1) Phase II ESA Combined.pdf

PHASE II ENVIRONMENTAL SITE ASSESSMENT

FOR

SOUTH CAMPUS MONTANA STATE TRAINING SCHOOL –

COTTAGE #5

VENTURE WAY

BOULDER, JEFFERSON COUNTY, MONTANA

REVISION 1

Prepared for:

U.S. ENVIRONMENTAL PROTECTION AGENCY

1595 Wynkoop Street

Denver, Colorado 80202

Prepared by:

WESTON SOLUTIONS, INC.

1435 Garrison Street, Suite 100

Lakewood, Colorado 80215 303-729-6100 Fax 303-729-6101

Date Prepared December 2018 TDD No. 0003/1808-05 Document Control No. W0628.1A.01850 Contract No. EP-S8-13-01 U.S. EPA Work Assignment Manager Stephanie Shen

PHASE II ENVIRONMENTAL SITE ASSESSMENT

FOR

SOUTH CAMPUS MONTANA STATE TRAINING SCHOOL –

COTTAGE #5

VENTURE WAY

BOULDER, JEFFERSON COUNTY, MONTANA

REVISION 1

U.S. ENVIRONMENTAL PROTECTION AGENCY

1595 Wynkoop Street

Denver, Colorado 80202

Prepared by:

WESTON SOLUTIONS, INC.

1435 Garrison Street, Suite 100

Lakewood, Colorado 80215 303-729-6100 Fax 303-729-6101

Prepared by: Date: ________ Michael Cherny

START Scientist

Reviewed and Approved by: Date: ________

Elliott Petri, P.E.

START Project Manager and

Environmental Professional

South Campus MT State Training School – Cottage #5, Boulder, MT Phase II ESA Report

Revision 1 – December 2018 Page i

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

TABLE OF CONTENTS

Section Page SUMMARY .............................................................................................................................. S-1

1.0 INTRODUCTION

1.1 SCOPE OF WORK AND PURPOSE

1.2 STATEMENT OF OBJECTIVES

2.0 SUMMARY OF BACKGROUND INFORMATION

2.1 PROPERTY DESCRIPTION, LOCATION, AND HISTORY

2.2 PREVIOUS ENVIRONMENTAL REPORTS AND RECORDS

3.0 DESCRIPTION OF WORK PERFORMED AND RATIONALE

3.1 ASBESTOS-CONTAINING MATERIAL

3.2 LEAD-BASED PAINT

3.3 VISUAL INSPECTIONS

3.4 DEVIATIONS FROM THE SAMPLING AND ANALYSIS PLAN

4.0 DESCRIPTION OF METHODS USED

4.1 ASBESTOS-CONTAINING MATERIAL

4.2 LEAD-BASED PAINT

4.3 PCBS, MERCURY, AND MOLD

5.0 PRESENTATION OF INFORMATION AND DATA ACQUIRED

5.1 ASBESTOS-CONTAINING MATERIAL

5.2 LEAD-BASED PAINT

5.3 PCBS, MERCURY, AND MOLD

6.0 EVALUATION AND INTERPRETATION OF INFORMATION, DATA, AND

RESULTS

6.1 ASBESTOS-CONTAINING MATERIAL

6.2 LEAD-BASED PAINT

6.3 PCBS, MERCURY, AND MOLD

6.4 CONCEPTUAL SITE MODEL

6.5 DISCLOSURE OF AVAILABLE DATA INSUFFICIENT TO MEET OBJECTIVES

7.0 CONCLUSIONS OF THE PHASE II ESA

8.0 SIGNATURE OF PHASE II ASSESSOR AND SEAL

9.0 SPECIFICATIONS FOR ASTM E1903-11 REPORT USE AND RELIANCE

9.1 SPECIAL TERMS AND CONDITIONS

9.2 LIMITATIONS AND EXCEPTIONS OF ASSESSMENT

9.3 DISCLAIMERS

10.0 REFERENCES

11.0 QUALIFICATIONS

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

LIST OF FIGURES

FIGURE 1 SITE LOCATION MAP

FIGURE 2 SITE FEATURES MAP

FIGURE 3 ACM SAMPLE LOCATION & EXTENT MAP – BUILDING 5 MAIN FLOOR

FIGURE 4 ACM SAMPLE LOCATION & EXTENT MAP – BUIDLING 5 SECOND

FLOOR

FIGURE 5 ACM SAMPLE LOCATION & EXTENT MAP – BUILDING 5 CRAWLSPACE

FIGURE 6 LBP LOCATION & EXTENT MAP – BUILDING 5 MAIN FLOOR

FIGURE 7 LBP LOCATION & EXTENT MAP – BUILDING 5 SECOND FLOOR

LIST OF TABLES

TABLE 1 ACM SAMPLE RESULTS AND ESTIMATED VOLUMES

TABLE 2 NON-DETECT FOR ASBESTOS SAMPLES

TABLE 3 LEAD-BASED PAINT SCREENING RESULTS

LIST OF APPENDICES

APPENDIX A PHOTOGRAPH LOG

APPENDIX B LABORATORY REPORTS

APPENDIX C SUPPLEMENTARY INFORMATION

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

LIST OF ACRONYMS

ACM asbestos-containing material AHERA Asbestos Hazard Emergency Response Act ASTM ASTM, International CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COC contaminant of concern DEQ Department of Environmental Quality EPA United States Environmental Protection Agency ESA Environmental Site Assessment HA homogeneous area HEPA high-efficiency particulate air JLDC Jefferson Local Development Corporation LBP lead-based paint LF linear feet mg/cm2 milligrams per square centimeter MT Montana O&M Operation and Maintenance PCB polychlorinated biphenyl P.E. Professional Engineer PLM Polarized Light Microscopy PPE personal protective equipment QA Quality Assurance QC Quality Control RACM regulated asbestos-containing material SAP Sampling and Analysis Plan

sq. ft. square feet START Superfund Technical Assessment and Response Team SOO Statement of Objectives TBA Targeted Brownfields Assessment TDD Technical Direction Document WESTON Weston Solutions, Inc.

XRF X-ray fluorescence

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

SUMMARY

The United States Environmental Protection Agency (EPA) tasked the Weston Solutions, Inc.

(WESTON) Superfund Technical Assessment and Response Team (START) to assist the EPA in conducting a Phase II Environmental Site Assessment (ESA) for the South Campus Montana (MT) State Training School – Cottage #5 located at Venture Way located in Boulder, MT (Site, Figure 1).

SCOPE OF WORK

This Phase II ESA was conducted in accordance with Technical Direction Document (TDD) 0003/1808-05 and ASTM, International (ASTM) E1903-11– Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process. The purpose of a Phase II ESA is to achieve the objectives set forth in the Statement of Objectives (SOO) developed by the EPA, user(s), and the Phase II Assessor. Goals for this Phase II ESA were to acquire and evaluate sufficient information to determine the location and concentration of potential environmental contamination at the Site, if present. The specific SOO for this Phase II ESA were as follows:

Perform a data gap assessment for the on-site building for ACM to supplement previous sampling results.

Develop sufficient information to render a reasonable professional opinion whether hazardous substances either are or are not present at the Site with respect to the potential concerns assessed. If present, include concentrations of hazardous substances based on field screening and/or laboratory analysis of samples.

Gather and provide sufficient data to assist the TBA recipient in making informed decisions with regard to the future use of the property.

Obtain sufficient data to support conceptual remediation cost estimating, if necessary.

SITE BACKGROUND

The Site is located in Boulder, MT in an area currently developed as commercial and industrial.

Constructed in 1923, the building was utilized as a dormitory for the State School for Feeble Minded. Until the 1970’s or 1980’s, the property was operated as such until being left vacant. The building was listed as a contributing property to the Montana State Training School Historic District, on the National Register of Historic Places, in 2014.

Jefferson Local Development Corporation (JLDC) is interested in redeveloping the Site for residential or commercial use. The Phase I ESA completed by START (WESTON, 2016) identified the possibility of asbestos-containing material (ACM), lead-based paint (LBP) and other environmental hazards being present, due to the age of the building. The Phase II ESA was performed as a result of the findings of the Phase I ESA.

Revision 1 – December 2018 Page S-2

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

SUMMARY OF RESULTS AND CONCLUSIONS

Phase II assessment fieldwork was conducted on August 5, 2016 with supplementary sampling on October 26, 2018. Results of the Phase II ESA have confirmed the presence of contaminants of concern (COCs) at the Site. The following list is a summary of the results and conclusions regarding COCs and associated media identified by START at the Site:

Asbestos Containing Material (ACM):

Of the 65 samples submitted for laboratory analysis, a total of 14 samples were determined to be “positive” (>1% asbestos) for asbestos. The following table indicates the locations and estimated extent of ACM identified at the Site. See Sections 5.1 and 6.1 of this report for a more detailed breakdown.

ACM Estimated Volume / Extent (Approximate) Location

Duct Insulation 25 sq. ft. Attic

Drywall 550 sq. ft. Second Floor

Light Insulation 40 sq. ft. First and Second Floors

Linoleum 1,130 sq. ft. First and Second Floors

Pipe Insulation 55 LF Crawlspace and First Floor

Pipe Insulation Debris 4,500 sq. ft. Crawlspace

Plaster 50 sq. ft. First Floor

Window Caulk 5,000 LF Second Floor Notes:

LF = linear feet

sq. ft. = square feet

Based on the results of the ACM survey, asbestos is present in the building. ACM is considered to be a COC in relation to the Site.

Lead-Based Paint (LBP):

Based on the X-ray fluorescence (XRF) results, elevated lead concentrations are present on the ceiling, walls, door frames, and exterior window components. The following table lists the location, current surface paint color, and estimated extent of LBP present at the Site. Although there were positive readings on the exterior, no bare soil (i.e. soil or sand not covered by grass, sod, other live ground covers, wood chips, gravel, artificial turf, or similar covering) was present around the dripline; therefore, lead-in-soil was not assessed. LBP is considered to be a COC at the Site.

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Location Current Surface Paint Color Estimated Extent

First Floor

Ceiling

Cream 3,100 sq. ft.

Light Blue 40 sq. ft.

White 50 sq. ft.

Wall

Coral 480 sq. ft.

Cream 6,000 sq. ft.

Gold 700 sq. ft.

Green 200 sq. ft.

Light Blue 260 sq. ft.

Pink 390 sq. ft.

Yellow 230 sq. ft.

First Floor Hall

Ceiling Cream 780 sq. ft.

Wall Cream 2,800 sq. ft.

Second Floor

Ceiling Cream 670 sq. ft.

White 2,050 sq. ft.

Door Frame Green 15 sq. ft.

Wall

Blue 1,300 sq. ft.

Coral 1,700 sq. ft.

Cream 3,000 sq. ft.

Green 750 sq. ft.

Light Gray 250 sq. ft.

White 550 sq. ft.

Yellow 1,200 sq. ft.

Second Floor Hall

Ceiling Cream 950 sq. ft.

Wall Cream 2,800 sq. ft.

Exterior

Window Frame Green 500 sq. ft.

Window Sash Green 100 sq. ft.

Revision 1 – December 2018 Page S-4

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This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Polychlorinated biphenyls (PCBs), Mercury, and Mold: A summary of the observations regarding the visual inspections conducted are presented below:

• Numerous light ballasts were observed throughout the building. Of the representative light ballasts observed, a mixture of PCB and non-PCB ballasts were identified. None of the light fixtures observed in the building appeared to be leaking fluids. PCBs are considered COCs in relation to the Site.

• Of the thermostats observed, mercury was not present as a component. Mercury is not considered a COC in relation to the Site.

• No mold was encountered at the Site. Mold is not considered a COC in relation to the Site.

SUMMARY OF RECOMMENDATIONS

Based on the results of the environmental assessment, START recommends the following:

Based on the ACM identified at the Site and reuse plans, START recommends contracting an accredited asbestos remediation company to assess hazard risk and determine appropriate remedial actions to address ACM at the Site (e.g., abatement, encapsulation, etc.). ACM remediation is recommended prior to any renovation or demolition activities at the Site in order to permanently mitigate exposure risk.

However, pending final redevelopment/re-use plans for the Site and considering the type and condition of ACM identified, development of an ACM Operations and Maintenance (O&M) Plan to monitor condition of ACM identified at the Site, removal of select ACM (e.g., friable pipe insulation), and/or a combination of these remediation methods could be implemented. START recommends contracting an accredited asbestos remediation company to create and implement an ACM O&M Plan to monitor the condition of ACM identified.

START recommends contracting an accredited lead remediation company to determine appropriate remedial actions needed once future use plans are determined to address the LBP at the Site during the cleanup phase of redevelopment (e.g., encapsulation, chemical stripping, removal, etc.). Dust control methods should be implemented for the debris. It is recommended that all work be performed by an EPA Lead-Safe certified firm. If construction materials are to be removed, it is recommended that the construction debris disposal facility be contacted to determine if Toxicity Characteristic Leaching Procedure (TCLP) samples will be required.

Based on the results of the LBP survey, all wall and ceiling paint should be considered LBP due to the spatial variation associated with the painting history. Due to the deteriorated condition of most surfaces, an encapsulant cannot be used unless the surfaces are prepared

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beforehand. Additionally, the paint chips and dust currently present on the floors will need to be vacuumed using a high-efficiency particulate air filter.

PCB-containing equipment (e.g., light ballasts) should be properly removed and disposed of during renovation activities.

This summary is intended to be a general description of the scope of work, results, conclusions, and recommendations identified as a result of the Phase II ESA of the Site; however, this section is not intended to be a “stand alone” document or to include the basis of all conclusions presented.

The report should be read and used in its entirety. Information included in this section is subject to the scope of services and limitations noted in the original TDD and in this complete report.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

1.0 INTRODUCTION

1.1 SCOPE OF WORK AND PURPOSE

The Weston Solutions, Inc. (WESTON) Superfund Technical Assessment and Response Team (START) conducted a Phase II Environmental Site Assessment (ESA) for the South Campus Montana (MT) State Training School – Cottage #5 located at Venture Way Boulder, MT (Site) (Figure 1). The ESA was conducted in accordance with Technical Direction Document (TDD) 0003/1808-05 and ASTM, International (ASTM) E1903-11 – Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process. The purpose of a Phase II ESA is to acquire and evaluate information sufficient to achieve the objectives set forth in the Statement of Objectives (SOO) developed by the user(s) and the Phase II Assessor. The scope of a Phase II ESA is related to the activities agreed upon to meet the objectives of the investigation as defined in the SOO which are subject to ongoing evaluation and refinement

This Phase II ESA report contains the results of the data collection activities and associated quality assurance (QA)/quality control (QC) measures conducted specific to the Site. Information used to conduct this Phase II ESA was based upon reasonably ascertainable, visually and physically observable conditions, and included testing or sampling of materials. The structure of this report is based on the ASTM International (ASTM) E1903-11 standard.

1.2 STATEMENT OF OBJECTIVES

The objectives were developed by the Jefferson Local Development Corporation (JLDC) (user), START (Phase II Assessor) and the United States Environmental Protection Agency (EPA) to obtain sound, scientifically valid data concerning actual property conditions at the Site with respect to the presence or the likely presence of target analytes/substances including, but not limited to, those within the scope of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The SOO for the Site were determined during the project scoping meetings held on June 1, 2016 and September 20, 2018 and as a result of the Phase I ESA conducted by WESTON on the Site (WESTON, 2016). The Phase II ESA objectives determined for the Site were as follows:

Perform a data gap assessment for the on-site building for ACM to supplement previous sampling results.

Develop sufficient information to render a reasonable professional opinion whether hazardous substances either are or are not present at the Site with respect to the potential concerns assessed. If present, include concentrations of hazardous substances based on field screening and/or laboratory analysis of samples.

Gather and provide sufficient data to assist the TBA recipient in making informed decisions with regard to the future use of the property.

Obtain sufficient data to support conceptual remediation cost estimating, if necessary.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

2.0 SUMMARY OF BACKGROUND INFORMATION

The Site is located in Boulder, MT in an area surrounded by commercial and industrial development. The TBA recipient, JLDC, has an interest in redeveloping the building for residential or commercial purposes. The stakeholders would like to determine the extent and locations of possible contaminants before moving forward with the redevelopment.

2.1 PROPERTY DESCRIPTION, LOCATION, AND HISTORY

The Site is approximately 2.3 acres located at Venture Way Boulder, Montana at 46.228521°N latitude and -112.119271°W longitude. It is an approximately 12,042 square feet (sq. ft.) two-story building with bathrooms, dormitories, and public spaces. Historically the building was used as a dormitory, until being abandoned in the 1970’s or 1980’s.

The Phase I ESA, performed by START, highlighted the possibility of asbestos-containing material (ACM), lead-based paint (LBP), and other environmental hazards being present, due to the age of the building. The Phase II ESA was performed as a result of the conclusions of the Phase

I ESA.

2.2 PREVIOUS ENVIRONMENTAL REPORTS AND RECORDS

Previous environmental reports and/or records, if available, were obtained by START from various sources, including local agencies, and reviewed for information relating to the Site. A summary of records obtained is provided below.

Document: Phase I Environmental Site Assessment for South Campus MT Training School – Cottage #5 Prepared for: EPA and JLDC Prepared by: START Date: July 2016 Report Source: START

Report Summary: The report is a recent ESA of the Site and was conducted according to the current ASTM standard.

Information Relating to the Site: This Phase I ESA concluded that there is potential for ACM, LBP, PCBs, and mercury-containing equipment to be present at the Site due to the age of the building.

Based on this conclusion, a Phase II ESA is recommended in order to investigate the building materials. No other recognized environmental conditions were identified in relation to the Site.

Document: TBA Application Prepared for: EPA Prepared by: JLDC Date: 2016 Report Source: EPA

Report Summary: The application gives brief summaries of site background information and environmental conditions at the site.

The application also provides contact names(s) and phone numbers for stakeholders, and potential redevelopment plans.

Information Relating to the Site: This application provided the background and history of the Site. The property is part of the MT State Training School campus and the buildings in question are currently vacant.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

3.0 DESCRIPTION OF WORK PERFORMED AND RATIONALE

This section summarizes the work performed and rationale for the work conducted to meet the SOO developed for the investigation as documented in the approved Sampling and Analysis Plan (SAP) for the Site (WESTON, 2018). Deviations from the approved SAP for this Phase II ESA are presented in Section 3.4.

Based upon the SOO developed for the Site, a building inspection was conducted as part of this Phase II ESA. The investigation included visual inspection, field screening, and/or sample collection for laboratory analysis. Details of the individual media investigations along with rationale are presented below. Photographs of field activities are included in the Photograph Log presented in Appendix A. The Phase II fieldwork was conducted on August 5, 2016 with supplementary sampling on October 26, 2018.

3.1 ASBESTOS-CONTAINING MATERIAL

This Phase II ESA involved an ACM survey, including the collection of bulk asbestos samples in order to establish the extent and presence of ACM. The survey was conducted by Montana Accredited Asbestos Building Inspectors: Mr. Joe Rudi, Mr. Michael Cherny, and Mr. Brent Merritt. Visual inspections were conducted on areas of the structures where an individual performing demolition or renovation operations may encounter regulated asbestos-containing material (RACM). Sample locations and the total number of samples were based on Asbestos Hazard Emergency Response Act (AHERA) standards (EPA, 2017), the Administrative Rules of Montana (MT DEQ, 2011), and/or the best professional judgment of the inspector. Each potential RACM location was touched to determine if it was friable. Bulk samples were collected of all suspect friable and non-friable RACM and submitted to an asbestos-certified laboratory for analysis.

3.2 LEAD-BASED PAINT

Due to the age of the building at the Site, this Phase II ESA involved a LBP survey by EPA Certified LBP Inspector: Mr. Michael Cherny. The LBP survey was conducted using an XRF instrument on painted surfaces to determine if materials were positive for lead (≥1 milligram per square centimeter [mg/cm2]). Visual inspections were conducted on areas of the building and XRF readings were collected based upon the best professional judgment of the inspector.

3.3 VISUAL INSPECTIONS

Due to the age of the building, visual inspections were conducted for PCB ballasts, mercury thermostats, and mold. The visual inspection included presence/non-presence determination of the hazards. Quantity and location information was documented where possible, but no samples were collected.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

3.4 DEVIATIONS FROM THE SAMPLING AND ANALYSIS PLAN

Due to the ongoing evaluation and refinement of the SOO, changes can occur to the approved SAP based upon site conditions encountered. No deviations from the approved SAP were identified during this Phase II ESA.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

4.0 DESCRIPTION OF METHODS USED

4.1 ASBESTOS-CONTAINING MATERIAL

Asbestos Bulk Sampling

Personnel performing the sampling wore personal protective equipment (PPE) appropriate to the hazard(s) presented and included gloves, Tyvek, booties, hard hats, and/or high-efficiency particulate air (HEPA) respiratory protection. Asbestos bulk samples were randomly collected using the grid system described in the EPA publication “Asbestos in Buildings – Simplified Sampling Scheme for Friable Surfacing Materials” (EPA, 1985). The following general sampling guidelines were followed during the inspection, as applicable:

In areas where homogeneous suspected RACM (surfacing) was less than 1,000 sq. ft., three randomly collected bulk samples were collected from each area;

In areas where homogeneous suspected RACM (surfacing) was at least 1,000 sq. ft. but less than 5,000 sq. ft., five randomly collected bulk samples were collected from each area;

In areas where homogeneous suspect RACM (surfacing) was at least 5,000 sq. ft., seven randomly selected bulk samples were collected from each area;

At least three samples were collected from thermal systems insulations;

Three random bulk samples will be collected from all mechanical system insulation and fittings, such as tees, elbows, and valves, that are not assumed to be ACM;

Three random bulk samples will be collected from each type of miscellaneous material that is not assumed to be ACM; and

Three random bulk samples will be collected from any type of non-friable suspected ACM that is not assumed to be ACM.

Quality Assurance (QA)/Quality Control (QC)

No QA/QC activities or sample types were required based upon the assessment techniques and sample collection methods.

Laboratory Analytical Methods

Samples collected were sent to Reservoirs Environmental Inc. in Denver, Colorado for polarized light microscopy (PLM) analysis by EPA Method 600/R-93/116 to determine a visual estimation of asbestos content and, if applicable, EPA Method 600/R-93/116 (400 Point Count).

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

4.2 LEAD-BASED PAINT

XRF Readings

In-situ XRF readings were collected using an Innov-X Alpha Series™ handheld XRF instrument to analyze painted and coated surfaces (interior and exterior) for lead during this Phase II ESA.

XRF readings were collected from walls, windows, and other painted surfaces in each room equivalent were collected. Room equivalents include painted or coated surfaces that are not considered to be separate rooms such as hallways and closets. A representative number of readings were collected from a subset of rooms considered by the certified LBP inspector to be of like coated surfaces.

In general, locations where the paint appeared to be thickest were selected for XRF analysis.

Locations where paint was worn away or scraped off were avoided. Areas over pipes, electrical surfaces, nails, and other possible interferences were also avoided. The XRF probe faceplate was allowed to lie flat against the surface of the test location to obtain a quality reading.

QA/QC

The following QA/QC activities were conducted as part of this investigation:

XRF Standardization Readings – XRF standardization readings were collected prior to use, every four hours during use (as applicable), and following use to verify accuracy.

No other QA/QC activities or sample types were required based upon the assessment techniques and sample collection methods. Based on the results of the standardization readings, all results reported are considered acceptable. Results of the QA/QC activities are presented in Table 3.

Laboratory Analytical Methods

Due to no inconclusive readings reported by the XRF instrument, no paint chip samples were collected for laboratory analysis.

4.3 PCBS, MERCURY, AND MOLD

Visual Inspections

Visual inspections were conducted for presence/non-presence of mercury thermostats, PCB ballasts, and mold. Suspect hazards encountered, if any, were documented in field notes and/or photographed.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

5.0 PRESENTATION OF INFORMATION AND DATA ACQUIRED

5.1 ASBESTOS-CONTAINING MATERIAL

A total of 65 bulk samples were collected from the Site and submitted for PLM analysis. ACM sample results are shown in Tables 1 and 2. Locations with positive results (> 1% asbestos) are displayed on Figures 3 through 5. Of the samples collected, the following number of samples were collected of each bulk material.

Bulk Material Number of Samples Collected

Brick and Mortar 9

Building Foundation 3

Ceiling Tile 3

Drywall 1

Insulations (Duct or light) 6

Linoleum 5

Miscellaneous 6

Pipe Insulation 6

Plaster 19

Stone Trim 6

Window Caulk 1

In addition, the following assumptions and items of note were observed during the ACM survey:

When appropriate, samples were collected from areas of the building material already damaged or disturbed.

The building is a brick construction with a concrete foundation and stone trim work. The roof was recently replaced and therefore was not sampled.

Drywall samples included compound and/or texture components. The walls and ceilings were predominately plaster, but renovated or repaired sections had some drywall present.

Based on the surfacing present, plaster was considered as one homogenous area per floor.

Floors were concrete with some linoleum present in select rooms. No cove base or carpet was observed at the Site.

Suspect window caulking was observed on all exterior windows and the sun porch.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Some suspect pipe insulation was present on a radiator in one of the rooms. Only fiberglass insulation was used on remaining heating/cooling system pipes. Additionally, no sink coatings were encountered.

The crawlspace had deteriorating pipe insulation and debris; therefore, the entire crawlspace is considered contaminated.

19 incandescent light fixtures were observed in the building with a suspect silver foil insulation.

Most of the attic was not insulated; however, some suspect duct insulation was present.

Miscellaneous materials sampled include wire wrap and joint compound.

5.2 LEAD-BASED PAINT

A total of 236 XRF readings were taken from the building. The XRF readings are listed in Table

3. The following number of readings were collected from each area:

Location Readings Count

Exterior 3

1st Floor 117

2nd Floor 116

5.3 PCBS, MERCURY, AND MOLD

The following observations were made during the visual inspections:

Light fixtures in the building used fluorescent and incandescent bulbs. None of the light fixtures observed in the building appeared to be leaking fluids. Presence of potential PCB ballasts was observed during the inspection.

No mercury-containing thermostats were observed.

No mold was encountered at the Site.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

6.0 EVALUATION AND INTERPRETATION OF INFORMATION, DATA,

AND RESULTS

The evaluation and interpretation of the information, data, and results for the Phase II ESA are presented below. This section summarizes the field screening data and laboratory results obtained to identify the location and extent of contamination. Benchmarks used for comparison are listed below:

ACM

Asbestos-Containing Materials in Schools Rule (40 Code of Federal Regulations Part 763, Subpart E). ACM is defined as any material containing more than one percent (1%) asbestos.

Administrative Rules of Montana (ARM) Asbestos Control (Title 17 Environmental Quality, Chapter 74 Noise, Asbestos Control, Methamphetamine Cleanup, Subchapter 3, Rule 354) (ARM, 2011).

LBP

U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition).

The HUD benchmark for lead-based paint is greater than or equal to 1.0 mg/cm2.

The locations of samples and extent of hazardous building materials exceeding benchmarks are depicted on Figures 3 through 7. Field readings and laboratory results for the samples collected are summarized in Tables 1 through 3. Photographs of the field activities conducted are presented in Appendix A. Copies of the laboratory reports are presented in Appendix B. Copies of the field sample location maps are presented in Appendix C.

6.1 ASBESTOS-CONTAINING MATERIAL

Of the 65 samples submitted for laboratory analysis, 14 samples were reported as “positive” (>1% asbestos) or trace for asbestos. Asbestos results ranged from trace to 80% total asbestos for an individual sample layer. Of the 14 samples, three were reanalyzed by point count analysis. Of these three reanalyzed samples, none were point-counted below one; therefore, these three samples are considered to be ACM. In all, 14 confirmed ACM samples were collected at the Site. The following table indicates the type, condition, and number of samples identified as ACM.

Identified ACM Condition Number of ACM Samples

Duct Insulation Friable 1

Drywall Friable 1

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Identified ACM Condition Number of ACM Samples

Light Insulation Friable 2

Linoleum Friable 5

Pipe Insulation Friable 2

Pipe Joint Friable 1

Plaster Friable 1

Window Caulk Friable 1

ACM sample collection locations and approximate extent of ACM are presented in Figures 3 through 5. The confirmed ACM sample(s), the asbestos containing layer(s), and the estimated volume of ACM is presented in Table 1. A list of the samples collected that were reported as non-detect for asbestos is presented in Table 2.

Interpretation of Results

Duct insulation present in the attic was confirmed to be ACM. A select portion of drywall on the second floor was confirmed as ACM. Light insulation in incandescent fixtures present throughout the building was confirmed to be ACM. Linoleum present in bathroom areas and the dining room were confirmed to be ACM, on each floor. ACM was present on a vertical pipe protruding from a steam heat radiator. Additionally, deteriorated pipe insulation and pipe joints were confirmed to be ACM in the crawlspace of the building. Due to debris being present, the crawlspace soils are assumed to be contaminated with ACM. Window caulk present on all exterior windows was confirmed to be ACM.

Five additional plaster samples were collected in the hallway on the main level in order to delineate the extent of the ACM compound found in sample 5F-PL01-210. Based on the sample results, it is believed that the ACM plaster compound is only present on one wall with a different construction history than the original walls.

Based on the laboratory results reported for the 14 confirmed ACM samples, asbestos is present at the Site. ACM is considered to be a contaminant of concern (COC) in relation to the Site. The following table indicates the location and estimated extent of ACM identified at the Site.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

ACM Estimated Volume / Extent (Approximate) Location

Duct Insulation 25 sq. ft. Attic

Drywall 550 sq. ft. Second Floor

Light Insulation 40 sq. ft. First and Second Floors

Linoleum 1,130 sq. ft. First and Second Floors

Pipe Insulation 55 LF Crawlspace and First Floor

Pipe Insulation Debris 4,500 sq. ft. Crawlspace

Plaster 50 sq. ft. First Floor

Window Caulk 5,000 LF Second Floor Notes:

LF = linear feet

sq. ft. = square feet

6.2 LEAD-BASED PAINT

Of the 236 XRF readings taken from the building, a total of 137 readings were positive for LBP contamination (≥1 mg/cm2). The following table indicates the location, current surface paint color, and percent lead for LBP identified at the Site.

Location (# of Positive Readings) Current Surface Paint Color

Area Concentration of LBP (± Error)

First Floor

Ceiling (11)

Cream 1 mg/cm2 (± 0.02 to 0.09)

Light Blue 1 mg/cm2 (± 0.06)

White 1 mg/cm2 (± 0.03 to 0.05)

Wall (52)

Coral 1 mg/cm2 (± 0.03 to 0.07)

Cream 1 mg/cm2 (± 0.02 to 0.13) to

2.49 mg/cm2 (± 0.35)

Gold 1 mg/cm2 (± 0.04 to 0.05)

Green 1 mg/cm2 (± 0.03)

Light Blue 1 mg/cm2 (± 0.02 to 0.08)

Pink 1 mg/cm2 (± 0.02 to 0.06)

Yellow 1 mg/cm2 (± 0.05)

First Floor Hall

Ceiling (1) Cream 1 mg/cm2 (± 0.02)

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Location (# of Positive Readings) Current Surface Paint Color

Area Concentration of LBP (± Error)

Wall (4) Cream 1 mg/cm2 (± 0.05 to 0.07)

Second Floor

Ceiling (10) Cream 1 mg/cm2 (± 0.02 to 0.03)

White 1 mg/cm2 (± 0.03 to 0.11)

Door Frame (1) Green 1.84 mg/cm2 (± 0.2)

Wall (51)

Blue 1 mg/cm2 (± 0.02 to 0.1)

Coral 1 mg/cm2 (± 0.03 to 0.12)

Cream 1 mg/cm2 (± 0.03 to 0.1)

Green 1 mg/cm2 (± 0.06 to 0.11)

Light Gray 1 mg/cm2 (± 0.03 to 0.05)

White 1 mg/cm2 (± 0.05 to 0.12)

Yellow 1 mg/cm2 (± 0.04 to 0.06)

Second Floor Hall

Ceiling (1) Cream 1 mg/cm2 (± 0.06)

Wall (3) Cream 1 mg/cm2 (± 0.02 to 0.05)

Exterior

Window Frame (1) Green 3.35 mg/cm2 (± 0.28)

Window Sash (1) Green 2.63 mg/cm2 (± 0.24)

A complete list of LBP readings is presented in Table 3. The location and approximate extent of LBP identified is presented in Figures 6 and 7.

Interpretation of Results

Based on the XRF results, elevated lead concentrations are present on the ceiling, walls, door frames, and exterior window components. The following table lists the location, current surface paint color, and estimated extent of LBP present at the Site. Although there were positive readings on the exterior, no bare soil (i.e. soil or sand not covered by grass, sod, other live ground covers, wood chips, gravel, artificial turf, or similar covering) was present around the dripline; therefore, lead-in-soil was not assessed. LBP is considered to be a COC at the Site.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Location Current Surface Paint Color Estimated Extent

First Floor

Ceiling

Cream 3,100 sq. ft.

Light Blue 40 sq. ft.

White 50 sq. ft.

Wall

Coral 480 sq. ft.

Cream 6,000 sq. ft.

Gold 700 sq. ft.

Green 200 sq. ft.

Light Blue 260 sq. ft, Pink 390 sq. ft.

Yellow 230 sq. ft.

First Floor Hall

Ceiling Cream 780 sq. ft.

First Floor Hall (Continued)

Wall Cream 2,800 sq. ft.

Second Floor

Ceiling Cream 670 sq. ft.

White 2,050 sq. ft.

Door Frame Green 15 sq. ft.

Wall

Blue 1,300 sq. ft.

Coral 1,700 sq. ft.

Cream 3,000 sq. ft.

Green 750 sq. ft.

Light Gray 250 sq. ft.

White 550 sq. ft.

Yellow 1,200 sq. ft.

Second Floor Hall

Ceiling Cream 950 sq. ft.

Wall Cream 2,800 sq. ft.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Location Current Surface Paint Color Estimated Extent

Exterior

Window Frame Green 500 sq. ft.

Window Sash Green 100 sq. ft.

6.3 PCBS, MERCURY, AND MOLD

The following additional items were noted:

• Numerous light ballasts were observed throughout the building. Of the representative light ballasts observed, a mixture of PCB and non-PCB ballasts were identified. Ballasts without a “No PCBs” label were assumed to contain PCBs. None of the light fixtures observed in the building appeared to be leaking fluids.

• Of the thermostats observed, mercury was not present as a component.

• No mold was encountered at the Site.

Interpretation of Results

Based on the visual inspection, PCBs are considered a COC at the Site since PCB ballasts were found in the building even though the ballasts did not appear to be leaking.

Based on the visual inspection, mercury is not considered a COC at the Site.

Based on the visual inspection, mold is not considered a COC at the Site.

6.4 CONCEPTUAL SITE MODEL

Per ASTM E1903-11 (Section 6.4.6), validation of the conceptual site model is conducted by evaluating testing results and other investigation findings to determine whether available information is sufficient to support sound conclusions regarding the presence of the target analytes.

The presence of the target analytes investigated as part of this Phase II ESA along with the current exposure pathways, as applicable, for the Site is presented in the following table.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

Target Analytes Media

Contaminants Present Above

Screening Benchmarks

Exposure Pathway

Exposure Route

Human Receptors

Residential Workers

ACM Building Materials Yes Potentially

Complete

Dermal -- X Ingestion -- X Inhalation -- X

LBP Building Materials Yes Potentially

Complete

Dermal -- X Ingestion -- X Inhalation -- X

Mercury, PCBs, and Mold

Building Materials

Yes (PCBs)

Potentially Complete

Dermal -- X Ingestion -- X Inhalation -- X

Comments: Evaluation of exposure pathway completeness is based upon the current site use as vacant and assumes that no people are currently accessing the Site or will be accessing the Site other than workers during future redevelopment. Once future site-specific activities are determined or if a change in current use occurs, exposure pathways should be re-assessed as they may alter the pathway completeness presented in this report and require further evaluation prior to conducting any activities or change in use at the Site.

Note:

-- = Receptor not at risk (Currently) X = Receptor at risk to exposure (Currently or Potentially)

6.5 DISCLOSURE OF AVAILABLE DATA INSUFFICIENT TO MEET OBJECTIVES

Per ASTM E1903-11 (Section 1.3.2), all Phase II ESA reports must disclose any respect in which available data are insufficient to meet the objectives of the assessment. Listed below are the disclosures in which the available data set for this investigation were insufficient to meet the objectives of this Phase II ESA, if any.

Based upon the objectives for this Phase II ESA, all objectives of this assessment were met based upon the available data. In no respect was the available data insufficient to meet the objectives.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

7.0 CONCLUSIONS OF THE PHASE II ESA

START performed a Phase II ESA in conformance with the scope and limitations of ASTM Practice E1903-11 for the South Campus MT State Training School – Cottage #5 located at Venture Way in Boulder, MT. The following list is a summary of the conclusions regarding COCs and associated media identified by START at the Site:

Asbestos-Containing Material

Based on the results of the ACM survey, asbestos is present in the building. ACM is considered to be a COC in relation to the Site.

Lead-Based Paint

Based on the results of the LBP screening, LBP is present in the building. LBP is considered to be a COC in relation to the Site.

PCBs, Mercury, and Mold

A summary of the observations regarding the visual inspections conducted are presented below:

Numerous light ballasts were observed throughout the building. Of the representative light ballasts observed, a mixture of PCB and non-PCB ballasts were encountered. None of the ballasts in the building appeared to be leaking fluids. PCBs are considered COCs in relation to the Site.

Mercury-containing equipment was not observed at the Site. Mercury is not considered a COC in relation to the Site.

No mold was not encountered at the Site. Mold is not considered a COC in relation to the Site.

RECOMMENDATIONS

Based on the results of the environmental assessment, START recommends the following:

Based on the ACM identified at the Site and reuse plans, START recommends contracting an accredited asbestos remediation company to assess hazard risk and determine appropriate remedial actions to address ACM at the Site (e.g., abatement, encapsulation, etc.). ACM remediation is recommended prior to any renovation or demolition activities at the Site in order to permanently mitigate exposure risk.

However, pending final redevelopment/re-use plans for the Site and considering the type and condition of ACM identified, development of an ACM Operations and Maintenance (O&M) Plan to monitor condition of ACM identified at the Site, removal of select ACM (e.g., friable pipe insulation), and/or a combination of these remediation methods could be implemented. START recommends contracting an accredited asbestos remediation

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

company to create and implement an ACM O&M Plan to monitor the condition of ACM identified.

START recommends contracting an accredited lead remediation company to determine appropriate remedial actions needed once future use plans are determined to address the LBP at the Site during the cleanup phase of redevelopment (e.g., encapsulation, chemical stripping, removal, etc.). Dust control methods should be implemented for the debris. It is recommended that all work be performed by an EPA Lead-Safe certified firm. If construction materials are to be removed, it is recommended that the construction debris disposal facility be contacted to determine if Toxicity Characteristic Leaching Procedure (TCLP) samples will be required.

Based on the results of the LBP survey, all wall and ceiling paint should be considered LBP due to the spatial variation associated with the painting history. Due to the deteriorated condition of most surfaces, an encapsulant cannot be used unless the surfaces are prepared beforehand. Additionally, the paint chips and dust currently present on the floors will need to be vacuumed using a high-efficiency particulate air filter.

PCB-containing equipment (e.g., light ballasts) should be properly removed and disposed of during renovation activities.

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01. It shall not be released or disclosed in whole or in part without the express written permission of the EPA.

8.0 SIGNATURE OF PHASE II ASSESSOR AND SEAL

This Phase II ESA was completed by the following START personnel and subcontractor(s), if applicable. Qualifications are provided at the end of the report:

Mr. Elliott Petri, P.E. – Project Manager, Engineer, Environmental Professional, MT and AHERA Certified Asbestos Building Inspector, and EPA Lead-Based Paint Inspector;

and

Mr. Michael Cherny, Scientist – MT and EPA AHERA Asbestos Inspector and EPA Lead-Based Paint Inspector; and

Mr. Joe Rudi, Scientist – MT and EPA AHERA Asbestos Inspector Mr. Brent Merritt, Scientist – MT and EPA AHERA Asbestos Inspector

Mr. Elliott Petri, P.E. has undertaken the role of Phase II Assessor for this assessment. The following is the certification statement as defined in ASTM Practice E1903-11 (Section 9.2.1):

We have performed a Phase II environmental site assessment at the South Campus MT State Training School – Cottage #5 located at Venture Way Boulder, MT in conformance with the scope and limitations of ASTM Practice E1903-11 and for the following objectives:

• Perform a data gap assessment for the on-site building for ACM to supplement previous sampling results.

• Develop sufficient information to render a reasonable professional opinion whether hazardous substances either are or are not present at the Site with respect to the potential concerns assessed. If present, include concentrations of hazardous substances based on field screening and/or laboratory analysis of samples.

• Gather and provide sufficient data to assist the TBA recipient in making informed decisions with regard to the future use of the property.

• Obtain sufficient data to support conceptual remediation cost estimating, if necessary.

Elliott Petri, P.E.

Certifying Environmental Professional (Print)

Project Manager Title

Signature

Date

Revision 1 – December 2018

0003/1808-05

This document was prepared by START for U.S. EPA Region 8, as tasked by the EPA, in accordance with Contract EP-S8-13-01.