Demolition projects for CPS may include residential, commercial, industrial properties, and former school buildings. The management of ACM for building demolition is regulated under the NESHAP. If the building, or portion of the building, to be demolished is a current school structure, the MEC needs to verify, in conjunction with CPS, the current AHERA status. If currently subject to AHERA, the MEC shall assist CPS with preparing a letter from CPS for submission to the Illinois Department of Public Health (IDPH) Asbestos Program stating the building has been decommissioned as a school. Once decommissioned, asbestos abatement at the building can be designed for performance in accordance with OSHA Asbestos Construction Standards and the less stringent NESHAP requirements in lieu of IDPH Rules and Regulations for School Buildings.
In accordance with the USEPA NESHAPs, the Owner (CPS) of a building being demolished must thoroughly inspect the property for ACM and have all regulated ACM properly removed from the structure prior to demolition. Furthermore, CPS policy is to properly remove and dispose and/or recycle PCB-containing equipment, universal wastes, chemical containers, and other hazardous and non-hazardous materials prior to demolition. Loose LBP shall be mitigated prior to demolition, but removal of intact LBP and lead-containing paints is not mandated.
The MEC should review existing documentation, including, but not limited to, the following:
- Demolition and design plans, as available
- As-built plans
- Asbestos Management Plan
- Three-Year Re-inspection Report (most current)
- Previous asbestos, LBP and other hazardous building material reports as available from the following sources:
- E-Builder
- Facility Inquiry (EAC)
- MEC archives
- Google Drive
- Facility Records
Upon completion of document review, a project specific survey must be completed of all areas of the building to be demolished prior to preparing the abatement design plans. The survey should be intrusive, and may involve selective demolition as necessary to thoroughly investigate all areas. All attempts to perform destructive testing must be completed by the MEC. Areas wherein access is not available should be specifically documented. The survey should serve to determine location and quantity of each type of hazardous building materials that will be affected by the proposed demolition work.
The MEC should provide a list of hazardous building materials that may remain during building demolition activities such as LBP and non-friable ACM. The MEC should provide cost analysis and economical benefits regarding abatement and recycling, or disposal of concrete and brick that may contain LBP or non-friable ACM. CPS will determine whether abatement of such materials should be conducted.
Based upon the findings of the document review and the project specific surveys, the MEC should design specifications, plans and scope sheets to remove hazardous building materials present within the building in accordance with applicable local, state and federal regulations, and in a manner that protects human health and environment. Note that asbestos abatement design plans must be signed and sealed by an Asbestos Project Designer licensed by IDPH. At minimum, the plans shall:
- Depict location, description, and quantity of all hazardous building materials present in the building using distinct hatching, notes or symbols for each material.
- Color alone should not be used as a distinguishing feature as drawings cannot be guaranteed to be printed in color.
- Identify hazardous building materials to be removed prior to building demolition.
- Drawings should indicate areas requiring selective demolition for access, if any. Responsible party should be indicated (abatement contractor, general contractor, etc.).
- Identify hazardous building materials that will not be removed during building demolition, if any.
- Use the followings title sheets, as applicable:
- Asbestos Abatement Plan – (Location), the sheet number should be ASB-1, ASB-2, etc., for Location use First Floor, Second Floor, etc.
- Lead-Based Paint – (Location), the sheet number should be LBP-1, LBP-2, etc for Location use First Floor, Second Floor, etc.
- All other items, such as PCBs equipment, universal waste, chemical containers, etc use Building Abatement Plan – (Location), the sheet number should be BA-1, BA-2, etc., for Location use First Floor, Second Floor, etc.
- Environmental Abatement Plan – (Location), the sheet number should be ENV-1, ENV-2, etc., for Location use First Floor, Second Floor, etc.
- Where feasible and in support of providing the most efficient design planning, multiple disciplines (ACM, LBP, etc.) may be included on the same plan.
- Show location and type of barriers and/or mini-containments to be used during asbestos abatement activities, location of worker and equipment decontamination stations, location where negative air machines to be exhausted, location of waste-out, location of dumpster, and other design components as needed.
- Comment on the availability of water and/or electricity during site abatement / demolition activities.