Appendix_E_-_Asbestos_LBP_Report.pdf

REPAIR JOLLY PAD PROJECT NUMBER NZAS 14�0102

MALMSTROM AFB, MT TYPE A INVESTIGATIVE SERVICES

APPENDIX – E

ASBESTOS – LEAD BASED PAINT ANALYSIS

1800 River Drive North Great Falls, MT 59401 (406) 761-3010 FAX (406) 727-2872

September 4, 2015

Mr. John Kauffman GPD Engineering, PC 524 First Avenue South Great Falls, Montana 59401

RE: Pre-Renovation Lead Paint Inspection

Repair Jolly Pad

Malmstrom Air Force Base, Montana

TD&H Project No. 15-201-070

Dear Mr. Kauffman, In accordance with our Agreement for Engineering Services, TD&H Engineering (TD&H) performed a pre-renovation asbestos and lead-in-paint inspection of the Jolly Pad repair and relocation project located on Malmstrom Air Force Base (MAFB), Montana, on August 5, 2015.

The inspections were completed on concrete pavement and pavement striping paint that will be impacted by the renovation.

PROJECT DESCRIPTION

The existing Jolly Pad helicopter landing area is to be relocated to an area that is closer to support buildings than of its current location. The proposed new location will likely require repair or replacement of existing concrete pavement, new underground wiring, and removal of existing striping paint.

This asbestos and lead-in-paint inspection was limited to those building materials likely to be impacted by the renovation as described above.

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 building materials (ACBM) 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 Mr.

Oran Grotbo 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 A.

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

Surfacing Materials: three samples for surfacing materials between 1 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 homogeneous area (HA) of thermal system insulation, which may include boiler insulation, mudded fittings, and/or expanded vermiculite insulation.

Miscellaneous Materials: At least three samples from each homogeneous area of miscellaneous material, such as ceiling tile, plaster, sheetrock (drywall), cove base, vinyl floor coverings, concrete, roofing, and brick and mortar.

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

Two suspect building materials were identified during the inspection. Bulk samples were collected from the concrete pavement in accordance with the currently recognized standard protocol developed under AHERA. Bulk samples were placed into containers and shipped to Crisp Analytical, LLC (CA Labs) located in Baton Rouge, Louisiana, for analysis using Polarized Light Microscopy (PLM) in accordance with the 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 percent by volume.

RESULTS

The laboratory analysis of the concrete pavement and pavement sealer samples indicated “None Detected” for asbestos. The analytical results are listed in Table 1, and the reports provided by CA Labs are provided in Appendix B. Sample identification and locations are shown in Appendix C.

Table 1

Non-Asbestos-Containing Building Materials

Jolly Pad - Malmstrom Air Force Base

Homogenous Area (HA) Sample Description Location

G1.1 Concrete Pavement Concrete Pavement Near Proposed Jolly Pad

N1.1 Pavement Sealant Concrete Pavement Near Proposed Jolly Pad

LEAD-IN-PAINT INSPECTION

A lead-in-paint survey was conducted to identify painted components that may require specialized handling to comply with the requirements of Occupational Safety and Health Administration (OSHA) or special disposal under the Resource Conservation and Recovery Act (RCRA), which is administered by the EPA.

Paint Chips

The TD&H technician collected two paint chip samples during the August 5th inspection; one from the white striping located at the existing helicopter landing pad location and a second composite sample from red, yellow, and pink striping near the proposed landing pad. The samples were packaged and shipped under chain-of-custody protocol to CA Labs for analysis using Atomic Absorption.

Lead-Based Paint Lead-based paint (LBP) is of concern both as a source of direct exposure through ingestion of paint chips and as a contributor to lead in interior dust and exterior soil. Regulatory agencies, which have addressed lead-based paint, include the Environmental Protection Agency (EPA), Department of Housing and Urban Development (HUD), OSHA, and the Consumer Products Safety Commission (CPSC). There is no state program for lead.

HUD guidelines define lead-based paint as:

Paint in liquid form which contains 0.06%, by weight, calculated as lead metal in total nonvolatile content of the liquid paint, or

Paint already applied which tests equal to or greater than 1.0 milligrams per square centimeter (mg/cm2) when using X-Ray Fluorescence (XRF) technology, or 5,000 milligrams per kilogram (mg/kg) (0.5% by weight) when using atomic absorption spectroscopic analysis (AA).

Lead-Containing Paint (LCP) The term “lead-containing paint” is used for paint that has lead concentrations at less than the HUD guidelines or EPA disposal regulations. The OSHA standard for lead in the construction industry does not recognize a minimum safe concentration of lead. If any painted surface has any detectable level of lead, it must be presumed to present an occupational exposure to lead for OSHA-regulated construction work until a negative exposure assessment or exposure monitoring establishes otherwise.

RESULTS

Laboratory results contained in Table 2 show that the two paint chip samples were analyzed as lead-containing paint. The laboratory report is listed in Appendix D, and the sample location areas are shown in Appendix C.

Table 2

Lead-In-Paint Sample Results

Jolly Pad, Malmstrom Air Force Base

Sample

Number Location Substrate Color

Concentration (% by weight of paint)

1 Present Jolly pad Concrete White 0.0217

2 Proposed Jolly Pad Location Concrete Pink, Red, Yellow 0.0298

RECOMMENDATIONS

Asbestos

Since there were no suspect for asbestos building materials identified during the inspection, no further action is required prior to the renovation project.

Lead Work involving components covered with paint containing lead is governed by regulations of the Occupational Safety and Health Administration (OSHA). Disposal of lead, paint containing lead, or building materials covered with paint containing lead is governed by regulations of the U.S. Environmental Protection Agency (EPA). Since none of the paint chips samples were analyzed as lead-based paint, only the OSHA requirements listed below will apply.

The lead-based/lead-containing painted surfaces found in this survey are intact and if not disturbed do not present a hazard to employees involved in the renovation. If these components are disturbed in a manner such as described below, then a hazardous condition may result and will need to be addressed according to OSHA regulations.

OSHA Requirements The OSHA standard for Lead in Construction, 29 CFR 1926, does not recognize a safe level of lead in dried paint to which workers may be exposed in an occupational setting. Consequently, any disturbance to painted surfaces which contain a measurable quantity of lead must be considered as having the potential to create a risk to workers.

The OSHA standard cites a Permissible Exposure Level (PEL) of 50 micrograms of lead per cubic meter of air (μg/m3) and an Action Level (AL) of 30 μg/m3. Any amount above these levels triggers several safety and health provisions, including, but not limited to:

1. A respiratory protection program

2. Personal protective clothing and equipment

3. Changing areas including segregated storage of work and non-work clothing

4. Hand-washing facilities

5. Blood testing

6. Employee training

If an employee is performing any of the following tasks:

1. Manual demolition, dry scraping, or dry sanding

2. Heat gun applications

3. Power tool cleaning

4. Other industrial operations involving lead as specified in the OSHA standard, then all of the above-mentioned safety items must be provided to the employees. If it is found that either the AL or the PEL is being exceeded, then other safety requirements must be met.

A negative exposure assessment (NEA) should be completed on employees that are performing the work. The NEA would ensure that good work practices would reduce employee exposure to elevated concentrations of airborne lead. The NEA should be performed on the same employees, using the same methods, and using the same tools that will be used for the duration of the project.

Recommended Response Actions Any work with LBP that has the potential to expose workers to airborne lead at or above the PEL should be performed by a certified lead abatement contractor.

LIMITATIONS

This asbestos and lead-in-paint 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 or lead and to inform the owner of the building materials that tested positive for asbestos or paint containing lead.

Most paving components were visible and accessible at the time of our site visit. However, additional suspect materials may be encountered during renovation. This asbestos inspection and lead in paint survey report is intended for use by GPD Engineering, PC and their clients. The scope of services performed by TD&H Engineering, Inc., 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 and look forward to assisting you through the remainder of the project. Should you have questions or need further clarification about information contained herein, please feel free to contact us at

(406) 751-5246.

Sincerely, TD&H ENGINEERING

Oran J. Grotbo Katie Rediske MTA-2256 Exp. 4/30/2016 MTA-3999 Exp. 01/08/2016 Project Manager Industrial Hygiene Technician

Appendices: A Documentation of Accreditation B Asbestos Laboratory Report C Asbestos and Paint Chip Sample Locations D Paint Chip Laboratory Results

J:\2015\15-201 MAFB Rpr Jolly Pad\INDUSTRIAL HYGIENE\Repair Jolly Pad Report 2015.09.04.doc

APPENDIX A

DOCUMENTATION OF

ACCREDITATION

APPENDIX B

ASBESTOS LABORATORY

REPORTS

Customer Project:

Reference #: Date: 8/14/2015

Analysis and Method

1800 River Drive North

Great Falls, MT 59401 Jolley Helicopter Pad 15-201-070

CBR15083004

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).

Crisp Analytical, L.L.C.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Materials Characterization - Bulk Asbestos Analysis Laboratory Analysis Report - Polarized Light

TD & H Engineering

Labs

A

C

Discussion

Qualifications

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

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.

Baton Rouge NVLAP Lab Code 200772-0 TEM/PLM TDH 30-0370

LDEQ

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.

Overview of Project Sample Material Containing Asbestos

Customer Project: Jolley Helicopter Pad 15-201-070 CA Labs Project #: CBR15083004

No Asbestos Detected.

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

Sample # Layer

Analysts Physical Description of

Subsample

Asbestos type / calibrated visual estimate percent

List of Affected Building

Material Types

Labs

A

C

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

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.

Baton Rouge NVLAP Lab Code 200772-0 TEM/PLM TDH 30-0370

LDEQ

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)

Polarized Light Asbestiform Materials Characterization

Customer Info: Attn: Customer Project:

8/14/2015

5 day 8/7/2015

Phone #

Fax #

98% qu, ca

G1.1-B 1 Gray Plaster Y None Detected 2% ce 98% qu, ca

Asbestos type / calibrated visual estimate percent

Non-asbestos fiber type / percent

Non-fibrous type

/ percent

G1.1-A 1 Gray Plaster Y None Detected 2% ce

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)

TD & H Engineering

Jolley Helicopter Pad

15-201-070

CBR15083004

1800 River Drive North

Great Falls, MT 59401 Date:

Turnaround Time: Samples Received:

1929 Old Denton Road

Carrollton, TX 75006

Phone 972-242-2754

Fax 972-242-2798

CA Labs, L.L.C.

12232 Industriplex, Suite 32

Baton Rouge, LA 70809

Phone 225-751-5632

Fax 225-751-5634

CA Labs Project #:

Labs

A

C

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

Chris Williams Senior Analyst

Analyst Alicia Stretz

Baton Rouge NVLAP Lab Code 200772-0 TEM/PLM TDH 30-0370

LDEQ

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:

2% ce 98% qu, bi, ma

N1.1-C 1 Black Tar Y None Detected 100% qu, bi

N1.1-B 1 Black Sealant Y None Detected

2% ce 98% qu, ca

N1.1-A 1 Black Sealant Y None Detected 2% ce 98% qu, bi, ma

G1.1-C 1 Gray Plaster Y None Detected

APPENDIX C

ASBESTOS AND PAINT CHIP

SAMPLE LOCATIONS

APPENDIX D

PAINT CHIP LABORATORY

REPORTS

Crisp Analytical, L.L.C.

2081 Hutton, Suite 301 Carrollton, TX 75006 Phone 972-488-1414 Fax 972-488-8006

Labs

A

C CA Labs, L.L.C.

12232 Industriplex, Suite 32 Baton Rouge, LA 70809 Phone 225-751-5632 Fax 225-751-5634�

Atomic Absorption Lead Report

Analysis Method: Lead in Paint analyzed by Atomic Absorption (AA)/SW-846-7420;

This analysis is not covered by the scope of accreditation by NVLAP.

Sample Prep Method: Samples are dissolved in nitric acid, extracted, and analyzed on a properly calibrated AA; Absorbency curve was calculated, bandwidth corrected, and wavelength at the time of the analysis was measured and recorded.

Client Information:

TD&H, Inc.

1200 25 th

Street S

Great Falls, MT 59401

Client Project:

Jolly Helicopter Pad

15-201-070

CA Labs Project #:

CBR15083080

Date: 08/14/2015

Phone: 406-761-3010 Turnaround Time: 5 day Samples Received:08/07/2015

Fax: 406-727-2872 Attn: Purchase Order #:

NVLAP # 200772-0 Approved Signatories:

___________ TDH # 30-0370 _____________ ____________

Stanley Massett III Christopher Williams Alicia Stretz Analyst Page 2 of 2 Laboratory Director Senior Analyst Notes:

The current guidelines for lead in paint from the Consumer Products Safety Council (CPSC) is 0.06% by weight; the Housing and Urban Development (HUD) guideline is 0.5% by weight.

CA Labs is participating in ELPAT rounds sponsored by American Industrial Hygiene Association (AIHA). This test report relates only to the items tested. This test reports relates only to the items tested. NVLAP accreditation does not imply endorsement by any US Government agency. 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 condition of sale, including the company's standard warranty and limitation 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 and handling fee may be assessed for the return of any samples.

Analysis performed at CA Labs, LLC. 12232 Industriplex Blvd, Suite 32, Baton Rouge, LA 70809. Phone 225-751-5632, fax 225-751-5634, after hours mobile 225-993-3471.

Sample# Sample Concentration:

parts per million (ppm)

Weight Percent:

JP-1 217.00 0.0217

JP-2 297.64 0.0298

Lab Blank < 1.00 ---- ----

Quality Control:

Duplicate: __0.79___RPD

Spike: __99.6___% Recovery

Crisp Analytical, L.L.C.

2081 Hutton, Suite 301 Carrollton, TX 75006 Phone 972-488-1414 Fax 972-488-8006

Labs

A

C CA Labs, L.L.C.

12232 Industriplex, Suite 32 Baton Rouge, LA 70809 Phone 225-751-5632 Fax 225-751-5634�

Baton Rouge NVLAP 200772-0 TEM / PLM TDH 30-0370 LDEQ/ LELAP-03069

ATOMIC ABSORPTION

LEAD ANALYSIS

LABORATORY ANALYSIS REPORT

TD&H, Inc.

1200 25 th Street S

Great Falls, MT 59401 reference number: CBR15083080

LABORATORY ANALYSIS:

Summary of lead analysis by atomic absorption in all relevant media using the method described in

SW-846-7420. All analysts have received the necessary in-house and extramural training to perform analysis of samples for the presence of lead. A duplicate analysis is performed on greater than ten percent of all samples. A spiked concentration sample is analyzed with each sample group for instrument calibration. All analysts are required to participate in quality control analysis rounds.

Instrument calibrations are performed on a daily, weekly, and monthly basis.

This report must not be used to claim product endorsement or any agency of the U.S. Government.

This test relates only to the items described and tested herein. This report may not be reproduced except in full, without written permission by CA Labs. CA Labs is accredited by the National

Voluntary Laboratory Accreditation Program (NVLAP) for selected test methods for airborne fiber analysis (TEM) and for bulk asbestos fiber analysis (PLM). CA Labs participates in ELPAT proficiency rounds provided by the American Industrial Hygiene Association (AIHA).

This method is not covered under the scope of accreditation of NVLAP.

METHOD:

The procedure for paint chip analysis follows AOAC5.009(974.02) and SW-846-7420. The analysis of soil, wipes, and wastewater for the presence of lead is also referenced by SW-846-7420. Methodology for the analysis of lead in air samples follows NIOSH Method 7082.

Analysis performed at CA Labs, LLC. 12232 Industriplex Blvd, Suite 32, Baton Rouge, LA 70809.

Phone 225-751-5632, fax 225-751-5634, after hours mobile 225-993-3471.