Attachment 0002 Inspection Report Clinton County Cottage.pdf

ASBESTOS INSPECTION

REPORT

Inspection Address:

Vacant Cabin

North of Clinton Iowa 52722 Project #: 26-30440w

Prepared for:

ACOE

Attn: Andy Retheford

25549 182nd St PO box 534 Pleasant Valley, Iowa 52767

Prepared by:

Steven M Goebel, Inspector

1/05/26 Date

25-13256 Inspector #

8/2/26 License Expiration date

TABLE OF CONTENT

1. INTRODUCTION

2. DEFINITIONS

3. GENERAL BUILDING OBSERVATIONS

4. REPORT DATA

a. METHOD

b. REPORT DATA

5. PROJECT SUMMARY

a. POSITIVE ASBESTOS SAMPLE LIST

b. CONCLUSIONS AND RECOMMENDATIONS

LIST OF APPENDICES

APPENDIX A - SAMPLE INVENTORY LIST & LAB ANALYSIS

APPENDIX B - INSPECTOR LICENSE AND CERTIFICATION

APPENDIZ C - PICTURES

SECTION 1

INTRODUCTION

For each area of the building, the inspector performing the inspection did the following:

1. Visually inspected the area(s) to identify the locations of all suspected

Asbestos Containing Building Materials.

2. Identify all homogeneous areas of friable and non-friable suspected asbestos.

3. Assume, if necessary, that some or all of the homogeneous area(s) are Asbestos Containing Material (ACM), and for each homogeneous area that is not assumed to be ACM, collect and submit bulk samples for analysis.

SECTION 2

DEFINITIONS:

HOMOGENEOUS AREA

An area which appears similar throughout in terms of color, texture, and date of material application.

SURFACING MATERIAL

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

THERMAL SYSTEM INSULATION

Means material applied to pipes, fittings, boilers breeching, tanks ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or other purposes.

MISCELLANEOUS MATERIAL

Interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include surfacing material or thermal system insulation.

SAMPLING AND ANALYSIS

All samples to be analyzed by Polarized Light Microscopy (PLM). Analysis was performed in accordance with EPA 40 CFR, Part 763, Appendix A to Subpart F.

A homogeneous area was considered not to contain Asbestos Containing Material (ACM) only if the results of all samples collected from the area showed asbestos in the amounts of one (l) percent (%) or less (_1%). A homogeneous area contains ACM when one or more samples collected from that area shows greater than one (1) percent (%) asbestos (>1%).

FRIABLE

Any material containing more than one (1) percent (%) asbestos that, when dry can be crumbled, pulverized, or reduced to a powder by hand pressure.

NON-FRIABLE (CATEGORY I)

Asbestos containing packaging, gaskets, resilient floor covering, and asphalt roofing products, containing more than one (1) percent (%) asbestos.

NON-FRIABLE (CATEGORY II)

Any excluding Non-Friable (Category I) Asbestos Containing Material, containing more than one (1) percent (%) asbestos.

SECTION 3

General Building Inspection Observations

The building inspection is conducted by a qualified and State of Iowa licensed Asbestos Inspector. The purpose of a building inspection is to identify existing building materials that are asbestos containing materials (ACM). If the inspection is conducted in an occupied building, the Inspector is sometimes denied accessibility to building areas and materials, i.e., the Inspector may not be allowed to cut through floor coverings or walls, remove quarry tiles, etc. There are many situations where ACM are concealed in wall cavities and other non-accessible areas, such as tunnels, crawl spaces, above ceilings, pipe chases, behind wall coverings, beneath debris piles, under various floor coverings, etc. When these situations occur in construction, renovation, and/or demolition, etc., materials in these areas shall be treated as ACM and handled as such by qualified and licensed asbestos personnel. If suspected asbestos containing material is discovered or damaged during the course of any activities, the material shall be considered and treated as ACM to diminish further fiber release. In addition, the Inspector uses an independent laboratory that analyzes the bulk building material samples using Polarized Light Microscopy (PLM). PLM analysis technique may not be as accurate as more expensive analysis techniques for certain building materials. It remains the Building Owner and/or Representative(s)’ responsibility to address this issue and consider analyzing suspect building material using different analysis techniques prior to disturbing the material(s). The following are areas that may not be inspected.

1. Tunnels and Crawl Spaces: During the inspection process, the Inspector attempts to check tunnels and crawl spaces for ACM and the degree of damage to the materials. In most cases, quantification of ACM in these areas is impossible due to the inaccessibility of these areas. In addition, these areas may fall under: "Confined Space Regulations". Due to the congestion in tunnels and crawl spaces, obtaining an accurate quantification for mudded joints, pipe wrap, etc. is almost impossible. The Inspector will quantify ACM only in accessible tunnels and crawl spaces and estimate the quantities in the inaccessible areas.

Some reasons for inaccessibility are as follows: flooded areas, pipe congestion, asbestos and other debris, electrical hazards, confined spaces, unknown gas emissions, low ceilings, etc.

2. Boilers and Thermal System Insulation: Interior portions of boilers, heaters, storage tanks, etc. are not always accessible. Materials in these areas will be treated as ACM. Areas of concern are packing inside boiler doors and liners.

Use extreme care and properly trained personnel when handling these types of materials. Some boilers have insulated metal jackets over fiberglass or ACM.

Thermal system insulation can be found in many different forms, i.e., air cell, preformed magnesium block, millboard, etc. All fiberglass materials are excluded as suspected ACM.

3. Debris: In areas where damaged ACM may be found there may and usually will be ACM debris in the general area of the damaged material. These areas shall be treated with the utmost care even during the inspection and quantification process. The Inspector considers any exposure to this type of material as a health threat.

4. State of Quantification: As a general rule, individual rooms or areas of estimation contain inherently more probability of an error than those groups of rooms or areas or an entire building. In other words, the aggregate tends to be more accurate than the sums of the individual parts. Therefore, when designing response actions (measurements, air samples, etc.), the project designer and the asbestos abatement contractor’s attention shall be given to ensure that quantification of materials and proper methods are followed through careful analysis of the site. If materials are quantified, the asbestos abatement contractor or owner, owner representatives or third parties are responsible for verifying the quantities.

5. The Inspector may take some latitude in the presentation of the Inspection

Report. When the Inspector has found floor tiles, linoleum, and/or carpeting listed he/she may or may not have adhesives listed. Adhesives have been known to contain asbestos and therefore, although not mentioned, it may be presumed to be ACM, listed or not. Testing of the adhesive prior to disturbing is recommended. The same is true for adhesives or mastics used to adhere linoleum to floors or counter tops. All toweled-on and/or sprayed-on surfacing materials; i.e., floor mastics, wall and ceiling surfacing, etc. are either suspected or presumed ACM unless sampled and analyzed to indicate that they are not

ACM.

6. In the Inspection Report, certain items such as mudded joints (MJ) or metal doors (MD), etc. are listed as units or number of units, i.e. 10 MJ, 3 Damaged, which is an indication of count rather than square feet or linear feet. Most materials listed in the assessment are either listed as square feet or linear feet with these noted exceptions.

7. In the Assessment Process, there are additional codes such as ME and MG;

ME representing miscellaneous electrical and MG representing miscellaneous gasket materials. Both codes are used to indicate materials that are unusual to the normal course of an assessment of the building. Miscellaneous electrical materials include old electrical wiring, switchboards, transite panels, etc.

Miscellaneous gasket materials can be found between (thermal) valves, on boiler doors, between fittings, between molds, etc. These codes give the Inspector the ability to qualify materials, which sometimes may not be considered as ACM.

8. An Asbestos Code Sheet is included with the Inspector's inspection report, which informs the client as to the Homogeneous Codes used during the inspection process.

9. Caution- Regarding Inspection results- Floor tiles, adhesives, and drywall (mud) found to not contain asbestos should be re-analyzed under the “Chatfield Method” of TEM analysis. Many times, the results from having these materials analyzed under PLM result in false positives or false negatives. After reviewing your report, please notify the inspector if you want these samples analyzed under the “Chatfield Method”.

10. Any sample less than 10% asbestos may be Point Counted. Point counting is a more accurate method of analyzing bulk samples. The results of the point counting are the results that will determine if the material will be treated as asbestos.

11. Asbestos inspections are performed based on current understanding of the regulations. As new interpretations of the regulations are made aware of by the EPA, DNR, and Iowa Division of Labor. Advanced Environmental Testing and Abatement Inc. will adapt their inspections to comply with these new procedures.

If additional sampling is required by the different agencies, Advanced Environmental will do the additional sampling. The owner is responsible for the additional cost for these samples as well as labor.

12. Advanced Environmental shall not be responsible for any cost of abating any additional asbestos discovered in any renovation or demolition activities. Any additional items discovered shall be tested when they become accessible. For example, old adhesives may be under new floor tiles and adhesives. Additional materials may be concealed in walls, under multi layers of flooring, etc.

13. All amounts listed are estimates. It is up to other contractors to field verify any amounts that are listed within this report.

14. All material that looks similar should be treated as asbestos containing materials.

15. Asbestos Material containing <1%. Some material tested for asbestos may contain trace amounts of asbestos and be below the threshold for asbestos contain material according to both the Iowa DNR and Iowa State Code. However, the Federal Occupational Safety and Health Administration still have some regulations that contractors must follow under 29 CFR 1926.1101. Contractors working with asbestos material with <1% asbestos must still produce a negative and initial exposure assessment, completed by a “competent person”.

Contractors must follow 29 CFR 1926. 1101 (g)(1)(ii) and (iii) and 29 CFR 1926.

1101(g)(3)(i), (ii), and (iv). Please contact Advanced Environmental Testing and Abatement, Inc. for consultation on how to handle material with <1% asbestos.

16. Flat roofs: If any layer of a flat roof tests positive for asbestos, all layers should be considered asbestos and removed as such. Advanced Environmental makes every effort to core roof samples through all layers. If flashing is identified as asbestos containing, all tar on walls and adjacent roof decks shall be bid as and treated as asbestos containing unless separately and disproved by the abatement contractor.

17. Prior to the start of any demolition, have the demolition contractor review the asbestos inspection report, do a building walk through and sign that he agrees with the report and sees no questionable items. If any suspect material is discovered during the demolition, the demolition contractor shall stop immediately and inform the building owner of the suspect materials.

18. If asbestos containing materials are found during demolition:

1: Stop demolition 2: Call inspector 3: Notify DNR of change through notification and phone call:

515-725-9576

Options for handling found asbestos during demolition activities:

1: Have the inspector stay on site and direct what ACM (RACM) should go as RACM or what they want to go as regular construction waste.

2: Least logical: Most Expensive: Treat all waste as RACM. This isn’t necessary in most cases. Demolition contractors have the most to gain in this option.

19. The inspector shall not be responsible for the cost of abating any “found” asbestos after the original inspection. The inspector did not create them just aided in identifying them. The owner pays for all abatement and RACM found or made on the site. Payment for the inspection means acceptance of the conditions herein – no exceptions.

ASBESTOS CODES

A = Assumed MJ = Mudded Joint ADH = Adhesive NC = Nose Cap APW = Air Cell Pipe Wrap NF = Non-friable BP = Boiler Plaster NSM = Not Suspect Material C = Ceiling P or PH = Previous History CAPS = Stair Treads PP = Patched Plaster/Drywall CQ = Can’t Quantify PSA = Sand Plaster CT = Ceiling Tiles PSM = Smooth Plaster CT/12 = 12” Ceiling Tiles S = Sample/Samples/Sampled DAM. = Damaged SCT = Suspended Ceiling Tile DEB = Debris SR = Sample Result DW = Drywall ST = Storage Tank

F = Friable SUR = Surfacing FE = Furnace Exhaust T = Thermal FT = Floor Tiles Thermal Pipe Measurement = Linear Ft GASK = Gaskets TR = Transite

GYM = Gypsum TSI = Thermal System Insulation HOMO = Homogeneous VC = Vibration Cloth LINO = Linoleum VDW = Vinyl Covered Drywall MISC = Miscellaneous Non-Friable W = Walls MAC = Metal Asbestos Chimney WD = Wood Door MATL DESC = Material Description N = North MD = Metal Door S = South ME = Miscellaneous Electrical E = East MF = Miscellaneous Friable W = West

1. All Metal Doors are listed by quantities, example 3 = 3 metal doors.

2. All Mudded Joints are listed by quantities of MJ, not sizes.

3. All Pipe Wrap materials are listed in linear feet.

4. All other measurements are square feet unless stated elsewhere.

5. Sample Results: N = Not Considered Asbestos Containing Material

Y = Considered Asbestos Containing Material P or PH = Previous History N/A = Not Analyzed <1% = Contains less than 1% Asbestos Containing Material

>1% = Contains more than 1% Asbestos Containing Material

6. All Adhesives are considered Asbestos Containing Material (ACM) which can’t be quantified - Non-Friable ACM.

7. All Seals and Gaskets are considered Asbestos Containing Material (ACM) which can’t be quantified – Non-Friable ACM.

SECTION 4

ASBESTOS INSPECTION REPORT SUMMARY

METHOD:

All collected samples were submitted to EMC LABS, INC., located in Phoenix, Arizona.

EMC LABS is accredited by the National Institute for Standards and Technology (NIST) under the National Voluntary Laboratory Accreditation Program (NVLAP #101926-0) for Polarized Light Microscopy (PLM) analysis. The sampling was conducted by a State of Iowa licensed asbestos inspector and followed the National Emission Standards for Hazardous Air Pollutants (NESHAPS) protocols. Bulk samples of suspect asbestos-containing materials (ACMs) were analyzed using EPA Method 600-R93-116 via PLM.

OVERVIEW:

Advanced Environmental Testing and Abatement, Inc. performed an Asbestos Containing Materials (ACM) Inspection on January 6th, 2025. The purpose of this inspection was to identify the presence of asbestos-containing materials prior to the future demolition of the building.

• Property Description:

o One story residential house

• Occupancy Status at Time of Inspection: Vacant

• Scope of Inspection: Entire house

RESULTS:

• Total Bulk Samples Collected: Thirty-nine (39) samples

• Asbestos Detected: Eleven (11) samples with asbestos.

All building materials similar in appearance, color, and/or texture to those determined to contain asbestos must be assumed to contain asbestos throughout the building.

SECTION 5

POSITIVE MATERIALS:

The following samples tested positive (>1%) for asbestos or are assumed to contain asbestos:

REGULATION REVIEW

The United State Environmental Protection Agency definition of asbestos containing materials (ACM) is a material with an asbestos content greater than 1%. According to Iowa Division of Labor, ACM is any material found to contain asbestos, regardless of its concentration. Materials containing asbestos containing <1% asbestos still have some Division of Labor regulations overseeing removal of the material.

CONCLUSIONS AND RECOMMENDATIONS

The results of laboratory testing during the asbestos renovations contained eleven (11) positive samples for asbestos in seven homogenous materials.

Advanced Environmental Testing and Abatement, Inc. make the following recommendations and conclusions:

1: Removal of all asbestos containing materials prior to demolition by a Permitted asbestos company with the Iowa Department of Inspections, Appeals, and Licensing.

Material Color Locations Quantity ACM%

Transite Siding Grey Exterior Under Vinyl 500 25% Chrysotile

APPENDIX A

SAMPLE INVENTORY LIST, LAB ANALYSIS

APPENDIX B

INSPECTOR LICENSE AND CERTIFICATION

APPENDIX C

PICTURES

Client: ACOE 25549 182nd St Pleasant Valley Iowa Attn: Andy Retheford

Address: North of Clinton At the end of 142nd St Clinton Iowa 52732

Abestos testing was conducted in the interior and exterior of an elevated cabin on the Mississippi River for future demolition.

A total of 9 bulk samples were collected on January 05, 2026. One samples tested positive for asbestos-containing material. Grey Transite siding tested positive 25% underneath existing viny siding on the exterior walls of the cabin..

During the testing all accessible areas were tested, the cabin is not in good shape.

The cabin is elevated and difficult to access do to dirt roads, the deck no longer exists, there is 1 set of stairs leading up to an exterior wall.

General Summary The information contained in this report reflects only the areas sampled at the time of inspection. The purpose of this asbestos inspection and testing was to identify the presence, quantity, and locations of asbestos-containing building materials (ACBM) that may be disturbed during planned renovation and/or demolition activities.

Representative bulk samples were collected from accessible and affected areas in accordance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements prior to renovation or demolition activities that may impact asbestos-containing materials. Sampling and evaluation were also conducted in compliance with the OSHA Construction Standard, 29 CFR 1926.1101(k)(5)(i–iii).

Suspect materials were sampled from Homogeneous Areas (HAs), defined as materials similar in age, appearance, and function. The objective of this inspection was to identify the locations and quantities of asbestos-containing materials prior to renovation, restoration, or demolition activities.

Bulk samples were analyzed using Polarized Light Microscopy (PLM) with dispersion staining in accordance with 40 CFR Part 763 and the Asbestos Hazard Emergency Response Act (AHERA). Each sample was analyzed for the six regulated asbestos fiber types, with asbestos content estimated and reported as a percentage by volume. Where additional quantification is required, further analysis may be performed using the EPA 600/R-93/116 400- or 600-point count method. Transmission Electron Microscopy (TEM) analysis may also be performed upon request.

It is the responsibility of the remediation contractor and/or building owner to ensure compliance with all applicable federal, state, and local regulations when asbestos-containing materials are present. This includes, but is not limited to, requirements established by OSHA, the EPA, and applicable state regulatory agencies. In Iowa, asbestos-containing building materials and their management during renovation or demolition activities are regulated by the Iowa Department of Natural Resources (IDNR) and the Iowa Division of Labor.

Sincerely, Steven M Goebel Advanced Environmental Testing and Abatement, Inc.

563-449-4281

CLIENT:

CONTACT:

CLIENT SAMPLE #: 1

ND 85-90 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 10-15

FRIABLE: Y DESCRIPTION:

CLIENT SAMPLE #: 2

20-25 ND TOTAL ASBESTOS %: 20-25

LAYER ID: A

LOCATION: NON-FIBROUS %: 75-80

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 3

ND 60-65 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 35-40

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 4

ND 55-60 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 40-45

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 5

ND 15-20 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 80-85

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 6

ND 15-20 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 80-85

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 7

ND <1-1 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 99-100

FRIABLE: N DESCRIPTION:

CLIENT SAMPLE #: 8

ND 95-99 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 1-5

FRIABLE: Y DESCRIPTION:

CLIENT SAMPLE #: 9

ND 15-20 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 80-85

FRIABLE: Y DESCRIPTION:

DATE ANALYZED:

US Corp of Engineers 1/5/2025 0126-21881/10799-1 1/5/2026

WHITE DRYWALL WITH BROWN LAYER

ROOF

ND= NONE DETECTED NACR= NOT ANALYZED AT CLIENT REQUEST TR= TRACE, LESS THAN 1% DETECTED

YELLOW INSULATION

ASBESTOS TYPE %

CELLULOSE

OTHER FIBER TYPES %

DW

FIBER GLASS

ASBESTOS TYPE %

BROWN FLOORING WITH GREEN COVER & DEBRIS

ASBESTOS TYPE % OTHER FIBER TYPES %

FIBER GLASS

CELLULOSE

ROOF

INSULATION

PINK INSULATION FOAM

OTHER FIBER TYPES %

ASBESTOS TYPE %

BLACK ROOFING WITH WHITE ROCK & TAR

OTHER FIBER TYPES %

Morland Environmental Services, LLC 527 Colleen Street

Woodhull, Illinois 61490 Phone ( 309 ) 236-6819 Email-tmorland@morlandenvironmentalservices.com

PLM BULK ANALYSIS REPORT

OTHER FIBER TYPES %

OTHER FIBER TYPES %

CELLULOSE

ASBESTOS TYPE %

INSULATION

FIBER GLASS

ASBESTOS TYPE %

BLACK ROOFING WITH WHITE & BLUE ROCK & TAR

OTHER FIBER TYPES %

FLOOR

BLACK BROWN MATERIAL WITH TAR

OTHER FIBER TYPES %

CELLULOSE

SIDING

WALL

ASBESTOS TYPE %

OTHER FIBER TYPES %

GREY CEMENTITIOUS MATERIAL WITH PAINT

ASBESTOS TYPE %

ASBESTOS TYPE %

BROWN FLOORING

CELLULOSE

FLOOR

CHRYSOTILE

Steve Goebel/25-27972W

Advanced Environmental 803 Ricker Street Waterloo, Iowa 52806

PROJECT NAME:

SAMPLE DATE:

REFERENCE #:

CLIENT SAMPLE #:10

ND 15-20 TOTAL ASBESTOS %: ND

LAYER ID: A

LOCATION: NON-FIBROUS %: 80-85

FRIABLE: Y DESCRIPTION:

Analyses performed using polarized light microscopy in accordance with the EPA method for determination of asbestos in bulk building materials;

PLM analysis of floor tile has been known to miss asbestos in small percentage of samples which contains asbestos. Thus negative PLM results

Morland Environmental Srvices, LLC (MES) assumes no responsibility for any consequences for actions taken by our clients or their agents as results

JVANALYSIS NO.:

EPA-600/R-93-116

The report may not be used to claim product endorsement by NVLAP or any agency of the US Government.

When asbestos is detected in layers of a hetrogenous sample, each individual layer will be reported separately.

DW

WHITE DRYWALL WITH BROWN LAYER

The above test report relates only to the items tested.

cannot be guaranteed. Morland Enviornmental Services (MES) suggest that samples reported as <1% or none detected be analyzed by TEM.

ND= NONE DETECTED NACR= NOT ANALYZED AT CLIENT REQUEST TR= TRACE, LESS THAN 1% DETECTED

ANALYZED BY:___________________________________________________

CELLULOSE

Morland Environmental Services, LLC 527 Colleen Street

Woodhull, Illinois 61490 Phone ( 309 ) 236-6819 Email-tmorland@morlandenvironmentalservices.com

ASBESTOS TYPE % OTHER FIBER TYPES %

Facility Name/Site Location ACOE Cabin North of Clinton off 142nd St Inspected By:

Travis Haas

Sample No Material Color Location Current Condition Results

1 Flooring Brown Interior Poor N

2 Transite Sididng Grey Exterior under Vinyl Siding OK 25%

3 Wall Black Exterior OK N

4 Flooring Brown Greem Intetior Poor N

5 Roofing Black Roof Poor N

6 Roofing Black Roof Poor N

7 Insulation Pink Interior Poor N

8 Insulation Yellow Interior Poor N

9 Drywall White Interior Poor N