Atch_3_Medicine_Lake_Obser_Tower_Lead___Asbestos_Survey_Report.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

November 19, 2020

Mr. Karl Henshaw Jackola Engineering & Architecture, PC 2250 Highway 93 South Kalispell, Montana 59901

RE: Letter Report

Asbestos and Lead-based Paint Inspections Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana Northern Project Number 999-4274

Dear Mr. Henshaw:

This letter report provides the summarized results of the asbestos and lead-based paint inspections performed by Greg Brownell (MTA-5502) of Northern Industrial Hygiene, Inc.

(Northern) on November 4, 2020 at the above referenced site. The inspections were performed to identify potential hazardous materials (asbestos and lead-based paint) that may be present in the building. Both inspections included the interior and the exterior of building including the roof finish materials.

Overview of Building

The construction date of the Observation Tower is unknown. The Observation Tower is a painted metal structure with a wood floor, metal walls, ceiling, and roof. The cab of the observation tower comprises of approximately 50 square feet of floor area.

Typical interior painted building components tested as part of this investigation include wood handrail; wood access hatch; metal cab walls and ceiling; and metal windows.

Typical exterior painted building components tested as part of this investigation include wood stair steps and metal stair stringers.

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 are regulated by several agencies.

Hazardous Materials Inspection

Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana

Northern Industrial Hygiene, Inc.

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.

Occupational Safety and Health Administration (OSHA) regulations, (29 CFR Parts 1910 and 1926) define an asbestos-containing material as:

Any material that contains more than one percent asbestos and also defines certain high-risk materials, which are presumed to contain asbestos, as Presumed Asbestos-containing Materials (PACM). The PACM designation applies to thermal system insulation, sprayed on or troweled on surfacing material and debris where such material is present. The PACM terminology was added to ensure compliance with the hazard communication provisions of the laws and specifically for buildings constructed prior to 1980.

The National Emissions Standards for Hazardous Air Pollutants (NESHAP), (40 CFR, Part 61, Subpart M) defines regulated asbestos containing material (RACM) as follows:

Friable asbestos-containing material containing more than one percent asbestos, which has been applied on ceilings, walls, structural members, piping, duct work, or any other part of a building, which when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. The term includes non-friable asbestos-containing materials after it becomes damaged, by any means, such that when dry, it may be crumbled, pulverized, or reduced to powder by hand-pressure.

Lead-Based Paint Overview

Lead is found in the paint on the inside and outside of many buildings. Most buildings constructed prior to World War II had lead-based paint applied to the interior or exterior surfaces. Some paints introduced up until 1977 contained some level of lead.

Regulations enforced by the Consumer Product Safety Commission banned the use of all but small amounts of lead in paints in 1978. However, manufacturers are still allowed to produce paints containing up to 90 parts per million lead.

If the paint which contains lead is in poor or damaged condition, persons working or living in the area can be exposed to small paint chips or lead-containing dust. Exposure can also result from construction, demolition, repair and refinish (sanding) operations or from the torch cutting or burning of painted materials.

Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana

Exposure to the lead can also occur as a result of hobbies or sports. Individuals who work with lead while making stained glass or while melting lead to make sinkers or bullets, or individuals that reload ammunition are all exposed to varying levels of lead.

Inspection Procedures

Asbestos 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 the Administrative Rules of Montana (ARM 17.74.354).

Since the primary concern for this investigation was to identify potential asbestos hazards in the entire building, Northern representatives visually inspected existing conditions considering each construction, addition, or renovation date as separate, unique buildings, if applicable.

Laboratory Analysis of Bulk Asbestos Samples

Bulk samples obtained during the inspection 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.

Lead-Based Paint

Lead-Based Paint Inspection Procedures

The painted surfaces in this inspection were analyzed for the presence of lead using a portable X-ray fluorescence instrument (XRF) manufactured for paint analysis. Portable XRF instruments expose the painted surface(s) to X-rays that cause lead to fluoresce with a characteristic frequency. The intensity of this fluorescence is measured by the instrument's detector and is then converted into a number that represents the amount of lead in the paint per unit area (milligrams per square centimeter). The XRF instrument has the capability to analyze the lead content of multiple layers of paint at one time.

The XRF is the preferred method for measuring the lead level in paint. Laboratory analysis of paint-chip samples is recommended for components that cannot be tested using XRF instruments or to confirm inconclusive XRF results. Northern uses the XRF instrument

Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana manufactured by NITON Corporation. The instrument is calibrated prior to, following and periodically during each day of field-testing. All field data is stored electronically by the instrument for direct transfer to computer and is also recorded on field forms.

The person performing this XRF inspection has received specific training in the use and interpretation of data collected by this instrument, and is familiar with the radiation safety requirements and proper use of the device.

For labeling and definition purposes in this report, the term lead-based paint means paint or other surface coatings that contain lead at a concentration equal to or greater than 1.0 mg/cm2 as measured using an XRF. This definition is utilized by the Department of Housing and Urban Development (HUD) and does not specifically apply to exposure concerns under the Occupational Safety and Health Administration (OSHA).

Because OSHA does not recognize a threshold of lead content in paint for personnel exposure concerns, the definition of lead-based paint in this report should be used only to discriminate paint with relatively high lead content from paint with relatively low lead content.

Inspection Findings

Asbestos

A total of two (2) materials were sampled following sample collection requirements outlined under the EPA, AHERA legislation and State of Montana regulations.

Laboratory results revealed that neither of the sampled materials contain asbestos.

For additional information refer to Table 1 and the attached laboratory report.

Lead-Based Paint

This inspection focused on identifying general painted building components on the interior and exterior of the building and performing testing of these components in various locations throughout the facility.

Seven painted interior and exterior building components were identified. Lead paint was detected on three of the identified painted building components tested. They are:

L3 Metal Cab Walls L4 Metal Cab Ceiling L5 Metal Cab Windows

Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana

The paint on these three components was peeling.

Reference Tables 2 and 3 for a description of identified painted building components and XRF test results.

Conclusions and Recommendations

Asbestos

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

The owner or operator is required to keep a copy of this asbestos inspection report on site during any renovation or demolition projects. The report must be made available to the MDEQ upon request.

Lead-Based Paint

Northern recommends any work on the metal cab walls, ceiling and windows be conducted by a Lead Renovation, Repair and Painting Rule (RRP) trained contractor in accordance with the applicable OSHA and EPA RRP regulations.

Limitations

This asbestos and lead-based paint inspection survey report was prepared based on information obtained during our on-site observations and interpretation of the XRF data as well as the laboratory results of bulk samples of building materials collected during the survey. The conclusions of this report are professional opinions based solely upon review of previously collected data, 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 inspection. We did not remove any permanent building enclosures or disassemble any equipment.

This inspection report is intended to identify asbestos-containing materials and lead-based paint building components. It is not intended to be used for the purpose of obtaining bids for their 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.

Medicine Lake Wildlife Refuge – Observation Tower

Medicine Lake, Montana

Our opinions are intended exclusively for use by Jackola Engineering & Architecture, PC.

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.

It was a pleasure to assist you with this project. Please call if you have any questions on our report, or if you need any additional assistance.

Respectfully submitted, NORTHERN INDUSTRIAL HYGIENE, INC.

Greg Brownell Asbestos Inspector

Attachments: Tables 1-3 Asbestos Laboratory Analysis Report Inspector Credentials Invoice

TABLE 1

SUMMARY OF MATERIALS SUSPECTED TO CONTAIN ASBESTOS

AND LABORATORY RESULTS

Material

Number Material Description

Friable

(Y/N) Sample Locations Laboratory Results

M8.1 Window Glazing Compound - White N Observation Tower Cab - East Window, North Window, and South Window

ND

M20.1 Thick-Bodied Traction Paint - Brown/Red N Stair Treads ND

Medicine Lake Wildlife Refuge Observation Tower

Medicine Lake, Montana

ND = No Asbestos Detected

Summary of Suspect ACM Page 1 of 1 Table 1

Material Color Material Screening

Number Building Component Substrate (at time of survey) Condition Result*

L1 Stairs Wood Red Peeling Negative

L2 Handrail Wood Red Intact Negative

L3 Wall Metal Red Peeling Positive

L4 Ceiling Metal Red Peeling Positive, Negative

L5 Window Metal Red Peeling Positive, Negative

L6 Hatch Wood Red Intact Negative

L7 Stair Stringer Metal Silver Intact Negative

* Pos = Lead-based paint - equal to or greater than 1.0 mg/cm2 measured using XRF screening.

* Neg = Nonlead-based paint - less than 1.0 mg/cm2 measured using XRF screening.

** Reference Table 3 for locations of confirmed materials, if any.

TABLE 2

IDENTIFIED PAINTED BUILDING COMPONENTS and XRF SCREENING RESULTS

Medicine Lake Wildlife Refuge

Medicine Lake, Montana

Observation Tower

Identified Materials and XRF Screening Results Page 1 of 1 Table 2

Site Insp. Room Side Read.

No

Mat.

No.

Component Substrate Color Cond. PbC Result

Medicine Lake Observation Tower GB NA NA 225 NA CALIBRATION NA NA NA 8.25 0

Medicine Lake Observation Tower GB NA NA 226 NA CALIBRATION NA NA NA 0 Negative

Medicine Lake Observation Tower GB NA NA 227 NA CALIBRATION NA NA NA 1 Positive

Medicine Lake Observation Tower GB NA NA 228 NA CALIBRATION NA NA NA 0.7 Negative

Medicine Lake Observation Tower GB NA NA 229 NA CALIBRATION NA NA NA 3.9 Positive

Medicine Lake Observation Tower GB EXTERIOR NA 230 1 STAIRS WOOD RED PEELING 0.04 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 231 1 STAIRS WOOD RED PEELING 0.02 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 232 1 STAIRS WOOD RED PEELING 0.03 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 233 1 STAIRS WOOD RED PEELING 0.02 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 234 1 STAIRS WOOD RED PEELING 0.01 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 235 1 STAIRS WOOD RED PEELING 0.1 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 236 1 STAIRS WOOD RED PEELING 0.07 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 237 1 STAIRS WOOD RED PEELING 0.02 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 238 1 STAIRS WOOD RED PEELING 0.02 Negative

Medicine Lake Observation Tower GB CAB C 239 2 HANDRAIL WOOD RED INTACT 0 Negative

Medicine Lake Observation Tower GB CAB C 240 2 HANDRAIL WOOD RED INTACT 0 Negative

Medicine Lake Observation Tower GB CAB A 241 3 WALL METAL RED PEELING 6.1 Positive

Medicine Lake Observation Tower GB CAB B 242 3 WALL METAL RED PEELING 5.8 Positive

Medicine Lake Observation Tower GB CAB C 243 3 WALL METAL RED PEELING 1.7 Positive

Medicine Lake Observation Tower GB CAB D 244 3 WALL METAL RED PEELING 1.2 Null

Medicine Lake Observation Tower GB CAB D 245 3 WALL METAL RED PEELING 2.3 Positive

Medicine Lake Observation Tower GB CAB A 246 4 CEILING METAL RED PEELING 0.9 Negative

Medicine Lake Observation Tower GB CAB B 247 4 CEILING METAL RED PEELING 3.6 Positive

Medicine Lake Observation Tower GB CAB C 248 4 CEILING METAL RED PEELING 0.13 Negative

Medicine Lake Observation Tower GB CAB D 249 4 CEILING METAL RED PEELING 0.13 Negative

Medicine Lake Observation Tower GB CAB D 250 4 CEILING METAL RED PEELING 0.12 Negative

TABLE 3

Results of XRF Instrument Paint Testing

Medicine Lake Wildlife Refuge

Medicine Lake, Montana

Observation Tower

Summary of XRF Instrument Readings Page 1 of 2 Table 3

Site Insp. Room Side Read.

No

Mat.

No.

Component Substrate Color Cond. PbC Result

TABLE 3

Results of XRF Instrument Paint Testing

Medicine Lake Wildlife Refuge

Medicine Lake, Montana

Observation Tower

Medicine Lake Observation Tower GB CAB A 251 5 WINDOW METAL RED PEELING 3.8 Positive

Medicine Lake Observation Tower GB CAB B 252 5 WINDOW METAL RED PEELING 0.18 Negative

Medicine Lake Observation Tower GB CAB C 253 5 WINDOW METAL RED PEELING 5 Positive

Medicine Lake Observation Tower GB CAB D 254 5 WINDOW METAL RED PEELING 3 Positive

Medicine Lake Observation Tower GB CAB D 255 6 HATCH WOOD RED INTACT 0 Negative

Medicine Lake Observation Tower GB CAB D 256 6 HATCH WOOD RED INTACT 0 Negative

Medicine Lake Observation Tower GB CAB D 257 6 HATCH WOOD RED INTACT 0 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 258 7 STAIR STRINGER METAL SILVER INTACT 0.25 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 259 7 STAIR STRINGER METAL SILVER INTACT 0.16 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 260 7 STAIR STRINGER METAL SILVER INTACT 0.16 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 261 7 STAIR STRINGER METAL SILVER INTACT 0.09 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 262 7 STAIR STRINGER METAL SILVER INTACT 0.14 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 263 7 STAIR STRINGER METAL SILVER INTACT 0.16 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 264 7 STAIR STRINGER METAL SILVER INTACT 0.07 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 265 7 STAIR STRINGER METAL SILVER INTACT 0.26 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 266 7 STAIR STRINGER METAL SILVER INTACT 0.05 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 267 7 STAIR STRINGER METAL SILVER INTACT 0.15 Negative

Medicine Lake Observation Tower GB EXTERIOR NA 268 7 STAIR STRINGER METAL SILVER INTACT 0.1 Negative

Medicine Lake Observation Tower GB NA NA 269 NA CALIBRATION NA NA NA 0 Negative

Medicine Lake Observation Tower GB NA NA 270 NA CALIBRATION NA NA NA 1.1 Positive

Medicine Lake Observation Tower GB NA NA 271 NA CALIBRATION NA NA NA 0.8 Negative

Medicine Lake Observation Tower GB NA NA 272 NA CALIBRATION NA NA NA 4.3 Positive

Summary of XRF Instrument Readings Page 2 of 2 Table 3

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

122004954EMSL Order:

Customer ID: NIHI62

Customer PO:

Project ID:

Attention: Phone:Greg Brownell (406) 245-7766

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

Received Date:201 South 30th Street 11/06/2020 10:25 AM

Analysis Date:Billings, MT 59101 11/06/2020

Collected Date: 11/04/2020

Project: 999-4274 / Medicine Lake Wild Life Refuge Tower

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

M8.1A

122004954-0001

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Window Glazing

Compound

Paint excluded

M8.1B

122004954-0002

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Window Glazing

Compound

Paint excluded

M8.1C

122004954-0003

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Window Glazing

Compound

Paint excluded

M20.1A

122004954-0004

None DetectedNon-fibrous (Other)100%Brown/Red

Non-Fibrous

Heterogeneous

Thick-Bodied Traction

Paint

M20.1B

122004954-0005

None DetectedNon-fibrous (Other)100%Brown/Red

Non-Fibrous

Heterogeneous

Thick-Bodied Traction

Paint

M20.1C

122004954-0006

None DetectedNon-fibrous (Other)100%Brown/Red

Non-Fibrous

Heterogeneous

Thick-Bodied Traction

Paint

Analyst(s)

Alexa Luna (2)

Ky Nguyen (4)

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: 11/09/2020 11:54:51

Page 1 of 1ASB_PLM_0008_0001 - 1.78 Printed: 11/9/2020 9:54 AM

OrderID: 122004954