Asbestos Survey N Mcd Crk Brg.pdf

Asbestos • Lead-Based Paint • Industrial Hygiene • Indoor Air Quality

201 South 30th Street Billings, Montana 59101

Phone: 406/245-7766

FAX: 406/254-1428

Billings, MT ♦ Helena, MT

December 22, 2020

Mr. Chris Hardan, PE Robert Peccia & Associates 3147 Saddle Drive Helena, MT 59601

RE: Letter Report

Asbestos Survey Kelly Camp Bridge

Glacier National Park, Montana Northern Project Number 399-951

Dear Mr. Hardan:

This letter report provides the summarized results of the asbestos survey performed by Todd Schneider (MTA-5179, exp. 9/4/2021) of Northern Industrial Hygiene, Inc. (Northern) on December 3, 2020 at the above referenced site. The survey was performed to identify potential hazardous materials (asbestos) that may be present in the bridge. This survey is being conducted due to the planned renovation.

Overview

The Kelly Camp Bridge is a wood and metal structure located a few miles north of the McDonald Lodge in Glacier National Park.

Asbestos Overview

Asbestos is a trade name for a group of fibrous naturally occurring minerals that were used widely in building materials because of its ability to bind, resist chemicals, insulate, and fireproof. Exposure to elevated levels of asbestos fibers has been documented to cause a variety of diseases including asbestosis and cancer. Consequently, the application, removal, and disposal of asbestos-containing materials is regulated by several agencies.

Asbestos in most building materials poses little threat to human health as long as the asbestos fibers are securely bound within the building material. However, as the materials deteriorate because of time or exposure, or are disturbed because of human or other activities, the potential increases for the fibers to become airborne. When this occurs, the risk to human health increases significantly when the fibers are inhaled.

The Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) defines an asbestos-containing material (ACM) as a material containing greater than (>) 1% asbestos and assigns ACM to three categories: regulated asbestos-containing material (RACM), Category I, and Category II. RACM is defined as an ACM that, when dry, can be crumbled, pulverized or reduced to powder by hand pressure (friable). RACM also includes: Category I and Category II materials that will be (or have been)

Mr. Chris Hardan Asbestos Survey Kelly Camp Bridge Glacier NP, Montana December 22, 2020

Northern Industrial Hygiene, Inc.

subjected to sanding, grinding, cutting or abrading, or; Category II materials that have a high probability of becoming (or have become) crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition/renovation operations. Category I ACMs are non-friable packings, gaskets, resilient floor covering, and asphalt roofing products. Category II ACMs are non-friable materials, excluding Category I non-friable ACMs, that, when dry, cannot be crumbled, pulverized, or reduced to powder by hand pressure.

The NESHAP requires that the building owner or operator provide notification at least 10 working days prior to commencing renovation activities that will disturb more than 160 square feet (SF) or 260 linear feet (LF) of RACM, or prior to any demolition activities. The NESHAP also requires that RACM be removed prior to renovation/demolition activities that will disturb the material.

The Montana Department of Environmental Quality (MDEQ) adopted the NESHAP by reference and requires the building owner/operator to apply for an Asbestos Abatement Permit at least 5 working days prior to commencing asbestos abatement project involving > 10 SF but less than (<) 160 SF in surface area or >3 LF but < 260 LF of RACM. The permit application must be submitted at least ten working days prior to commencing an asbestos abatement project involving >160 SF or 260 LF of RACM or prior to any demolition. Notification of the MDEQ satisfies the NESHAP notification requirement.

The MDEQ requires that personnel conducting permitted asbestos abatement projects be accredited by the State of Montana. The MDEQ also requires an asbestos abatement design be prepared by a State of Montana accredited asbestos project designer for projects requiring an Asbestos Abatement Project Permit.

The Occupational Safety and Health Administration (OSHA) requires that employees that will be exposed to any amount of asbestos be trained in accordance with the provisions of 29 CFR 1926.1101. The OSHA standard also requires that employee exposure to asbestos fibers not exceed either the permissible exposure limit (PEL) of 0.1 fibers per cubic centimeter (f/cc) of air for an eight (8) hour time-weighted average (TWA) or the excursion limit (EL) of 1.0 f/cc for any thirty (30) minute work period.

Asbestos Survey Procedures

Sampling Procedures

The asbestos survey was performed using the applicable portions of the currently recognized standard protocol developed for schools under AHERA, as promulgated in Title 40, Code of Federal Regulations (40 CFR), Part 763 and as amended in the Federal Register and as established in ARM 17.74.354. Since the primary concern for this investigation was to identify potential asbestos hazards in the entire bridge, Northern representatives visually inspected existing conditions considering each construction, addition, or renovation date as separate, unique buildings, if applicable.

Kelly Camp Bridge Glacier NP, Montana

Laboratory Analysis of Bulk

Bulk samples obtained during the survey were assigned bulk sample numbers and entered on sample summary/chain-of-custody forms. The samples were transported to the laboratory by overnight courier under standard chain-of-custody procedures. The analysis was performed in accordance with EPA Method 600/R-93/116, which employs polarized light microscopic techniques with dispersion staining for identification of mineral forms of asbestos. The quantification of asbestos in the sample is intended to be an estimate only and the limit of detection for this method is approximately 1% by volume.

Asbestos Survey Findings

A total of one material suspected to contain asbestos was identified on the bridge. That material, a black tar was given sample number M20.1 and three bulk samples were collected following sample collection requirements outlined under the EPA, AHERA legislation and State of Montana regulations.

Laboratory results revealed that the sampled material does not contain asbestos.

For additional information refer to the attached laboratory report.

Conclusions and Recommendations

Asbestos was not found in the suspect material sampled and analyzed therefore Northern offers no recommendations regarding these materials during renovation work.

It is recommended the owner or operator keep a copy of this asbestos survey report on site during the renovation project and during any subsequent renovation projects. The report must be made available to the MDEQ upon request.

Limitations

This asbestos survey report was prepared based on information obtained during our on-site observations and interpretation of the laboratory analysis of bulk samples of building materials collected during the survey. The conclusions of this report are professional opinions based solely upon our visual site observations and interpretations of laboratory analyses and field data as described in our report.

This report has been prepared to provide information concerning the various types and estimated quantities of asbestos-containing materials present at this site. It includes only those materials that were visible and accessible at the time of our survey. We did not remove any permanent building enclosures or disassemble any equipment.

Kelly Camp Bridge Glacier NP, Montana

This survey and report is intended to identify asbestos-containing materials. It is not intended to be used for the purpose of obtaining bids for its removal by abatement contractors. The scope of services performed by Northern may not be appropriate to satisfy the needs of other users, and any use or re-use of this document, or the findings presented herein, is at the sole risk of the user.

Our opinions are intended exclusively for use by Robert Peccia & Associates. The opinions presented herein apply to the site conditions existing at the time of our investigation.

Therefore, our opinions and recommendations may not apply to future conditions that may exist at the site that we have not had the opportunity to evaluate.

We trust this summary report provides sufficient information for planning purposes. We appreciate the opportunity to assist you and look forward to continuing to work with you.

Please contact us if you have any questions or require additional information.

Respectfully submitted, NORTHERN INDUSTRIAL HYGIENE, INC.

Todd Schneider EPA/Montana Accredited Asbestos Inspector

Attachments: Laboratory Analysis Report Inspector Credentials Invoice

EMSL Analytical, Inc.

3356 West Catalina Drive Phoenix, AZ 85017

Tel/Fax: (602) 276-4344 / (602) 276-4053 http://www.EMSL.com / phoenixlab@emsl.com

122005402EMSL Order:

Customer ID: NIHI62

Customer PO:

Project ID:

Attention: Phone:Todd Schneider (406) 245-7766

Fax:Northern Industrial Hygiene, Inc. (406) 254-1428

Received Date:201 South 30th Street 12/07/2020 10:15 AM

Analysis Date:Billings, MT 59101 12/10/2020

Collected Date: 12/03/2020

Project: Kelly Camp Bridge / 399-951

Test Report: Asbestos Analysis of Bulk Materials via EPA 600/R-93/116 Method using Polarized

Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

M20.1A

122005402-0001

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Bridge Tar

M20.1B

122005402-0002

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Bridge Tar

M20.1C

122005402-0003

None DetectedNon-fibrous (Other)100%Black

Non-Fibrous

Homogeneous

Bridge Tar

Analyst(s)

Alexa Luna (1)

Jillian Chesson (2)

Michelle Wilson, Laboratory Manager or Other Approved Signatory

EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non- friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Phoenix, AZ NVLAP Lab Code 200811-0, AZ0937, CO AL-19027

Initial report from: 12/14/2020 11:41:00

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 12/14/2020 9:41 AM

OrderID: 122005402