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					APPENDIX A
 Asbestos Assessment Report
                                                                               A.L.M. CONSULTING, LLC
May 26, 2010


Mr. Chris Cerquone
AMEC Geomatrix Consultants
1001 S. Higgins Avenue
Missoula, Montana 59801

RE:   Report of Findings for Pre-demolition Asbestos and Lead-Based Paint Inspection Services
      Former Berg Lumber Office and Shed, Lewistown, Montana
      A.L.M. Project No. 051001-AMC

Dear Mr. Cerquone:

In accordance with our April 26, 2010, Subcontract Task Order No. 2, between AMEC Earth & Environmental,
Inc. and A.L.M. Consulting, LLC (A.L.M.) performed a pre-demolition asbestos and lead-based paint (LBP)
inspection of building materials for the above referenced project. The pre-demolition inspection was performed
by Mr. Ryan McGee, a Montana-accredited asbestos inspector, accreditation number MTA-1705.

Asbestos

The asbestos portion of the inspection was completed in accordance with the Administrative Rules of Montana
(ARM) 17.74.354, Section 3 of the Montana Asbestos Work Practices and Procedures Manual (MAWPPM), and
relevant sections of the Environmental Protection Agency (EPA) – Asbestos Hazards and Emergency Response
Act (AHERA) regulation 40 CFR 763. The asbestos inspection was also completed in accordance with the EPA
National Emission Standard for Hazardous Air Pollutants (NESHAP) regulation 40 CFR 61, which requires an
asbestos inspection be completed prior to planned renovation or demolition of any structure.

A.L.M. personnel were escorted by Mr. Duane Ferdinand during the initial site visit, whereby A.L.M. evaluated
interior and exterior building materials of the former Berg Lumber office and shed on the property. Building
materials considered during the inspection included vinyl floor tile, vinyl sheet flooring, sheetrock materials,
window glazing/caulking, and asphalt roof/siding and associated underlayment. Building materials considered
suspect for containing asbestos were categorized, numbered, and placed into homogeneous areas for sample
collection and laboratory analysis, as follows:

        Surfacing Materials (S): Surfacing materials (texture) may include interior wall and/or ceiling materials, as
        well as, exterior wall décor (e.g. stucco or plaster). For surfacing/texture materials, a minimum of 3-
        samples are required for materials up to 1000 square feet (SF), 5-samples for materials between 1,000
        and 5,000 SF, and at least 7-samples for materials over 5,000 SF.

        Thermal System Insulation (T): A minimum of 3-samples from each HA of thermal system insulation,
        which may include boiler insulation, mudded fittings, and/or expanded vermiculite insulation.

        Miscellaneous Material (M): A minimum of 3-samples from each HA of miscellaneous material, such as
        floor tile, flooring mastics, vinyl sheet flooring, and roof materials.




           1316 8th Avenue, Helena, Montana 59601        Phone: (406) 461-4037     Fax: (406) 449-0382
Former Berg Lumber Office/Shed                                                      Pre-demolition Inspection Report

Based on information provided to us during the proposal process, we originally estimated a total of 15 samples,
which would need to be collected to complete the inspection. However, upon arrival to the project, we
realized that the shed was actually a former office also, which had eight building materials generally considered
suspect for containing asbestos. The office had eleven building materials present. To complete the inspection,
in accordance with current regulatory guidelines, A.L.M. personnel obtained a total of 55 samples to complete
the inspection.

Bulk material samples were collected and shipped under chain-of-custody protocol to Carolina Environmental,
Inc. (CEI) in Cary, North Carolina for asbestos analysis to confirm or deny the presence of asbestos. Based on
laboratory analysis three building materials in the office and two building materials in the shed (office) were
confirmed positive for containing asbestos in concentrations greater than one percent (>1%). Building materials,
which contain >1% asbestos, are considered as an asbestos-containing building material (ACBM) and are placed
into one of the following three NESHAP categories for abatement considerations, prior to demolition.

           Category I non-friable ACBM are generally considered as packings, gaskets, resilient floor coverings, and
           asphalt roof products, which contain greater than one percent asbestos.

           Category II non-friable ACBM are ACBM, excluding Category I non-friable ACBM, such as cement
           asbestos board and cement asbestos pipe materials, which contain greater than one percent asbestos.

           Regulated Asbestos-Containing Materials (RACM) are friable materials, Category I non-friable ACBM
           that will or may be subjected to sanding, grinding, cutting, or abrading or Category II non-friable ACBM
           that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder
           by forces acting on or expected to act on the ACBM through the course of renovations and/or
           demolition activities.

Table 1 below identifies the five building materials confirmed positive for asbestos. The table also includes the
sample identification number, the building material description, the sample location, the concentration of
asbestos, the NESHAP category, and recommended response actions for abatement prior to commencing with
demolition of the buildings located on the property.

                                    TABLE 1. Asbestos-Containing Building Materials

                                                                                           *NESHAP       Response
 Sample ID         Building Material Description      Sample Location      % Asbestos
                                                                                           Category       Action
    F2.1        Vinyl Floor Tile                   Office                      5%          Category 1    Remove
   M8.1         Window Glazing                     Office                      2%         Category I1    Remove
   M8.2         Window Caulking                    Office                     10%          Category 1    Remove
   M8.3         Window Glazing                     Shed                        2%         Category I1    Remove
    F2.3        Vinyl Floor Tile                   Shed                        2%          Category 1    Remove

In addition to the five building materials confirmed positive for containing asbestos, one additional building
material within the office was confirmed positive for containing asbestos, however, based on laboratory analysis
the sheetrock wall systems within the office was less than one percent (<1%) asbestos.

Building materials, which contain <1% asbestos are not currently regulated by the EPA or the Montana
Department of Environmental Quality – Asbestos Control Program (MDEQ-ACP). The Occupational Safety and
Health Administration (OSHA), however, does not recognize a safe concentration for asbestos, and therefore
the sheetrock wall systems may be subjected to removal prior to demolition. Please see the recommendation
section for asbestos considerations.


A.L.M. Consulting, LLC                                      Page 2                         Project No. 051001-AMC
Former Berg Lumber Office/Shed                                                 Pre-demolition Inspection Report

The following building materials were considered suspect for containing asbestos, however, based on laboratory
analysis, did not contain asbestos and are therefore are not considered for abatement prior to demolition.


    Office                                                       Shed
        F1.1 – Vinyl Sheet Flooring - Office                         M1.2 – Sheetrock Wall Materials
        F2.2 – Vinyl Floor Tile - Office                             S1.1 – Troweled-on Surfacing Materials
        M5.1– 12” x 12” Ceiling Tile                                 S2.2 – Chimney Patch Materials
        R3.1 – Green Asphalt Shingle Roof                            R3.5 – Ext. Asphalt Siding/Underlayment
        R3.2 – Red Asphalt Shingle Roof                              R3.6 – Green Asphalt Shingle Roof
        R3.3 – White Asphalt Shingle - Skirting                      R3.7 – Blue Asphalt Shingle Roof
        R3.4 – Red Asphalt Shingle – Skirting

Copies of the laboratory analytical results and chain-of-custody paperwork for asbestos-containing building
materials (ACBM) are presented in Appendix A, for review.

Lead-Based Paint

The LBP portion of the inspection was completed in accordance with the EPA Resource Conservation and
Recovery Act (RCRA) for waste characterization of potential LBP. The sampling procedures developed for this
project were completed in accordance with the “Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods”, also known as SW-846.

One composite bulk material sample of the anticipated waste stream, from the office and the shed, for this
demolition project was obtained and submitted to EMSL Analytical, Inc. for TCLP analysis. Results from the
TCLP analysis showed that the anticipated waste stream remained below the RCRA regulatory standard of 5.0
milligrams per liter (mg/L), with a lead concentration of 2.4 mg/L. No special containerization or transportation
and disposal considerations pertaining to lead-based paint will be required for the demolition project.

RECOMMENDATIONS

The asbestos inspection of the former Berg Lumber office and shed was completed to confirm or deny the
presence of asbestos in building materials scheduled to be impacted by the planned demolition. The five building
materials confirmed positive for containing asbestos in concentrations >1% are considered as ACBM, and will be
required to be abated prior to demolition.

In addition to the five building materials confirmed positive for containing asbestos, the sheetrock wall systems
within the office were also confirmed positive for containing asbestos. However, based on the laboratory
analysis, the sheetrock joint compound was the only material that tested positive, the remaining sheetrock,
paper, and tape materials did not contain asbestos. The overall concentration of the wall system, when analyzed
as a composite, was confirmed to contain <1% asbestos.

Building materials, which contain <1% asbestos are not currently regulated by the EPA or the MDEQ-ACP. The
Occupational Safety and Health Administration (OSHA), however, does not recognize a safe concentration for
asbestos, and therefore the sheetrock wall systems may be subjected to removal prior to demolition. The
following recommendations should be considered prior to scheduling the demolition project.

    1. In accordance with the EPA NESHAP regulation 40 CFR 61.145, a NESHAP Permit Application for
       demolition of the office and shed should be submitted to the Montana DEQ at least 10 days prior to
       scheduling the demolition.




A.L.M. Consulting, LLC                               Page 3                            Project No. 051001-AMC
Former Berg Lumber Office/Shed                                                   Pre-demolition Inspection Report

    2. Prior to scheduling the demolition the asbestos-containing window glazing/caulking materials and vinyl
       floor tile materials within each building shall be removed by an accredited (40-hour trained) asbestos
       contractor/supervisor, capable of completing the work in accordance with EPA, MDEQ-ACP, and OSHA
       guidelines. The asbestos waste shall be containerized appropriately and transported to a landfill capable
       of accepting Category I and Category II asbestos waste.

    3. The landfill accepting the asbestos waste should also be contacted to determine if they will require
       special disposal considerations of building materials containing asbestos at concentrations <1%. By
       regulation, materials containing asbestos at a concentration of <1% are not considered as an asbestos
       containing material; however, it has been our experience that landfills often prefer disposal of this
       material as an asbestos containing material. If the landfill requires the sheetrock materials to be treated
       separately from the demolition waste, we would recommend removing the sheetrock during the project
       to get the windows and flooring materials removed.

    4. In accordance with the NESHAP and OSHA guidelines for demolition, it is required that the demolition
       contractor complete the demolition with as little or no visible emissions as possible. Therefore, for
       similar projects it has been suggested to utilize water during demolition to keep the dust down to a
       minimum.

LIMITATIONS

The opinions and conclusions presented in this report are based on the site conditions observed and
information reviewed at the time of the inspection. No inspection can wholly eliminate uncertainty regarding
the potential for contaminants in connection with a property. The inspection was intended to reduce, but not
eliminate, this uncertainty.

Within the limitations of the agreed-upon scope of work, A.L.M. has conducted this inspection in a professional
manner in accordance with generally accepted practices, using the degree of skill and care ordinarily exercised
by environmental consultants under similar circumstances. Due to physical limitations inherent to this or any
inspection, A.L.M. does not warrant that the site is free of pollutants or that all pollutants have been identified.
As such, no absolute determination of environmental risks can be made. No other warranties, expressed or
implied, are made.

We appreciate this opportunity to provide these asbestos and lead-based paint inspection services and look
forward to assisting you on this project. If you should have questions or need further clarification about
information contained herein, please feel free to contact me at (406) 461-4037 or via e-mail at
rmcgee@bresnan.net.

Respectfully submitted,




Ryan D. McGee
Owner/Project Manager


APPENDIX A – Carolina Environmental, Inc. – Asbestos Analytical Results
APPENDIX B – EMSL Analytical, Inc. – TCLP Analytical Results
APPENDIX C – Floor Plan of Sample Areas and Inspection Photographs
APPENDIX D – A.L.M. Personnel Asbestos Accreditations and Certifications

A.L.M. Consulting, LLC                                Page 4                             Project No. 051001-AMC
                  APPENDIX A

CAROLINA ENVIRONMENTAL, INC.
  ASBESTOS ANALYTICAL RESULTS
OFFICE
SHED
             APPENDIX B

   EMSL ANALYTICAL, INC.
TCLP ANALYTICAL RESULTS
                                   EMSL Analytical, Inc.
                                    3 Cooper St., Westmont, NJ 08108
                                   Phone: (856) 858-4800             Fax: (856) 858-9551         Email: westmontleadlab@emsl.com




  Attn:    Ryan McGee                                                                                    Customer ID:               ALMC78
           A.L.M. Consulting, LLC                                                                        Customer PO:
           P.O. Box 7886                                                                                 Received:                  05/10/10 12:02 PM
           Helena, MT 59604                                                                              EMSL Order:                201005735

  Fax:         (406) 449-0382                         Phone:      (406) 461-4037
                                                                                                         EMSL Proj:
  Project:     Berg Lumber- 151001-AMC




             Test Report: Toxicity Characteristic Leaching Procedure (SW846, 1311/7420)
                                                                                                                                                                                          Lead
  Client Sample Description             Lab ID       Collected           Analyzed                                                                                                     Concentration
 Lead TCLP-01                              0001                         5/11/2010                                                                                                           2.4 mg/L
                                 Various Areas-Office/Shed




                                                                                                                                     Shannon Kauffman, Lead Lab Supervisor
                                                                                                                                     or other approved signatory


  The test results contained within this report meet the requirements of NELAC unless otherwise noted. This report relates only to those items tested. Samples received in good condition
  unless otherwise noted. Quality Control Data associated with this sample set is within acceptable limits, unless otherwise noted
  Samples analyzed by EMSL Analytical, Inc. 3 Cooper St., WestmontNJ NJ-NELAP 04653



Test Report ChmSnglePrm/nQC-7.12.0 Printed: 5/11/2010 12:08:49 PM                                                                                                                              Page 1 of 1
               APPENDIX C

FLOOR PLAN OF SAMPLE AREAS
                      AND
  INSPECTION PHOTOGRAPHS
                    INSPECTION PHOTOGRAPHS – OFFICE




Front of Office looking east                         Extra box of vinyl plastic asbestos tile stored for use




Non- asbestos vinyl sheet flooring – Main Entrance   Back of Office looking west




Asbestos-containing vinyl floor tile – Rear Office   Representative sample of 2% asbestos window glazing
                     INSPECTION PHOTOGRAPHS – SHED




Front portion of shed/office looking southwest        Photograph of chimney flue looking west




Back portion of shed/office looking east              Exterior of shed looking southeast




Floor of the shed/office – Non-ACM surfacing debris   Representative sample of 2% asbestos window glazing
present on the sandbags.
                        APPENDIX D

          A.L.M. PERSONNEL ASBESTOS
ACCREDITATIONS AND CERTIFICATIONS

				
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