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.
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
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
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
Sample ID Building Material Description Sample Location % Asbestos
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.
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.
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.
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
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
Ryan D. McGee
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
CAROLINA ENVIRONMENTAL, INC.
ASBESTOS ANALYTICAL RESULTS
EMSL ANALYTICAL, INC.
TCLP ANALYTICAL RESULTS
EMSL Analytical, Inc.
3 Cooper St., Westmont, NJ 08108
Phone: (856) 858-4800 Fax: (856) 858-9551 Email: email@example.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
Project: Berg Lumber- 151001-AMC
Test Report: Toxicity Characteristic Leaching Procedure (SW846, 1311/7420)
Client Sample Description Lab ID Collected Analyzed Concentration
Lead TCLP-01 0001 5/11/2010 2.4 mg/L
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
FLOOR PLAN OF SAMPLE AREAS
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.
A.L.M. PERSONNEL ASBESTOS
ACCREDITATIONS AND CERTIFICATIONS