A9_29001 29002 Final Hazmat Report.pdf

Pre-Demolition Asbestos, Lead-

Containing Paint, and Hazardous Materials Survey Malmstrom Air Force Base

Buildings 29001, 29002, and 29005

Great Falls, Cascade County, Montana 59402

October 15, 2024 | Terracon Project No. C4235078

Prepared for:

Jacobs Government Services Company

125 Broadway Avenue

Oak Ridge, Tennessee

Prepared by:

Terracon Consultants, Inc.

Great Falls, Montana

Facilities | Environmental | Geotechnical | Materials

October 15, 2024

Jacobs Government Services Company

125 Broadway Avenue

Oak Ridge, Tennessee 37830

Attn: Mr. Bert Tondo, Federal Subcontract Administrator

P: (865) 220-4823

E: Robert.Tondo@jacobs.com

Re: Pre-Demolition Asbestos, Lead-Containing Paint, and Hazardous Materials Survey

Malmstrom Air Force Base

Buildings 29001, 29002, and 29005

Great Falls, Cascade County, Montana 59402

Terracon Project No. C4235078

Dear Mr. Tondo:

The purpose of this report is to present the results of a limited asbestos inspection, lead-containing paint survey, and hazardous materials inventory performed on September 4, 2024, in Buildings 29001, 29002, and 29005 located on Malmstrom Air Force Base in Great

Falls, Montana. This inspection was conducted in general accordance with the client requested Scope of Services outlined in Jacobs Government Services Company’s Scope of

Work for Geotechnical, Environmental, and Hazardous Materials Investigations and

Development of Design Seismic Ground Motions, GBSD Consolidated Maintenance Facility

(CMF), Malmstrom Air Force Base, Great Falls, Montana, dated October 8, 2023. We understand that this inspection was requested in preparation for the proposed demolition of these buildings for the development of the future Consolidated Maintenance Facility (CMF).

No asbestos-containing materials or lead-containing paint were identified by laboratory analysis of samples collected during the inspection. Hazardous building materials were identified throughout the site. Please refer to the attached report for details. Terracon appreciates the opportunity to provide this service to Jacobs Government Services

Company. If there are questions regarding this report, or if any further assistance is needed, please contact Keanan Allen at (406) 453-5400.

Sincerely, Prepared By: Reviewed By:

Keanan T. Allen J. Rush Bowers, MSPH, CIH, CSP

Senior Staff Scientist Senior Industrial Hygiene Consultant

State of Montana Inspector Authorized Project Reviewer https://na3.documents.adobe.com/verifier?tx=CBJCHBCAABAAIbz573AYSeQMfSerHIr8jlvOvHpXBVoe

Pre-Demolition Asbestos, Lead-Containing Paint, and Hazmat Survey

Buildings 29001, 29002, and 29005 | Malmstrom Air Force Base iii

Certification No. MTA-6319

Table Of Contents

1.0 Introduction

1.1 Project Objective

1.2 Reliance

2.0 Building/Area Description

3.0 Inspection Procedures

3.1 Visual Assessment for Asbestos

3.2 Physical Assessment for Asbestos

3.3 Visual Assessment for Lead-Containing Paint

3.4 Physical Assessment for Lead-Containing Paint

3.5 Hazardous Building Materials

3.6 Asbestos Sample Collection

3.7 Lead-Containing Paint Chip Sample Collection

3.8 Sample Analysis

3.8.1 Asbestos Analysis

3.8.2 Lead-Containing Paint Samples

4.0 Regulatory Overview

4.1 Asbestos

4.2 Lead-Containing Paint

4.3 Hazardous Building Materials

5.0 Findings and Recommendations

5.1 Asbestos

5.2 Lead-Containing Paint

5.3 Hazardous Building Material

5.4 Inaccessible Areas and Assumed Materials

6.0 General Comments

iv

APPENDICES

APPENDIX A Table 1: Asbestos Testing Summary Table

APPENDIX B Asbestos and Lead-Containing Paint Sample Location Drawing

APPENDIX C Asbestos Laboratory Analytical Reports and Chain-of-Custody

APPENDIX D Photograph Log

APPENDIX E Table 2: Lead-Containing Paint Testing Summary Table

APPENDIX F Lead-Containing Paint Analytical Reports and Chain-of-Custody

APPENDIX G Summary of Hazardous Building Materials

APPENDIX H Certifications

Pre-Demolition Asbestos, Lead-Containing Paint, and Hazardous Materials Survey

Building 29001, 29002, and 29005 | Malmstrom Air Force Base

Montana DEQ ACM Inspection Information

The following information is provided in accordance with MDEQ ARM 17.74.354 INSPECTION

REQUIREMENTS FOR DEMOLITION AND RENOVATION ACTIVITIES (effective date of April 13, 2024).

Project Site: Buildings 29001, 29002, and 29005, Malmstrom Air Force Base Great Falls, Montana

59402

Date of Inspection: September 4, 2024

Date of Final Report: October 15, 2024

Date of Report Expiration: October 15, 2027

Scope and Purpose of Inspection1:

The scope of work included an asbestos inspection of accessible suspect materials of the building interior and exterior for the purpose of future demolition of Buildings 29001, 29002, and 29005.

No Regulated Asbestos-Containing Material (RACM) was found to be present in the building (or project area).

See Section 5.0 Findings and Recommendations and Appendices A, B, and C of the written Asbestos

Inspection Report referenced in the header above for details.

Inspector:

Keanan T. Allen

Senior Staff Scientist

State Accreditation No. MTA-6319

Expiration Date: October 20, 2024

1 The scope and purpose of the inspection and how it corresponds to the extent of the planned renovation or demolition activity.

October 15, 2024 | Terracon Project No. C4235078

Facilities | Environmental | Geotechnical | Materials i

Executive Summary Terracon Consultants, Inc. (Terracon) conducted a pre-demolition asbestos, lead-containing paint, and hazardous building materials survey on Buildings 29001, 29002, and 29005 located on Malmstrom Air Force Base in Great Falls, Montana. The purpose of this survey was to sample and identify suspect asbestos-containing materials (ACM) and lead-containing paint (LCP) and provide information regarding the identity, location, condition, and approximate quantities of ACM and LCP in the interior and exterior areas of the buildings for future demolition. Additionally, an inventory of potential hazardous building materials was developed for proper disposal prior to demolition of the building.

The survey was performed on September 4, 2024, by Mr. Keanan T. Allen, an Asbestos

Hazardous Emergency Response Act (AHERA) and State of Montana-certified Asbestos

Inspector. The inspection was performed in general accordance with the client requested

Scope of Services outlined in Jacobs Government Services Company’s Scope of Work for

Geotechnical, Environmental, and Hazardous Materials Investigations and Development of

Design Seismic Ground Motions, GBSD Consolidated Maintenance Facility (CMF), Malmstrom

Air Force Base, Great Falls, Montana, dated October 8, 2023, and the sampling protocols established in USEPA 40 CFR Part 763, Subpart E, known as AHERA. The inspection included the interior and exterior areas of Buildings 29001, 29002, and 29005.

Conclusions

Terracon collected 15 bulk samples from five homogenous areas of suspect asbestos-containing materials (ACM). No asbestos was detected in any of the samples collected.

Terracon collected three paint chip samples from three homogenous areas of suspect lead-containing paint (LCP). No lead was detected in any of the paint chip samples collected.

Terracon identified several building materials inventoried as hazardous waste for proper management and disposal prior to site demolition. Please refer to Section 5.0 and Appendix

G of this report for more information pertaining to Hazardous Building Materials.

Recommendations

No recommendations are being submitted with regards to the asbestos and lead-containing paint survey because no asbestos or lead was detected in any of the samples.

Hazardous materials should be removed and properly discarded based on their assumed hazardous containing materials prior to the demolition of the buildings. Reusing and recycling may be applicable based on their individual conditions and materials.

October 15, 2024 | Terracon Project No. C4235078

Facilities | Environmental | Geotechnical | Materials

1.0 Introduction

Terracon Consultants, Inc. (Terracon) conducted an asbestos, lead-containing paint, and hazardous building materials survey on Buildings 29001, 29002, and 29005 located on

Malmstrom Air Force Base in Great Falls, Montana. The surveys were performed on

September 4, 2024, by Mr. Keanan T. Allen, an Asbestos Hazard Emergency Response Act

(AHERA) and State of Montana-certified Asbestos Inspector.

Samples of suspect asbestos-containing materials (ACM) were collected to determine asbestos content. Paint chip samples were taken for analysis to determine the presence of lead within painted surfaces. An inventory of potential hazardous building materials was developed for proper disposal prior to demolition. The inspection was conducted in general accordance with the client requested Scope of Services outlined in Jacobs Government

Services Company’s Scope of Work for Geotechnical, Environmental, and Hazardous

Materials Investigations and Development of Design Seismic Ground Motions, GBSD

Consolidated Maintenance Facility (CMF), Malmstrom Air Force Base, Great Falls, Montana, dated October 8, 2023.

1.1 Project Objective

Terracon understands that this asbestos, lead-containing paint, and hazardous building materials survey was requested in support of the planned demolition of Buildings 29001, 29002, and 29005 for development of the future Consolidated Maintenance Facility (CMF) to satisfy requirements of the USEPA 40 CFR Part 61, Subpart M, the NESHAP. Terracon also understands that the intent of the assessment is to assist the client with communicating the presence, location, and quantity of ACM, LCP, and hazardous building materials to employees, vendors, and contractors working in the building during demolition.

1.2 Reliance

This report has been prepared for the exclusive use of Jacobs Government Services

Company (Jacobs, client) and any authorization for use or reliance by any other party

(except a governmental entity having jurisdiction over the site) is prohibited without the express written authorization of the client and Terracon. Any unauthorized distribution or reuse is at the client’s sole risk. Notwithstanding the foregoing, reliance by authorized parties will be subject to the terms, conditions, and limitations stated in the proposal, this report, and Terracon’s contract with the client. The limitation of liability defined in the terms and conditions is the aggregate limit of Terracon’s liability to the client and all relying parties unless otherwise agreed in writing.

2.0 Building Description

The scope of this assessment included the interior and exterior areas of Buildings 29001, 29002, and 29005 on Malmstrom Air Force Base in Great Falls, Montana. The structures were built sometime between 1994 and 2004 based on aerial imagery, with no known remodels or renovations. Building 29001 is an approximately 1,000-square-foot, single-story structure. It consists of a concrete foundation with no interior walls, wooden studs and support structures, and exterior sheet metal façade and roofing. There were no interior walls, only wooden studs and support structures. The interior floor was bare concrete. There was no interior ceiling, only the wooden support beams and exposed metal roofing. The building was abandoned, and no active heating, ventilating, and air conditioning (HVAC) systems or interior insulation were observed within the building.

Building 29002 is an approximately 100-square-foot, single-story structure. It consists of a gravel floor foundation, concrete masonry unit (CMU) block walls, and metal roofing. The exterior façade was CMU blocks with plaster texturing. The interior walls were bare CMU blocks. The interior floor was bare gravel over soil. The interior ceiling was exposed metal roofing. No HVAC system or insulation was observed, including inside the CMU block walls.

Building 29005 is an approximately 150-square-foot, single-story structure. It consists of a concrete foundation with a raised plywood floor, plywood interior walls, and exterior sheet metal walls and roofing. The interior walls were painted plywood, with fibrous batting between the plywood and exterior metal sheeting. The interior floor was painted plywood.

The interior ceiling was painted plywood, with fibrous glass batting found above the plywood and below the metal roofing. No HVAC was observed within the building, only a fan to exhaust air when the server was in operation. The building was insulated with fibrous glass batting found between the plywood and metal exterior siding.

3.0 Inspection Procedures

This assessment was conducted by Mr. Keanan T. Allen, an Asbestos Hazard Emergency

Response Act (AHERA) and State of Montana-certified Asbestos Inspector. A copy of the asbestos inspector’s certification is attached as Appendix H.

3.1 Visual Assessment for Asbestos

Terracon began the asbestos sampling activities with a visual assessment, including identification and inventory of readily visible and accessible Homogenous Areas (HAs) of suspect ACM. An HA consists of a material that appears similar throughout in terms of color, texture, and date of application. The assessment was conducted throughout visually accessible areas of the site. Materials identified as wood, metal, or glass were not considered suspect ACM.

3.2 Physical Assessment for Asbestos

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.3 Visual Assessment for Lead-Containing Paint

Terracon visually assessed the interior and exterior of Buildings 29001, 29002, and 29005 to identify suspect LCP on surfaces. Painted or otherwise coated surfaces that appear similar throughout in terms of color, texture, substrate, and date of application are treated as a homogeneous material for paint chip collection purposes. Painted or otherwise coated surfaces were visually assessed for evidence of distress, flaking, or peeling.

3.4 Physical Assessment for Lead-Containing Paint

A physical assessment of each selected painted surface was conducted to assess its condition. The painted surfaces were assessed as good, fair, or poor condition depending on degree of cracking, peeling, or chipping.

3.5 Hazardous Building Materials

Terracon conducted a visual inspection of readily accessible areas and made an inventory listing the recognizable and identified hazardous building materials. Terracon did not handle, open, or move any identified hazardous chemicals or waste and no sample collection was conducted. Additionally, Terracon did not open functioning or operational equipment to identify internal components that might contain hazardous materials but made assumptions based on visual assessments of the equipment according to the age and historical use of hazardous materials in these components. This inventory included the following:

◼ Polychlorinated Biphenyls (PCBs). The presence, location, and condition of suspect PCB-containing equipment such as fluorescent light ballasts and electrical transformers and equipment were assessed and discussed in this report. Such equipment was inspected for external labels indicating PCB-content, serial numbers and signs of leakage. Sampling of fluid in reservoirs were not included in this scope of work.

◼ Mercury. The presence, location, and condition of suspect mercury vapor-containing equipment such as fluorescent, mercury vapor, high intensity discharge (HID), and other lamps, as well as liquid mercury-containing equipment such as thermostats were assessed and discussed in the report.

◼ Chlorofluorocarbons (CFCs). The presence, location, and condition of suspect

CFC-containing equipment, such as refrigerators and air conditioning units were assessed and discussed in the report. Such equipment was inspected for external labels indicating CFC content and serial numbers.

◼ Heavy Metals. The presence, location, and conditions of suspected heavy-metal containing equipment such as computers, batteries, and other equipment were inventoried and discussed in this report.

◼ Paints / Solvents / Chemicals / Pesticides / Herbicides / Compressed

Gases. The presence, location, and quantity of any identified paints, solvents, chemicals, pesticides, herbicides, and compressed gasses were inventoried and discussed in this report.

◼ Radioactive Sources. The presence, location, and condition of suspected radioactive sources such as smoke detectors or tritium-gas filled exit signs were inventoried and discussed in the report.

The inventory of such materials is included in Appendix G.

3.6 Asbestos Sample Collection

Based on results of the visual observation of the interior and exterior of Buildings 29001, 29002, and 29005, bulk samples of suspect ACM were collected in general accordance with the sampling protocols outlined in 40 CFR Part 763, Subpart E. Samples of suspect materials were collected from randomly selected locations in each HA. Bulk samples were collected using wet methods, as applicable, to reduce the potential for fiber release.

Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content. Terracon collected 15 bulk samples from five homogeneous areas of suspect ACM.

A table presenting suspect material descriptions, sample locations, results, and quantities is presented in Appendix A. An asbestos sample location drawing is provided in Appendix B.

Although reasonable effort was made to inspect accessible suspect materials, additional suspect but unsampled materials could be located in walls, in voids, or in other concealed areas.

3.7 Lead-Containing Paint Chip Sample Collection

Based on the results of the visual observation, paint chip samples of painted surfaces were collected from the identified homogeneous areas from the interior and exterior areas of

Buildings 29001, 29002, and 29005. Three paint chip samples were collected from different painted substrates. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. The sampled coated surfaces are tabulated in

Appendix E.

3.8 Sample Analysis

3.8.1 Asbestos Analysis

Bulk samples were submitted under chain-of-custody (COC) to EMSL (NVLAP # 101048-0) in Cinnaminson, New Jersey, for analysis by Polarized Light Microscopy (PLM) using EPA

Method 600/R-93/116. The asbestos content, where applicable, was determined by microscopic visual estimation. The laboratory analytical report and COC are provided in

Appendix C.

During the analysis, the laboratory further separated individual layers from the materials submitted. Three additional layers were separated by the laboratory resulting in a total of

18 analyzed samples.

When the laboratory identifies discrete layers within a sample, each layer is treated as a separate material and analyzed individually. When joint compound and/or tape is applied to wallboard it becomes an integral part of the wallboard and in effect becomes one material forming a wall system (i.e., drywall system). Therefore, where a demolition or renovation impacts such a wall system and in states that allow it, a composite analysis of the wall system (overall percentage of asbestos in the joint compound, tape, and wallboard) should be conducted. If the analysis shows an asbestos content of greater than one percent and at least 160 square feet of the wall system is involved in the demolition or renovation activities

(whether planned or unplanned, during a calendar year), then the activities would be subject to the asbestos NESHAP regulation. Please note, however, that US OSHA and some state agencies also require layer analysis to be reported for drywall systems but do not accept composite analysis results; if any layer contains greater than 1% asbestos, then the entire system is considered ACM.

NESHAP requires that any analytical detection of asbestos by PLM less than 10% must be assumed to contain greater than 1% unless analysis by PLM Point Count proves that the samples contained less than or equal to 1% asbestos. No samples were re-analyzed by PLM

Point Count by EMSL.

3.8.2 Lead-Containing Paint Samples

Paint chip samples of suspect LCP were delivered under chain-of-custody to Scientific

Analytical Institute (SAI) for analysis using Atomic Absorption Spectrophotometry

(AAS)/Atomic Emission Spectroscopy-Inductively Coupled Plasma (AES-ICP) USEPA SW846

3050B/AA (7420). SAI is accredited under the American Industrial Hygiene Association

(AIHA) Environmental Lead Laboratory Accreditation Program (ELLAP) program (LAB ID

173190). Copies of the analytical reports and chain-of-custody forms are provided in

Appendix F.

4.0 Regulatory Overview

4.1 Asbestos

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure. Friable ACMs are considered regulated asbestos-containing material (RACM).

The asbestos NESHAP regulation classifies ACM as RACM, Category I nonfriable ACM or

Category II nonfriable ACM. RACM includes all friable ACMs; Category I nonfriable ACMs that have become friable or will be or have been subjected to sanding, grinding, cutting, or abrading; and Category II nonfriable ACMs that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I nonfriable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics, and asphalt roofing products that contain more than 1% asbestos. Category II nonfriable ACM are all other nonfriable materials other than Category I nonfriable ACM that contain more than 1% asbestos. Category II nonfriable ACM generally includes but is not limited to cementitious material such as cement pipes, cement siding, cement panels, glazing, mortar and grouts.

The Montana Department of Environmental Quality (MDEQ) incorporates the asbestos

NESHAP by reference in ARM Title 17, Chapter 74. The owner or operator must provide

MDEQ with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than to 160 square feet, 260 linear feet or 35 cubic feet of volume. The owner or operator must provide MDEQ with written notification at least 5 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts involving more than 10 square feet but less than 160 square feet, more than 3 linear feet but less than 260 linear feet linear feet or more than 3 cubic feet but less than 35 cubic feet of volume.

The OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work. The standard also specifies requirements for handling materials containing asbestos in concentrations less than or equal to one percent.

4.2 Lead-Containing Paint

The LCP screening was performed in general accordance with the procedures prescribed in the

EPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). Lead is regulated by the EPA and OSHA at the federal level and by MDEQ at the state level.

The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials.

Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L). EPA exempts from most RCRA requirements those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

Detectable lead quantities may constitute a lead dust hazard during renovation or demolition activities. Personnel performing renovation or demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure. OSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Currently, any proposed renovation/demolition is subject to the OSHA regulations (29 CFR 1926.62 – Lead Exposure in Construction).

Contractors and employers are required to comply with 29 CFR 1926.62. Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than 50 micrograms per cubic meter (g/m3) averaged over an eight-hour period without adequate protection. The OSHA Standards also establish an action level of

30 g/m3, which if exceeded, triggers the requirement for medical monitoring.

The OSHA standard does not define the amount of lead in paint that constitutes lead

Containing paint. A negative exposure assessment per trigger task should be conducted to determine if actual airborne levels are below the required OSHA action and permissible levels.

4.3 Hazardous Building Materials

The USEPA’s universal waste regulations are found in 40 CFR 273 Universal Wastes. The State of Montana has adopted 40 CFR 273 and does not recognize universal wastes other than those set forth by the USEPA. The universal waste regulation streamlines the hazardous waste management standards for certain categories of hazardous waste that are commonly generated by a wide variety of establishments. The universal waste regulations apply to four types of universal waste:

◼ Batteries (40 CFR 273.2)

◼ Pesticides (40 CFR 273.3)

◼ Mercury-containing equipment (40 CFR 273.4)

◼ Mercury lamps (40 CFR 273.5)

The standard helps to promote the collection and recycling of universal waste, ease the regulatory burden on retail stores and other generators that wish to collect these wastes, ease the regulatory burden on transporters of these wastes, and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

Four types of regulated participants are defined in the universal waste system: small quantity handlers, large quantity handlers, universal waste transporters, and universal waste destination facilities.

In general, materials managed as universal waste can be stored for a year and are not required to be shipped with a manifest. In addition, universal waste does not need to be counted for the purpose of determining whether the generator is conditionally exempt small quantity, small quantity, or large quantity. The universal waste regulations do require that the materials be managed in a way to prevent releases to the environment and tailors those requirements to each type of universal waste (for small quantity handlers and for large quantity handlers). Finally, the standards also include labeling, a requirement to respond to releases, and transport to a facility that is permitted or otherwise designated for receiving hazardous waste, like a recycler.

Polychlorinated Biphenyls

The USEPA regulation 40 CFR 761, Subpart R regulates disposal of PCB bulk product waste under section 761.62. Small ballasts containing less than 50 parts per million (ppm) PCB may be disposed of at a solid waste landfill. However, the effort to determine the PCB content in ballasts is burdensome, and the USEPA recommends that all PCB ballasts be disposed of at a

TSCA-approved incinerator facility. It should be noted that ballasts manufactured after 1978 do not typically contain PCBs and “No PCBs” will be stated on labels affixed to these ballasts.

If no indication is made on the ballast label, the ballast should be assumed to contain PCBs.

The PCB inspection consisted of locating suspect PCB-containing equipment, such as electrical transformers, large electrical capacitors and electrical light ballasts.

Chlorofluorocarbons (CFC)

The USEPA regulations 40 CFR 82, Subpart F under Section 608 of the Clean Air Act include requirements for the safe disposal of refrigeration and air-conditioning equipment. These requirements are designed to minimize refrigerant emissions when these appliances are disposed of. CFCs are not considered a hazardous waste if reclaimed.

Air conditioning units and other refrigeration devices will not be accepted at a solid waste landfill unless regulated refrigerants have been properly evacuated and recovered from the equipment.

Smoke/Heat Detectors

Smoke/heat detectors can be one of two kinds: photoelectric or ionizing. The ionizing variety contains a small amount of radioactive material (americicium-241).

Specific requirements do not exist for the disposal of smoke/heat detection devices. USEPA’s

Household Hazardous Waste program encourages waste reduction and minimization, but does not exert any special disposal requirements. Many manufacturers encourage the return of the devices to their facilities for salvage and recycling of components. The battery or batteries should be removed from the unit(s) prior to disposal.

Tritium Exit Signs

Exit signs that glow in the dark (without need of an external energy source such as electricity) often contain a radioactive gas called tritium. Tritium exit signs pose little or no threat to public health and safety and do not constitute a security risk. Tritium is regulated by the

United States Nuclear Regulatory Commission (USNRC) 10 CFR 31.5.

The USNRC requires proper accounting and disposal of all radioactive materials. Proper handling and accounting are important, because a damaged or broken sign could cause mild radioactive contamination of the immediate vicinity, requiring a potentially expensive clean up.

5.0 Findings and Recommendations

5.1 Asbestos

Terracon collected 15 samples from five HAs identified in the interior and exterior areas of

Buildings 29001, 29002, and 29005. Laboratory analysis reported that no asbestos was identified in any of the samples collected during this inspection.

A table presenting suspect material descriptions, sample locations, and sample results is presented in Appendix A. Asbestos sampling location drawings are provided in Appendix B.

The laboratory analytical reports of sample results and COC are provided in Appendix C. A photo log of HAs sampled in the building is provided in Appendix D.

5.2 Lead-Containing Paint

Terracon collected paint chip samples from areas suspected to be coated with lead-containing paint that may be disturbed during the demolition. Terracon collected three samples from three locations at the site. Laboratory analysis reported that no lead was identified in any of the lead paint chip samples collected during this inspection.

A table of suspect lead paint descriptions, sample location, and sample results is presented in Appendix E. Asbestos and lead-containing paint sampling location drawings are provided in Appendix B. The laboratory analytical reports of sample results and COC are provided in

Appendix F. A photo log of paint chip samples collected in the building is provided in

Appendix D.

5.3 Hazardous Building Material

Polychlorinated Biphenyl (PCB) Containing Oils

Terracon identified five light emitting diode (LED) lamps within Building 29001, with no apparent signs of any light ballasts. No light ballast-containing fixtures were identified in

Buildings 29002 or 29005. Light ballasts potentially contain PCB-containing oils. Refer to

Appendix G for additional information regarding the location and quantity of the above listed items. Testing for PCBs was beyond the scope of this survey.

Management and Disposal Considerations – PCB-Containing Oils

Prior to the start of demolition activities, all light fixtures with ballasts that will require removal will need to be examined and those not marked No PCBs must be placed in a properly labeled metal drum for management as PCB containing waste and will need to be disposed of in accordance with state and federal regulations. The contractor taking possession of any known or suspected PCB containing items for disposal must have a valid

IPA Identification Number for Regulated Waste Activity.

Mercury-Containing Items

Terracon did not observe any fluorescent strip lights or light fixtures during the survey in

Buildings 29001, 29002, or 29005 that may contain trace amounts of mercury.

Refer to Appendix G for additional information regarding the hazardous materials identified in each building.

Management and Disposal Considerations – Mercury-Containing Items

Prior to the start of demolition activities, any fluorescent light bulbs on site are required to be removed undamaged and stored in an undamaged condition until they are reused or recycled in accordance with state and federal regulations. Devices that contain mercury are required to be reused or removed and disposed of in accordance with state and federal regulations.

Battery-Containing Items

Terracon observed a server system within Building 29005. No additional battery-containing items were identified within Buildings 29001 or 29002. Devices that contain batteries are required to be reused or removed and disposed of in accordance with state and federal regulations.

Refer to Appendix G for additional information regarding the location and quantity of the above listed items.

Management and Disposal Considerations – Batteries

Prior to the start of demolition activities, batteries are required to be removed undamaged and stored in an undamaged condition until they are reused or recycled in accordance with state and federal regulations. Devices that contain batteries are required to be reused or removed and disposed of in accordance with state and federal regulations.

Ozone-Depleting Chemical (ODC)-Containing Items

Terracon identified a fire extinguisher in Building 29002 during the survey that may contain ozone-depleting chemicals. No other ODC-containing items were identified in Buildings

29001 or 29005.

Refer to Appendix G for additional information regarding the location and quantity of items containing ODCs.

Management and Disposal Considerations – ODC-Containing Items

Items which contain ODCs must be removed and disposed of according with federal, state and local regulations prior to demolition. However, if these items are recycled or reused, this option may negate the need for an EPA Identification Number.

Radioactive Source Containing Items

Terracon did not observe any items that may contain trace amounts of radioactive material in any of the observed buildings.

Refer to Appendix G for additional information regarding the location and quantity of items that may contain radioactive sources.

Management and Disposal Considerations – Radioactive Sources Containing Items

These items and materials must be removed undamaged and stored in an undamaged condition until they are disposed of according to federal, state and local regulations prior to demolition.

Miscellaneous Hazardous / Universal Waste Materials

Terracon did not identify any miscellaneous chemicals, solvents, paints, or fluids during the survey that require special disposal. These materials are not accepted at demolition debris landfills and so require special disposal or recycling.

Refer to Appendix G for additional information regarding the description, location and quantity of these miscellaneous materials.

Management and Disposal Considerations – Miscellaneous Hazardous / Universal Waste

These items and materials must be removed undamaged and stored in an undamaged condition until they are reused or recycled or disposed of in accordance with state and federal regulations.

5.4 Inaccessible Areas and Assumed Materials

Terracon did not perform sampling that required demolition or destructive activities such as knocking holes in walls, dismantling of equipment, or removal of protective coverings.

Reasonable efforts to access suspect materials within known areas of restricted access (e.g., crawl spaces) were made; however, confined spaces or areas that may pose a health or safety risk to Terracon personnel were not sampled. Sampling did not include suspect materials that could not be safely reached with available ladders or manlifts.

Although limited areas of the building were inspected, there is the potential for hidden, inaccessible materials that can be buried behind walls or underneath the concrete slab.

6.0 General Comments

The asbestos, lead-containing paint, and hazardous building materials survey sampling was conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale.

The results, findings, conclusions, and recommendations expressed in this report are based on conditions observed during our survey of the proposed demolition of Buildings 29001, 29002, and 29005 on Malmstrom Air Force Base. The information contained in this report is relevant to the date on which these surveys were performed, and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by Jacobs for specific application to their project as discussed. This report is not a bidding document. Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories, or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied, is made.

APPENDIX A

Asbestos Testing Summary Table

HA No. Material Description Sample No.

Homogenous

Area Location

Estimated

Quantity Lab Results

1 Concrete Flooring

HA1-FC2-1

Building 29001

Foundation floor

975 SF

ND

HA1-FC2-2 ND

HA1-FC2-3 ND

2 Red fire stop caulk

HA2-CA7-4

Building 29005 fan vent exhaust

1 SF

ND

HA2-CA7-5 ND

HA2-CA7-6 ND

White batt insulation with paper backing

HA3-AW1-7

Building 29005 top ceiling insulation

100 SF

ND

HA3-AW1-8 ND

HA3-AW1-9 ND

4 Brick and mortar

HA4-MA2-10

Building 29002 walls

250 SF

ND

HA4-MA2-11 ND

HA4-MA2-12 ND

5 White caulk

HA5-CA3-13

Building 29002

Caulking at wall joints

5 SF

ND

HA5-CA3-14 ND

HA5-CA3-15 ND

Key:

ND = none detected SF = square feet

APPENDIX B

Asbestos and Lead-Containing Paint Sample

Location Drawings

1392 13th Avenue Southwest Great Falls, Montana 59404

PH. (406) 453-5400

C4235078

October 2024

MDH

KTA

JRB

JRB

NA

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Sample LocationsDIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

Asbestos and Lead-Containing Paint Sample Location – Building 29001

Pre-Demolition Asbestos, Lead-Containing Paint, and Hazmat Survey

Buildings 29001, 29002, and 29005 Malmstrom Air Force Base, Great Falls, Montana 59402

Negative Asbestos Sample Location

Negative Lead Sample Location

C4235078

October 2024

MDH

KTA

JRB

JRB

NA

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Sample LocationsDIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

Asbestos and Lead-Containing Paint Sample Location – Building 29002

Negative Asbestos Sample Location

Pre-Demolition Asbestos, Lead-Containing Paint, and Hazmat Survey

Buildings 29001, 29002, and 29005 Malmstrom Air Force Base, Great Falls, Montana 59402

13-15

C4235078

October 2024

MDH

KTA

JRB

JRB

NA

Project Manager:

Drawn by:

Checked by:

Approved by:

Project No.

Scale:

File Name:

Date:

Exhibit

Sample LocationsDIAGRAM IS FOR GENERAL LOCATION

ONLY, AND IS NOT INTENDED FOR

CONSTRUCTION PURPOSES

Asbestos and Lead-Containing Paint Sample Location – Building 29005

Negative Asbestos Sample Location

Negative Lead Sample Location

4-6

Pre-Demolition Asbestos, Lead-Containing Paint, and Hazmat Survey

Buildings 29001, 29002, and 29005 Malmstrom Air Force Base, Great Falls, Montana 59402

7-9

APPENDIX C

Asbestos Laboratory Analytical Reports and

Chain of Custody

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042418485EMSL Order:

Customer ID: TERR25

Customer PO: C4235078

Project ID:

Attention: Phone:Keanan Allen (406) 209-2502

Fax:Terracon Consultants, Inc. (406) 587-9170

Received Date:1392 13th Avenue S.W. 09/05/2024 9:40 AM

Analysis Date:Great Falls, MT 59404 09/10/2024

Collected Date: 09/04/2024

Project: CMF / MAFB / Herberger's / Great Falls, Montana 59402 / C4235078

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

FC2 - 1

042418485-0001

None DetectedNon-fibrous (Other)100%Gray/Various

Non-Fibrous

Homogeneous

Building 29001 -

Foundation Floor -

Concrete Flooring

HA: 1

FC2 - 2

042418485-0002

None DetectedNon-fibrous (Other)100%Gray/Various

Non-Fibrous

Homogeneous

Building 29001 -

Foundation Floor -

Concrete Flooring

HA: 1

FC2 - 3

042418485-0003

None DetectedNon-fibrous (Other)100%Gray

Non-Fibrous

Homogeneous

Building 29001 -

Foundation Floor -

Concrete Flooring

HA: 1

CA7 - 4

042418485-0004

None DetectedNon-fibrous (Other)100%Red

Non-Fibrous

Homogeneous

Building 29005 - Fan

Vent Exhaust - Red

Fire Stop Caulk

HA: 2

CA7 - 5

042418485-0005

None DetectedNon-fibrous (Other)100%Red

Non-Fibrous

Homogeneous

Building 29005 - Fan

Vent Exhaust - Red

Fire Stop Caulk

HA: 2

CA7 - 6

042418485-0006

None DetectedNon-fibrous (Other)100%Red

Non-Fibrous

Homogeneous

Building 29005 - Fan

Vent Exhaust - Red

Fire Stop Caulk

HA: 2

AW1 - 7- Insulation

042418485-0007

None DetectedNon-fibrous (Other)20%Glass80%White

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

White Batt Insulation

HA: 3

AW1 - 7- Backing

042418485-0007A

None DetectedNon-fibrous (Other)25%Cellulose75%Brown/Black

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

Paper Backing

HA: 3

AW1 - 8- Insulation

042418485-0008

None DetectedNon-fibrous (Other)20%Glass80%White

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

White Batt Insulation

HA: 3

AW1 - 8- Backing

042418485-0008A

None DetectedNon-fibrous (Other)25%Cellulose75%Brown/Black

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

Paper Backing

HA: 3

AW1 - 9- Insulation

042418485-0009

None DetectedNon-fibrous (Other)10%Glass90%White

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

White Batt Insulation

HA: 3

AW1 - 9- Backing

042418485-0009A

None DetectedNon-fibrous (Other)25%Cellulose75%Brown/Black

Fibrous

Homogeneous

Building 29005 - Top

Ceiling Insulation -

Paper Backing

HA: 3

Initial report from: 09/11/2024 09:50:46

Page 1 of 2ASB_PLM_0008_0002 - 2.31 Printed: 9/11/2024 9:50 AM

EMSL Analytical, Inc.

200 Route 130 North Cinnaminson, NJ 08077

Tel/Fax: (800) 220-3675 / (856) 786-5974 http://www.EMSL.com / cinnasblab@EMSL.com

042418485EMSL Order:

Customer ID: TERR25

Customer PO: C4235078

Project ID:

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

MA2 - 10

042418485-0010

None DetectedNon-fibrous (Other)100%Gray/Tan

Non-Fibrous

Homogeneous

Building 29002 -

Walls - Brick & Mortar

HA: 4

MA2 - 11

042418485-0011

None DetectedNon-fibrous (Other)100%Gray/Tan

Non-Fibrous

Homogeneous

Building 29002 -

Walls - Brick & Mortar

HA: 4

MA2 - 12

042418485-0012

None DetectedNon-fibrous (Other)100%Gray/Tan

Non-Fibrous

Homogeneous

Building 29002 -

Walls - Brick & Mortar

HA: 4

CA3 - 13

042418485-0013

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Building 29005 -

Caulking at Wall

Joints - White Caulk

HA: 5

CA3 - 14

042418485-0014

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Building 29005 -

Caulking at Wall

Joints - White Caulk

HA: 5

CA3 - 15

042418485-0015

None DetectedNon-fibrous (Other)100%White

Non-Fibrous

Homogeneous

Building 29005 -

Caulking at Wall

Joints - White Caulk

HA: 5

Analyst(s)

Amiri Lewis (6)

Rebecca Kelly (12)

Samantha Rundstrom, 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. Cinnaminson, NJ NVLAP Lab Code 101048-0, AIHA LAP, LLC-IHLAP Lab 100194, PA ID# 68-00367, LA #04127

Initial report from: 09/11/2024 09:50:46

Page 2 of 2ASB_PLM_0008_0002 - 2.31 Printed: 9/11/2024 9:50 AM

O r d e r I D

P a g e

O f

APPENDIX D

Photograph Log

Photo #1 HA1-FC2-1: Building 29001:

Concrete flooring.

Photo #2 HA2-CA7-4: Building 29005: Red fire stop caulk.

Photo #3 HA3-AW1-7: Building 29005: White batt insulation with paper backing.

Photo #4 HA4-MA2-10: Building 29002: Brick and mortar.

Photo #5 HA5-CA3-13: Building 29002: White caulk.

Photo #6 LCP #1: Building 29001: Exterior beige paint.

Photo #7 LCP #2: Building 29005: Interior white paint.

Photo #8 LCP #3: Building 29005: Door brown paint.

APPENDIX E

Lead-Containing Paint Testing Summary Table

Sample ID. Description Mass (g) Concentration

(ppm)

Concentration

(% by weight)

LCP #1

Building 29001 exterior beige paint

0.0291 <55 <0.0055

LCP #2

Building 29005 interior white paint

0.0324 <49 <0.0049

LCP #3

Building 29005 door brown paint

0.0794 <50. <0.0050

Key:

g = grams LCP = Lead-Containing Paint ppm = parts per million

APPENDIX F

Lead-Containing Paint Analytical Reports and

Chain-of Custody

Analysis for Lead Concentration in Paint Chips by Flame Atomic Absorption Spectroscopy

EPA SW-846 3050B/6010C/7000B

Lab Order ID:Attn: 10061864Customer: Terracon Consultants Inc.

1392 13th Ave SW Great Falls , MT 59404

Analysis:

Date Received:

Keanan Allen

PBP

09/06/2024

Project: CMF (C4235078) Date Reported: 09/13/2024

Sample ID

Lab Sample ID

Description

Lab Notes

Concentration (ppm)

Concentration (% by weight)

Mass (g)

LCP#1

10061864_0001

Building 29001 exterior beige paint <550.0291 <0.0055%

LCP#2

10061864_0002

Building 29005 interior white paint <490.0324 <0.0049%

LCP#3

10061864_0003

Building 29005 door brown paint <50.0.0794 <0.0050%

Disclaimer: Unless otherwise noted blank sample correction was not performed on analytical results. Scientific Analytical Institute participates in the AIHA ELPAT program. ELPAT Laboratory ID: 173190. This report relates only to the samples tested and may not be reproduced, except in full, without the written approval of SAI. Analytical uncertainty available upon request. The quality control samples run with the samples in this report have passed all EPA required specifications unless otherwise noted. RL: (Report Limit for an undiluted 50ml sample is 4µg Total Pb).

Athena Summa (3)

Analyst Approved Signatory

Page 1 of 1L-F-021 r17 2/13/2027 Scientific Analytical Institute, Inc. 4604 Dundas Dr. Greensboro, NC 27407 (336) 292-3888

Scientific Analytical Institute 4604 Dundas Dr. Greensboro, NC 27407

Phone: 336.292.3888 Fax: 336.292.3313

Lab Use Only } i& I _ C .-1,J I

Lab Order ID: -1-->.DY.,<...:=......c\LJ:s<.L-l)V::'\......_~ Client Code: _____ _ www.sailab.com lab@sailab.com

Contact Information Company Name: C·

Address:

Contact:

PO Number: C,Y-~-3 S-t:> 7 8

Project Name/Number: C/14 F {Co/2350

Lead Test T Paint Chips by Flame AA

(PBP)

Wipe by Flame AA

PBW)

Sample ID#

L/'/J #I I cP #:l.

LCP #3

Soil by Flame AA 0

BS)

Air by Flame AA

BA)

Other 0

Description/Location

/k/jt:l,-AA--2. Cf 001 Gk,;.. 1.,.~. .na,.J l?""·/.J/!u, ;Z!CX>5 -r / - ~~ ..,.,,/

&_· L/A... _d ~, ~ -,~ /)t><>'r /Jr(';.JA o.,;,;/- V I

Billin /Invoice Information Company: ~.....-~ ~4 Address: 31Z r3'"- . SW

Contact: 'htb1 f,A.J,o-/ Phone 0: '/06-L/53·9-fOO

Turn Around Times 3 Hours D 72 Hours

6 Hours D 96 Hours

12 Hours D 120 Hours

24 Hours D 144+ Hours

48 Hours D

Volume/ Area Comments

- --. ,,4// ~~ co&~,;, 40"'t A- ½K z. .-n,~$

I

A.rr.eote d ~

.n Re\eC'-t: ~-c:::::i

Total Number of Samples '3 nf /

D D

D

APPENDIX G

Summary of Hazardous Building Materials

October 15, 2024 | Terracon Project No. C4235078

Quantity Units Quantity Units

ODC-Containing Items Quantity Units

Quantity Units

Quantity Units

Other (describe)

Metal-Containing Items Air Conditioners/Heat Pumps

Capacitors…