Attachment 9 Hazardous Building Materials Inspection Report.pdf

LIMITED HAZARDOUS BUILDING

MATERIALS INSPECTION REPORT

USDA ARS Pendleton Buidling Repairs 48037 County 788 Road

Adams, Oregon

Project Number: 233884.00

September 22, 2023

Prepared for:

Coffman Engineers, Inc.

Attn: Phillip Baker, PE

10 N. Post, STE 500

Spokane, Washington 99201

Prepared by:

Fulcrum Environmental Consulting, Inc.

207 West Boone Avenue

Spokane, Washington 99201

Report Title: Hazardous Building Materials Inspection Report

Project Number: 233884.00

Date: September 22, 2023

Site: Columbia Plateau Conservation Research Center 48037 County 788 Road Adams, Oregon

Prepared for: Coffman Engineers, Inc.

Attn: Phillip Baker, PE 10 N. Post, STE 500 Spokane, Washington, 99201

Prepared by: Fulcrum Environmental Consulting, Inc.

207 West Boone Avenue Spokane, Washington 99201

(509) 459-9220

The professionals who completed site services, prepared, and reviewed this report include but are not limited to:

Authored by: Date: 9.22.2023

Roque Reyes, Environmental Scientist Fulcrum Environmental Consulting, Inc.

Reviewed by: Date: 9.22.2023

Scott Groat, Regional Manager Fulcrum Environmental Consulting, Inc.

Report Integrity:

Fulcrum Environmental Consulting, Inc.’s scope of service for this project was limited to those services as established in the proposal, contract, verbal direction, and/or agreement. This report is subject to applicable federal, state, and local regulations governing project-specific conditions and was performed using recognized procedures and standards of the industry. Scientific data collected in situ may document conditions that may be specific to the time and day of service, and subject to change as a result of conditions beyond Fulcrum’s control or knowledge. Fulcrum makes no warranties, expressed or implied as to the accuracy or completeness of other’s work included herein. Fulcrum has performed these services in accordance with generally accepted environmental science standards of care at the time of the inspection.

No warranty, expressed or implied, is made.

TABLE OF CONTENTS

SECTION PAGE

1.0 INTRODUCTION

2.0 SCOPE OF WORK

3.0 PURPOSE

4.0 BUILDING DESCRIPTION

Building 1

Building 2

Building 3

Building 11

5.0 ASBESTOS CONTAINING MATERIALS

5.1 Regulatory Basis

5.2 Sampling Methodology

5.2.1 Visual Inspection

5.2.2 Asbestos Hazard Emergency Response Act Material Classification

5.2.3 Homogeneous Areas

5.2.4 Representative Samples

5.2.5 Friability

5.3 Homogeneous Materials Identified During the Inspection

Building 1

Building 2

Building 3

Building 11

5.3.1 Assumed Asbestos Containing Materials

5.3.2 Assumed Non-Asbestos Containing Materials

5.4 Laboratory Methodologies

5.4.1 Asbestos Containing Materials

5.4.2 Materials Containing 1% or Less Asbestos

5.5 Asbestos Containing Materials Summary

6.0 LEAD CONTAINING MATERIAL

6.1 Regulatory Basis

6.2 Inspection and Sampling Methodology

6.2.1 Paint Chip Sample Collection for Laboratory Analysis

6.3 Components Identified During the Inspection

6.3.1 Assumed Lead Containing Materials Identified

6.3.2 Assumed Non-Lead Containing Materials

6.4 Paint Chip Results

6.5 Lead Containing Materials Summary

7.0 LIGHTING AND ELECTRICAL COMPONENTS

7.1 Lighting and Electrical Components Regulatory Basis

7.2 Lighting and Electrical Components Inspection Methodology

7.3 Lighting and Electrical Components Identified During Inspection

7.4 Lighting and Electrical Components Summary

8.0 POLYCHLORINATED BIPHENYLS

8.1 Polychlorinated Biphenyl Caulk Regulatory Basis

8.2 Polychlorinated Biphenyl Caulk Inspection Methodology

8.3 Polychlorinated Biphenyl Caulk Summary

9.0 CONCLUSIONS

9.1 Asbestos Containing Materials

9.2 Lead Containing Materials

9.3 Lighting and Electrical Components

9.4 Polychlorinated Biphenyls

10.0 LIMITATIONS

TABLES

Table 1 Asbestos Laboratory Results – Building 1 Table 2 Asbestos Laboratory Results – Building 11 Table 3 Paint Chip Analytical Results Table 4 Lighting and Electrical Component Quantities Table 5 PCB Analytical Results – Building 1 Table 6 PCB Analytical Results – Building 11

FIGURES

Figure 1 Building 1 – ACM Sample Location Map Figure 2 Building 3 – ACM Sample Location Map Figure 3 Building 11 – ACM Sample Location Map Figure 4 Building 1 – LCM Sample Location Map Figure 5 Building 2 – LCM Sample Location Map Figure 6 Building 3 – LCM Sample Location Map Figure 7 Building 11 – LCM Sample Location Map Figure 8 Building 1 – PCB Sample Location Map Figure 9 Building 11 – PCB Sample Location Map

APPENDICIES

Appendix A Professional Certifications Appendix B Site Photographs Appendix C Asbestos Containing Material Results Appendix D Lead Analytical Results Appendix E PCB Analytical Results

INSPECTOR CERTIFICATION SUMMARY

The following summarizes the relevant professionals and their certification(s) responsible for the completion of field inspection services for this project. See certificates in Appendix A.

Inspector License Type License Expiration

Nick Hays AHERA Building Inspector BII20230331-06 3/31/2024

Roque E. Reyes AHERA Building Inspector #186853 11/16/2023 Oregon Health Authority Lead Risk Assessor #2792-Indv-R 9/12/2025

Limited HBM Inspection 1 Pendleton Building Repair Project

1.0 INTRODUCTION

This report provides the methods, results, and summary of a limited inspection for hazardous building materials (HBM) of four (4) buildings of the Columbia Plateau Research Center located at 48037 County Road in Adams, Oregon. Fulcrum understands that localized repairs are scheduled to occur in each of the four (4) buildings. See Figure 1 for the site location.

On August 9th and 10th, 2023, Roque Reyes (#186853) and Nick Hays (BII20230331-06), both Asbestos Hazard Emergency Response Act (AHERA) accredited building inspectors with Fulcrum, completed the limited hazardous building materials inspection. The lead inspection was completed by Roque Reyes (#2792-Indv-R), an Oregon Health Authority certified Lead Risk Assessor.

See Appendix A for applicable certifications.

2.0 SCOPE OF WORK

Fulcrum was retained by Coffman Engineers, Inc. (Coffman), to complete a limited HBM inspection of Building 1 (excluding the roof), Building 2, Building 3 (only Rooms 303 and 304), and Building 11 (only Room 1101 and the associated fume hood exhaust vent on the roof). Fulcrum’s inspection was limited to the following HBM:

Asbestos Containing Materials (ACM) Lead Containing Materials (LCM) Lighting and Electrical Components (LEC) Polychlorinated Biphenyl Containing Caulk (PCBs)

Fulcrum’s scope of work excluded sampling through TPO-type roofing that would require specialized patching. Fulcrum’s scope of work consisted of site inspections, material sampling, sample analysis, and reporting. All inspection tasks were completed by accredited, certified, or qualified professionals.

Fulcrum did not dismantle onsite equipment to determine if potentially hazardous material components were present.

3.0 PURPOSE

The purpose of this inspection is to identify the presence or absence of hazardous materials to assist with renovation, planning and construction cost estimates.

Limited HBM Inspection 2

4.0 BUILDING DESCRIPTION

Building 1

Building 1 was constructed in 1970 and is 15,032 square feet. The exterior of the building is comprised of tan painted concrete masonry unit (CMU) block walls, tan painted wood siding, and fiberglass panels.

The roof is a combination of composite roof shingles and a TPO-type roof.

The building is separated into the main building and the annex. The main building is comprised of offices, lobby, conference rooms, restrooms, laboratories, server room, and mechanical room. Flooring is a combination of 12-inch green vinyl tile, ceramic tile, and sheet vinyl flooring. Walls are a combination of CMU and finished gypsum wallboard. Vermiculite insulation is present in CMU block walls. Ceilings are a combination of finished gypsum wallboard and 2-foot by 4-foot suspended ceiling tiles. Interstitial space is present above suspended ceiling tiles and gypsum wallboard ceilings. The interstitial space is occupied by heating, ventilation, and air conditioning (HVAC) ducting, plumbing, and electrical.

The annex is comprised of a cubicle office area, laboratories, a restroom, storage room, and greenhouse.

Flooring is a combination of 12-inch vinyl tile, concrete, and sheet vinyl flooring. Walls are a combination of CMU black walls, finished gypsum wallboard, wood, and fiberglass. Ceilings are a combination of 2-foot by 4-foot suspended ceiling tiles, metal, and wood.

Building 2

Building 2 is an equipment garage building constructed in 1976 totaling 4,867 square feet. The exterior is comprised of tan painted metal wall panels with 12 garage doors. The roof is corrugated sheet metal.

The interior is comprised of unpainted concrete floors, painted metal wall panels, and a metal ceiling.

Lighting was observed to be light-emitting diode (LED) fixtures.

Building 3

Building 3 is a machine/metal shop constructed in 1977 totaling 4,864 square feet. Fulcrum’s inspection was limited to Rooms 303 and 304 on the south portion of Building 3. The exterior is comprised of tan painted metal wall panels with 12 garage doors. The roof is corrugated sheet metal. Interior building finishes in Rooms 303 and 304 include unpainted concrete floors, painted wood and metal panel walls, and metal ceilings. Brown sprayed-on fireproofing is present on structural metal, metal ceilings, and behind metal panel walls. Lighting was observed to be primarily fluorescent fixtures with 4-foot fluorescent lamps.

Building 11

Building 11 is a microlab constructed in 1986 totaling 4,500 square feet. Fulcrum’s inspection was limited to room 1101 and the associated fume hood exhaust vent on the roof. Room 1101 is a laboratory with a chemical fume hood. Interior finishes include sheet vinyl flooring, gypsum wallboard walls, and

Limited HBM Inspection 3

2-foot by 4-foot suspended ceiling tiles. The interstitial space above the ceiling tiles is occupied by electrical wiring and spray foam insulation on the underside of the metal roof. The Room 1101 fume hood exhaust is present on the southeast portion of the metal roof. Lighting was observed to be primarily fluorescent fixtures with 4-foot fluorescent lamps.

5.0 ASBESTOS CONTAINING MATERIALS

Asbestos containing materials (ACM) were used extensively from the early 1900s to the late 1970s, when the manufacture of most asbestos products was banned in the U.S. The ban did not include all products nor the use and application of asbestos products. Therefore, suspect ACM may be present in structures built after the initial ACM ban and in newly constructed facilities. Since the 1990s, importation of building materials from foreign countries, perhaps unknowingly, has resulted in the use of ACM in new construction.

5.1 Regulatory Basis

Asbestos inspection purpose is in compliance with regulatory requirements enforced by local, state and federal agencies, including: 29 Code of Federal Regulations (CFR) 1926.1101, Asbestos; 40 CFR Part 61, National Emissions Standard for Hazardous Air Pollutants (NESHAPs), and 40 CFR Part 763 Asbestos Hazard Emergency Response Act (AHERA); and Washington Administrative Code (WAC) 296- 62-077, Asbestos, Tremolite, Anthophyllite, and Actinolite asbestos. Under these regulations an ACM is defined as any material containing greater than one (1) percent (%) asbestos.

These regulations require the owner to inspect a facility for the presence of ACM prior to undertaking a construction, remodel, renovation, maintenance, or demolition project, and to provide inspection results to affected contractors or employees.

5.2 Sampling Methodology

The asbestos inspection was conducted by the AHERA accredited Building Inspector(s), as specified in pertinent regulatory references.

Fulcrum’s ACM sampling method consists of the following tasks:

Visual inspection of the area of investigation for the presence of suspect ACM, determination of friability, and any damage to highly suspect ACM.

Identification of homogeneous materials present within the area of investigation and the AHERA classification of the material as either a surfacing material (SUR), thermal system insulation (TSI), or miscellaneous (MSC) material.

Establishment of the homogeneous material identifier and a description of the homogeneous material, such as, dimensions, color, texture, etc.

Limited HBM Inspection 4

Collection of representative sample(s) of the homogeneous material per AHERA sampling requirements.

5.2.1 Visual Inspection

A visual inspection of all accessible spaces within the building was conducted in accordance with applicable regulatory and industry standards.

The northwest custodial closet and center building era boy’s restroom were inaccessible at the time of the inspection.

5.2.2 Asbestos Hazard Emergency Response Act Material Classification

Under Asbestos Hazard Emergency Response Act (AHERA), suspect ACM are classified as surfacing (SUR), thermal system insulation (TSI), or Miscellaneous (MSC). As defined in AHERA, 40 CFR 763:

“Surfacing Material” (SUR) means material in a school building that is sprayed-on, troweled-on, or otherwise applied to surfaces, such as acoustical plaster on ceilings and fireproofing materials on structural members, or other materials on surfaces for acoustical, fireproofing, or other purposes.

“Thermal System Insulation” (TSI) means material in a school building applied to pipes, fittings, boilers, breeching, tanks, ducts, or other interior structural components to prevent heat loss or gain, or water condensation, or for other purposes.

“Miscellaneous Material” (MSC) means interior building material on structural components, structural members or fixtures, such as floor and ceiling tiles, and does not include SUR or TSI.

Subsequent revisions and regulatory guidance have applied these definitions to all buildings, regardless of use, and inclusion of exterior ACM based on their material type. For instance, pipe insulation in an exterior tunnel is considered TSI.

5.2.3 Homogeneous Areas

An AHERA material classification was further subdivided into “Homogeneous Areas”. Homogeneous Areas are those materials that are consistent throughout a building and are based on color, texture and/or construction era. Identification of suspect building materials using this homogeneous area definition is the current industry standard, and is the process used by federal, state, and local agencies for determining regulatory compliance.

Homogeneous Areas are often then subcategorized into general material type groups or systems, such as vinyl tile, that can be indexed with an abbreviation, such as VT, for ease of reference in summary data tables.

Limited HBM Inspection 5

5.2.4 Representative Samples

Fulcrum collected samples of suspect materials per AHERA regulations, the industry standard for both sample collection and analysis. Except where the AHERA accredited Building Inspector has identified a limited quantity of suspect MSC, Fulcrum’s standard sampling method requires that analytical results from three (3) samples of each suspect material are collected to determine if a material is non-ACM. Of each suspect ACM, a representative, full depth sample of the material is sampled and placed into a labeled resealable bag.

Where Fulcrum’s AHERA accredited Building Inspector identifies a suspect ACM to be unique, the total area/length of the suspect ACM to be limited, or simply an additional confirmatory sample is useful to conclude a report, less than three may be determined by the inspector to be sufficient.

5.2.5 Friability

Friability is an indicator of a material’s potential to release asbestos fibers. Materials are divided into two general friability categories, friable or non-friable.

“Friable” means that the material, when dry, may be crumbled, pulverized, or reduced to powder by hand pressure. Friable material also includes previously non-friable material that has become damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure.

“Non-friable” materials are defined as materials which when dry may not be crumbled, pulverized, or reduced to a powder by hand pressure.

Friable materials are the most hazardous form of ACM. Their physical composition lends them more susceptible to releasing asbestos fibers into the air when they are disturbed.

Non-friable ACM are generally associated with materials that have the asbestos fibers bound within a protective flooring or in an asphalt or concrete/mortar matrix. The release of asbestos fibers by these materials is typically associated with an external force or aggressive action being applied to the material:

sawing, grinding, chipping, sanding, etc. Non-friable ACM are considered the less hazardous of these two categories.

The friability of a material is an important consideration when assessing and recommending a material’s response action. In addition to the assessment considerations, the friability of a material is important with respect to regulatory compliance. Compliance considerations include, but not limited to, worker certification and protection, engineering controls, notification and disposal requirements.

When determining the friability of a material, Fulcrum inspectors utilize the “hand pressure or touch” test as required by law. However, this friability test was further supplemented by visual observations as to the material’s matrix structure and judging whether an external aggressive action (cutting, sawing, grinding, sanding, etc.) would be required to release asbestos fibers. If a non-aggressive action, such as

Limited HBM Inspection 6 striking or bumping the material with a sharp object, water damage, delamination, etc. is anticipated to release fibers, the material is classified as a friable material by Fulcrum.

5.3 Homogeneous Materials Identified During the Inspection

The following summary presents the homogeneous areas identified during the inspection by AHERA material classification:

Building 1

SUR: The AHERA accredited Building Inspector(s) did not classify any suspect ACM in Building 1 as surfacing materials.

TSI: The AHERA accredited building inspector(s) classified the following suspect ACM in Building 1 as thermal system insulation materials:

4-inch white pipe insulation (TSI-B1-01) 4-inch white pipe insulation associated with joints, elbows, and tees (JETs) (TSI-B1-02) 4-inch orange pipe insulation (TSI-B1-03) 4-inch orange pipe insulation associated with JETs (TSI-B1-04) 4-inch green pipe insulation (TSI-B1-05) 4-inch green pipe insulation associated with JETs (TSI-B1-06) Vermiculite insulation in CMU block walls (TSI-B1-07) 4-inch red pipe insulation (TSI-B1-08) 4-inch red pipe insulation associated with JETs (TSI-B1-09) Fiber glass insulation with associated silver wrap (TSI-B1-10) Pink batt type insulation with associated silver wrap (TSI-B1-11)

MSC: The AHERA accredited building inspector(s) classified the following suspect ACM in Building 1 as miscellaneous materials and assigned the associated homogeneous abbreviation:

6-inch orange gasket associated with boilers (MSC-B1-01) White sheet vinyl flooring with beige adhesive and blue leveling compound (SVF-B1-01) 4-inch gray floor base with associated cream adhesive (FB-B1-01) 2-foot by 4-foot pinhole ceiling tile (CT-B1-01) 2-foot by 4-foot smooth white suspended ceiling tile (CT-B1-02) 12-inch white with brown streaks vinyl floor tile (VT-B1-01) 4-inch white floor base with associated tan adhesive (FB-B1-02) 12-inch gray vinyl floor tile (VT-B1-02) Dark gray sealant associated with HVAC (SEA-B1-01) 12-inch tan with light blue specks vinyl floor tile (VT-B1-03) White finished gypsum wallboard system (GWB-B1-01) White/gray door putty (DP-B1-01)

Limited HBM Inspection 7

Black cement expansion joint sealant (SEA-B1-02) Smooth brown finished gypsum wallboard system (GWB-B1-02) 4-inch brown floor base with associated tan adhesive (FB-B1-03) 2-inch tan ceramic tile with associated brown grout (CER-B1-01) Gray sealant associated with fume hood duct (SEA-B1-03) White cement board panels associated with fume hood (CAB-B1-01) White lining associated with fume hood (MSC-B1-02) White wood patterned sheet vinyl flooring with black adhesive (SVF-B1-02) Finished gypsum wallboard walls and ceilings within the main portion (GWB-B1-03) 12-inch green vinyl tile with yellow/white speckles with black adhesive (VT-B1-04) Silver sealant associated with floor base in room 150 (SEA-B1-04) Red brick with gray mortar associated with chimney (MSC-B1-03) Ebonite countertops (MSC-B1-04) Silver sealant on corners of metal flashing (SEA-B1-05) 3-tab roofing material over storage building (RFM-B1-01) Silver and black roof penetration sealant (SEA-B1-06) Matte gray coating on southwest fume hood duct (MSC-B1-05) Brown sealant on southwest fume hood duct (SEA-B1-07) White sealant on southwest fume hood duct (SEA-B1-08) Brown/white sealant on east fume hood duct (SEA-B1-09) Gray deteriorated coating on east fume hood duct (MSC-B1-06) White window putty associated with exterior windows (WP-B1-01) Brown door putty associated with exterior doors (DP-B1-02)

Building 2

No suspect ACM were identified in Building 2 at the time of the inspection.

Building 3

SUR: The AHERA accredited Building Inspector(s) classified the following suspect ACM in Building 3 Rooms 303 and 304 as surfacing materials:

Brown fluffy sprayed on fire proofing on structural steel (SUR-B3-01)

TSI: The AHERA accredited building inspector(s) did not classify any suspect ACM in Building 3 Rooms 303 and 304 as thermal system insulation materials.

MSC: The AHERA accredited building inspector(s) classified the following suspect ACM in Building 3 Rooms 303 and 304 as miscellaneous materials and assigned the associated homogeneous abbreviation:

White wrap with associated orange insulation on garage doors (MSC-B3-01) White window glazing on exterior door (WG-B3-01)

Limited HBM Inspection 8

Building 11

SUR: The AHERA accredited Building Inspector(s) classified the following suspect ACM in Building 11 Room 1101 and roof as surfacing materials:

Silver paint associated with fume hood/HVAC on roof (SUR-B11-01)

TSI: The AHERA accredited building inspector(s) did not classify any suspect ACM in Building 11 Room 1101 and roof as thermal system insulation materials.

MSC: The AHERA accredited building inspector(s) classified the following suspect ACM in Building 11 Room 1101 and roof as miscellaneous materials and assigned the associated homogeneous abbreviation:

Black tar sealant associated with fume hood/HVAC on roof (SEA-B11-01) White sealant associated with fume hood/HVAC on rood (SEA-B11-02) Black sealant associated with roof penetrations (SEA-B11-03) Off-white floor base with tan adhesive (FB-B11-01) Cobblestone sheet vinyl flooring with tan adhesive (SVF-B11-01) White cement board associated with fume hood (CAB-B11-01) White liner associated with fume hood (MSC-B11-01) 2-foot by 4-foot pinhole suspended ceiling tile (CT-B11-01) Gray cement board associated with fume hood cabinets (CAB-B11-02)

5.3.1 Assumed Asbestos Containing Materials

An assumed ACM is any material that the inspector assumes contains greater than 1 percent asbestos based on previous inspection results; manufacturers’ labels, age, appearance; or inspector’s expertise.

Fulcrum assumed the built-up roofing system of Building 1 to be asbestos containing. Materials located in areas of Buildings 3 and 11 that were not inspected are assumed to be asbestos containing.

5.3.2 Assumed Non-Asbestos Containing Materials

Under AHERA inspection criteria, some materials can be assumed to be non-ACM based on manufacturers’ labels, age, appearance, or inspector’s expertise. The following materials were identified and were assumed to be non-ACM based on manufacturers’ labels, age, appearance, or inspector’s expertise:

Wood components – shelves, doors, trim, framing, throughout Glass – windows exterior/interior, throughout Concrete – foundation, throughout

Limited HBM Inspection 9

Metal – plumbing, ducting, throughout

5.4 Laboratory Methodologies

Fulcrum collected a total of 172 bulk samples of suspect ACMs from the inspected areas of Buildings 1, 3, and 11. Samples were shipped by common carrier, under chain of custody, to Aerobiology Laboratories, a NVLAP accredited laboratory (200869-0), located at 780 Simms Street, Suite 104, Golden, Colorado. Samples were analyzed using PLM method EPA 600/R-93/116.

Samples that could be separated into multiple layers in the laboratory were analyzed by individual layer.

Except in specific cases, individual layer analysis, rather than composite analysis, is the determining factor in declaring a material an ACM or a non-ACM. For report identification purposes, the layers received a letter and/or number designation. The sample results are presented in Appendix D and sample locations can be found in Figures 2-4.

5.4.1 Asbestos Containing Materials

By regulatory definition an ACM is any homogeneous areas that contains greater than 1 percent asbestos in one or more of the samples analyzed or were classified as ACM based on the inability to differentiate between ACM and non-ACM areas. See Table 1 for materials containing greater than 1 percent asbestos.

Table 1: Asbestos Laboratory Results Summary – Building 1

Sample Number Index Material Location1 Comments

081023-B1-54 081023-B1-55 081023-B1-56

DP-B1-01 White/gray door putty

Room 149 (Greenhouse)

20% Chrysotile in silver resinous material

081023-B1-57 081023-B1-58 081023-B1-59

SEA-B1-02

Black cement expansion joint sealant

Room 149 (Greenhouse)

20% Chrysotile in silver resinous material

081023-B1-61 081023-B1-62

FB-B1-03

4-inch brown floor base with tan adhesive

North Hallway, East North Hallway, Center

3% Chrysotile in white compound2

081023-B1-81 081023-B1-82 081023-B1-83

SVF-B1-02

White wood pattern sheet vinyl flooring with black adhesive

Room 104 3% Chrysotile in black tar

081023-B1-84 081023-B1-85 081023-B1-86

GWB-B1-03

Finished gypsum wallboard walls and ceilings

Room 127 North Hallway Room 130

4% Chrysotile in off-white compound

081023-B1-87 081023-B1-88 081023-B1-89

VT-B1-04

12-inch green with yellow/white speckles vinyl tile with black adhesive

South hallway North Hallway Room 127

4% Chrysotile in gray tile and 6% Chrysotile in black tar

Limited HBM Inspection 10

Sample Number Index Material Location1 Comments

081023-B1-96 081023-B1-97 081023-B1-98

MSC-B1-04 Ebonite countertops Room 136 Room 128 Room 127

20% Chrysotile in black fibrous resinous material

081023-B1-105 081023-B1-106 081023-B1-107

SEA-B1-06

Silver and black roof penetration sealant

Main Roof, West Main Roof, East

15% Chrysotile in black fibrous tar

1. Locations identified in the table reflect the locations sampled and may not represent all locations of identified materials.

2. ACM white compound is an artifact of ACM finished gypsum wallboard substrate.

Table 2: Asbestos Laboratory Results Summary – Building 11

Sample Number Index Material Location1 Comments

080923-B11-01 080923-B11-02 080923-B11-03

SUR-B11-01

Silver paint on room 1101 fume hood/HVAC on roof

Roof, Fume hood duct

2% Chrysotile in silver paint

080923-B11-04 080923-B11-05 080923-B11-06

SEA-B11-01

Black tar sealant on room 1101 fume hood/HVAC on roof

Roof, Fume hood duct

5% Chrysotile in black tar with silver paint

1. Locations identified in the table reflect the locations sampled and may not represent all locations of identified materials.

5.4.2 Materials Containing 1% or Less Asbestos

By regulatory definition a non-ACM is any material that contains 1 percent or less asbestos. However, materials with no asbestos identified are managed differently than materials where asbestos is present though at concentrations below the threshold for a regulated asbestos material. The following materials sampled were identified with 1 percent or less asbestos:

Vermiculite insulation in CMU block walls – Building 1 – <0.25% Tremolite White window glazing on southeast exterior door – Building 3 – <0.25% Chrysotile

5.5 Asbestos Containing Materials Summary

Fulcrum collected a total of 172 bulk samples of suspect ACMs from the inspected areas of Buildings 1, 3, and 11. Laboratory analysis identified the following materials to be ACM:

Building 1

White/gray door putty – Approximately 1 each (EA) Black cement expansion joint sealant – Approximately 70 linear feet (LF) Black adhesive associated with white wood pattern sheet vinyl flooring – Approximately 255 square feet (SF)

Limited HBM Inspection 11

Finished gypsum wallboard walls and ceilings – Approximately 23,000 SF 12-inch green vinyl tile and associated black adhesive – Approximately 9,335 SF Ebonite countertops – Approximately 18 EA Silver and black roof penetration sealant – Approximately 3 EA Assumed asbestos containing built-up roofing – Approximately 15,000 SF

Provided quantities are estimates and subject to revision. The quantities shown should not be used for bidding. The quantities in a bid specification shall take precedence.

Building 11

Silver paint on room 1101 fume hood roof duct – Approximately 1 unit Black tar sealant on room 1101 fume hood roof duct – Approximately 1 unit

Provided quantities are estimates and subject to revision. The quantities shown should not be used for bidding. The quantities in a bid specification shall take precedence.

The following materials were identified with an asbestos concentration of less than 1% asbestos:

Vermiculite insulation in CMU block walls – Building 1 White window glazing on southeast exterior door – Building 3

6.0 Lead Containing Material

Lead containing materials (LCM) are any product, with naturally occurring lead, or manufactured, or produced with lead. Lead materials can include, but are not limited to, paint, varnish, mortar, alloys, etc.

Lead containing material inspections may be performed using paint chip sampling and laboratory analysis, field x-ray fluorescence (XRF) instrumentation, or a combination of both approaches. Fulcrum utilized paint chip collection for this inspection.

6.1 Regulatory Basis

The purpose of the LCM investigation is to facilitate pending modernization and demolition activities in compliance with pertinent regulations while protecting workers, the public, and the environment. For purposes of this investigation, LCM are being evaluated under or based upon the following regulations:

Worker Protection: OSHA 3142-12R Lead in Construction: Oregon OSHA OAR Division 3/D Consumer Protection: 16 CFR 1303 Ban of Lead Containing Paint and Certain Consumer

Products Bearing Lead-Containing Paint and 16 CFR 1500 Federal Hazardous Substance Act.

The most stringent lead regulations are found in the lead in construction regulations administered by OSHA, in federally managed areas, and Oregon OSHA. Under these worker protection regulations any

Limited HBM Inspection 12 material containing a detectable concentration of lead is an LCM. Lead in construction regulations apply to all work environments during many types of tasks including, but not limited to, the following:

Demolition or salvage of structures where lead or materials containing lead are present;

Removal or encapsulation of materials containing lead;

New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead;

Installation of products containing lead;

Lead contamination/emergency clean-up;

Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed; and Maintenance operations associated with the construction activities described in this section.

In 1978, the Consumer Product Safety Commission (CPSC), under 16 CFR Part 1303, enacted limits on the lead concentration in household paints to not more than 0.06% lead by weight, or 600 milligrams per kilogram (mg/Kg). Under the Consumer Product Safety Improvement Act of 2008, the acceptable concentration of lead in consumer products was lowered to 0.009% or 90 mg/Kg. While the OSHA has not identified a specific lead concentration below which the lead in construction regulations do not apply, they have issued guidance that the CPSC established values are a reasonable lower concentration for determining applicability of the lead in construction regulations.

Fulcrum’s inspection did not include characterization of potential waste. Depending upon selected demolition methods, additional waste characterization of composite, building components are sampled for lead in conformance with ASTM Standard E 1908-16 Standard Guide for Sample Selection of Debris Waste from a Building Renovation or Lead Abatement Project for Toxicity Characteristic Leaching Procedure (TCLP) Testing for Leachable Lead (Pb) may be required.

6.2 Inspection and Sampling Methodology

A visual inspection of accessible portions of the investigation area was conducted. The inspection was conducted in substantial conformance with applicable regulatory and industry standards. Relevant portions of the 1995 HUD guidance (Revised in 2012) and Washington State lead-based paint regulations. The LCM inspection consists of following basic steps:

Identification of homogenous areas and components Paint Chip sample collection for laboratory analysis

Characteristic painted surfaces were classified as homogeneous areas based on color of surface paint, substrate, construction era, and in some cases, color of sublayers. Homogeneous materials are one of the key elements for referencing both lead and non-lead materials identified during the inspection and used within this report. Sample locations in the facility were selected to be representative of the various homogeneous areas. Full-layer thicknesses of existing paint were evaluated to obtain a historical representation of all paints applied to the tested component.

Limited HBM Inspection 13

Paints that appear homogeneous for a given substrate may have been manufactured during different time periods and by different companies or may obscure the underlying variations in paint history and application areas. To counterbalance this possibility, multiple paint chip samples of suspect homogeneous components with surface areas greater than (>) 1,000 square feet were collected in different locations and analytical results compared to confirm lead content conclusions.

For this inspection report, homogeneous areas/materials were developed using the site figures, surface color, and component composition as primary considerations, supported by visual observations made in the field regarding material appearance, texture, size, color, and/or manufacturers’ labels. Suspect painted surfaces were then sampled to determine if they contain lead or are non-lead containing based on laboratory results. Once the analytical results were received and reviewed, additional samples may be collected for materials with inconsistent results.

6.2.1 Paint Chip Sample Collection for Laboratory Analysis

Fulcrum’s certified Lead Inspector or Risk Assessor collected 19 paint chip samples of select building materials where homogenous materials were visually identified. Paint chip sample analytical results are used to determine if the lead concentrations in the paint or varnish is above 600 mg/Kg and appropriate for disclosure to the project contractor for worker protection purposes. Lead concentrations above 5,000 mg/Kg are considered LBP.

Lead paint chip samples were submitted to NVL Laboratories, Inc., a NVLAP accredited laboratory (#102063-0) located in Seattle, Washington, an Environmental Lead Proficiency Analytical Testing (ELPAT) Program certified laboratory. Submitted samples are analyzed by EPA Method 7000B for total lead. See Appendix E for complete Lead Analytical Results.

6.3 Components Identified During the Inspection

Painted components identified during the inspection are identified in Table 3.

6.3.1 Assumed Lead Containing Materials Identified

The following materials are assumed to contain lead greater than the limit of detection:

Metal pipe caps and plumbing Plumbing components Solder or plumbing and metal brazed components Metal structural components

6.3.2 Assumed Non-Lead Containing Materials

The following materials are assumed to be non-lead containing materials:

Limited HBM Inspection 14

Glass Unpainted wood Unpainted concrete Unpainted pipes Unpainted plastics

6.4 Paint Chip Results

Results of this inspection indicate that lead was detected in concentrations greater than or equal to the method reporting limit of detection for the following homogenous area. Sample results shown in Bold represent analytical results greater than 600 mg/Kg for total lead and a potential worker protection concern. Results greater than or equal to 5,000 mg/kg are considered a lead-based paint. See Table 3 for a summary of paint chip analytical results. See Appendix E for all paint chip laboratory analysis.

Table 3: Paint Chip Analytical Results

Sample Number Location Paint Color Identified

Component

Reporting Limit in mg/Kg

Results in mg/Kg

Results in Percent

PC-B1-01 Building 1 White CMU 87 140 0.014 PC-B1-02 Building 1 White Metal 140 <140 <0.014

PC-B1-03 Building 1 White Gypsum Wallboard 57 <57 <0.0057

PC-B1-04 Building 1 White Wood 79 <79 <0.0079 PC-B1-05 Building 1 Brown Metal 130 1,300 0.13 PC-B1-06 Building 1 Tan Gypsum

Wallboard 64 1,100 0.11

PC-B1-07 Building 1 White Metal 260 <260 <0.026 PC-B1-08 Building 1 Gray CMU 53 160 0.016 PC-B1-09 Building 1 White CMU 110 720 0.072 PC-B1-10 Building 1 Tan CMU 60 <60 <0.0060 PC-B1-11 Building 1 White Wood 94 <94 <0.0094 PC-B1-12 Building 1 Tan Wood 45 190 0.019 PC-B2-01 Building 2 White Metal 520 <520 <0.052 PC-B2-02 Building 2 White Metal 680 <680 <0.068 PC-B2-03 Building 2 Gray Metal 450 <450 <0.045 PC-B2-04 Building 2 White Metal 190 <190 <0.019 PC-B2-05 Building 2 Red Structural Steel 150 810 0.081 PC-B2-06 Building 2 Tan Metal 790 1,900 0.19 PC-B3-01 Building 3 Yellow Wood 100 <100 <0.010 PC-B3-02 Building 3 Black Structural Steel 440 <440 <0.044 PC-B3-03 Building 3 Tan Metal 180 7,900 0.79 PC-B3-04 Building 3 White Metal 150 <150 <0.015

Limited HBM Inspection 15

Sample Number Location Paint Color Identified

Component

Reporting Limit in mg/Kg

Results in mg/Kg

Results in Percent

PC-B11-01 Building 11 White Gypsum Wallboard 56 <56 <0.0056

PC-B11-02 Building 11 Tan Metal 1,200 2,600 0.26 PC-B11-03 Building 11 White Metal 610 <610 0.061

6.5 Lead Containing Materials Summary

Fulcrum collected a total of 25 paint chip samples. Results of the paint chip collection indicate the following painted components have lead in amounts equal or greater than 600 mg/Kg, which is the general guidelines for worker exposure risk:

Brown Paint on metal doors – Building 1 Tan paint on gypsum wallboard walls – Building 1 White paint on CMU block walls – Building 1 Red paint on structural steel – Building 2 Tan paint on exterior metal panels – Building 2 Tan paint on exterior metal panels – Building 11

The following painted components were identified with lead greater than 5,000 mg/Kg and are considered lead based paint:

Tan paint on exterior metal panels – Building 3

Fulcrum assumed that all glazed tile and wall block, metal pipe caps and plumbing, roof jackets, plumbing components, and solder or plumbing and metal brazed components were lead containing.

The identified materials contained in this report are classified as a lead containing material and are regulated by OSHA and Oregon OSHA regulations.

7.0 Lighting and Electrical Components

Lighting and electrical components (LEC) is a general term that refers to potential waste streams associated with all electrical equipment when components fail, are replaced, or are removed during renovation or demolition activities. Waste can include transformers and ballasts with polychlorinated biphenyl (PCB), non-PCB ballasts, di(2-ethylhexyl) phthalate (DEHP) ballasts, mercury vapor lamps and bulbs, mercury switches, and other waste streams.

Electrical transformers have utilized mineral oil mixed with varying quantities of PCB as dielectric fluid since the early 1950s. This mixture was also commonly used in fluid filled light ballasts prior to 1978 the end of the PCB phase out enforced by congress due to its toxicity. In 1979, DEHP was used to replace

Limited HBM Inspection 16

PCBs as a dielectric in ballasts. By 1985, the dangers of DEHP were realized and all ballasts for four-foot fixtures were manufactured without DEHP, it took six more years, until 1991, to phase out the use of DEHP in ballasts for eight-foot fixtures and high intensity fixtures. Light ballasts have also been shown to contain other hazardous materials besides PCB and DEHP, both in newer and older ballasts.

Ballasts that have been manufactured without PCB are labeled as “No PCB” or “Non-PCB,” approximately half of all ballast labeled non-PCB have been known to contain DEHP. Individual ballasts that are not labeled are assumed to be PCB containing. Sampling of individual ballasts is not traditionally completed as the testing costs exceed disposal costs.

Fluorescent lamps and bulbs have historically contained mercury. Lamps and bulbs that have low concentrations of mercury may be designated with green ends or caps. Although typically of a low quantity, the mercury present in these lamps and bulbs should be captured and recycled, not disposed of in landfills; mercury lamps and bulbs can be managed as universal waste.

Thermostatic switches have historically utilized a mercury containing device to reflect the temperature within a zone or area. Switches include wall mounted thermostats, and switches incorporated within heating and cooling systems.

7.1 Lighting and Electrical Components Regulatory Basis

This investigation was designed to identify LEC that may require segregation and special handling or waste characterization prior to disposal as a result of modernization and demolition activities.

Requirements for waste characterization are identified in Ecology’s Dangerous Waste Regulations, WAC 173-303; EPA’s Toxic Substance Control Act (TSCA), 40 CFR Part 761; EPA’s Identification and Listing of Hazardous Waste in 40 CFR Part 261; and EPA’s Designation, Reportable Quantities, and Notification in 40 CFR Part 302.

7.2 Lighting and Electrical Components Inspection Methodology

Fulcrum’s inspector conducted a visual inspection of LEC to determine potential hazardous constituents such as polychlorinated biphenyl (PCB), di(2-ethylhexyl) phthalate (DEHP) or mercury. Fulcrum completed the following inspection procedure during this LEC inspection:

Record and identify the workspace or functional area being inspected.

Identify the type and number of all lighting fixtures and record tube length, size, and number.

Observe any plastic or metal diffusers or other covers for indications of oil staining or discoloration that may be associated with an oil release, electrical fire or sparking, failed ballast, etc.

Identify number of other bulb or fixture types.

Record observations.

Limited HBM Inspection 17

7.3 Lighting and Electrical Components Identified During Inspection

Fulcrum’s inspection identified fluorescent lighting fixtures throughout the inspected areas of Buildings 1, 3 and 11. Fluorescent lamps consisted of 4-foot fixtures and compact fluorescent lights (CFLs). No mercury switches were identified. Lighting fixtures in Building 1 were observed to be hard wired and did not contain ballasts. LED lighting fixtures were identified in Building 2. See Table 4 for a summary of fluorescent lighting components identified during the inspection.

Table 4: Lighting and Electrical Component Quantities

Location Building 1 Building 3 Building 11

4-Foot Lamps 580 180 24

CFLs 2 - -

7.4 Lighting and Electrical Components Summary

Fulcrum’s LEC inspection identified 4-foot fluorescent lamps and CFLs. Lighting fixtures in Building 1 were observed to be hard wired and did not contain ballasts. LED lighting fixtures were identified throughout Building 2. Ballasts in the inspected areas of Building 3 and 11 were identified as electronic.

All lighting and electrical components that are scheduled to be removed should be recycled or disposed of in accordance with local, state, and federal requirements prior to building renovation or demolition.

8.0 Polychlorinated Biphenyls

8.1 Polychlorinated Biphenyl Caulk Regulatory Basis

Polychlorinated biphenyls (PCBs) belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were manufactured in the United States from 1929 until Congress banned the manufacture of PCBs in 1976. PCB containing products were phased out of use in 1979. They have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications. PCBs were used widely in caulk and elastic sealant materials from the 1950s through the 1970s to improve the plasticity and flexibility of the caulk. The concentrations of PCBs used in caulk ranged from 50 mg/Kg to 440,000 mg/Kg.

PCB containing materials are regulated under 40 CFR Part 761: Toxic Substances Control Act (TSCA).

In recent years, EPA has determined that caulk containing PCBs was used in many buildings dating from the 1950s through the 1970s, including schools.

Limited HBM Inspection 18

In general, buildings constructed after about 1978 are unlikely to contain PCBs in caulk or sealants. On September 25, 2009, EPA announced new guidance for school administrators and building managers with important information about managing PCBs in caulk and sealants. In general, EPA recommends, but does not require, that school buildings be evaluated for the potential presence of PCB containing caulk and sealants and that PCB caulk be removed during modernization activities. While these rules are specific to school buildings, the inspection and management protocol can be used as a guidance for inspecting and evaluating commercial and industrial buildings.

Caulk and sealants may be used in the following locations including, but not limited to:

Surrounding window and door frames Expansion and sealing joints between concrete or CMU wall panels Expansion and sealing joints between concrete floor slabs, or between the floor slab and surrounding walls Building penetration sealants

Suspect PCB containing caulk and sealants may be present below exposed finish materials and may not be apparent until modernization or demolition.

PCB that remains tightly adhered to the substrate can generally be disposed of as a PCB Bulk Product waste in a solid waste landfill, provided the landfill has granted permission for disposal. Caulks and sealants containing PCB that will be segregated from the substrate will require abatement by personnel trained in the potential hazards and work practices appropriate for PCB containing caulks.

8.2 Polychlorinated Biphenyl Caulk Inspection Methodology

Fulcrum collected suspect PCB samples from Building 1 and the inspected areas of Building 11. No suspect PCB containing caulk or sealants were observed in Building 2 or the inspected areas of Building 11.

Fulcrum utilized nitrile-type powder-free disposable gloves for sample collection. At each location a segment of caulking or sealant was removed using a utility knife. Following sampling collection each utility knife blade was disposed. Samples were placed into individual plastic bags or 4 ounce borosilicate glass jars with Teflon -lined lids. Samples were shipped by commercial carrier and submitted under chain-of-custody to Fremont Analytical, Inc. (Fremont), a Washington State accredited laboratory (C910-23) located in Seattle, Washington. All caulking and sealant samples submitted for PCB analysis were analyzed by EPA Method 8082 with a method reporting limit less than 1 mg/Kg. The following tables summarize the PCB caulking analytical results.

Limited HBM Inspection 19

Table 5: PCB Analytical Results in mg/Kg – Building 1

PCB-

Aroclors

PCB-

B1-001

Exterior Window

PCB-

B1-002

Exterior Window

PCB-

B1-003

Exterior Window

PCB-

B1-004 Fume Hood

PCB-

B1-005 Fume Hood

PCB-

B1-006 Fume Hood

PCB-

B1-007 Fume Hood

PCB-

B1-008 Fume Hood

PCB-

B1-009 Fume Hood

1016 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1221 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1232 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1242 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1248 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1254 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1260 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1262 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 1268 <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645 Total <0.465 <1.18 <1.33 <0.588 <1.33 <0.377 <0.606 <0.541 <0.645

Table 6: PCB Analytical Results in mg/Kg – Building 11

PCB-Aroclors

PCB-B11-

Exterior Door

PCB-B11-

Exterior Door

PCB-B11-

Exterior Door

PCB-B11-

Roof

PCB-B11-

Roof

PCB-B11-

Roof

1016 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1221 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1232 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1242 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1248 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1254 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1260 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1262 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 1268 <1.67 <0.714 <4.00 <0.392 <0.870 <0.385 Total <1.67 <0.714 <4.00 <0.392 <0.870 <0.385

Laboratory analysis did not identify PCBs above the method reporting limit in the samples collected. See Appendix E for laboratory analytical.

8.3 Polychlorinated Biphenyl Caulk Summary

Laboratory analysis indicated that the suspect PCB samples collected from Building 1 and Building 11 were below the reporting limit. No suspect PCB containing caulks or sealants were observed in Building 2 or the inspected areas of Building 3. See Appendix E for PCB Analytical Results.

Limited HBM Inspection 20

9.0 Conclusions

9.1 Asbestos Containing Materials

Fulcrum collected a total of 172 bulk samples of suspect ACMs from the inspected areas of Buildings 1, 3, and 11. Laboratory analysis identified the following materials to be ACM:

Building 1

White/gray door putty –…