7-4-CR27001-27093730 Hazmat Survey.pdf

THREE-YEAR REINSPECTION

PRE-DEMOLITION INSPECTION

FOR ASBESTOS, LEAD, AND

UNIVERSAL, HAZARDOUS AND TOXIC WASTES

SOUTHERN UTAH UNIVERSITY

MULTIPURPOSE BUILDING

351 West University Boulevard

Cedar City, Utah 84720

June 18, 2026

Prepared for:

Ms. Aubrey Stapel

Project Manager

State of Utah

Department of Administrative Services

Division of Facilities Construction and Management (DFCM)

4315 South 2700 West, Floor 3

Taylorsville, Utah 84129-2128

Prepared by:

Hill West Environmental

7963 Douglas Drive

Park City, Utah 84098

State of Utah Company Certification # ASBC-495

Claude Dahlk, CHMM, CIEC

(801) 450-8060

TABLE OF CONTENTS

Table of Contents

EXECUTIVE SUMMARY ....................................................................................... i

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTION

3.0 INSPECTION PROCEDURES

3.1 Asbestos-Containing Materials (ACM)

3.2 Bulk Sample Collection

4.0 INSPECTION RESULTS

4.1 Asbestos-Containing Materials

4.2 Non-Asbestos-Containing Materials

4.3 Bulk Sample Analytical Results

4.4 Damage and Hazard Assessment

4.5 Homogeneous Areas with Special Considerations

4.6 Suspect Materials Presumed to be Asbestos-Containing Materials

4.7 Inaccessible Areas

4.8 Material(s) assumed to contain >1.0% asbestos

5.0 RESPONSE ACTIONS

5.1 Applicable Rules and Regulations

5.3 Renovation and Demolition (EPA and OSHA)

6.0 COST ESTIMATES

Appendices

Appendix A: Data Tables (Asbestos)

Appendix B: Original Inspection Report 2016

Appendix C: Laboratory Reports

Appendix D: Photographs (Asbestos)

Appendix E: Project Limitations

Page i Pre-Demolition Inspection Report

EXECUTIVE SUMMARY

On June 8, 2026, Hill West Environmental (Hill West) conducted a three-year re-inspection of the Southern Utah University – Multipurpose Building located at 351 West University Blvd, Cedar City, Utah. Hill West reviewed a previous report completed by R & R Environmental, Inc. completed in August 2016.

Based on our review of the R & R Environmental, Inc. report, Hill West collected additional suspect bulk samples to comply with current Division of Air Quality (DAQ) regulations. Ms. Aubrey Stapel, Improvements Project Manager with the State of Utah, Division of Facilities Construction and Management (DFCM), requested this inspection to identify asbestos-containing materials (ACM);

building components with lead-containing coatings; and Universal, Hazardous and Toxic waste materials that need to be addressed before the building is renovated/demolished.

Hill West identified the following materials during this inspection:

Asbestos-Containing Materials

Homogeneous Area Number

Material Description

Asbestos Content

Amount

Cost Estimate

M01 Exterior caulk

Gray / white resinous caulk

Rooms: Exterior Doors &

Windows

3% Chrysotile

598 lf $10,000.00

M02 Window Gasket Material

Gray / tan resinous material

Rooms: Windows

2% Chrysotile

544 lf $20,000.00

M03 Vinyl Floor Tile

All 9” floor tile

Rooms: 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 208, 213, 214, 215, 216, 217, 218, Assumed

7,507 ft2 $37,600.00

M03A Floor Tile Mastic

Tan resinous material

Rooms: 100, 100A, 100B, 101, 102, 104, 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 208, 213, 214, 215, 216, 217, 218, 219

5% Chrysotile

11,259 ft2 $39,000.00

M11 Rolled Vinyl Flooring

Off white / tan sheet vinyl with gray fibrous backing Rooms:

113, 114

25% Chrysotile

964 ft2 $10,000.00

Page ii

M21 CMU Block Filler

White block filler

Rooms: Throughout

>5,000 ft2 $100,000.00

(Depends on square footage)

M33 Roofing Material

Assumed ~ 48,125 ft2 N/A

T01 TSI – Plaster Fitting

Gray fibrous plaster

Rooms: Tunnels, walls, ceilings

20% Chrysotile

~ 320 each $15,000.00

M05 Foam Floor Padding

Tan resinous material

Rooms: North 200 Corridor, 213, 214, 215, 216, 217, 218

<1% Chrysotile

(By Point Count)

630 ft2 $2,500.00

S043 Plaster Surfacing

Tan granular plaster

Rooms: Scattered throughout

>5,000 ft2 $50,000

(Depends on square footage)

M033 Grey Caulking Exterior

2% Chrysotile ~ 300 lf $3,600.00

Notes:

1. Homogeneous Area Number (Not related to building room numbers.)

2. Cost Estimates include asbestos removal costs only; abatement design and management fees and replacement costs are not included. Please refer to Section 7.0 for more details.

3. This ACM contains less than 1% asbestos by Point Count and is therefore not subject to the NESHAP. Removal of this material is a Class II Operation under OSHA, which requires 40-hour trained supervisors, trained workers and specific work practices (wet methods, prompt clean-up of debris, HEPA vacuums, etc.

4. Thermal Systems Insulation Plaster Fittings and End Sealant material may be concealed in walls and above ceilings.

Building Components with XRF Lead readings ≥ 0.4 mg/cm2

• Window Sills 5.4 - 10.1

• Ceramic Tiles 2.3 - 2.7

• Door Frames 3.3

• Bulletin Boards 0.4 - 2.8

• Structural Beams / Columns 2.8 - 9.7

• Sinks 4.5 - 9.0

• Walls 0.4 - 9.0

Page iii

Exterior

• Structural Beams / Columns 2.8 - 9.7

(9.6 mg/cm2 – >9.9 mg/cm2)

Universal, Hazardous, and Toxic Wastes

● PCB Ballast Throughout

~ 308 units

● Fluorescent Light Throughout

~ 616 tubes

● Refrigeration Units Throughout

~ 13 Units

● Thermostats Throughout

~ 45 Units

Conclusions

ACM – The Asbestos Containing Items are regulated under the Environmental Protection Agency (EPA) for renovation and demolition activities. Therefore, Hill West recommends that a Utah-certified abatement contractor remove and properly dispose of the ACM in these buildings that may be disturbed during future demolition. All non-friable roofing materials can remain in-place for demolition as long as wet-methods are used during demolition activities.

Lead – Lead-based paint was identified on shower ceramic wall tile, Door Frames, Structural Beams, Window Seals, Bulletin Board, Sink, and Walls.

Subtitle C of the Resource Conservation and Recovery Act (RCRA) requires the generator to determine if demolition wastes are hazardous. Toxicity Characteristic Leaching Procedure (TCLP) testing is the preferred method for determining this. The demolition wastes from this project should undergo TCLP testing prior to disposal to determine if they are hazardous.

Universal, Hazardous and Toxic Wastes – DFCM follows the protocols for identification and disposal of hazardous materials developed by the Salt Lake Valley Health Department (SLVHD). These protocols require building owners to identify and remove all universal, hazardous and/or toxic waste from buildings before they are demolished. Disposal/recycling of these materials must follow Environmental Protection Agency (EPA) guidelines outlined in 40 CFR 173 (Shippers – General Requirements for Shipments and Packaging), As such, Hill West recommends that the materials identified during this inspection be removed and disposed/recycled by properly trained and licensed contractors.

Page iv

Cost Estimates

Hill West’s cost estimates to remove the hazardous materials outlined above are:

● Asbestos-containing Materials: $337,700.00

● Hazardous Materials (Universal Wastes): $20,000.00

The cost estimates above are provided for use in long-term budgeting and planning only and do not have a level of accuracy sufficient to be used as construction design cost estimates. The actual cost of asbestos removal is highly dependent on a number of factors such as the size of the job (single room or mechanical enclosure, or an entire floor or building); the required time frame for removal; the time of year the job is conducted ; and travel time and distance to the job for the contractor. Therefore, actual removal costs could vary significantly from these estimates. The cost estimates are based on a four (4) month project time schedule for all abatement to be completed.

The report that follows this Executive Summary should be read in its entirely because it includes important information, such as material descriptions and locations, regulatory requirements, and building specific recommended response actions.

Pre-Demolition/Renovation Asbestos Inspection Report

Southern Utah University Multipurpose Center

351 West University Blvd Cedar City, Utah

1.0 INTRODUCTION

On June 8, 2026, Hill West Environmental conducted a three (3) year asbestos re-inspection of the Southern Utah University – Multipurpose Center located at 351 West University Blvd, Cedar City, Utah. The purpose of this survey was to identify the existence, extent, and condition of both friable and non-friable asbestos-containing materials (ACM) within the facility. Bulk samples were collected from suspect materials and analyzed for asbestos content. Each occurrence of ACM was assessed for damage and friability. Appendix A contains Data Tables that have been prepared by the inspector based on the results of this inspection.

2.0 BUILDING DESCRIPTION

Building Identification

Building Name…………………………… SUU Multipurpose Building

Building Address………………………… 351 West University Blvd

Cedar City, Utah

Building Construction

Building Construction Date………

Renovations……………………………… Unknown

Building Type……………………………. Gymnasium, Classrooms, Offices

Building Total Sq. Ft…………………….. ~ 60,000 ft2

Structural System……………………….. Reinforced Concrete

Exterior Wall Construction……………… Brick/concrete

Floor Deck Construction………………... Reinforced concrete

Roof Construction………………………. Flat membrane

Floors Above Grade………

Floors Below Grade…………………….. 2

Interior Finishes

Floors……………………….................... Concrete, ceramic tile, vinyl floor tile, linoleum, glued carpet

Walls……………………………………… Brick, wallboard system, plaster

Ceilings…………………………………… Wallboard System, Suspended Ceiling Panels, Ceiling Tiles

Attic……………………………………….. Partial

Crawl space……………………………… Yes – Concrete tunnels

Building Mechanical

Heating System…………………………. Campus Plant

Mechanical Piping…………..………….. Campus Plant

Cooling Plant……………………………. Campus Plant

Appendix B contains the original R&R Environmental, Inc Inspection Report completed in 2016.

3.0 INSPECTION PROCEDURES

3.1 Asbestos-Containing Materials (ACM)

All accessible areas of the facility were visually inspected to identify suspect asbestos containing materials (ACM.) All accessible surfaces, structures, and mechanical systems within these areas were examined and all suspected ACM was touched to determine friability.

Suspect ACM was identified and assessed in homogeneous areas. A homogeneous area is defined as a single material, uniform in texture and appearance, installed at one time, and unlikely to consist of more than one type, or formulation, of material. In cases where joint compound and / or tape has been applied to wallboard (gypsum board) and cannot be visually distinguished from the wallboard, it is considered an integral part of the wallboard and in effect becomes one material forming a wall or ceiling “system.”

Each homogeneous area was given a unique material identification number.

Each ID number begins with a letter: “S” for surfacing materials, “T” for thermal system insulation, or “M” for miscellaneous materials. This letter is followed by a three-digit number, assigned in consecutive order. This number is used to identify the homogeneous area throughout the inspection report.

3.2 Bulk Sample Collection

Bulk samples were collected from all accessible homogeneous areas of suspect ACM for subsequent laboratory analysis to determine actual asbestos content.

Sampling was conducted in a manner that minimized damage to the building, did not leave any unsightly marks, and did not create a health hazard for the inspectors.

The number of samples collected from each homogeneous area generally followed the EPA Asbestos Hazard Emergency Response Act (AHERA) regulations (40 CFR §763.86). Friable surfacing materials were sampled using the random sampling scheme given in the EPA publication 560 / 5-85-30a, titled “Asbestos in buildings: Simplified Sampling Scheme for Friable Surfacing Materials."” Between three and seven samples were collected from friable surfacing materials, depending on the size of the homogeneous area. Bulk sample IDs collected during the inspection were entered on chain-of-custody forms for submittal to the analytical laboratory.

3.3 Bulk Sample Analysis

Bulk samples were analyzed using polarized light microscopy (PLM) and visual estimation in accordance with the EPA Interim Method for the Determination of Asbestos in Bulk Insulation Samples, EPA-600 / M4-82-020. Samples were analyzed by Dixon Information, Inc. 78 West 2400 South, South Salt Lake City, Utah 84115. The laboratory is accredited under the National Institute of Standards and Technology–National Voluntary Laboratory Accreditation Program (NIST-NVLAP) for bulk-asbestos sample analysis and is also accredited by the American Industrial Hygiene Association (AIHA).

Federal EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) and AHERA regulations define ACM as material containing greater than 1% asbestos by weight; materials containing less than 1% asbestos are not considered regulated ACM.

Further, the NESHAP regulations state that any sample found to contain less than 10% asbestos but greater than “none detected,” by visual estimation, must be assumed to contain greater than 1% asbestos unless confirmed to be less than 1.0% asbestos by point counting analysis.1

Despite EPA and Utah Division of Air Quality (UDAQ) rules exempting building materials containing 1% or less asbestos from stringent regulation, OSHA regulations outline specific precautionary work practices when employees work with materials containing even trace amounts of asbestos.2

The laboratory reports can be found in Appendix C of this report.

1 NESHAP point counting includes examining materials under a polarizing microscope using an eyepiece reticule that superimposes a grid of points over the field of view; 400 points are examined.

2 OSHA regulations pertaining to asbestos in buildings include 29 DFR 1926.1001. OSHA has also issued interpretive letters that provide clarification about how materials containing less than 1% asbestos should be handled. (See www.osha.gov)

4.0 INSPECTION RESULTS

4.1 Asbestos-Containing Materials

The Executive Summary and Table 1 in Appendix A list all homogeneous areas that contain asbestos. Each material is described by type of material, friability and visual appearance.

Friability is defined in accordance with EPA’s NESHAP regulations.

“Friable ACM” is any material containing more than 1% asbestos (as determined by PLM) that, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure and also includes non-friable ACM that may become friable during building demolition.

“Non-friable ACM” is any material containing more 1% asbestos (as determined by PLM) that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

“Category I non-friable ACM” are asbestos-containing resilient floor coverings (commonly known as vinyl asbestos tile (VAT), asphalt roofing products, packings, and gaskets.

“Category II non-friable ACM” encompasses all other non-friable ACM.

“Non-friable RACM” is used to denote thermal system insulation that is in good condition but would become friable during renovation or demolition and therefore is “regulated asbestos containing material” (RACM).

4.2 Non-Asbestos-Containing Materials

Homogeneous areas of suspect ACM are identified as non-ACM if the laboratory analysis shows the material to contain no detectable asbestos. Table 2, located in Appendix A of this report, lists all homogeneous areas that were found to be non-ACM.

4.3 Bulk Sample Analytical Results

Table 3, located in Appendix A, lists all of the bulk samples in order by sample number, that were collected from homogeneous areas of suspect ACM, along with the laboratory analytical results. Each sample was given a unique sample number. There may be more than one sample number for the same homogeneous area of suspect ACM. The homogeneous areas of suspect ACM are identified on this table by their material identification numbers. The sample location listed on this table provides a brief, but specific, description of the location where the sample was collected. This is different than the homogeneous area location provided on Tables 1 and 2. The sample locations listed in Table 3 provide a short description of the location where the sample was collected. This is different from the homogeneous area location provided on Tables 1 and 2. Appendix D contains photographs of suspect ACM samples that were collected during this inspection.

4.4 Damage and Hazard Assessment

Each homogeneous area of ACM has been assessed for existing damage, accessibility, and potential for future damage and this information is presented in Table 4, located in Appendix A of this report. This table also lists the substrate present beneath each homogeneous area of ACM.

Each homogeneous area of friable ACM and asbestos-containing building material (ACBM) was classified into one of the following seven categories, as specified in EPA’s AHERA regulations (40 CFR 763.88):

(1) Damaged or significantly damaged thermal system insulation ACM.

(2) Damaged friable surfacing ACM.

(3) Significantly damaged friable surfacing ACM.

(4) Damaged or significantly damaged friable miscellaneous ACM.

(5) ACBM with potential for damage.

(6) ACBM with potential for damage.

(7) Any remaining friable ACBM or friable suspected ACBM.

The damage categories are defined as follows:

“Undamaged” means the material had no visible damage, or extremely minor damage or surface marring (i.e., a room full of floor tile with only two or three small corners chipped off on the tile).

“Damaged” means the material had visible damage evenly distributed over less than 10% of its surface, or localized over less than 25% of its surface.

“Significantly Damaged” means the material had visible damage that is evenly distributed over 10% or more of its surface or localized over 25% or more if its surface.

Each homogeneous area of ACM was evaluated for accessibility to the building occupants and the general public, assuming the building was fully occupied, using the following assessment categories.

“Inaccessible” means the material was located in an area that people had no reason to enter and could not access without special measures. One example would be above a solid ceiling.

“Rarely Accessed” identifies a material that was in a location that could be accessed but wasn’t unless there was a specific need. An example would be a pipe tunnel. Another example would be a high ceiling that is out of reach and not subject to any specific disturbance.

“Periodic Access” identifies a material that was in a location that was accessible, was not occupied full time, but was accessed on a routine basis. An example would be a mechanical room or boiler room.

“Continuous Access” identifies a material that was in a location that was occupied full time and was within reach of the occupants, or was frequently subject to direct disturbance. Examples would be exposed floor tile or a normal height ceiling.

4.5 Homogeneous Areas with Special Considerations

Metal doors: Rooms which had metal doors included the boiler room and lower level exits out of the building. These types of doors should be assumed to contain asbestos.

4.6 Suspect Materials Presumed to be Asbestos-Containing Materials without Laboratory Analysis

Location Asbestos Material Quantity

All Roofing materials – Flat roof with membrane liner/flashing/caulking

~ 48,000 ft2

4.7 Inaccessible Areas

Some building structures may have been constructed after the application of ACM, and therefore may have obscured these materials from visual examination during this inspection. Typical scenarios include thermal system insulation inside hardened mechanical chases, floor tile, and mastic under walls, and sprayed on texturing and/or fireproofing behind structural supports or architectural features which is suspected within the dorm room walls.

4.8 Material(s) assumed to contain >1.0% asbestos without subsequent

TEM or Point Count Analysis

None.

5.0 RESPONSE ACTIONS

5.1 Applicable Rules and Regulations

In Utah, EPA asbestos regulations are administered by the UDAQ).3 Utah Occupational Safety and Health Administration (UOSHA) has adopted the Federal OSHA regulations.4 In addition, the SLVHD regulates demolition activities in Salt Lake County.5 The SLVHD regulations for pre-demolition building inspections require an asbestos inspection, but also required building owners to inspect the building for other hazardous materials such as universal wastes, hazardous and toxic wastes and lead-based paint. Similar to asbestos, these wastes, if present must be removed prior to demolition.

Regulatory factors relevant to lead-based paint abatement decision-making are included in Appendix B.

3 R307-801. Asbestos, Utah Division of Air Quality Rules, Implementation of Toxic Substances

Control Act Title II, Asbestos Certification, Asbestos Training, notifications and Asbestos Work Practices for Renovations and Demolitions (See www.airquality.utah.gov).

4 Asbestos, Tremolite, Anthphylite, and Acitnolite Standards, Chapter D (Construction), Section

58; and Chapter Z (General Industry), Section 1001, Utah Occupational Safety and Health Rules and Regulations (Administered by Utah Occupational Safety and Health Division) (See www.uosh.utah.gov).

5 Salt Lake City – County Health Department, Health Regulation #1 Section 12

(See www.slvhealth.org).

http://www.airquality.utah.gov/ http://www.uosh.utah.gov/ http://www.slvhealth.org/

5.2 Renovation and Demolition (EPA and OSHA)

A listing of ACM found during this inspection is presented in the Executive Summary at the front of this report and in Appendix A, Table 1.

NESHAP regulations require the removal of friable ACM and non-friable ACM that could become friable during demolition activities. Therefore, we recommend that all of the ACM in this building be removed and properly disposed of by a licensed asbestos abatement contractor before renovation activities begin which have the potential of disturbing areas where these materials are located.

Despite EPA and UDAQ rules exempting building materials containing 1% or less asbestos from stringent regulation, OSHA regulation outline specific precautionary work practices when employees work with materials containing even trace amounts of asbestos. Strict compliance by building owners with OSHA asbestos regulations may result in response actions not required by EPA and Utah DAQ for certain unregulated materials6.

6 OSHA regulations pertaining to asbestos in buildings include 29 CFR 1926.1101 and 29 CFR

1910.1001. OSHA has also issured interpretive letters that provide clarification about how materials containing less than 1% asbestos should be handled. (See www.osha.gov).

http://www.osha.gov/

6.0 COST ESTIMATES

Details of the estimated removal costs by homogeneous area can be found in Table 5, Appendix A, and the Executive Summary table.

Cost Estimate Limitations

These cost estimates are provided for the use of long-term budgeting and planning only and do not have a level of accuracy sufficient to be used as construction design cost estimates. The actual cost of asbestos removal is highly dependent on the size of the project or quantity of materials removed in a single abatement enclosure. The unit costs associated with small-scale emergency projects will typically be significantly greater than the costs associated with larger, planned projects. The cost estimates attempt to capture the costs associated with the removal of all asbestos-containing materials identified in this survey as part of one removal contract.

Material replacement and consultant abatement management costs are not included in these estimates and can add significantly to the project costs.

The estimated costs of removing lead-containing materials are not included here because there is no regulatory requirement to remove lead. Some lead-containing materials may not be disturbed during the renovation and may therefore remain in place. In addition, disposal costs of demolition wastes may vary significantly, depending on TCLP testing.

June 18, 2026

Claude Dahlk, CHMM, CIEC Date Asbestos Inspector ASB-0433

Appendix A

Data Tables (Asbestos)

Table 1

Asbestos-containing Materials by Homogeneous Area

Southern Utah University - Multipurpose Building

State of Utah-DFCM

Material Description/Location Friability Asbestos Content Amount

Gray / white resinous caulk

Rooms: Exterior Doors & Windows

No

598 lf

Gray / tan resinous material

544 lf

All 9” floor tile

Rooms: 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 208, 213, 214, 215, 216, 217, 218, 219

7,507 ft2

Tan resinous material

Rooms: 100, 100A, 100B, 101, 102, 104, 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 11,259 ft2

Off white / tan sheet vinyl with gray fibrous backing Rooms: 113, 114

964 ft2

White block filler

>5,000 ft2

M33

Roofing Material

No Assumed ~ 48,125 ft2

T01 TSI – Plaster Fitting

Yes 20% Chrysotile

~ 320 each

Tan resinous material

Rooms: North 200 Corridor, 213, 214, 215, 216, 217, 218

No

S043 Plaster Surfacing

Tan granular plaster

Rooms: Scattered throughout

No <1% Chrysotile

(By Point Count

M33 Gray Caulking

2% Chrysotile 300 LF

Table 2

Homogeneous Areas That Do Not Contain Asbestos

Material Description/Location Amount

M04 Vinyl Floor Border

Brown

4,500 ft2

M06 Carpet Adhesive

Yellow / gray resinous material

>3,500 ft2

M07

Ceiling Tile Adhesive

Brown resinous material

>9,382 ft2

M08 Ceiling Panel

2’ x 4’, white/gray perlite 3,116 ft2

M09

Ceiling Tile

12” White / tan ceiling tile

>1,476 ft2

M10 Ceiling Tile

12” White / gray perlite

>800 ft2

M12 Vinyl Stair Tread

Off-white / gray vinyl 60 ft2

M13 Vinyl Floor Tile & Mastic

12” yellow tile, yellow mastic 1,171 ft2

M14 Vinyl Cove Base & Mastic

Black cove, white resinous mastic

150 ft2

M15 Vinyl Cove Base & Mastic

6” Black cove, off-white mastic

35 lf

M16 Vinyl Cove Base & Mastic

Black cove, white resinous mastic 120 lf

M17 Vinyl Cove Base & Mastic

90* Black cove, white resinous mastic

454 lf

M18 Sink Undercoating

Gray resinous material

15 each

M19 Sink Undercoating

White fibrous resinous material

2 each

Material Description/Location Amount

M20 Chemical Counter Top

Black granular resinous material

160 lf

M22

Window Panel Material

Pink/brown drywall with white paint

300 ft2

M23

Duct Adhesive

Yellow Resinous Material

175 ft2

M24

Duct Sealant

White compound

112 lf

M25

Cloth HVAC Vibration Isolator Black woven material

384 lf

M26

Vinyl HVAC Vibration Isolator Black resinous and white woven material

190 lf

M27

Vinyl HVAC Vibration Isolator White resinous and white woven

117 lf

M28

Air Handler Sealant Black resinous material

240 lf

M29

Ceramic Tile Mortar

Gray granular plaster

>1,000 ft2

M30

Pool Lining

Blue glazing, gray plaster, gray granular plaster, white granular plaster

M31

Wall System

White compound, white tape, joint compound, white/brown drywall

M32

TSI – End Sealant

White resinous, gray fibrous materials

230 ft2

S01

Textured Ceiling Material

White paint, white texture

4,122 ft2

S02

343 ft2

S03

Textured Ceiling Material White foamy textured 935 ft2

S05

Textured Wall Material

13,892 ft2

S06 Exterior Stucco

Off-white granular resinous material, gray granular cementitious material, white micaceous material

2,190 ft2

Table 3 Bulk Sample Analytical Results by Sample Number

Sample Number

Homogeneous Area Number

Material Sampled Sample Location Analytical

Results

SUU-MP-01

M01

Exterior Caulk

South Exterior

SUU-MP-02 M01 Exterior Caulk South Exterior 3% Chrysotile

SUU-MP-03 M01 Exterior Caulk South Exterior None Detected

SUU-MP-04 M02 Window Gasket Material South Exterior None Detected

SUU-MP-05 M02 Window Gasket Material South Exterior None Detected

SUU-MP-06 M02 Window Gasket Material South Exterior 2% Chrysotile

SUU-MP-07 M03 / M03A 9" VFT & Mastic Room 200 Assumed (tile)

5% Chrysotile

(mastic)

SUU-MP-08 M04 Vinyl Floor Boarder Room 200 None Detected

SUU-MP-09 M05 Tan Foam Floor Padding North 200 Trace Chrysotile

SUU-MP-10 M03 / M03A Concealed Vinyl Flooring North 200 Assumed (tile)

4% Chrysotile

(mastic)

SUU-MP-11 M06 Carpet Adhesive Room 212 None Detected

SUU-MP-12 M07 Ceiling Tile Adhesive Room 111 None Detected

SUU-MP-13 M07 Ceiling Tile Adhesive Room 208 None Detected

SUU-MP-14 M07 Ceiling Tile Adhesive Room 208 None Detected

SUU-MP-15 M08 2' x 4' Ceiling Panel Room 200 None Detected

SUU-MP-16 M08 2' x 4' Ceiling Panel Room 210 None Detected

Homogeneous Area Number

Material Sampled Sample Location

SUU-MP-17 M08 2' x 4' Ceiling Panel Room 211 None Detected

SUU-MP-18 M09 12" Ceiling Tile Room 208 None Detected

SUU-MP-19 M10 12" Ceiling Tile Room 205 None Detected

SUU-MP-20 M11 Rolled Vinyl Flooring Room 113 25% Chrysotile

SUU-MP-21 M12 Vinyl Stair Tread Room 100B None Detected

SUU-MP-22 M13 Vinyl Floor Tile & Mastic Room 210 None Detected

SUU-MP-23 M14 Vinyl Cove Base & Mastic Room 210 None Detected

SUU-MP-24 M15 Vinyl Cove Base & Mastic Room 111 None Detected

SUU-MP-25 M16 Vinyl Cove Base & Mastic Room 111 None Detected

SUU-MP-26 M17 Vinyl Cove Base & Mastic Room 111 None Detected

SUU-MP-27 M18 Sink Undercoating (gray) Room 210 None Detected

SUU-MP-28 M19 Sink Undercoating (white) Room 202 None Detected

SUU-MP-29 M20 Resin Counter Top Room 210 None Detected

SUU-MP-30 S01 Textured Ceiling Material #1 Room 200 None Detected

SUU-MP-31 S01 Textured Ceiling Material #1 Room 200 None Detected

SUU-MP-32 S01 Textured Ceiling Material #1 Room 200 None Detected

SUU-MP-33 S01 Textured Ceiling Material #1 Room 200 None Detected

SUU-MP-34 S01 Textured Ceiling Material #1 Room 100 None Detected

SUU-MP-35 S01 Textured Ceiling Material #1 Room 100 None Detected

SUU-MP-36 S01 Textured Ceiling Material #1 Room 100 None Detected

Homogeneous Area Number

Material Sampled Sample Location

SUU-MP-37 S02 Textured Ceiling Material #2 Room 206 None Detected

SUU-MP-38 S02 Textured Ceiling Material #2 Room 207 None Detected

SUU-MP-39 S02 Textured Ceiling Material #2 Room 210C None Detected

SUU-MP-40 S03 Textured Ceiling Material #3 Room 116 None Detected

SUU-MP-41 S03 Textured Ceiling Material #3 Room 209 None Detected

SUU-MP-42 S03 Textured Ceiling Material #3 Room 107 None Detected

SUU-MP-46 S03 Textured Ceiling Material #3 Room 104C None Detected

SUU-MP-47 S04 Plaster Surfacing Room 104 None Detected

SUU-MP-48 S04 Plaster Surfacing Room 114 None Detected

SUU-MP-49 S04 Plaster Surfacing Room 109 Trace Chrysotile

SUU-MP-50 S04 Plaster Surfacing Room 110 Trace Chrysotile

SUU-MP-51 S04 Plaster Surfacing Room 111 None Detected

SUU-MP-52 S04 Plaster Surfacing Room 111 None Detected

SUU-MP-53 S04 Plaster Surfacing Attic None Detected

SUU-MP-54 M21 CMU Block Filler Room 208 3% Chrysotile

SUU-MP-55 M21 CMU Block Filler Room 209 None Detected

SUU-MP-56 M21 CMU Block Filler Room 205 3% Chrysotile

SUU-MP-57 M21 CMU Block Filler Room 111 3% Chrysotile

SUU-MP-58 M21 CMU Block Filler Room 111 3% Chrysotile

SUU-MP-59 M21 CMU Block Filler Room 102 2% Chrysotile

Homogeneous Area Number

Material Sampled Sample Location

SUU-MP-60 M21 CMU Block Filler Room 110A 3% Chrysotile

SUU-MP-61 S05 Wall Texture Material Room 200A None Detected

SUU-MP-62 S05 Wall Texture Material Room 209H None Detected

SUU-MP-63 S05 Wall Texture Material Room 209E None Detected

SUU-MP-64 S05 Wall Texture Material Room 210 None Detected

SUU-MP-65 S05 Wall Texture Material Room 210B None Detected

SUU-MP-66 S05 Wall Texture Material Room 116A None Detected

SUU-MP-67 S05 Wall Texture Material Room 205 None Detected

SUU-MP-68 M22 Window Panel Material Room 200A Stairs None Detected

SUU-MP-69 M23 Yellow Duct Adhesive Attic None Detected

SUU-MP-70 M24 White Duct Sealant Attic None Detected

SUU-MP-71 M25 Cloth Vibration Isolator Attic None Detected

SUU-MP-72 M26 Vinyl Vibration Isolator Attic None Detected

SUU-MP-73 M27 White Vibration Isolator 103 None Detected

SUU-MP-74 M28 Air Handler Sealant Attic None Detected

SUU-MP-75 M29 Ceramic Tile Mortar Room 107 None Detected

SUU-MP-76 M30 Pool Lining Under 116A None Detected

SUU-MP-77 M30 Pool Lining Under 116A None Detected

SUU-MP-78 M30 Pool Lining Under 116A None Detected

SUU-MP-79 M30 Pool Lining Under 116A None Detected

Homogeneous Area Number

Material Sampled Sample Location

SUU-MP-80 M30 Pool Lining Under 116A None Detected

SUU-MP-81 M30 Pool Lining Under 116A None Detected

SUU-MP-82 M30 Pool Lining Under 116A None Detected

SUU-MP-83 M31 Wall System Attic None Detected

SUU-MP-84 M31 Wall System Attic None Detected

SUU-MP-85 M31 Wall System Room 209I None Detected

SUU-MP-86 M31 Wall System Room 209G None Detected

SUU-MP-87 M31 Wall System Room 205G <1% Chrysotile

(By Point Count)

SUU-MP-88 M31 Wall System Room 212C None Detected

SUU-MP-89 M31 Wall System Room 108B None Detected

SUU-MP-90 M32 TSI - End Sealant Room 103 None Detected

SUU-MP-91 M32 TSI - End Sealant Tunnels None Detected

SUU-MP-92 M32 TSI - End Sealant Room 01 None Detected

SUU-MP-93 T01 TSI - Plaster Fitting Tunnels None Detected

SUU-MP-94 T01 TSI - Plaster Fitting Tunnels 20% Chrysotile

SUU-MP-95 T01 TSI - Plaster Fitting Tunnels None Detected

SUU-MP-96 S06 Exterior Stucco Material Southeast Exterior None Detected

SUU-MP-97 S06 Exterior Stucco Material Southeast Exterior None Detected

SUU-MP-98 S06 Exterior Stucco Material South Exterior None Detected

SUU-MP-99 S06 Exterior Stucco Material South Exterior None Detected

Homogeneous Area Number

Material Sampled Sample Location

SUU-MP-100 S06 Exterior Stucco Material South Exterior None Detected

Start of Hill Wests Samples

SUU-01A M21 White Block Filler Downstairs Outside

Locker room

2% Chrysotile

SUU-01B M21 White Block Filler Downstairs Outside

Locker room

2% Chrysotile

SUU-01C M21 White Block Filler Downstairs Outside

Locker room

2% Chrysotile

SUU-02A M33 Gray Caulk Downstairs Outside

Locker room

2% Chrysotile

SUU-02B M33 Gray Caulk Downstairs Outside Locker room

None Detected

SUU-MP-12B M07 Ceiling Tile Adhesive Room 208 None Detected

SUU-MP-12C M07 Ceiling Tile Adhesive Room 208 None Detected

Note: ND = No Asbestos Detected, NA = Not Analyzed, TR = <1% Asbestos

Table 4

Damage and Hazard Assessment by Homogeneous Area

Material Type Substrate Assessment Category

Damage Accessibility Disturbance Potential

Metal X Undamaged Periodic Access

Low

M02 Window Gasket Material

Access

Low

M03 9” Vinyl Floor Tile

Concrete X Undamaged Rarely

Accessed Low

M03A Flooring Mastic

Accessed

Low

M11 Rolled Vinyl Flooring

Concrete 5 Undamaged Continuous

Access Low

M21 CMU Block Filler

Masonry X Undamaged

Access Low

T01

Thermal System Insulation – Plaster Fitting

Metal Pipe

5 Undamaged Periodic Access

Low

M33 Gray Caulk Caulk X Undamaged Continuous

Access

Damage Categories Each homogenous area of ACM was classified into one of the following seven categories, as specified in EPA’s AHERA regulations (40 CFR §763.88):

(1) Damaged or significantly damaged thermal system insulation ACM.

(2) Damaged friable surfacing ACM.

(3) Significantly damaged friable surfacing ACM.

(4) Damaged or significantly damaged friable miscellaneous ACM.

(5) ACBM with potential for damage.

(6) ACBM with potential for significant damage.

(7) Any remaining friable ACBM or friable suspected ACMB.

(X) Not applicable (material is non-friable surfacing or miscellaneous material).

● “Undamaged” means the material had no visible damage, or extremely minor damage or surface marring (i.e., a room full of floor tile with only two or three small corners chipped off of the tile).

● “Slight Damage” means the material had visible damage evenly distributed over less than 10% of its surface, or localized over less than 25% of its surface.

● “Significantly Damaged” means the material had visible damage that is evenly distributed over 10% or more of its surface or localized over 25% or more of its surface.

Hazard Assessment Categories Each homogeneous area of ACM was evaluated for accessibility and the hazard the material presents to building occupants and the general public. The assessment assumes a fully occupied building.

● ”Inaccessible”” means the material was located in an area that people had no reason to enter and could not access without special measures. One example would be above a solid ceiling.

● “Rarely-Accessed” identifies a material that was in allocation that could be accessed but wasn’t unless there was a specific need. An example would be a pipe tunnel. Another example would be a high ceiling that is out of reach and not subject to any specific disturbances.

● “Periodic Access” identifies a material that was in a location that was accessible, was not occupied full time, but was accessed on a routine basis. An example would be a mechanical room or boiler room.

● “Continuous Access” identifies a material that was in a location that was occupied full time and was within reach of the occupants, or was frequently subjected to direct disturbance.

Examples would be exposed floor tile or normal height ceiling tile.

Table 5

Estimated Abatement Costs by Homogeneous Area

Material Type Amount Unit Cost Extended Cost

598 lf $16.00 $10,000.00

M02 Window Gasket Material 544 lf $16.00 $20,000.00

M03 9” Vinyl Floor Tile and mastic 7,507 ft2 $5.00 $37,600.00

M03A Flooring Mastic 11,259 ft2 $3.50 $39,000.00

M11 Rolled Vinyl Flooring 964 ft2 $10.00 $10,000.00

>5,000 ft2 $20.00 $100,000.00

S041 Plaster Surfacing Tan granular plaster Rooms: Scattered throughout

>5,000 ft2 $10.00 $50,000.00

T012 Thermal System Insulation – Plaster Fittings

320 each $48.00 $15,000.00

M05

Foam Floor Padding Tan resinous material Rooms: North 200 Corridor, 213, 214, 215, 216, 217, 218

630 ft2 $4.00 $2,500.00

S042

Plaster Surfacing

>5,000 ft2 $10.00 $50,000.00

M33 Gray Caulk 300 Lf $12.00 $3,600.00

Total Estimated Abatement Cost $337,700.00

1. This ACM contains less than 1% asbestos by Point Count and is therefore not subject to the NESHAP. Removal of this material is a Class II Operation under OSHA, which requires 40-hour trained supervisors, trained workers and specific

2. Thermal Systems Insulation Plaster Fittings and End Sealant material may be concealed in walls and above ceilings.

Note: Estimated abatement costs do not include replacement costs or costs for a consultant to manage the abatement.

These materials are not regulated under EPA as friable and therefore only OSHA regulations apply for properly removed materials.

Appendix B

Original Inspection Report 2016

THREE-YEAR REINSPECTION

PRE-DEMOLITION INSPECTION

FOR ASBESTOS, LEAD, AND

UNIVERSAL, HAZARDOUS AND TOXIC WASTES

MULTIPURPOSE BUILDING

August 26, 2022

Mr. Jon Vance

Project Manager

State of Utah

Department of Administrative Services

Division of Facilities Construction and Management (DFCM)

4315 South 2700 West, Floor 3

Taylorsville, Utah 84129-2128

Hill West Environmental

7963 Douglas Drive

Park City, Utah 84098

State of Utah Company Certification # ASBC-495

Claude Dahlk, CHMM, CIEC

(801) 450-8060

Table of Contents

EXECUTIVE SUMMARY ....................................................................................... i

1.0 INTRODUCTION

2.0 BUILDING DESCRIPTION

3.0 INSPECTION PROCEDURES

3.1 Asbestos-Containing Materials (ACM)

3.2 Bulk Sample Collection

4.0 INSPECTION RESULTS

4.1 Asbestos-Containing Materials

4.2 Non-Asbestos-Containing Materials

4.3 Bulk Sample Analytical Results

4.4 Damage and Hazard Assessment

4.5 Homogeneous Areas with Special Considerations

4.6 Suspect Materials Presumed to be Asbestos-Containing Materials

4.7 Inaccessible Areas

4.8 Material(s) assumed to contain >1.0% asbestos

5.0 RESPONSE ACTIONS

5.1 Applicable Rules and Regulations

5.3 Renovation and Demolition (EPA and OSHA)

6.0 COST ESTIMATES

Appendices

Appendix A: Data Tables (Asbestos)

Appendix B: Original Inspection Report 2016

Appendix C: Laboratory Reports

Appendix D: Photographs (Asbestos)

Appendix E: Project Limitations

Page i

EXECUTIVE SUMMARY

On July 27, 2022, Hill West Environmental (Hill West) conducted a three-year re-inspection of the Southern Utah University – Multipurpose Building located at 351 West University Blvd, Cedar City, Utah. Hill West reviewed a previous report completed by R & R Environmental, Inc. completed in August 2016.

Based on our review of the R & R Environmental, Inc. report, Hill West collected additional suspect bulk samples to comply with current Division of Air Quality (DAQ) regulations. Mr. Jon Vance, Improvements Project Manager with the State of Utah, Division of Facilities Construction and Management (DFCM), requested this inspection to identify asbestos-containing materials (ACM);

building components with lead-containing coatings; and Universal, Hazardous and Toxic waste materials that need to be addressed before the building is renovated/demolished.

Hill West identified the following materials during this inspection:

Asbestos-Containing Materials

Gray / white resinous caulk

Rooms: Exterior Doors &

598 lf $10,000.00

Gray / tan resinous material

544 lf $10,000.00

All 9” floor tile

Rooms: 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 208, 213, 214, 215, 216, 217, 218, 7,507 ft2 $21,000.00

Tan resinous material

Rooms: 100, 100A, 100B, 101, 102, 104, 104A, 104C, 107, 107A, 110A, 112, 200, 201, 202, 202A, 203, 205A, 208, 213, 214, 215, 216, 217, 218, 219

11,259 ft2 $30,000.00

Off white / tan sheet vinyl with gray fibrous backing Rooms:

113, 114

964 ft2 $10,000.00

Page ii

White block filler

>5,000 ft2 Depends on square footage

M33 Roofing Material

Assumed ~ 48,125 ft2 N/A

~ 320 each $15,000.00

Tan resinous material

Rooms: North 200 Corridor, 213, 214, 215, 216, 217, 218

$2,500.00

S043 Plaster Surfacing

>5,000 ft2 N/A

M033 Grey Caulking Exterior

2% Chrysotile ~ 300 lf $3,600.00

2. Cost Estimates include asbestos removal costs only; abatement design and management fees and replacement costs are not

3. This ACM contains less than 1% asbestos by Point Count and is therefore not subject to the NESHAP. Removal of this material is a Class II Operation under OSHA, which requires 40-hour trained supervisors, trained workers and specific

4. Thermal Systems Insulation Plaster Fittings and End Sealant material may be concealed in walls and above ceilings.

Building Components with XRF Lead readings ≥ 0.4 mg/cm2

• Window Sills 5.4 - 10.1

• Ceramic Tiles 2.3 - 2.7

• Door Frames 3.3

• Bulletin Boards 0.4 - 2.8

• Structural Beams / Columns 2.8 - 9.7

• Sinks 4.5 - 9.0

• Walls 0.4 - 9.0

Exterior

• Structural Beams / Columns 2.8 - 9.7

Page iii

(9.6 mg/cm2 – >9.9 mg/cm2)

Universal, Hazardous, and Toxic Wastes

● PCB Ballast Throughout

~ 308 units

● Fluorescent Light Throughout

~ 616 tubes

● Refrigeration Units Throughout

~ 13 Units

● Thermostats Throughout

~ 45 Units

Conclusions

ACM – The Asbestos Containing Items are regulated under the Environmental Protection Agency (EPA) for renovation and demolition activities. Therefore, Hill West recommends that a Utah-certified abatement contractor remove and properly dispose of the ACM in these buildings that may be disturbed during future demolition. All non-friable roofing materials can remain in-place for demolition as long as wet-methods are used during demolition activities.

Lead – Lead-based paint was identified on shower ceramic wall tile, Door Frames, Structural Beams, Window Seals, Bulletin Board, Sink, and Walls.

Subtitle C of the Resource Conservation and Recovery Act (RCRA) requires the generator to determine if demolition wastes are hazardous. Toxicity Characteristic Leaching Procedure (TCLP) testing is the preferred method for determining this. The demolition wastes from this project should undergo TCLP testing prior to disposal to determine if they are hazardous.

Universal, Hazardous and Toxic Wastes – DFCM follows the protocols for identification and disposal of hazardous materials developed by the Salt Lake Valley Health Department (SLVHD). These protocols require building owners to identify and remove all universal, hazardous and/or toxic waste from buildings before they are demolished. Disposal/recycling of these materials must follow Environmental Protection Agency (EPA) guidelines outlined in 40 CFR 173 (Shippers – General Requirements for Shipments and Packaging), As such, Hill West recommends that the materials identified during this inspection be removed and disposed/recycled by properly trained and licensed contractors.

Page iv

Cost Estimates

Hill West’s cost estimates to remove the hazardous materials outlined above are:

● Asbestos-containing Materials: $99,600.00

● Hazardous Materials (Universal Wastes): $15,000.00

The cost estimates above are provided for use in long-term budgeting and planning only and do not have a level of accuracy sufficient to be used as construction design cost estimates. The actual cost of asbestos removal is highly dependent on a number of factors such as the size of the job (single room or mechanical enclosure, or an entire floor or building); the required time frame for removal; the time of year the job is conducted ; and travel time and distance to the job for the contractor. Therefore, actual removal costs could vary significantly from these estimates. The cost estimates are based on a four (4) month project time schedule for all abatement to be completed.

The report that follows this Executive Summary should be read in its entirely because it includes important information, such as material descriptions and locations, regulatory requirements, and building specific recommended response actions.

Southern Utah University Multipurpose Center

351 West University Blvd Cedar City, Utah

1.0 INTRODUCTION

On July 27, 2022, Hill West Environmental conducted a three (3) year asbestos re-inspection of the Southern Utah University – Multipurpose Center located at 351 West University Blvd, Cedar City, Utah. The purpose of this survey was to identify the existence, extent, and condition of both friable and non-friable asbestos-containing materials (ACM) within the facility. Bulk samples were collected from suspect materials and analyzed for asbestos content. Each occurrence of ACM was assessed for damage and friability. Appendix A contains Data Tables that have been prepared by the inspector based on the results of this inspection.

2.0 BUILDING DESCRIPTION

Building Identification

Building Name…………………………… SUU Multipurpose Building

Building Address………………………… 351 West University Blvd

Cedar City, Utah

Building Construction

Building Construction Date………

Renovations……………………………… Unknown

Building Type……………………………. Gymnasium, Classrooms, Offices

Building Total Sq. Ft…………………….. ~ 60,000 ft2

Structural System……………………….. Reinforced Concrete

Exterior Wall Construction……………… Brick/concrete

Floor Deck Construction………………... Reinforced concrete

Roof Construction………………………. Flat membrane

Floors Above Grade………

Floors Below Grade…………………….. 2

Interior Finishes

Floors……………………….................... Concrete, ceramic tile, vinyl floor tile, linoleum, glued carpet

Walls……………………………………… Brick, wallboard system, plaster

Ceilings…………………………………… Wallboard System, Suspended Ceiling Panels, Ceiling Tiles

Attic……………………………………….. Partial

Crawl space……………………………… Yes – Concrete tunnels

Building Mechanical

Heating System…………………………. Campus Plant

Mechanical Piping…………..………….. Campus Plant

Cooling Plant……………………………. Campus Plant

Appendix B contains the original R&R Environmental, Inc Inspection Report completed in 2016.

3.0 INSPECTION PROCEDURES

3.1 Asbestos-Containing Materials (ACM)

All accessible areas of the facility were visually inspected to identify suspect asbestos containing materials (ACM.) All accessible surfaces, structures, and mechanical systems within these areas were examined and all suspected ACM was touched to determine friability.

Suspect ACM was identified and assessed in homogeneous areas. A homogeneous area is defined as a single material, uniform in texture and appearance, installed at one time, and unlikely to consist of more than one type, or formulation, of material. In cases where joint compound and / or tape has been applied to wallboard (gypsum board) and cannot be visually distinguished from the wallboard, it is considered an integral part of the wallboard and in effect becomes one material forming a wall or ceiling “system.”

Each homogeneous area was given a unique material identification number.

Each ID number begins with a letter: “S” for surfacing materials, “T” for thermal system insulation, or “M” for miscellaneous materials. This letter is followed by a three-digit number, assigned in consecutive order. This number is used to identify the homogeneous area throughout the inspection report.

3.2 Bulk Sample Collection

Bulk samples were collected from all accessible homogeneous areas of suspect ACM for subsequent laboratory analysis to determine actual asbestos content.

Sampling was conducted in a manner that minimized damage to the building, did not leave any unsightly marks, and did not create a health hazard for the inspectors.

The number of samples collected from each homogeneous area generally followed the EPA Asbestos Hazard Emergency Response Act (AHERA) regulations (40 CFR §763.86). Friable surfacing materials were sampled using the random sampling scheme given in the EPA publication 560 / 5-85-30a, titled “Asbestos in buildings: Simplified Sampling Scheme for Friable Surfacing Materials."” Between three and seven samples were collected from friable surfacing materials, depending on the size of the homogeneous area. Bulk sample IDs collected during the inspection were entered on chain-of-custody forms for submittal to the analytical laboratory.

3.3 Bulk Sample Analysis

Bulk samples were analyzed using polarized light microscopy (PLM) and visual estimation in accordance with the EPA Interim Method for the Determination of Asbestos in Bulk Insulation Samples, EPA-600 / M4-82-020. Samples were analyzed by Dixon Information, Inc. 78 West 2400 South, South Salt Lake City, Utah 84115. The laboratory is accredited under the National Institute of Standards and Technology–National Voluntary Laboratory Accreditation Program (NIST-NVLAP) for bulk-asbestos sample analysis and is also accredited by the American Industrial Hygiene Association (AIHA).

Federal EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) and AHERA regulations define ACM as material containing greater than 1% asbestos by weight; materials containing less than 1% asbestos are not considered regulated ACM.

Further, the NESHAP regulations state that any sample found to contain less than 10% asbestos but greater than “none detected,” by visual estimation, must be assumed to contain greater than 1% asbestos unless confirmed to be less than 1.0% asbestos by point counting analysis.1

Despite EPA and Utah Division of Air Quality (UDAQ) rules exempting building materials containing 1% or…