Attch_12_-_Design_Phase_Asbestos_Report.pdf

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

February 3, 2016

341 CES Funds

Mr. Kenneth Murphy

Building 470, Room 20

39 78th Street North

Malmstrom AFB, MT 59402

RE: Limited Pre- Renovation Asbestos Inspection

Central Heating Plant

Malmstrom Air Force Base

TD&H Project No. 15-253-087

Dear Mr. Murphy, In accordance with our verbal Notice to Proceed, TD&H Engineering (TD&H) performed a limited pre-renovation asbestos of the burner at the Central Heating Plant on January 27, 2016.

PROJECT DESCRIPTION

The asbestos inspection was performed on building materials delineated by Mr. Ron Dodd that included brick samples in the entrance to the burner in the Central Heating Plant at Malmstrom

Air Force Base. At the time of inspection, castable refractory brick that may be impacted by the renovation was observed; however, it was not accessible for sampling.

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 Ms.

Laura Hart 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

(HAs) 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 spray-applied and trowel-applied 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 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 HA of miscellaneous material, such as ceiling tile, sheetrock (drywall), cove base, electrical wiring insulation, concrete, roofing, and brick and mortar.

Patching Materials: 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.

A total of two suspect building materials were identified during the inspection. Only one was sampled due to the lack of accessibility of the second building material. Bulk samples were collected from the building in accordance with the currently recognized standard protocol developed under AHERA. Bulk samples were placed into containers and shipped to Crisp

Analytical Laboratories (CA Labs) of 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

Laboratories in the analysis of these samples has a limit of approximately 0.1% by volume.

One homogenous material, castable refractory brick, was not accessible during the inspection and thus was presumed to contain asbestos in quantities greater than 1%. The material will be classified as presumed asbestos-containing material (PACM) until it can be determined otherwise by laboratory analysis.

Table 1

Asbestos-Containing Building Materials

Central Heating Plant

Malmstrom Air Force Base

Homogenous Area

Description Asbestos Content NESHAP Category

Approximate

Area (sf) Location

Castable Refractory

Brick Assumed > 1% RACM* 1,200 Inside Burner

*This material must be assumed RACM until a certified asbestos inspector is able to touch it and verify that it is Category II.

The laboratory analysis of the sampled material indicated “None Detected” for asbestos. Sample identification and locations are shown in Appendix C.

Table 2

Non-Asbestos-Containing Building Materials

Central Heating Plant

Malmstrom Air Force Base

Homogenous Area

(HA)

Sample Description Location-Room

G2.1 Interior Brick Burner Entrance

Following receipt of the laboratory report, building materials presumed to contain asbestos were placed into one of the following three categories using NESHAP criteria:

Category I: non-friable asbestos-containing packings, gasket, resilient floor covering, 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.

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 operations.

According to the NESHAP regulation 40 CFR 61.145 (c)(1)(i) and ARM 17.74, any RACM or

Category I or II ACM that may be rendered friable1 during demolition must be properly abated prior to demolition. However, NESHAP also requires that when ACM is present, there must be no visible dust caused by general demolition activities. 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 the NESHAP regulation 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

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

Environmental Quality (MDEQ), Permitting and Compliance Division – Asbestos Control

Program.

RECOMMENDATIONS

The following recommendations for materials containing asbestos are based on our observations and the anticipated scope of renovation.

Asbestos

One area of PACM was identified. The castable refractory brick will remain PACM until testing of the material shows that it contains does not contain asbestos in quantities greater than 1%. The castable refractory brick must be assumed to be a regulated material until a certified asbestos inspector can verify that it is nonfriable, making it Category II. If the material can be identified as Category II and is maintained in a nonfriable state, the material may be removed in an unregulated fashion under state and federal law and disposed of as general construction waste.

Any grinding, sawing, abrading, or pulverizing of the Category II asbestos-containing material will render those materials friable and regulated (RACM).

Asbestos abatement for RACM and PACM must be performed by an EPA certified 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).

Asbestos removal for Category II ACM in a nonfriable “intact” condition must be overseen by a

“competent person” holding current Montana accreditation as an Asbestos

Contractor/Supervisor. If these materials are removed in a nonfriable manner, asbestos abatement permitting will not be required; however, transport of RACM is regulated and will require a permit. Limited air monitoring may be necessary for OSHA compliance.

While federal law permits disposal of Category II nonfriable ACM in a Class II landfill as general waste, MDEQ considers this material to be “special waste” under Montana Solid Waste

Rules. This may require that all categories of ACM must be segregated from the general demolition waste for disposal in the designated asbestos disposal area at the High Plains Sanitary

Landfill located north of Great Falls. 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 Montana Waste Systems be contacted for clarification prior to bidding or disposal.

If desired, TD&H can perform sampling on the castable refractory brick with a 24-hour turnaround time once the material becomes accessible. Although this might delay the project; if laboratory analysis of the material tested negative for asbestos, then abatement and disposal of asbestos-containing material would not be required.

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 the owner of the building materials that tested positive.

Most building components were visible and accessible at the time of our site visits. However, castable refractory brick was not accessible for our inspector, and additional suspect materials may be encountered during renovation. As the castable refractory brick was not accessible, it was presumed to be asbestos-containing. This asbestos inspection report is intended for use by

Malmstrom Air Force Base personnel 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 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

761-3010.

Laura Hart Oran Grotbo

MTA-4587 Exp. 4/16/2016 MTA-2566 Exp. 4/30/2016

Industrial Hygiene Technician Project Manager

Appendices: A Documentation of Accreditation

B Asbestos Laboratory Reports

C Asbestos Sample Locations

APPENDIX A

DOCUMENTATION OF

ACCREDITATION

APPENDIX B

ASBESTOS LABORATORY

REPORTS

Pace Analytical Services, Inc.

1800 Elm St. SE - Suite 1830

Minneapolis, MN 55414

(612) 607-6457

Oran Grotbo

Great Falls, MT 59401

RE: 15-253-087, MAFB Heating Plant Burner

15-253-087

Dear Oran Grotbo:

February 02, 2016

Work Order #: 1600215

Michelle Pivec For Steven D. Felton

Project Manager

Bulk Asbestos Analysis Report

The microscopy department of Pace Analytical Services, Inc. received your analytical request on January 29, 2016. The sample(s) were analyzed in the Pace Industrial Hygiene laboratory unless otherwise noted. The objective of this analysis was to determine the presence of asbestos using polarized light microscopy (PLM) and to determine the percent of asbestos and non-asbestos fibrous components by calibrated visual area estimation. Analytical results are summarized on the following laboratory report.

Methodology

Bulk asbestos analysis is conducted in accordance with the Environmental Protection Agency's (EPA) methods 40 CFR, Part 763, Ch. 1, Subpart F, Appendix A (7-1-87 Edition) and EPA/600/R-93/116. All analyses are in compliance with the quality control procedures specified by the methods. All samples are examined for homogeneity. If a sample contains more than one layer, each layer is analyzed individually. Total fibrous content is calculated for joint compound/wallboard systems by combining layer results according to their percentages of the total sample. All routine quality assurance procedures were followed, unless otherwise noted.

Remarks

This test report relates only to the items submitted for analysis.

Samples are retained at our laboratory for a period of 30 days and will be disposed of unless otherwise instructed by the client.

This report can not be copied, except in its entirety, without prior written permission from Pace Analytical Services, Inc.

We appreciate your decision to use Pace Analytical Services, Inc. for this project. We are committed to being your vendor of choice to meet your analytical needs.

If you have any questions please contact me at 612-607-6457.

Sincerely, TD&H Engineering 1800 River Drive North

Microscopist

Steven D. Felton

TD&H Engineering

01/29/16

Pace Analytical Services, Inc. (IH Laboratory)Laboratory:

Lab Contact:

Date Reported:

15-253-087, MAFB Heating Plant Burner

Michelle Pivec For Steven D. Felton Page 2 of 3

Client:

Client Reference:

Log-In:

PO Number: 15-253-087

2/2/2016

Sample No: Client ID:1600215-01 G2.1 A

Macroscopic

Description

No. of

Layers and Layer

Designator

Percent of

Total Sample

Non-Fibrous

Components*

Other Fibrous Non-

Asbestos Content

Total or Layer %

Asbestos Content

Total or Layer % Analytical

Date

Red/gray cementitious 1 100 1,3 None Detected 02/01/16None Detected

Sample No: Client ID:1600215-02 G2.1 B

Macroscopic

Description

No. of

Layers and Layer

Designator

Percent of

Total Sample

Non-Fibrous

Components*

Other Fibrous Non-

Asbestos Content

Total or Layer %

Asbestos Content

Total or Layer % Analytical

Date

Red/gray cementitious 1 100 1,3 None Detected 02/01/16None Detected

Sample No: Client ID:1600215-03 G2.1 C

Macroscopic

Description

No. of

Layers and Layer

Designator

Percent of

Total Sample

Non-Fibrous

Components*

Other Fibrous Non-

Asbestos Content

Total or Layer %

Asbestos Content

Total or Layer % Analytical

Date

Red/gray cementitious 1 100 1,3 None Detected 02/01/16None Detected

Footnotes and Definitions

* Key to Non-Fibrous Components

1 = Rock/Mineral fragments 5 = Diatoms 9 = Vinyl 13 = Spores/Pollen

2 = Mica/Vermiculite 6 = Perlite 10 = Foam/Rubber 14 = Foil

3 = Binders 7 = Adhesive/Mastic 11 = Paint

4 = Opaques 8 = Tar 12 = Other

< Less Than

> Greater Than

Reports\RPT 21.05

TD&H Engineering

01/29/16

Pace Analytical Services, Inc. (IH Laboratory)Laboratory:

Lab Contact:

Date Reported:

15-253-087, MAFB Heating Plant Burner

Michelle Pivec For Steven D. Felton Page 3 of 3

Client:

Client Reference:

Log-In:

PO Number: 15-253-087

2/2/2016

Reports\RPT 21.05

APPENDIX C

ASBESTOS SAMPLE

LOCATIONS