HomeMy WebLinkAboutH4 Asbestos Disposal Commission Memorandum
REPORT TO: Honorable Mayor and City Commission
FROM: Rick Hixson, City Engineer
Chris Kukulski, City Manager
SUBJECT: Request to Dispose of Asbestos Contaminated Soil in the City Landfill
MEETING DATE: August 7, 2006
BACKGROUND: The City of Bozeman has received a request from TriMedia Consultants
on behalf of Story Distributing to accept 10 to 12 cubic yards of asbestos contaminated soil at the
City landfill. The source of the soil is an abandoned warehouse property on the east side of
Wallace Avenue near its intersection with Church Street. Attached to the request was a copy of
the May 2005 investigation report performed by Maxim Technologies, Inc., which summarizes
their findings regarding concentrations and extent of contaminants on the subject site, Tracts 3 &
4 of the Story and Church Street Properties site. The report indicated that in one of the
investigated grid sections the soil showed an asbestos level above the regulated threshold of 1%
(2%). While the request from TriMedia was for disposal of 10 to 12 cubic yards, the Maxim
report indicated that the actual quantity could be as much as 140 cubic yards.
Since Commission Resolution No. 3830 states in Section 2 "To extend the life of the City of
Bozeman Landfill Class II Cell for the convenience of the City of Bozeman residents, the City of
Bozeman Landfill shall be open to City of Bozeman non-commercial residents only for the
purpose of disposing of acceptable household waste", and since Commission Resolution No.
3860 states that "WHEREAS, the Bozeman landfill does not accept asbestos, unless specifically
approved by the Bozeman City Commission..." it is necessary that we bring this request before
the Commission for a decision.
RECOMMENDATION: From the perspective of volume 10 to 12 cubic yards is very minor.
My concern is that the soil investigation indicated that it could be as much as 140 cubic yards in-
situ, which means in place. It could be even more than that once excavated. 140 plus cubic yards
is no longer a very minor amount. Further, accepting this waste from a private commercial
enterprise is at variance with the policy stated in Commission Resolution 3830_ Therefore, we
are recommending not accepting the asbestos contaminated soil as requested.
FISCAL EFFECTS: The Solid Waste Superintendent has suggested that if the Commission
chooses to accept the contaminated soil, a fee of$100.00 per cubic yard be assessed. We further
suggest that should the Commission agree to allow the waste to be accepted at the landfill, a limit
of 12 cubic yards be imposed, and that all Federal, State and Local regulations regarding
handling and disposal of Asbestos Contaminated Soil be strictly enforced.
ALTERNATIVES: As suggested by the City Commission.
Respectfully submitted,
Rick Hixson, City Engineer Chris A. Kukulski, City Manager
Attachments: Letter from TriMedia
Additional Asbestos Soil Investigation,
Maxim Technologies
Report compiled on August 1, 2006
TriMedia 8645 BozoHuffine Lane,Suite 3
Bozeman,MT 59718
406-556-0800
Consultants 406 556-0805 Fax
www.trimedia consuifants,con
Environmental • Health&Safety • Planning/GIS . Industrial Hygiene Engineering
July 25, 2006
Mr. Chris Kukulski, City Manager
City of Bozeman
PO Box 1230
Bozeman,Montana 59771-1230
Re: Disposal ofAsbestos-Contaminated Soil-Story Distributing Company's South Wallace Warehouse
Property Excavation Project in Bozeman, Montana
TriMedia Project Number 26-079
Dear Mr. Kukulski:
On behalf of the Story Distributing Company (Story Distributing), TriMedia Consultants (TriMedia) is
requesting authorization from the City of Bozeman to dispose of asbestos-contaminated soil at the City of
Bozeman Landfill. The source of the soil is an abandoned warehouse property owned by Story Distributing
and is located on the east side of South Wallace Avenue at the intersection of Wallace and Curtiss Street, in
Bozeman,Montana.
The impacted soil has resulted from historical asbestos ore handling and stockpiling activities on the site and
neighboring sites. You may recall the recent 2003 cleanup of the property to the east and northeast now being
developed as the Bozeman City Library site. As with the library site, the soil on the Story Distributing
property contains asbestos as raw mineral fragments. At the request of the City of Bozeman, Maxim
Technologies(Maxim)conducted an Additional Asbestos and Soil Investigation of Tracts 3 and 4 of the City
of Bozeman Story and Church Streets property. Details of this investigation were contained in a report dated
May 2, 2005. forwarded to Mr. James Goehrung, Superintendent of Facilities and Lands at the City of
Bozeman. A copy of the report has also been enclosed for ease of reference, while a brief summary of
sampling methodology and results is provided herein.
During their investigation in March 2005, Maxim established a sampling grid covering Tracts 3 and 4
(property to the east of the Story Distributing site)and the Story Distributing site,the latter which was divided
into eight grid squares. Each grid square was 50 feet by 50 feet in size. Within each grid,Maxim collected
two composite soil samples, one of surface soil and the other of subsurface soil. Surface samples were
collected from visually impacted soil and not collected if visual impact at that location were not noted.
Surface samples consisted of five sub-samples collected and blended into a single composite sample for each
grid square. For each subsurface sample,three sub-samples were collected from depths of eight, 16,and 24
inches below ground surface(bgs). In the absence of visual surface impacts,test pits were dug in the center
of each grid square.
a professional service company
Marquette;Michigan Ann Arbor,Michigan Ft.Atkinson, Wisconsin Bozeman,Montana
Mr. Chris Kukulski,City Manager
City of Bozeman
July 25, 2006
Page 2
Of the eight grid squares sampled on the Story Distributing property, visible signs of surface asbestos
contamination were not noted. However, the test pit for the specific sampling grid called CB-8A revealed
visible asbestos ore which appeared to start at about six inches bgs. Laboratory analysis of a composite
sample collected from sub-samples located within the test pit at eight, 16, and 24 inches bgs revealed the
presence of two percent tremolite asbestos. Test pits from elsewhere on the Story Distributing property did
not reveal the presence of buried asbestos ore. Trace amounts of tremolite asbestos were noted in surface soil
samples elsewhere onsite though not at levels exceeding applicable regulatory limits.
TriMedia proposes to excavate the test pit location within the grid CB-8A on the Story Distributing property
to a depth of 24 inches bgs and dispose of the asbestos-contaminated soil. We estimate the soil to be removed
will be approximately 10-12 cubic yards. The soil type is brown clayey sand with rocks and cobbles,pieces
of asbestos ore,and wire.
Based on current knowledge of site conditions and analytical results of the proposed waste, it is TriMedia's
professional opinion that the soils offered for disposal are the result of a one-time occurrence and are
consistent with established Landfill acceptance criteria for regulated asbestos-containing material. Please
note the soil contains friable asbestos and therefore requires applicable landfill acceptance.
TriMedia requests that upon review of the submitted disposal package,you contact me with written approval
or denial to dispose of waste material at the City of Bozeman Landfill. Included in this correspondence,
please provide information on the planned use and corresponding disposal charge per ton of waste material.
TriMedia is currently coordinating plans to excavate and transfer the waste material to the City of Bozeman
Landfill. Should you have any questions regarding this disposal request,please do not hesitate to contact me
at 556-0800.On behalf of the professional staff at TriMedia,thank you for your assistance with this important
regulatory matter.
Sincerely,
TriMedia Consultants
r
ott D. Jagigerrrf�HMM
Principal Environmental Scientist
SDJ/msw/tla/mlh
Enclosure: Maxim Technologies Additional Asbestos Soil Investigation Report, Dated May 2, 2005
cc: Mr. Doug Alexander, Story Distributing Company
TriMedia File 26-079
Consulting Engineers&Environmental Scientists
MAXColumbus Center IM1601 Second Avenue North,Suite 116
l E C H N O L U G I E S Great Falls,Montana 59401
A DIVISION OFTE KATECH,INC. Telephone:(406)453-1641
Fax:(406)771-0743
E-mail:maximgl@mt.ne1
May 2, 2005
Mr.James Goehrung
Superintendent of Facilities and Lands
City of Bozeman
P.O. Box 1230
Bozeman, Montana 59771
RE: Additional Asbestos and Soil Investigations —Tracts 3 and 4
City.of Bozeman Story and Church Streets Property
Bozeman, Montana
Maxim Project No. 4550707.1 10
Dear Mr. Goehrung:
Maxim Technologies (Maxim) has completed the additional asbestos soil investigation at the Story and
Church Street Properties — Tracts 3 and 4 - in Bozeman, Montana, as noted in Maxim's Proposal to
Perform Additional Asbestos and Soil Investigations in Tracts 3 and 4, dated February 18, 2005. This report
summarizes our observations during the site investigation and the analytical results of the composite
asbestos samples collected and the volatile petroleum hydrocarbons (VPH), extractable petroleum
hydrocarbons (EPH), pesticides, herbicides, pH corrosivity, and Resource Conservation.and Recovery
Act (RCRA) metals in soil collected from the test pits of Tract 3. One test pit within the Story and
Church Street Properties did indicate a regulated quantity of asbestos-in-sail; none of the analytical
results indicated a regulated quantity of VPH, EPH, pesticides, herbicides, pH corrosivity, and/or RCRA
metals.
Maxim appreciates the opportunity to have been of service on this project. If you have any questions
regarding the information presented in this report, or if we can be of additional service, please contact
us at (406) 453-1641.
Keith Cron, M.S.
Industrial Hygienist
Maxim Technologies
TABLE ��� o���U�^���R�^��
" ��=~°~°~ �~" CONTENTS
" ~"
EXECUTIVESUMMARY......................................... ..............................................................................l
PROJECTBACKGROUND....................................................................................................................1
SITEVISIT..................................................................................................................................................2
METHODS .................................................................................................................................................3
Asbestos Investigation-Tracts ] and 4.... -.........------- ..........-......... ...... ........... ................ - ...........�3
SoilInvestigation-Tract 3...................... .................. ......... ............. ..... ............ - .................... - ...................4
f-E8{JLI8 AND DISCUSSION.................. ................... .......................................... ................................5
Asbestos Investigation-Tracts 3 and 4........... .........- .......... - ..........................................................--...........5
TestPit Soil Data...... ..........-........... ......... ............-................ ..................... ...... ......... ............ ......... ......5
AsbestosSoil Analysis Data....... ........ -........... - ........ ....... ....... -..................................... .......................5
Soil ]nvestigudoo-Tract 3..... .............. ........... ......... .............................. .................................................. ........6
TestPit CB-0 Field Dxta-..................-~ .......... - ........... -......... ....... ........ ................... ....................6
TestPit CB-\0 Analytical Data.........--.......... ....... ...........................................................................................6
EEC8--'^._-....----.'..---~...---..._--..---.--...--'....--'~.--..,-----^^----.9
LIMITATIONS.........................................................................................................................................ll
TABLES
Table t Summary o{Asbestos-Containing Soils................ ................................. ......................................................S
Table Dk Summary of Soil Investigation Analytical Results............................................................................ .......7
���������U����K���
��" " ~�"���"��""�^�
Appendix A' Figures
/kppendkB: Asbestos Inspector Accreditation
Appendix C: Ioyt Pit Log Field Data
Appendix D: Analytical Results
ADDITIONAL ASBESTOS S®IL,
INVESTIGATION
Tracts 3, 4, and Story Distributing Property
r
Ted-inolog 'es
A[ET ftA TECH COMPANY
HOQILI011d1 /"VnucaLVA Allu Oun 111YC.]L1rAL1U11
May 2, 200S Bozeman, Montana
Page I
EXECUTIVE SUMMARY
Maxim has conducted the additional asbestos and soil investigation at the Story Distributing and Church
Street properties —Tracts 3 and 4 - in Bozeman, Montana, as noted in the Maxim proposal to perform
additional asbestos and soil investigations in Tracts 3 and 4 dated February 18, 200S. The analytical
results for the composite asbestos soil samples noted one sample to be asbestos-containing waste
material (ACWM); this sample was collected and composited from the Story Distributing property test
pit location 8A. (See Appendix A: Figure I.) Additionally, one analytical result from the surface of a
visual suspect asbestos contaminated area was collected from grid location 8A.
Two additional samples were found to contain "trace" amounts of asbestos that were located within the
Church Streets properties —Tract 4; they were collected from test pits I C and 3A. Additionally, a field
quality control sample was collected from test pit 3A but labeled 7C (a continuation of the gridded
system located within the Story Distribution properties); this sample was found to contain "trace"
amounts of asbestos. The Environmental Protection Agency (EPA) National Emission Standard for
Hazardous Air Pollutants (NESHAP) threshold for asbestos-containing materials (ACM) and/or asbestos-
containing waste materials (ACWM), as governed by 40 Code of Federal Regulation (CFR) Part 61
Subpart M, and as referenced in Administrative Rules of Montana (ARM) 17.74.102, that defines a
material to contain asbestos if it contains more than one percent asbestos.
None of the target analytes included in the soil investigation of Tract 3 were present at or above the
Preliminary Remediation Goals (PRG's) as noted by EPA Region 9.
PROJECT BACKGROUND
At the request of the City of Bozeman (City), Maxim Technologies (Maxim) has conducted a limited soil
investigation in and surrounding a former asbestos ore waste dump on the south end of a parcel of
property owned by the City of Bozeman located between Main Street and Story Street in Bozeman,
Montana (Appendix A: Figure 2). Maxim understands that in past operations surface soils were graded
with a bulldozer, and in that grading some asbestos-impacted surface could have been buried to a
maximum depth of approximately 24 inches. Most of the area where this is believed to have occurred is
in Tract 4, though there is a small area on neighboring private property owned by Story Distributing
where surface soils potentially impacted with asbestos ore were used to fill a surface depression. In
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 2
addition, Maxim investigated an area in adjacent Tract 3 that has sparse vegetation and was suspected of
having been impacted by petroleum hydrocarbons, pesticides, herbicides, and/or heavy metals. This
work follows an initial site investigation in Tract 4 conducted by Maxim in August 2004.
The objectives of this site investigation were I) to determine if gross asbestos contamination is present
in the area of the former ore dump in Tract 3 and 4 and on the adjacent private parcel owned by Story
Distributing (Figure 2), and 2) determine if there is gross contamination in the small area identified
within Tract 3 (Figure 2).
SITE VISIT
On March 10, 2005, Mr. Donnie McCurry, a Maxim Senior Environmental Technician; Mr. Mike Ellerd, a
Maxim Senior Project Manager; ELM utility locate; and Al Aldrich Ready Mix Operator, met on site.
Prior to any work starting, the site specific Health and Safety Plan (HASP) was reviewed and signed by
everyone on site. During the test pit excavation, employee exposure was measured for asbestos fibers
using National Institute of Occupational Safety and Health (NIOSH) Method 7400. Task#1 consisted of
establishing the sampling grid on Tract 4 and of the Story Distributing property. Task #2 consisted of
excavating test pits and collecting soil samples within the Tract 4 gridded system. (See sampling grid in
Appendix A: Figure 3.) The samples were collected in chronological order for Tract 4 test pits on
3/10/05 in the following sampling grid locations: I A, I B, and I C; 2B, 2C, 2A; 3A, 3B, 3C, and 3D (past
east fenceline between rows two and three); and 4E, 4D, and 4C (past east fenceline between rows two
and three). The excavation equipment was decontaminated at the end of the day. Additionally, Maxim
personal performed additional site observations within a Montana Department of Environmental Quality
(MDEQ) fenced-in area onsite; these observations, conducted with a shovel, did not indicate any suspect
material.
On March 11, 2005, additional samples were collected in chronological order for Tract 3 test pits by Mr.
McCurry in the following sampling grid locations: 3A, 3B, and 3C (west of sample grid I A, I B, and I C);
4A and 413 (west of sample grid I A, I B, and I C). It should be noted that Maxim was instructed by Mr.
Goehrung not to submit the samples past the east fenceline between Rows Two and Three as
instructed; rather, Maxim was to establish a continuation of the sampling grid to the west of the original
sampling grid. The numbering was thus continued with the following sampling grid numbers: 3A, 3B, and
3C; 4A and 4B. Therefore, the only analytical results shown are from those submitted for Tract 3 for
the respective test pits. The test pit excavation continued to sampling grid location BA; it was within
this test pit excavation that obvious signs of suspect asbestos ore were visible. Throughout this test pit
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 3
excavation, the excavation was misted with water to minimize aerosolization of asbestos fibers.
Decontamination of equipment was performed after test pit excavation 8A. Additional samples were
collected in chronological order from the Story Distribution property test pits on March 3, 2005, in the
following sampling grid locations: 8B; 7A, 7B, 7C; and 6B and 6A. Decontamination of equipment was
performed after the conclusion of the excavation from sampling grid location 6A in the Story
Distributing property prior to concluding the day with single test pit sampled from within the Tract 3
vegetative stressed area.
METHODS
The asbestos investigation was designed to document any residual surficial suspect asbestos-containing
material present in soils and document any composited subsurface asbestos-containing material present
to a depth of two feet both within Tracts 3 and 4 and the Story Distributing property as described by
Mr. Tom BLANK of the Montana Department of Environmental Quality (MDEQ) in a telephone
conversation with Mr. Peter Klevberg of Maxim on BLANK, 2005, Additionally, Maxim collected a
surficial soil sample and composited subsurface sample within a visually (sparsely vegetated) suspect
property area for ecological toxicants. Soils were visually classified and data recorded in a field
notebook.
Asbestos Investigation —Tracts 3 and 4
The asbestos component of this investigation was conducted in accordance with the National Emissions
Standards for Hazardous Air Pollutants (NESHAP) and ARM 17.42.304. The inspection was performed
using applicable portions of the currently recognized standard protocol developed for schools under the
Asbestos Hazard Emergency Response Act (AHERA), as promulgated in Title 40, Code of Federal
Regulations, Part 763,.Subpart E, and incorporated in ARM 17.42.304. Mr. Donnie McCurry, a Maxim
asbestos inspector licensed by the Montana Department of Environmental Quality (MDEQ), conducted
and oversaw all field activities. A copy of his accreditation is included in Appendix B.
Maxim established an initial sampling grid covering adjoining portions of Tracts 3 and 4 and the Story
Distributing property (See Figure 2 in Appendix A). The grid consisted of square sections of 50 feet by
50 feet. In keeping with previous practice six grid squares were sampled in Tract 4, beginning at the
western edge of the property and extending 150 feet. Five 50 feet by 50 feet square sections were
included in Tract 3 beginning at the western edge of Tract 3 and continuing 100 to 150 feet east.
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 4
Throughout the course of the investigation the HASP was followed to mitigate employee and
environmental exposure to asbestos soil fiber aerosolization by wetting down areas displaying visual
asbestos ore.
The Story Distributing property was divided into eight grid squares. A total of 19 contiguous grid
squares were sampled. Two composite soil samples were collected from each segment, one consisting
of surface soil and the other of subsurface soil when applicable. For the surface samples, five sub-
samples were collected and blended into a single composite sample for each grid; surface samples were
only collected from visually impacted surface soil. In the absence of visual impacts, surface samples were
not collected. For the subsurface samples, a test pit was advanced using a backhoe to a maximum depth
of 24 inches in each section, and three sub-samples were collected from depths of approximately eight,
16, and 24 inches below ground surface (bgs). The test pits were located at the point of highest visible
surface impacts within each square; however, in the absence of visible impacts, test pits were located in
the approximate center of each square.
All samples were submitted to Northern Analytical Laboratories in Billings, Montana. Northern
Analytical is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP). All
equipment was decontaminated between visibly contaminated test pits in .accordance with Maxim's .
standard operating procedures. Analysis was performed by Northern Analytical Laboratories utilizing
Polarized Light Microscopy (PLM) in accordance with EPA Method 600/R4-93-1 16. Northern Analytical
Laboratories is accredited by the National Institute of Standards and Technology's (NIST) National
Voluntary Laboratory Accreditation Program (NVLAP). The analysis for identification of the presence
of asbestos was performed under the supervision of a Certified Industrial Hygienist. The quantification
of asbestos in the sample is intended to be an estimate only; the limit of detection for this method is
approximately 1% by volume.
Soil Investigation - Tract 3
The MDEQ had identified an area of stressed vegetation along the eastern edge of Tract 3 measuring
approximately 40 feet by 50 feet (Appendix A: Figure 2). Because of the stressed vegetation, the MDEQ
had expressed concerned about potential contamination. Maxim collected one surface sample and one
subsurface sample in accordance with the procedures outlined above. Both surface and subsurface
samples were collected in areas exhibiting the least vegetative growth or most visibly stressed
vegetation. The samples were submitted to Northern Analytical for a variety of analyses to identify
suspected contaminants.
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 5
Specifically, the soil samples were analyzed for volatile petroleum hydrocarbons (VPH) and extractable
petroleum hydrocarbons (EPH) screen according to Massachusetts Department of Environmental
Protection methods (MDEP, 1998a and 1998b), pesticides according to EPA Methods 8081A and 8082,
herbicides according to EPA Method 8 15 1 A, pH corrosivity according to EPA Method 9045C, and eight
RCRA (Resource Conservation and Recovery Act) metals (arsenic, barium, cadmium, chromium, lead,
mercury, selenium and silver) according to EPA Methods 6010E and 7471A.
RESULTS AND DISCUSSION
Asbestos Investigation --Tracts 3 and 4
Test Pit Soil Data
.Data collected from the 20 test pits are summarized below and are presented as logs in Appendix C.
Soils encountered in all three tracts were primarily granular, ranging from silty fine sand to gravel.
Roots were abundant in test pits CB-3A, CB-3B, and CB-4B. A steel pipe was encountered in test pit
CB-6A. A buried concrete pad was encountered in the center of grid square 9A, forcing the test pit
location to be moved 10 feet to the north. Visible asbestos ore was encountered in test pit CB-8A. No
other test pit encountered visible evidence of asbestos contamination.
Asbestos Soil Analysis Data
Following receipt of the laboratory report, asbestos-containing waste material (ACWM) was identified.
Laboratory analysis confirmed that asbestos was present above the limit of detection for this analytical
method in five of the composite test pit samples. The sample from test pit CB-BA contained more than
1% asbestos and is, therefore, ACWM. If this sample is representative of the soil in grid square *A, and
the thickness of the asbestos-containing layer is 1 '/2. feet, then the total volume of ACWM is
approximately 140 bank (in-situ) cubic yards. Trace amounts of asbestos were noted in three
composite test pit samples and one surface sample as presented in Table I. The results of the laboratory
analysis are contained in the Appendix D.
Table 1: Summary of Asbestos-Containing Soils
City of Bozeman
Test Pit Percent
Number and Description Asbestos Approximate Quantity
Sample ID
CB-6A Story Discrjbuung Property Brown clayey sand with 2! 14b'bank cubic yards
rocks and co661es chunks of asbestos laden ore wire
sew.
Ore appears to start it about six inches
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 6
C8-7C Quality Control Sample:Duplicate from CB-3A Trace Tremolite NA
CB-BA-SS Story Distributing Property:Grab sample of surficial soil Trace Tremolite NA
CB-I C City of Bozeman Tract 3:0—6"very dark brown silty Trace Tremolite NA
find sand with rounded gravel and cobbles;6—24"dark
brown silty fine sand
CB-3A City of Bozeman Tract 3=0— 12"very dark brown silty Trace Tremolite NA
fine sand with rounded gravel and root systems: 12—24"
dark brown silty fine sand with few specks of gray clayey
sand
The composite samples displaying trace concentrations of tremolite did not contain visible asbestos ore
in the test pits; therefore, it is impossible for Maxim to establish that ACWM is not present in small
quantities in these test pits or the grid squares they represent.
All test pits not mentioned in Table I did not contain a detectable amount of asbestos as identified by
the applicable methodology. To the extent each test pit is representative of its respective grid square,
these grid squares do not contain ACWM. However, complete excavation would be necessary to verify
this.
Soil Investigation — Tract 3
Test Pit CB-10 Field Data
Mr. McCurry collected test pit data from a single 24" excavation in the distressed vegetation area in
Tract 3. Soil data from test pit CB-10 are presented on the test pit log. The soil encountered in test pit
CB-10 was silty fine sand with varying amounts of gravel. No evidence of discoloration or unusual odor
was observed.
Test Pit CB-10 Analytical Data
Maxim received the laboratory analytical results for Tract 3 in the distressed vegetation area for both
the surficial soil sample and the test pit soil sample on April 20, 2005. Tests were conducted in the
following manner:
• Massachusetts Department of Environmental Protection "Method for the Determination of
Volatile Petroleum Hydrocarbons (VPH)"Jan. 1998;
• Massachusetts Department of Environmental Protection "Method for the Determination of
Extractable Petroleum Hydrocarbons (EPH)"Jan. 1998; and,
• Solid Waste (SW) -- 846 "Test Methods for Evaluating Solid Waste", 3rd Edition, updates I, II,
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 7
I IA, 1113, and 111.
Laboratory analytical results are summarized in Table II. It should be noted that none of the specific
contaminants were above the EPA Region 9 Preliminary Remediation Goals (PRG's) for residential soil
and industrial soil values. Most measured concentrations were below the laboratory practical
quantification limits (PQL's). Sample CB-SS-3 -- same as location CB-10 - was collected from the
surficial soils, and sample CB-SB-3 was a composite collected from the test pit. The pH of the soil was
relatively neutral with a surficial value of 7.5 and a subsurface value of 8.3; the moisture content was
approximately 22%at the surface but dropped to 7% in the subsurface.
Table II: Summary of Soil Investigation Analytical Results
City of Bozeman
Contaminant CB-SB-3 CB-SS-3 EPA PRG EPA PRG
Measured Value Measured Value Residential Soil Industrial Soil
(mg/kg) (mg/kg) (mglkg) (mg/kg)
Total Extractable Hydrocarbons <11* <13* NA NA
Screen
2,4—Dichlorophenoxyacetic Acid <50 <0.05 690 7,700
(Herbicide)
2,4—Dichlorophenoxy butyric Acid <99 <0.1 490 4,900
(Herbicide)
Dalapon(Herbicide) <100 <0.1 1,800 18,000
Dicamba(Herbicide) <20 <0.02 1,800 18,000
1,3—Dichlorpropene(Herbicide) <150 <0.15 0.78 1.8
Dinoseb(Herbicide) R** R** 61 620
2-Methyl-4-chlorophenoxyacetic <20 <70 31 310
acid(MCPA)(Herbicide)
2-(2-Methyl-4-chiorophenoxy) <10 <10 61 620
propanoic acid(MCPP)(Herbicide)
Pentachlorophenol(Herbicide) <0.01 <0.01 3 9
Picloram(Herbicide) <.002 <D 02 4,300 43,000
2,4,5—Trichlorophenoxyacetic <0.01 <0 01 610 6,200
Acid(Herbicide)
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 200S Bozeman, Montana
Page 8
Contaminant CB-SB-3 CB-SS-3 EPA PRG EPA PRG
Measured Value Measured Value Residential Soil Industrial Soil
(mgfkg) (mgfkg) (mglkg) (rngikg)
PAS-Trichlorophmoxy) <0.02 <0.02 490 4,900
propionic Acid
Polychlorinated Biphynol's(All <0-032 <0.032 0.22 0.74
Compounds)
Aldrin(Pesticide) <0.003 <0.003 0.0029 0.1
Hexachlorocyclohexane(Alpha) <0A03 <0.003 0.09 0.36
(Pesticide)
Hexachlorocyclohexane(Beta) <0.003 <0.003 0.32 1.3
(Pesticide)
Hexachlorocyclohexane(Gamma) <0.003 <0.003 0.44 1-7
(Pesticide)
Hexachlorocyclohexane(Derivitive) <0.003 <0.003 0.32 1.3
(Pesticide)
A-Chlordane(Pesticide) <0.003 <0.003 1.6 6.5
G-Chlordane(Pesticide) <0.003 <0.003 1.6*** 6.5***
DDD(Pesticide) <0.007 <0.007 2.4 10
DDE(Pesticide) <0.007 <0.007 1.7 7.0
DDT(Pesticide) <0.007 <0.007 1.7 7A
Dieldrin(Pesticide) <0.007 <0.007 0.03 0.1 I
Endosulfan(1.II,and Sulfate) <0.007 <0.007 370 3,700
(Pesticide)
Endrin(Sulfate)(Pesticide) <0.007 <0.007 I B 180
Heptachlor(Pesticide) <0.003 <0.003 •0.1 1 0-38
Heptachlor Epoxide(Pesticide) <0-003 <0.003 0-053 0.19
Methoxychlor(Pesticide) <0.032 <0.032 310 3,100
Toxaphene(Pesticide) <0.064 <0.064 0.44 1.6
Arsenic(Total) <10 <10 0.39 1.6
Barium(Total) 124 198 5,400 67,000
Cadmium(Total) <2 <2 37 4S0
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 9
Contaminant CB-SB-3 CB-SS-3 EPA PRG EPA PRG
Measured Value Measured Value Residential Soil Industrial Soil
(mgikg) (mgikg) (mglkg) (ring/kg)
Chromium(Total) 24 30 210 450
Lead(Total)
<10 44 400 800
Mercury(Total) <0.I 0.1 23 310
Silver(Total) <5 <5 390 5,100
Selenium(Total) <10 <10 390 5.100
Benzene(VPH) <O.03 <0.03 0.64 1.4
Ethylbenzene(VPH) <0.06 <0.06 400 400
Methyl-tert-butyl ether(VPH) <0.03 <0.03 32 70
Naphthaene(VPH) eO.32 <0.32 56 190
Toluene(VPH) <0.06 <0.06 520 520
Xylenes(VPH) <0.19 <0.19 270 420
C5-C8 Aliphatics <6 <6 10(*) 50(*)
C9-C 12 Aliphatics 1-
6 <6 70(*) 300(")
C9-CIO <I <1 10(*) 5D(
*For EPH compounds the 50 mg/kg screening level is used to determine if further analysis is required as noted in MDEQ Tier I.
**The sample results were rejected due to deficiencies in the ability to analyze the samples and meet quality control criteria.
The presence or absence cannot be determined. *** Chlordane (technical) data used, not specific contaminant. (*) MDEQ
residential value<10 feet to groundwater. ('*) MDEQ commercial value<10 feet to groundwater
Note that only the metals barium, chromium, lead, and mercury were found to be at a detectable
concentrations in the soil samples; however, the measured concentrations were below the most
stringent risk-based soil guidelines. The laboratory level of detection for arsenic was above both risk-
based soil guidelines. Based upon the non-detectable results of the other soil contaminants, Maxim has
no relevant basis to suspect soil contaminated with arsenic.
RECOMENDATIONS
The excavation of any materials that are contaminated with ACM is governed by 40 CFR Part 61,
Subpart M, also know as NESHAP. The regulatory framework of the asbestos NESHAP for excavation
is as follows:
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page 10
1. The definition of a "Facility" includes inactive waste disposal sites.
2.. An inactive waste disposal site is defined as a site where ACWM has not been added for one
year.
3. Renovation means the altering of a "Facility" in any way, which includes the excavation of an
inactive waste disposal site.
4. If the project is subject to 40 CFR 61.145, you must hire a licensed asbestos contractor and
follow the asbestos NESHAP renovation regulations as follows:
a. Submit a Notification of Intent to Perform an Asbestos Abatement Project (Notice) to
the MDEQ. The Notice must include facility information, owner/operator information,
emission control procedures, disposal location, and other information. The Notice
includes a ten-working day notification prior for the MDEQ review and processing.
b. Emission Control requirement of 40 CFR 61.145 must be met, including the adequate
wetting of the excavated material and no visible emissions from the RACM. The area
where the RACM abatement is being performed must be cordoned off, and asbestos
warning signs must be clearly visible at all entrances or exits. This may also include
perimeter area monitoring.
c. Waste handling provisions of 40 CFR 6 1.150 must be met. It includes the following:
i. Adequately wet;
ii. Polyethylene lined and covered trucks or containers; and,
iii. Proper manifesting, waste generator label, and warning signs used.
d. Disposal at a site operated in accordance with 40 CFR 1.154, an "approved" landfill that
is permitted by the EPA and MDEQ to accept RACM.
S. The RACM removal project is completed after all the RACM is removed and visual inspection is
performed by the licensed asbestos contractor or a licensed asbestos inspector. In an
excavation, this would be for the affected area where RACM was removed. Any RACM not
disturbed will not need to be inspected.
The worker/operator definition of the asbestos NESHAP includes anyone who "...owns, leases,
operates, controls, or supervises the facility being demolished or renovated or any person who owns,
leases, operates, controls, or supervises the demolition operation or both." This means that any parry
or person that meets the above definition is potentially liable for compliance with the asbestos NESHAP
throughout the renovation.
Maxim Technologies
Additional Asbestos and Soil Investigation City of Bozeman
May 2, 2005 Bozeman, Montana
Page II
If RACM is identified and is not scheduled for excavation, then other portions of the asbestos NESHAP
may apply regarding deed recording or cover requirements depending on the information supplied
regarding the project and the potential for future RACM exposure. The ability to rework the
excavation project to disturb as little RACM as possible will help with disposal and handling costs, avoid
the potential for airborne asbestos fibers, and avoid any further liability from the RACM due specifically
to handling or off-site disposal. In some instances, as determined by the MDEQ and the landowner,
institutional controls for the RACM being left in place will be sufficient to ensure that the RACM is safe.
These controls may include deed notification or restrictions.
It would be prudent to have-an accredited.-asbestos inspector present during site grading work if_future_
development may impact soils„proximate to grid square 8A. Additional sampling or abatement may be
necessary.
LIMITATIONS
The services performed by Maxim Technologies have been conducted in a manner consistent with that
level of skill and care ordinarily exercised by other members of the profession currently practicing in
this area, under similar budgetary and time constraints. The conclusions and recommendations
provided herein are based on limited site data and may need to be modified if site activities encounter
conditions differing from those at the time of our site investigation.
If conditions differing from our original findings are identified, Maxim should be immediately contacted
to review these conditions and determine if there are any material impacts on any of our opinions and
recommendations.
Report Prepared by: Report Reviewed by:
Keith Cron, M.S. Peter Klevberg, P.E.
C `J
Industrial Hygienist Branch Manager
Maxim Technologies