadic throughout, they may not be noted in this report.

Inspectors generally check for underlying flooring materials at corners, seams, thresholds or damaged areas, and not all flooring is lifted. It is possible that multiple types of flooring are present under the accessible flooring if the top flooring is

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Page | 40 replacement flooring. Use caution if removing replacement flooring. If old black mastic is found in isolated areas or throughout, even if not identified during an inspection, it should be treated as asbestos containing for renovation purposes, or if building materials are to be recycled, as it is likely to contain asbestos. If underlying flooring is found which is not identified in the report, additional inspection is necessary.

BLACK MASTIC INFORMATION

➢ When replacement flooring is sampled, multiple colors of mastic may be present below it. When black mastic is found amongst the multiple colors, it is likely the original mastic, and it is also likely to contain asbestos. Without inspection of the entire floor space, it is impossible to know whether the black mastic is residual or if it is prevalent.

➢ It is noteworthy that in the 1990’s, schools did not typically remove old black mastic when they removed floor tile. Rather, they just covered over it. Therefore, it is very common to find prevalent black mastic and a newer mastic (often yellow) underneath replacement flooring.

➢ In addition, the laboratory may not report the presence of black mastic in replacement flooring samples, or they may report it at quantities less than 1%, which meets the definition of a non-asbestos containing material. Therefore, when reviewing inspection reports, you may read that a replacement mastic is non-asbestos containing. We recommend using caution when replacement flooring is removed, even if sample results say the underlying mastic is non-asbestos containing. If black mastic is discovered along with other colors of mastic, it should be treated as asbestos containing. The sample results may not accurately reflect the entire floor surface.

For pre-demolition inspections, the inspection was completed under the assumption that all non-regulated asbestos containing materials will remain in the building during the demolition process and will be taken to the landfill as general construction debris.

If present, these materials were sufficiently sampled for this purpose. If building materials are to be recycled, additional sampling may be necessary (NOBs, materials with trace amounts of asbestos, etc.). Please note that no materials with black mastic attached should be recycled without first removing the black mastic. Black mastic should be treated as asbestos containing, regardless of laboratory analysis results for the black mastic.

If the inspection included the building exterior, it was not an exhaustive inspection of the entire exterior surface area, but, rather, random areas were inspected. Additionally, on multi-level buildings, exterior materials may appear homogeneous from the ground to the top levels, but it is possible that different building materials are present. Care should be taken during renovation and/or demolition activities of multi-level buildings to ensure that exterior materials identified are homogeneous.

Room numbers, room dimensions, occupant names, buildings years, etc. may not be accurate in this report if information provided to us, such as on a diagram, was not current, and in the future if building information changes after the date of the inspection.

A material may be called “fireproofing” in this report for general description purposes; however, such a description shall not mean that it is a fire-rated material.

While inaccessible materials, spaces or areas are excluded from the scope of the inspection, some may have been inspected.

Photos may not be provided for all materials. Photos either reflect sample locations (when designated with a number) or general material locations (when sample number is not included in the photo). When a photo is shown with a zero (i.e. MFA-0), it typically means the material is assumed to contain asbestos, and no samples were collected. For an assumed material, if the Sample Area ID is noted on a diagram, it often reflects the location of the photo.

Samples are analyzed by a laboratory approved or accredited (as applicable) by the National Voluntary Laboratory Accreditation Program (NVLAP) or American Industrial Hygiene Association (AIHA).

The analysis results relate only to the materials sampled and only as found in the locations described in this report.

For qualitative analysis: If asbestos was detected, a material will be reported as an asbestos containing material, even though the asbestos was not quantified. If no asbestos was detected, a material will be reported as a non-asbestos containing material.

Asbestos content within a homogeneous area may vary. Therefore, random samples of a homogeneous area may indicate an asbestos content of less than 1% or no asbestos detected, while other random samples taken from the same material may indicate an asbestos content of greater than 1%. IDEAL sampled according to accepted sampling protocol (unless otherwise noted by limitations in the description of the scope of work) and is not liable if materials are re-sampled and found to contain asbestos.

All asbestos containing friable materials are regulated. The process of renovation/demolition may cause non-friable category I or non-friable category II materials to become friable, and therefore regulated. Asbestos containing non-friable category II materials are generally reported as regulated, as they are likely to become friable during the process of renovation/demolition.

Exceptions may exist, such as pliable caulking material.

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Regardless of the classification of asbestos containing materials at the time of the inspection, if any non-friable material becomes friable during demolition or renovation, that material is then considered RACM and is subject to all NESHAP rules.

ADDITIONAL SAMPLING/ANALYSIS OPTIONS

➢ When sample analysis is stopped at the first positive, analysis of remaining samples is an option.

➢ When friable and non-friable category II materials containing less than 10% asbestos as determined by PLM, EPA Method

600/R-93/116 were identified, they must be point counted*, analyzed by TEM or treated as assumed ACM prior to removal/renovation in commercial buildings or apartments with more than four units. TEM is recommended. [*PLM Point Count is a method specified in EPA regulations (NESHAP Final Rule). However, bulk sample analysis methods are continually improving, and other analysis methods are now available to help verify asbestos content. One of these methods is TEM, and EPA has subsequently specified that it is an acceptable alternative to PLM Point Count.]

➢ If only one sample of a material has been collected, it is likely due to limited quantities or accessibility. If for any other reason and analysis indicates that no asbestos was detected, additional sampling is an option.

➢ Non-friable category I materials that contain trace amounts of asbestos as determined by PLM are reported as non-asbestos containing materials. Additional sampling is an option.

➢ Additional sampling and/or analysis to verify asbestos content is an option for any material.

ADDITIONAL SAMPLING/ANALYSIS RECOMMENDATIONS

➢ Non-friable organically bound (NOB) materials found to be non-ACM by PLM are recommended to be analyzed by TEM to confirm negative results for all renovation projects or for demolition projects where concrete is to be recycled.

➢ Laboratory analytical results may vary for a sampled material. Additional analysis for a material may be done or recommended if it is discovered that differing results for the same material exist. The definition of a homogeneous area as used by an asbestos inspector may differ from a laboratory’s usage of the word homogeneous. The color description by the lab may differ from the color description used by an inspector.

➢ If a prior inspection report exists for any of the materials sampled within this report, the results may be contradictory. If client knows a prior report exists and was not provided to IDEAL for review, IDEAL recommends a careful review for contradictory results and TEM analysis considerations.

TEM results supersede PLM results.

When trace amounts of asbestos are detected by TEM, a material is reported as non-asbestos containing.

When trace amounts of asbestos are detected in terrazzo materials as determined by TEM, they are reported as non-asbestos containing. However, we recommend against sanding such materials for maintenance purposes.

It is often difficult to penetrate a terrazzo material for a core sample without causing destructive sampling to it. Other suspect asbestos containing materials may exist below the hard terrazzo top surface (such as a soft mud bed, etc.). Therefore, if any material is found below the hard top surface during renovations, additional inspection service is necessary.

The inspection is limited and excludes exhaustive sampling and analysis methods to verify a material’s asbestos content. For instance, unless otherwise noted, the inspection service excluded verifying (by TEM) the asbestos content of all materials containing greater than 1% asbestos as determined by PLM as well as verifying the asbestos content of all materials in which no asbestos (or trace amounts) of asbestos were detected by PLM.

The area estimates shall not be used for bidding purposes. All quantities and conditions that affect costs for asbestos removal and disposal must be verified. Area estimates may include materials known/assumed to be present behind walls, above ceilings, inside boilers, under floors, etc.

This report is not a specification for removal of asbestos containing material, nor shall it be used as such.

The inspection service excluded any inspection for the presence of mold or other contaminants. IDEAL shall not be held responsible for disturbance of any mold or other contaminants or amplification of same.

At least one representative trained in the provisions of 40 CFR Part 61, Subpart M, is to be on site during demolition or renovation. The person is to have in his or her possession evidence that the requisite training has been accomplished. The person is to ensure that if additional quantities of known or suspect asbestos containing materials are found, applicable asbestos rules will be followed.

This report was completed based on our interpretations of regulations. Changes in accepted practices or in applicable regulations cannot be anticipated and have not been addressed.

This report shall not be reproduced, except in full, without the written consent of IDEAL. IDEAL may not retain records for more than one year. IDEAL reserves the right to provide copies of chains of custody rather than originals, as the originals will only be archived for a limited period of time.

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The scope of work was based on an understanding between IDEAL and client, whether the understanding was from verbal conversation or written document(s). The scope of work and report shall be deemed accepted by client unless client advises to the contrary in writing to IDEAL within 10 days of the date the report is sent.

No warranty or guarantee, expressed or implied, is made as to the conclusions, findings and/or professional advice included in this report.

Asbestos Removal The following information is presented for informational purposes only. It is not a complete outline of asbestos regulations, nor is it to be used as asbestos removal specifications. It is important to understand that asbestos in buildings is regulated by several government agencies. Each agency has its own definition of “Public and commercial buildings”.

The EPA definition of “Public and commercial buildings” under the NESHAP regulation is any building that is not a residential building of four or fewer dwelling units. Single-family homes are not considered “public and commercial buildings”. The EPA, however, does include residential buildings in the NESHAP regulations if demolition of the properties is part of an urban renewal project, a highway construction project, or for any shopping mall development, industrial development or other private commercial development.

Under NESHAP regulations, in some cases the EPA requires notification prior to asbestos removal. NESHAP also requires notification prior to building demolition/renovation even if no asbestos was detected. All notifications must be sent to the IL EPA and post marked or delivered at least ten working days prior to the asbestos removal, demolition or renovation.

Also, in some cases, IDPH requires notification 2 working days prior to an asbestos abatement project. The completion of this form is not required for buildings that are included in IDPH’s definition of an “industrial building”.

The Illinois Environmental Protection Act, publish date: January 1999, Title II: Air Pollution, Section 9a. states that no person shall: Cause or threaten or allow the discharge or emission of any contaminant into the environment in any State so as to cause or tend to cause air pollution in Illinois, either alone or in combination with contaminants from other sources, or so as to violate regulations or standards adopted by the Board under this ACT. Based on this Act, all friable asbestos containing materials and those likely to become friable during demolition should be removed from the building prior to demolition.

The building owner is responsible for ensuring all current federal, state and local asbestos rules and regulations are followed. In Illinois, depending on the type and quantity of asbestos removal, the following may be necessary:

-The use of an IDPH licensed asbestos abatement contractor.

-The use of EPA-AHERA accredited, IDPH licensed asbestos workers.

-The use of EPA-AHERA accredited, IDPH licensed asbestos supervisors.

-The use of EPA-AHERA accredited, IDPH licensed asbestos project designer.

-The use of EPA-AHERA accredited, IDPH licensed asbestos air sample professional.

-The use of an OSHA-competent on-site person.

K-12 school buildings have more stringent removal regulations than those noted above.

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Environmental Services Provided by

IDEAL Environmental Engineering, Inc.

Please contact us to assist you with the following:

Asbestos

Asbestos Inspections Asbestos Laboratory Analysis (NVLAP, PAT) Asbestos Management Planning Asbestos Abatement Design Asbestos Abatement Project Management Asbestos Abatement Air Sampling Asbestos Consulting (Emergencies, Cleanup, Abatement) Asbestos Documentation Organization

Training

Asbestos Worker Training Asbestos Supervisor Training Asbestos Worker and Supervisor Refresher Training Asbestos Floor Tile Removal Worker & Competent Person Courses Asbestos Roofers Course Asbestos Awareness Training (Initial & Refresher) LEAD RRP Training (Initial & Refresher)

Lead

XRF Inspections Lead Sampling Lead Design Lead Monitoring Lead in Water Sampling

Other Available Services

Indoor Environmental Quality Assessments (Mold) Bleacher Inspections

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