Asbestos Report.pdf

DEPARTMENT OF THE AIR FORCE

HEADQUARTERS 341st Missile Wing (AFGSC)

MEMORANDUM FOR: 341 CES/CEO 02 May 2024

FROM: KATIE REDISKE, NEPA MANAGER, 341 CES/CENP

SUBJECT: ASBESTOS INSPECTION SUPPLEMENTAL AMENDMENT – BUILDING 500,

ROOM 034M, MALMSTROM AFB

In August of 2016, an asbestos inspection was completed in Room 034M in Building 500 for a planned renovation project. The inspection report is titled “Limited Pre-Renovation Asbestos Inspection, Building 500, Room 34m (Work Order 40920 & 40965), Malmstrom Air Force Base, Montana, TD&H Engineering Job No. 16-059-089.” Montana regulations require that a supplemental amendment is required if: (a) the initial inspection date is greater than three years prior to the initiation of an asbestos project; (b) the scope of work at the inspected site has changed; or, (c) the inspection requirements under this rule have changed since the inspection report date. It has been more than three years since the original inspection, and the inspection requirements have also changed. The carpet is slated for replacement in the near future and was therefore reinspected.

Ms. Katie Rediske, an asbestos inspector accredited by the Montana Department of Environmental Quality (MDEQ), visited the project location on April 04, 2024, in accordance with Administrative Rules of Montana (ARM) 17.74.354(3)(a). During the reinspection, the carpet description in the report did not match; however, the original sample locations noted in the report were observed. This would indicate that the carpet appearance may have faded or otherwise changed over time and that the mastic sampled during the 2016 inspection is still in place. The carpeted area covers approximately 1,225 square feet. The 2016 laboratory analysis determined that all of the samples collected during the inspection were Non-Detect for asbestos and are therefore considered Non-asbestos containing material. Thus, no further action is required at this time regarding asbestos for the carpet mastic. No additional Homogenous Areas were observed during the site visit.

If additional materials other than the reinspected carpet will be impacted, or if the scope of the renovation is increased to impact additional building materials, please contact Katie Rediske at (406) 731-6150.

Katie Rediske, NEPA Manager MTA-2999; Exp: 03/29/2025 341st Civil Engineer Squadron Malmstrom Air Force Base

Non-Asbestos Summary Table Homogeneous Area (HA) HA Description Location Estimated Area

M4.1 Mastic under carpet Bldg 500 Rm 34M 1,225 SF

Attachments:

A. Katie Rediske Asbestos Inspector Certificate B. 2016 Asbestos Report C. Asbestos Summary for Landfill has met the requirements of Montana Administrative Rule

17.74.362 and/or 17.74.363 for accreditation in the following asbestos occupation(s) through the specified expiration date(s).

KATIE E REDISKE

K A

TI

E

R

ED

IS

K

ST

V

N

G R

EA

T

FA

LL

S M

T

MTA-3999

Asbestos Inspector 03/29/2025

MT DEQ Asbestos Control Program

BOZEMAN, GREAT FALLS, KALISPELL & SHELBY, MT | SPOKANE, WA | LEWISTON, ID | WATFORD CITY, ND | MEDIA, PA | LEHI, UT

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

August 24, 2016

341 CES Funds Attn: Mr. Kenneth Murphy Building 470, Room 20 39 78th Street North Malmstrom AFB, MT 59402-7536

RE: LIMITED PRE-RENOVATION ASBESTOS INSPECTION

BUILDING 500, ROOM 34M (WORK ORDER 40920 & 40965)

MALMSTROM AIR FORCE BASE, MONTANA

TD&H ENGINEERING JOB NO. 16-059-089

Dear Mr. Murphy, In accordance with your verbal Notice to Proceed, TD&H Engineering (TD&H) performed a limited pre-renovation asbestos inspection of the above mentioned building on August 4, 2016.

PROJECT BACKGROUND

The walls are constructed of drywall, the ceiling is 2 ft. by 4 ft. lay-in ceiling panels, and the floor is concrete covered by carpet. Renovation planned for Room 34M includes patch and repaint walls, install new carpeting and ceiling panels, and install electrical outlets in the ceiling and upper wall areas.

Only those building materials delineated by Mr. Robert Richards, a representative of the Air Force, as likely to be impacted by the renovation are included in this limited inspection.

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 or demolition 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.

PAGE NO. 2

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

AUGUST 24, 2016

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 during the inspection is based on the following:

Surfacing Materials: Three samples for 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, plaster, sheetrock (drywall), cove base, vinyl floor coverings, 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, materials of less than 10 square feet in total area.

Five suspect building materials were identified during the inspection. 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, 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.

None of the samples collected during the inspection were determined by laboratory analysis to contain asbestos and were listed in the report as "None Detected." The HAs are listed in Table 1, the laboratory report is contained in Appendix B, and sample locations are shown on Figure 1 in Appendix C.

PAGE NO. 3

Table 1 Non-Asbestos-Containing Building Materials

Building 500, Room 34M - Malmstrom Air Force Base

Homogenous Area

(HA)

Sample Description Location

C2.1 2' x 4' Ceiling Panels - White w/ Deep

Fissures & small pinholes 34M

C2.2 2' x 4' Ceiling Panels - White w/

Medium Deep, Parallel Fissures & Faint Pinholes

D1.1 Drywall 34M

S1.1 Orange-Peel Wall Texture 34M

M4.1 Carpet Mastic - Dark

Blue/Burgundy/Green Carpet

RECOMMENDATIONS

Since all of the samples were analyzed as “none detected,” no further action relative to asbestos is required before the renovation may begin.

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, which materials tested positive.

Most building components were visible and accessible at the time of our site visit.

However, additional suspect materials may be encountered during the renovation. 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.

PAGE NO. 4

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.

Sincerely, TD&H Engineering

Katie Rediske Oran Grotbo MTA-3999 Exp. 01/07/2017 MTA-2566 Exp. 4/29/2017 Industrial Hygiene Technician Project Manager

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

APPENDIX A

Documentation of Accreditation

APPENDIX B

Asbestos Laboratory Report

Customer Project:

Reference #: Date: 8/11/2016

Analysis and Method

1800 River Drive North Great Falls, MT 59401

Building 500-MAFB 16-059-089

CBR16082979

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).

CA Labs

Dedicated to

Quality

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

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: Building 500-MAFB 16-059-089 CA Labs Project #: CBR16082979

No Asbestos Detected.

Carrollton, TX 75006

Baton Rouge, LA 70809

Sample # Layer

Analysts Physical Description of Subsample

Asbestos type / calibrated visual estimate percent

List of Affected Building Material Types

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.

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:

8/11/2016 5 day 8/8/2016

Phone # Fax #

100% qu, bi

M4.1B 1 Tan Mastic Y None Detected 100% qu, bi

Non-asbestos fiber type / percent

Non-fibrous type / percent

M4.1A 1 Tan Mastic Y None Detected

406-761-3010 Date Of Sampling:

406-727-2872 Purchase Order #:

Sample # Com ment

Layer

Homo-geneo us (Y/N)

Building 500-MAFB 16-059-089

Great Falls, MT 59401 Date:

Turnaround Time: Samples Received:

Carrollton, TX 75006

Baton Rouge, LA 70809

CA Labs Project #:

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

Stanley Massett III Senior Analyst Analyst Alicia Stretz

20% fg 60% ce 20% qu, pe, ma

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.

bi - binder or - organic ma - matrix mi - mica ot -other wo - wollastinite ta - talc sy - synthetic ce - cellulose pa - palygorskite (clay) Approved Signatories:

2 Tan Ceiling Tile Y None Detected

C2.1B 1 White Surfacing Y None Detected 100% qu, bi

C2.1A 1 White Surfacing Y None Detected 100% qu, bi

M4.1C 1 Tan Mastic Y None Detected

C2.1C 1 White Surfacing Y None Detected

Carrollton, TX 75006

Baton Rouge, LA 70809

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

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

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for bi - binder ot -other wo - wollastinite

C2.2C 1 White Surfacing Y None Detected

C2.2B 1 White Surfacing Y None Detected

C2.2A 1 White Surfacing Y None Detected

20% qu, pe, ma

D1.1/S1.1A 1 White Surfaced White Compound N None Detected

100% qu, pe, bi, ca

60% ce

Carrollton, TX 75006

Baton Rouge, LA 70809

2. Fire Damage no significant fiber damages effecting fibrous percentages

3. Actinolite in association with Vermiculite

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

10% ce 90% qu, gy

Preparation Method: HCL acid washing for carbonate based samples, chemical reduction for organically bound components, oil immersion for bi - binder ot -other wo - wollastinite

2 White Drywall with Paper N None Detected

D1.1/S1.1C 1

D1.1/S1.1B 1

APPENDIX C

Asbestos Sample Locations