Atch2_B500 - Asbestos Inspection Report.pdf

MONTANA | WASHINGTON | IDAHO | NORTH DAKOTA | PENNSYLVANIA

4 0 6 . 7 6 1 . 3 0 1 0 t d h e n g i n e e r i n g . c om

1 8 0 0 R i v e r D r i v e N o r t h

G r e a t F a l l s , MT 5 9 4 0 1

January 16, 2020

TSgt Austin Cook

341 CES/CEOER

39 78th Street North Malmstrom AFB, MT 59402

RE: LIMITED PRE-RENOVATION ASBESTOS INSPECTION

BUILDING 500 – ROOMS 227, 323 & ROOF

MALMSTROM AIR FORCE BASE, MONTANA

WORK ORDER NUMBER 6144142

TD&H ENGINEERING JOB NO. 19-004-078

Dear TSgt Cook, In accordance with your Notice to Proceed, TD&H Engineering, Inc. (TD&H) performed a limited pre-renovation asbestos inspection in Building 500 on January 7, 2020. This asbestos inspection report must be kept on site during all renovation activities.

PROJECT BACKGROUND

We understand that renovation work on the roof and in Rooms 227 and 323 of Building 500 will include removal and replacement of the air handler and ducting for ACU #1 located in room 227. The inspection was limited to those materials delineated by Mr. Scott Pickering with the Air Force.

ASBESTOS INSPECTION

The Administrative Rules of Montana (ARM) 17.74.354 require an asbestos inspection be completed for all building materials prior to scheduled renovation activities to determine if asbestos-containing materials (ACM) are present. The National Emissions Standards for

Hazardous Air Pollutants (NESHAP – 40 CFR 61) and the ARM regulate asbestos due to the respiratory hazard that airborne asbestos fibers present. The inspection was performed by Mrs. Katie Rediske of TD&H, a Montana-accredited asbestos inspector, in accordance with the Environmental Protection Agency (EPA) – Asbestos Hazards and Emergency

Response Act (AHERA) regulation 40 CFR 763. Documentation of accreditation is provided in Appendix B.

Building materials were identified, categorized, numbered, and placed into homogeneous areas (HAs) for sample collection and laboratory analysis. The number of samples collected from building materials identified in the inspection is based on the following:

PAGE NO. 2

t d h e n g i n e e r i n g . c o m

JANUARY 16, 2020

• Surfacing Materials: Three samples for spray-applied and trowel-applied surfacing materials between 10 and 1,000 square feet (SF), five samples for surfacing materials between 1,000 and 5,000 SF, seven samples for surfacing materials over

5,000 SF.

• Thermal System Insulation: Three samples from each HA of thermal system insulation, which may include boiler insulation, mudded fittings, and/or expanded vermiculite insulation.

• Miscellaneous Materials: Three samples from each HA of miscellaneous material, such as ceiling tile, sheetrock (drywall), cove-base mastic, insulation, concrete, roofing materials, floor tile and mastic, and mortar.

• Materials Less Than 10 SF: At least one sample from each HA of patching material, such as replacement floor tiles or patching plaster, or materials of less than 10 SF in total area.

Seven suspect building materials were identified during the inspection. Bulk samples were collected from these materials in accordance with the currently recognized standard protocol developed under AHERA. Bulk samples were placed into containers and shipped to CA Labs, LLC located in Baton Rouge, Louisiana, for analysis using

Polarized Light Microscopy (PLM) in accordance with EPA Method 600/R4-93-116. CA

Labs is accredited through the National Institute of Standards and Technology’s (NIST)

National Voluntary Laboratory Accreditation Program (NVLAP). The point-counting technique employed by CA Labs in the analysis of these samples has a limit of detection of approximately 0.1% precision on samples that contained asbestos at concentrations under 1%.

The membrane roof may be impacted during the renovation. However, the roof’s warranty precluded sampling until renovation is to begin. Therefore, the membrane covering the roof must be presumed asbestos-containing (PACM). This HA is shown in

Table 1 below.

Also shown in Table 1 is a Condition Ranking as detailed in the Malmstrom Air Force Base

Asbestos Management and Operations Plan. The plan lists four rankings as provided by

Mr. Robert Richards. These are detailed below:

• Ranking 1: Asbestos is damaged and poses a health hazard.

• Ranking 2: Asbestos is damaged but does not pose an immediate health hazard.

• Ranking 3: Asbestos is in good condition, does not pose a hazard, but is vulnerable to damage or wear.

PAGE NO. 3

JANUARY 16, 2020

• Ranking 4: Asbestos is in good condition and does not pose a hazard under normal conditions.

Table 1 Presumed Asbestos-Containing Building Materials

Building 500 – Malmstrom Air Force Base

Homogenous Area

Description Asbestos Content

NESHAP

Category

Condition Ranking

Location

R1.1 – Roof Membrane

PACM I 4 Roof

All other samples collected during the inspection were determined to be non-asbestos containing and were listed in the report as “None Detected.” The HAs sampled are shown in Table 2. The analytical report provided by CA Labs is provided in Appendix B, and sample locations are shown on Figure 1 in Appendix C.

Table 2

Non-Asbestos-Containing Building Materials

Building 500 – Malmstrom Air Force Base

Homogenous Area (HA) Sample Description Location (Rooms)

G1.1 Concrete Rooms 227 and 323

T1.1

Thermal System Insulation –

Fiberglass paper backing around copper pipe

Roof and Rooms 227 and 323

T3.1 Thermal System Insulation – Pipe wrap around HVAC duct; less than

10 SF

Room 227

T7.1 Heating, Ventilation, and Air

Conditioning (HVAC) Putty Room 227

T9.1 HVAC Vibration Collar; less than 10 SF Room 227

T11.1 Painted Ends on HVAC unit; less than

10 SF

Roof

Building materials assumed as asbestos-containing were placed into one of the following three categories using NESHAP criteria:

• Category I: Non-friable 1 asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products – all containing more than 1% asbestos.

• Category II: All non-friable materials containing more than 1% asbestos except those found in Category I.

1 Friable means able to be crushed or reduced to powder by hand pressure when dry, or similarly broken or pulverized mechanically.

PAGE NO. 4

JANUARY 16, 2020

• Regulated Asbestos-Containing Materials (RACM): Friable materials, Category I non-friable materials that will or may be subjected to sanding, grinding, cutting, or abrading; or Category II non-friable materials that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition/renovation operations.

According to NESHAP regulation 40 CFR 61.145 (c)(1)(i) and ARM 17.74, any RACM, or assumed Category I or II ACM, that may be rendered friable during demolition or renovation activities must be properly abated prior to beginning the project, which must be overseen by someone with training as a “competent person” per OSHA. NESHAP also requires that any demolition or renovation activities be free of visible dust or fugitive emissions from any regulated substances, including asbestos. All building materials should be adequately wetted to prevent release of particulate. Depending on the type of renovation planned, OSHA and state regulations may require personal air monitoring and the use of engineering controls.

It is a requirement under NESHAP regulations that at least ten working days prior to an asbestos abatement project, a written notification must be provided to the EPA. In the State of Montana, notification of asbestos abatement is sent to the Montana Department of Environmental Quality (MDEQ), Permitting and Compliance Division – Asbestos Control Program.

RECOMMENDATIONS

The roof membrane (R1.1) is presumed ACM. No other areas of ACM were identified.

The Category I roofing material is non-friable and, if maintained in a non-friable state, may be removed in an unregulated fashion under state and federal law in both commercial and residential settings. Any grinding, sawing, abrading, or pulverizing of the Category I PACM will render it friable and regulated (RACM).

If the PACM is handled in such a way that renders it RACM, asbestos abatement must be performed by a Montana-accredited abatement contractor. All personnel involved in the disturbance or removal of building components assumed to contain asbestos, or identified as asbestos-containing, must be trained according to the requirements set forth in 29 CFR

1926.1101 (k)(9) and 75-2-511, Montana Code Annotated (MCA).

The MDEQ considers all categories of asbestos-containing material to be “special waste” under Montana Solid Waste Rules. Transport of RACM waste is regulated and will require a permit. RACM waste must also be segregated from the general renovation waste for disposal in the designated asbestos disposal area at a local landfill that is licensed to accept asbestos-containing material. Many landfills require that all categories of ACM be segregated from the general demolition waste stream. RACM must be double-bagged or double-wrapped in 6-mil plastic sheeting; non-RACM may be single-wrapped. All material must be wrapped “burrito style” with taped seams. The name and contact information of the owner must be provided in each waste package. We recommend that contractors contact potential landfills for clarification prior to bidding or disposal.

PAGE NO. 5

JANUARY 16, 2020

Malmstrom Air Force Base Asbestos Management and Operations Plan as described above also includes recommendations for performing Operations and Maintenance (O&M) for each HA identified as ACM or PACM. The recommendations as supplied by Mr.

Richards are as follows:

• Ranking 1: Coordinate immediate removal or abatement.

• Ranking 2: Qualified personnel to control or encapsulate as soon as possible.

• Ranking 3: Schedule periodic re-inspection to ensure the area remains stable. This applies particularly to potentially friable asbestos, such as mechanical room TSI.

• Ranking 4: Schedule periodic re-inspection to ensure the area remains stable.

As listed in Table 1, the membrane roof received Condition 4 Ranking. The recommended

O&M ranking will also be Ranking 4.

LIMITATIONS

This asbestos inspection report was prepared based on information gathered during one site visit and interpretations of laboratory analytical results provided by CA Labs. The inspection report has been prepared to provide information concerning the various types of building materials that were considered suspect for containing asbestos and to inform you of which building materials tested positive.

This asbestos inspection report is intended for use by Malmstrom Air Force Base and their clients. The scope of services performed by TD&H Engineering 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.

We appreciate this opportunity to provide these industrial hygiene-consulting services to you. Should you have questions or need further clarification about information contained herein, please feel free to contact us at (406) 761-3010.

Sincerely, Katie Rediske Oran Grotbo MTA-3999 Exp. 10/18/2020 MTA-2566 Exp. 4/26/2020 Industrial Hygiene Technician Project Manager

TD&H ENGINEERING TD&H ENGINEERING

Appendices: A Documentation of Accreditat ion B Asbestos Laboratory Report C Asbestos Sample Locations

J:\2019\19-004 MAFB IH Services\INDUSTRIAL HYGIENE\078 - Building 500 Rooms 249B, 227\078_Building 500 - Asbestos Inspection Report.doc

APPENDIX A

Documentation of Accreditation

APPENDIX B

Asbestos Laboratory Report

Attn:

Customer Project:

Reference #: Date: 1/15/2020

Analysis and Method

Discussion

Qualifications

CA Labs

Dedicated to

Quality

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

NVLAP #200772-0

TDSHS #300370

CDPHE #AL-18111

LELAP #03069

Materials Characterization - Bulk Asbestos Analysis

Summary of polarizing light microscopy (PLM / Stereomicroscopy bulk asbestos analysis) using the methods described in 40CFR Part 763

Appendix E to Subpart E (Interim and EPA 600 / R-93 / 116 (Improved). The sample is first viewed with the aid of stereomicroscopy. Numerous liquid slide preparations are created for analysis under the polarized microscope where identifications and quantifications are preformed. Calibrated liquid refractive oils are used as liquid mouting medium. These oils are used for identification (dispersion staining). A calibrated visual estimation is reported, should any asbestiform mineral be present. Other techniques such as acid washing are used in conjugation with refractive oils for detection of smaller quantities of asbestos. All asbestos percentages are based on calibrated visual estimation traceable to NIST standards for regulated of asbestos. Traceability to measurement and calibration is achieved by using known amounts and types of asbestos from standards where analyst and laboratory accuracy are measured. As little as 0.001% asbestos can be detected in favorable samples, while detection in unfavorable samples may approach the detection limit of 0.50% (well above the laboratory definition of trace).

Vermiculite containing samples may have trace amounts of actinolite-tremolite, where not found be PLM should be analyzed using TEM methods and / or water separation techniques. Suspected actinolite/vermiculite presence will be indicated through the sample comment section of this report.

Fibrous talc containing samples may even contain a related asbestos fiber known as anthophyllite. Under certain conditions the same fiber may actually contain both talc and anthophyllite (a phenomenon called intergrowth). Again, TEM detection methods are recommended. CA Labs PLM report comments will denote suspected amounts of asbestiform anthophyllite with talc, where further analysis is recommended.

Some samples (floor tiles, surfacings, etc.) may contain fibers too small to be detectable by PLM analysis and should be analyzed by TEM bulk protocols.

Laboratory Analysis Report - Polarized Light

TD & H Engineering Oran Grotbo

1800 River Drive North

Great Falls, MT 59401 MAFB Building 500-Room 227

CBR20010118

A "trace asbestos" will be reported if the analyst observes far less than 1% asbestos. CA Labs defines "trace asbestos" as a few fibers detected by the analyst in several preparations and will indicate as such under these circumstances.

Quantification of <1% will actually be reported as <=1% (allowable variance close to 1% is high). Such results are ideal for point counting, and the technique is mandatory for friable samples (NESHAP, Nov. 1990 and clarification letter 8 May 1991) under 1% percent asbestos and the "trace asbestos". In order to make all initial PLM reports issued from CA Labs NESHAP compliant, all <1% asbestos results (except floor tiles) will be point counted at no additional charge.

CA Labs is accredited by the National Voluntary Accreditation Program (NVLAP) for selected test methods for airborne fiber analysis (TEM), and for bulk asbestos fiber analysis (PLM). All analysts have a college degree in a natural science (geology, biology, or environmental science) or are recognized by a state professional board in one these disciplines .Extensive in-house training programs are used to augment education background of the analyst. The group leader of polarized light has received supplemental McCrone Research training for asbestos identification. This report is not covered by the scope of AIHA accreditation. Analysis performed at CA Labs, LLC 12232 Industriplex, Suite 32 Baton Rouge, LA 70809.

Labs

A

C

Overview of Project Sample Material Containing Asbestos

Customer Project: MAFB Building 500-Room 227 CA Labs Project #: CBR20010118

No Asbestos Detected.

Glossary of abbreviations (non-asbestos fibers and non-fibrous minerals):

CA Labs

Dedicated to

Quality

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

NVLAP #200772-0

TDSHS #300370

CDPHE #AL-18111

LELAP #03069

Asbestos type / calibrated visual estimate percent

List of Affected Building

Material Types

Sample # Layer

Analysts Physical Description of

Subsample ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot - other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay)

This report relates to the items tested. This report is not to be used by the customer to claim product certification, approval or endorsement by NVLAP, NIST, AIHA LAP, LLC, or any other agency of the federal government. This report may not be reproduced except in full without written permission from CA Labs. These results are submitted pursuant to CA Labs' current terms and sale, condition of sale, including the company's standard warranty and limitations of liability provisions and no responsibility or liability is assumed for the manner in which the results are used or interpreted. Unless notified in writing to return the samples covered by this report, CA Labs will store the samples for a period of ninety (90) days before discarding. A shipping or handling fee may be assessed for the return of any samples.

Labs

A

Polarized Light Asbestiform Materials Characterization

Customer Info: Attn: Customer Project:

1/15/2020

5 day 1/8/2020

Phone # 1/7/2020

Fax # 19-004-078

Laboratory Director

Chris Williams

100% qu, ma, bi

T7.1B 1 Gray Sealant Y None Detected 100% qu, ma, bi

T7.1A 1 Gray Sealant Y None Detected

70% ce 30% qu, ma, ot

2 Yellow Fibrous Insulation Y None Detected 100% fg

T3.1 1 White Wrap on Foil N None Detected

100% qu, ma, bi

2 Yellow Fibrous Insulation Y None Detected 100% fg

T11.1 1 White Sealant Y None Detected

1800 River Drive North

Great Falls, MT 59401 Date:

Turnaround Time: Samples Received:

CA Labs

Dedicated to

Quality

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

NVLAP #200772-0

TDSHS #300370

CDPHE #AL-18111

LELAP #03069

406-761-3010 Date Of Sampling:

406-727-2872 Purchase Order #:

Oran Grotbo CA Labs Project #:

TD & H Engineering

MAFB Building 500-Room 227

CBR20010118

Homo-geneo us

(Y/N)

Asbestos type / calibrated visual estimate percent

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

Y None Detected 10% sy 90% qu, maT9.1 1 Black Sealant

Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116)

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot -other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay) Approved Signatories:

Analyst Alicia Stretz

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Daniel LaCour Senior Analyst

Labs

A

1/15/2020

5 day 1/8/2020

Phone # 1/7/2020

Fax # 19-004-078

Laboratory Director

Chris Williams

Daniel LaCour Senior Analyst

Analyst Alicia Stretz

Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116)

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot -other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay) Approved Signatories:

70% ce 30% qu, ma, ot

2 Yellow Fibrous Insulation Y None Detected 100% fg

N None Detected 70% ce 30% qu, ma, ot

T1.1D 1 White Wrap on Foil N None Detected

70% ce 30% qu, ma, ot

2 Yellow Fibrous Insulation Y None Detected 100% fg

T1.1B 1 White Wrap on Foil N None Detected

100% qu, ma, bi

T1.1A 1 White Wrap on Foil N None Detected 70% ce 30% qu, ma, ot

Asbestos type / calibrated visual estimate percent

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

T7.1C 1 Gray Sealant Y None Detected

406-761-3010 Date Of Sampling:

406-727-2872 Purchase Order #:

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

Homo-geneo us

(Y/N)

CA Labs Project #:

TD & H Engineering

MAFB Building 500-Room 227

CBR20010118

1800 River Drive North

Great Falls, MT 59401 Date:

Turnaround Time: Samples Received:

CA Labs

Dedicated to

Quality

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

NVLAP #200772-0

TDSHS #300370

CDPHE #AL-18111

LELAP #03069

Oran Grotbo

T1.1C 1 White Wrap on Foil

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Labs

A

1/15/2020

5 day 1/8/2020

Phone # 1/7/2020

Fax # 19-004-078

Laboratory Director

Chris Williams

1. Fire Damage significant fiber damage - reported percentages reflect unaltered fibers

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

4. Layer not analyzed - attached to previous positive layer and contamination is suspected

5. Not enough sample to analyze

6. Anthophyllite in association with Fibrous Talc

7. Contamination suspected from other building materials

8. Favorable scenario for water separation on vermiculite for possible analysis by another method

9. < 1% Result point counted positive

10. TEM analysis suggested

Daniel LaCour Senior Analyst

Analyst Alicia Stretz

Analysis Method: Interim (40CFR Part 763 Appendix E to Subpart E) / Improved (EPA-600 / R-93/116)

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for identification of asbestos types by dispersion attaining / becke line method.

ca - carbonate gypsum - gypsum bi - binder or - organic ma - matrix mi - mica ve - vermiculite ot -other pe - perlite qu - quartz fg - fiberglass mw - mineral wool wo - wollastinite ta - talc sy - synthetic ce - cellulose br - brucite ka - kaolin (clay) pa - palygorskite (clay) Approved Signatories:

100% qu, ma, ca

G1.1C 1 Gray Grout Y None Detected 100% qu, ma, ca

G1.1B 1 Gray Grout Y None Detected

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

G1.1A 1 Gray Grout Y None Detected 100% qu, ma, ca

Sample # Com ment

Layer

Analysts Physical Description of

Subsample

Homo-geneo us

(Y/N)

Asbestos type / calibrated visual estimate percent

Turnaround Time: Samples Received:

406-761-3010 Date Of Sampling:

406-727-2872 Purchase Order #:

CA Labs

Dedicated to

Quality

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

NVLAP #200772-0

TDSHS #300370

CDPHE #AL-18111

LELAP #03069

Oran Grotbo CA Labs Project #:

TD & H Engineering

MAFB Building 500-Room 227

CBR20010118

1800 River Drive North

Great Falls, MT 59401 Date:

Labs

A

APPENDIX C

Asbestos Sample Locations

N

FIGURE 1

LIMITED ASBESTOS INSPECTION

SAMPLE LOCATIONS

MAFB BUILDING 500 - ROOMS 227, 323 AND ROOF

X1.1-A

X1.1-A

Non-ACM Sample Location

ACM Sample Location

KEY:

T7.1-A

T7.1-B

T7.1-C

T9.1T1.1-B

T1.1-C

T3.1

FIGURE 2

LIMITED ASBESTOS INSPECTION

SAMPLE LOCATIONS

MAFB BUILDING 500 - ROOMS 227, 323 AND ROOF

G1.1-A G1.1-B

G1.1-C

T1.1-A

East Corner of Building

FIGURE 3

LIMITED ASBESTOS INSPECTION

SAMPLE LOCATIONS

MAFB BUILDING 500 - ROOMS 227, 323 AND ROOF

T11.1

T1.1-D

Roof