A06_Specs_03_XAPPENDIX-C_ORCA_Chateau_Hazardous_Materials_Report.pdf

Hazardous Materials Survey Oregon Caves National Monument and Preserve

Oregon Caves Chateau

Prepared for:

Pier 9, The Embarcadero, Suite 107 San Francisco, CA 94111

Prepared By:

Vista Environmental Consulting

2984 Teagarden Street San Leandro, CA 94577

December 27, 2017 Project No. 173011004

TABLE OF CONTENTS

EXECUTIVE SUMMARY

PAGE

1. INTRODUCTION 1

2. METHODOLOGY 1

3. RESULTS 4

4. RECOMMENDATIONS 18

5. LIMITATIONS & EXCLUSIONS 20

ASBESTOS DATA KEY

APPENDICES

A. HAZARDOUS MATERIALS DATA

Hazardous Materials Summary

Asbestos Sampling Inventory Asbestos Sample and Material Location Drawings Photo Documentation Asbestos Analytical Reports Lead XRF Sequential Reports Lead Preliminary Waste Characterization Analytical Reports i

EXECUTIVE SUMMARY

Vista Environmental Consulting (Vista) reviewed existing hazardous materials survey data and performed a supplemental pre-renovation hazardous materials survey for the Oregon Caves Chateau, Oregon Caves National Monument and Preserve, 19000 Caves Hwy, Cave Junction, OR 97523 (Project Site). The survey was performed to identify and sample accessible suspect asbestos-containing materials, representative building components for the presence of lead-containing surface coatings/lead-based paints (LCSC/LBP), Polychlorinated Biphenyls (PCBs) in light fixture ballasts, and other hazardous materials including chemicals of concern that may be in the path of construction for the renovation project. Vista also performed preliminary waste characterization estimate sampling of building materials for lead. Vista performed the survey on October 10 and 11, 2017.

The results of Vista’s review of existing asbestos survey data and Vista’s supplemental hazardous materials survey indicate that the following hazardous materials may be in the path of construction areas:

Asbestos-Containing Materials

MATERIAL DESCRIPTION LOCATION ESTIMATED

QUANTITY

Wallboard/Joint Compound White/White

Basement 2 - Toilet, North Wall of Walk-in Refrigerators, Hallway to Staff Dining, Storage

Areas, Staff Lounge, Staff Bath, and Staff Bedrooms

5, 500 SF

Vinyl Floor Tile/Mastic 9" Light Brown Multi Colored/Black

Basement 2 - Staff Lounge, Staff Bedrooms and Closets 1,250 SF

Vinyl Floor Tile 9" Beige with Yellow & Red Streaks Basement 2 - Staff Dining 875 SF

Vinyl Floor Tile/Mastic 9" Green & White Checkerboard/Black 1st Floor - Linen Closet 60 SF

Vinyl Floor Tile/Mastic 9' Green Mottled/Black 2nd Floor - Linen Closet 55 SF

Vinyl Floor Tile 9" White with Green Streaks

3rd Floor - Room 304, 305, 311, and 312 South Bath 175 SF

Vinyl Sheet Flooring Off-White, Stone Chip 3rd Floor - Room 312 West Bath 25 SF

Flange Gasket Fire Suppression System, Concealed Basement 3 - Mechanical Room 6 SF

Insulators Unknown, Electric Boxes Basement 3 - Mechanical Room; Basement 2 - Laundry Area 5 SF

Insulation Paper Unknown, Electric Boxes Basement 3 - Mechanical Room; Basement 2 - Laundry Area 5 SF

Vinyl Floor Tile 9" Beige Basement 2 - Laundry Room Table under Vinyl Sheet Flooring 35 SF ii

MATERIAL DESCRIPTION LOCATION ESTIMATED

QUANTITY

Insulation Gray, Pipe & Fitting, "Air Cell"

Visible: Basement 2 - Laundry, East of Walk-in Refrigerators, Staff Bedroom 2 and 3;

Basement 1 - Ceiling Plenum above Kitchen Entrance. Assumed: Interstitial Spaces to

Radiators, Sinks, Showers and Tubs.

3,200 LF

Texture Coat White, Medium Basement 2 - Storage, Staff Lounge, and Staff Bedrooms 3,125 SF

Vinyl Floor Tile 12" Green Basement 2 - Staff Bath 15 SF

Vinyl Floor Tile 12" White Basement 2 - Staff Bath 15 SF

Vinyl Sheet Flooring Light Brown, Battle Ship Basement 1 - Coffee Shop and Kitchen Foyers;

2nd Floor - Central Storage 1,150 SF

Vinyl Sheet Flooring Off-White With Gold Flecks 3rd Floor - Room 303 Bath 50 SF

Insulation White, Fire Door Basement 2 - Stairway to Basement 1; 2nd Floor - Stairway to 3rd Floor

50 SF

(2 Doors)

Vinyl Floor Tile Unknown, Beige Basement 1 - Gift Shop 2,250 SF

Lead-Based Paint and Materials

Floor Room Component Substrate Color Condition Pb Units

B3 Outside Door Wood Brown Deteriorated 0.08 mg/cm2

B3 Outside Fire Escape Metal Brown Deteriorated 3 mg/cm2

B2 Outside Stairs Metal Brown Intact 10.1 mg/cm2

B2 Staff Dining Wall Concrete White Intact 6.4 mg/cm2

1 102 Door Wood Gray Intact 1.8 mg/cm2

1 102 Window Wood White Intact 7.2 mg/cm2

1 105 Wall Plastic Beige Intact 4.6 mg/cm2

1 Outside Stairs Metal Brown Intact 4.4 mg/cm2

1 Outside Fire Escape Wood Brown Intact 10.1 mg/cm2

1 Women’s RR Door Frame Wood White Intact 4 mg/cm2

1 Women’s RR Door Wood White Intact 4.6 mg/cm2

2 202 Wall Plastic Beige Intact 7.6 mg/cm2

2 209 Wall Plastic White Intact 3.8 mg/cm2

2 214 Door Frame Wood White Intact 3.4 mg/cm2

2 214 Door Wood White Intact 3.7 mg/cm2

2 214 Wall Wood White Intact 3.9 mg/cm2 iii

2 214 Window Casing Wood White Intact 4.3 mg/cm2

2 214 Trim Wood White Intact 4.8 mg/cm2

2 214 Window Wood White Intact 6.2 mg/cm2

2 214 Cabinet Wood White Intact 6.6 mg/cm2

2 214 Wall Ceramic Tan Intact 7.2 mg/cm2

2 214 Window Casing Wood White Intact 7.9 mg/cm2

2 215 Door Frame Wood Varnish Intact 1.9 mg/cm2

2 215 Door Wood Varnish Intact 2.2 mg/cm2

2 Stairwell Baseboard Wood Gray Intact 1.5 mg/cm2

3 304 Trim Wood Brown Intact 1.2 mg/cm2

3 304 Window Casing Wood Brown Intact 1.2 mg/cm2

3 304 Window Wood White Intact 1.5 mg/cm2

3 304 Door Frame Wood Gray Intact 1.6 mg/cm2

3 304 Window Casing Wood White Intact 1.7 mg/cm2

3 Storage Door Wood Brown Intact 1.1 mg/cm2

3 Storage Window Wood Brown Intact 1.7 mg/cm2

3 Storage Baseboard Wood Brown Intact 2 mg/cm2

Lead Preliminary Waste Characterization

Sample # Building Materials Pb Units

ORCA-WASTE-01 Painted Plaster, Ceramic Tiles, Painted Concrete, Painted Wood, Unpainted Wood, “NuWood” Panels, Painted Fire Escape Wood <0.3 mg/l

Other Hazardous Materials

Material Contaminant Estimated Quantity

Fluorescent Light Tubes Universal Waste 338 Fluorescent Tubes (4' Length) Universal Waste 152

Compact Fluorescent Universal Waste 17 Batteries: Emergency Lights, Exit Signs & Back-up Universal Waste 18

Light Fixture Ballasts Polychlorinated Biphenyls 76 Refrigerators/Freezers Ozone Depleting Chemicals 8

Smoke Detectors Low-Level Radiation 58 Compressor and Generators Petroleum Products 2 iv

Chemical Inventory

Chemical Name State Estimated Quantity

Location Other

Information

Acrylic Glaze Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet Classic Color

No-Rinse TSP Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet Jasco

Orange Power Degreaser

Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet

NA

Air Compressor Oil Liquid 1 Quart B3: Mechanical Room -

Flammable Cabinet

NA

CitrusStrip Liquid 3 Quarts B3: Mechanical Room -

Flammable Cabinet Stripping Gel

Paint Thinner Liquid 2 Gallons B3: Mechanical Room -

Flammable Cabinet Sunnyside

Cement Additive Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet Acryl 60

Stain Liquid 3 Gallons B3: Mechanical Room -

Flammable Cabinet

NA

Lacquer Thinner Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet

NA

Gasoline Liquid 5 Gallons B3: Mechanical Room -

Flammable Cabinet

NA

Polyurethane Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet

NA

Rubbing Alcohol Liquid 1/2 Gallon B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Window Cleaner Liquid 1/2 Gallon B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Liquid Drain Cleaner Liquid 1/2 Gallon B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Metal Polish Liquid 8 oz.

B3: Mechanical Room - Other

Haz Mats Cabinet Brasso

Penetrating Oil Liquid 16 oz.

B3: Mechanical Room - Other

Haz Mats Cabinet

WD-40

PVC Pipe Glue Liquid 16 oz.

B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Pipe Joint Compound Liquid 8 oz.

B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Anti-Seize Lubricant Liquid 8 oz.

B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Solder Weld Solid 7.1 grams B3: Mechanical Room - Other

Haz Mats Cabinet

NA

Paint/Stain Liquid 100 Gallons B3: Mechanical Room Shelf NA

Spray Paint Liquid 3,900 grams B3: Mechanical Room Shelf NA v

Estimated Quantity

Location Other

Information

Paint/Primer Liquid 9 Gallons B2: Staff Dining Room NA

Oven Cleaner Liquid 128 oz. B2: Laundry Storage Keystone Sysco

Degreaser Liquid 2 Gallon B2: Laundry Storage Reliance Sysco

Pot & Pan Degreaser Liquid 2 Gallon B2: Laundry Storage Reliance Sysco

Heavy Duty Degreaser Solid 5 Gallon B2: Laundry Storage Keystone

Orange Surface Cleaner

Solid 2 Gallon B2: Laundry Storage Sysco Keystone

Aerosol Contact Insecticide

Liquid 90 oz. B2: Laundry Storage Sysco Keystone

Germicidal Ultra Bleach

Liquid 3 Gallons B2: Laundry Storage Sysco Keystone

Floor Cleaner & Conditioner

Liquid 4 Gallons B2: Laundry Storage First Street

Lime Away Liquid 1 Gallon B2: Laundry Storage Keystone Sysco

High Traffic Floor Polish

Liquid 2 Gallons B2: Laundry Storage Zep

Pine Multi-Surface Cleaner

Liquid 2 Gallons B2: Laundry Storage Keystone Sysco

Wood Oil Liquid 2 Gallons B2: Laundry Storage Keystone Sysco

Reliance Glass Cleaner Liquid 2 Gallons B2: Laundry Storage Keystone Sysco

The Hazardous Materials Summary, Asbestos Sampling Inventory, Asbestos Sample and Materials Locations Drawings, Photo Documentation, Asbestos Analytical Reports, Lead XRF Sequential Reports, and Lead Preliminary Waste Characterization Analytical Reports can be found in Appendix A – Hazardous Materials Data.

All asbestos abatement projects must be conducted by an Oregon Department of Environmental Quality (DEQ) licensed contractor under the provisions of OAR 340-248-0120.

Should the removal of identified regulated friable asbestos-containing materials involve > 3 square feet or > 3 linear feet, then a 10 day advance notification (Form ASN 1) to the DEQ is required under the provisions of OAR 340-248-0260. For removal of non-friable asbestos, a 5 day advance notification (Form ASN 6) is required to the DEQ under the provisions of OAR 340-248-0260.

vi

All activities involving potential and identified lead-based and lead-containing paints, coatings, and materials should be conducted in accordance with, Title 29 CFR 1926.62, Title 40 CFR 745, and U.S.

Department of Housing and Urban Development Guidelines For the Evaluation and Control of Lead- Based Paint Hazards in Housing pursuant to Title X of the Housing and Community Development Act of 1992 (HUD Guidelines).

Any welding, cutting or heating of metal surfaces containing surface coatings should be conducted in accordance with Title 29 CFR 1926.354 Welding, Cutting, and Heating in Way of Preservative Coatings, which requires surfaces covered with toxic preservatives, and in enclosed areas, be stripped of all toxic coatings for a distance of at least 4 inches, in all directions, from the area of heat application prior to the initiation of such heat application, or Title 29 CFR 1926.353 Ventilation and Protection in Welding, Cutting and Heating.

All potential and identified Hazardous Materials impacted by the work should be removed and disposed of in accordance with Title 40 CFR 260 to 263 Resource Conservation and Recovery Act (RCRA).

After demolition, the resulting wastes may be hazardous under federal RCRA standards for lead and/or other metals and therefore require proper handling, packaging, labeling, and transportation under a proper manifest to a permitted hazardous waste storage, treatment and disposal facility.

The waste characterization estimate data found in this report are estimates only and cannot be used in place of waste characterization sampling of each selective demolition segregated waste stream prior to shipment for disposal. Further, all surface preparation, paint removal wastes, and paint debris on the ground must be considered RCRA Class I hazardous wastes unless sampling proves otherwise.

All potential and identified Universal Waste materials (UW) impacted by the work should be removed and recycled or disposed of in accordance with Title 40 CFR 273. Universal wastes include but are not limited to batteries; mercury containing thermostats & gauges; high intensity/sodium vapor and fluorescent lighting tubes; electronic components, and other items.

All suspect (pre-1979) PCB ballasts must be visually inspected prior to disposal to determine if they contain PCB’s. Those ballasts marked No PCB’s or PCB Free can be considered as such and should be treated as UW - electronic waste. All PCB-containing devices, including, but not limited to ballasts should be removed or have the oils removed and properly handled, collected, stored, transported and recycled or disposed of by an approved recycling or disposal facility in accordance with the requirements of Title 40, CFR 761.

vii

Devices containing ozone depleting chemicals, low level radioactive sources, paint or other chemicals, should be collected, waste characterized, disposed or recycled according to Oregon and Federal rules and regulations, whichever is more stringent.

The documents found in the appendices are not stand-alone documents and should not be separated from this report. Any discrepancies between the contractual bid set documentation and site visits must be submitted in writing to the Owner or Owner’s representative, prior to bidding. Should materials similar to those identified in this report, or if other forms of suspect hazardous materials are encountered, contractors should be instructed to immediately cease work activities which may initiate an exposure episode, and notify the appropriate management personnel.

Report prepared for the Company by:

Christopher R. Burns Senior Project Manager

Oregon Caves Chateau December 27, 2017 Hazardous Materials Survey Project No. 173011004

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1.0 INTRODUCTION

Vista Environmental Consulting (Vista) performed a pre-renovation hazardous materials survey for the Oregon Caves Chateau, Oregon Caves National Monument and Preserve, 19000 Caves Hwy, Cave Junction, OR 97523 (Project Site) as a sub-consultant to the Architectural Resources Group, Inc. (ARG).

The purpose of this survey was to identify hazardous materials specifically impacted by the renovation project so they can be removed if impacted and so any resulting waste can be properly characterized for disposal. The data provided in this report can assist all parties involved in this project make informed decisions regarding regulatory compliance and the health and safety of their employees. This survey included the following:

• Previous hazardous materials survey data were reviewed and considered for current sampling approach.

• Visible and accessible suspect asbestos-containing materials (ACM) were assessed and sampled to determine asbestos content.

• Representative painted and coated building components were assessed and categorized based upon standard selective demolition practices and sampled for lead content which can be used for worker protection estimates.

• Preliminary waste characterization estimate sampling for Lead

• Visible and accessible materials commonly found in buildings which can potentially have hazardous properties that are regulated were assessed, but not sampled. These materials include, but are not limited to:

Universal Waste (UW) materials, such as non-incandescent lamps, batteries, mercury-containing devices, and electronic waste; Batteries include, but are not limited to those found in exit signs, emergency lights, fire alarm systems, and back-up power system;

Polychlorinated biphenyls (PCBs) containing devices such as lamp ballasts, wet-type transformers, and hydraulic systems;

Devices which may contain ozone depleting chemicals, such as Heating, Ventilation and

Air Conditioning (HVAC) systems, refrigerators, freezers, and water coolers/fountains;

Other chemicals of concern

2.0 METHODOLOGY

Vista performed the hazardous materials survey on October 10 and 11, 2017. The asbestos survey was conducted by Christopher Burns and Javier Rocha, EPA Asbestos Model Accreditation Plan (MAP) accredited and trained AHERA asbestos inspectors. The lead paint screening survey was conducted by

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Christopher Burns who is a lead inspector certified by an EPA-authorized lead-based paint program.

Other suspect hazardous materials were visually identified by Javier Rocha who is Hazardous Waste Operations and Emergency Response (HAZWOPER) trained.

The survey involved taking material samples but didn’t include destructive testing involving demolition of components and finishes to reveal concealed suspect materials. Vista’s intent was to perform a thorough survey with a good faith effort to access all materials down to the structural or mechanical components and/or interstitial spaces without using destructive investigation techniques. Materials similar to those in this report may be present in areas which were not accessed.

Vista reviewed and used historical data from MACTEC Engineering and Consulting, Inc. (MACTEC) report titled “Asbestos-Containing Materials Survey Report for National Park Service United States Department of The Interior Oregon Caves National Monument Cave Junction, Oregon” dated November 17, 2011 where appropriate. The referenced MACTEC report should be included with this report for supporting documentation wherever this report is used. Suspect materials that were not addressed in that report, or needed clarification because of ambiguous homogeneity or location, were sampled. Additional samples of some materials listed as “none detected” were also sampled to confirm analytical results.

Materials that had historical data indicating that they were asbestos or were inaccessible at the time of this survey were assumed to be asbestos.

2.1 Asbestos

The asbestos survey was performed generally in conformance with the AHERA protocol (40 CFR Part 763, Subpart E). Visual identification was performed by assessing visible and accessible structural, architectural, and mechanical components for the presence of suspect ACM at the project site.

This ACM survey was conducted in the following manner:

Suspect ACM was categorized into homogeneous materials. A homogeneous material is defined as being a surfacing material, thermal system insulation, or miscellaneous material which is uniform in color and texture. It may also be additionally subcategorized using the date of installation, when available.

A sampling scheme was developed based upon the location and quantity of the suspect homogeneous ACM. A rough order of magnitude estimate of each suspect homogenous ACM was calculated and recorded for future reference. A sampling scheme, including a specific number of samples per suspect homogeneous ACM, was calculated prior to sampling.

Sampling guidelines established by the United States Environmental Protection Agency (USEPA) were utilized for sampling each suspected homogeneous ACM. Methods described in Title 29 CFR 1926.1101 were utilized in the collection of each suspect homogeneous ACM sample.

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Trained AHERA asbestos inspector personnel, using appropriate sampling tools and leak-tight closable bags, collected building materials that were suspected to contain ACM.

Each suspect ACM sample was collected and sealed in its container and appropriately labeled with a unique sample identification number and recorded on an asbestos bulk sampling log. Each log contains a chain-of-custody to assure the proper transition of the samples from Vista to the analytical laboratory.

Sampling tools were decontaminated by using a clean wet cloth between collection of each of the suspect samples to prevent the possibility of cross contamination of subsequent suspect ACM samples.

Suspect ACM samples were delivered, under proper chain-of-custody protocol, to Forensic Analytical Laboratories in Hayward, California. Forensic Analytical Laboratories is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) and American Industrial Hygiene Association (AIHA). The samples were submitted for analysis by Polarized Light Microscopy (PLM) utilizing dispersion staining techniques in accordance with the EPA’s “Method for the Determination of Asbestos in Bulk Building Materials” U.S. EPA/600/R-93/116, Visual Area Estimate, dated July 1993 and adopted by the NVLAP as Test Method Code 18/A01.

Representative samples of “trace” asbestos materials were further analyzed by 400-point bulk asbestos point count utilizing National Emission Standards for Hazardous Air Pollutants (NESHAP) Final Rule, 40 CFR, Part 61 methodology.

2.2 Lead

Paint and Materials Vista’s lead construction screening survey used an X-Ray Fluorescence (XRF) direct read spectrum analyzer device to take readings of representative painted and coated surfaces for evaluation of lead levels for worker health and safety and preliminary waste characterization prior to construction activities. The device used was a NITON Corporation XRF Spectrum Analyzer, Model XLp- 300 A. This device is a solid-state detector optimized for lead L-shell and K-shell X-ray detection and uses a 40 mCi 109Cd (1,480 Mbq) isotope for an excitation source.

This survey was a limited screening for the purpose of characterizing the lead content in paint and coatings likely to be disturbed during work activities. For this purpose, XRF analysis was used to screen for lead levels and provides results that are generally representative of typical conditions but are not inclusive of all painted/coated surfaces present at the Project Site. This survey was not a surface by surface inspection as outlined in the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing pursuant to Title X of

- 4 -the Housing and Community Development Act of 1992. These analytical data can be helpful in evaluation of lead-related environmental risks in general, but cannot be used to calculate worker exposures and are not a substitute for employee exposure monitoring or waste stream sampling.

Preliminary Waste Characterization Estimate One sample comprised of painted plaster, ceramic tile, painted concrete, painted wood, unpainted wood, and “NuWood” panels was collected. Painted and unpainted metal was not included, because metal is usually salvaged and recycled during demolition projects. Asbestos-containing materials were not included since these materials must be removed prior to demolition activities. Materials stored on the Project Site that were not part of the building structure were not accessed.

The sample was delivered, under proper chain-of-custody protocol, to FAL in Hayward, California. FAL is accredited under American Industrial Hygiene Association (AIHA) and the Environmental Lead Laboratory Accreditation Program (ELLAP) for multiple metals analysis. The samples were prepared and analyzed by method Toxicity Characteristic Leaching Procedure (TCLP) EPA 1311/7000B.

2.3 Other Hazardous Materials

Devices with potential hazardous materials were visually identified during the survey walk-through and their quantities were estimated and recorded. No attempt was made to disassemble devices or sample suspect materials within the devices. For example, fluorescent light fixtures must be presumed to contain Universal Waste lamps, and ballasts which contain PCB oil are electronic waste, pending removal and disassembly of each unit to determine explicit product specific information that proves otherwise. Other contaminants of concern were visually inspected and quantified

3.0 RESULTS

3.1 Asbestos

The table below provides a combined summary of detected asbestos containing materials for this project based on a review of the existing referenced MACTEC survey report (dated 2011) and Vista’s supplemental survey and associated results (reported herein) of the bulk samples collected for asbestos, and analyzed by PLM Methodology.

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HOMO.

ID MATERIAL DESCRIPTION LOCATION CAL/OSHA

CLASS

NESHAPS

CATEGORY

A Wallboard/Joint Compound White/White

Basement 2 - Toilet, North Wall of Walk-in

Refrigerators, Hallway to Staff Dining, Storage

Areas, Staff Lounge, Staff Bath, and Staff Bedrooms

Class II

NA (Composite <1% by Point

Count, Wallboard=ND, Joint Compound=2%)

B Vinyl Floor Tile/Mastic

9" Light Brown Multi Colored/Black

Basement 2 - Staff Lounge, Staff Bedrooms and

Closets Class II Category I - Non-

Friable

C Vinyl Floor Tile 9" Beige with Yellow & Red Streaks Basement 2 - Staff Dining Class II Category I - Non-

Friable

D Vinyl Floor Tile/Mastic

9" Green & White Checkerboard/Black 1st Floor - Linen Closet Class II Category I - Non-

Friable

E Vinyl Floor Tile/Mastic

9' Green Mottled/Black 2nd Floor - Linen Closet Class II Category I - Non-

Friable

F Vinyl Floor Tile 9" White with Green Streaks

3rd Floor - Room 304, 305, 311, and 312 South Bath Class II Category I - Non-

Friable

G Vinyl Sheet Flooring

Off-White, Stone Chip

3rd Floor - Room 312 West Bath Class II Friable (RACM when Removed)

H Flange Gasket Fire Suppression System, Concealed

Basement 3 - Mechanical Room Class II Category I - Non-

Friable

Q Insulators Unknown, Electric Boxes

Basement 3 - Mechanical Room; Basement 2 -

Laundry Area Class II Category II -

Non-Friable

R Insulation Paper Unknown, Electric Boxes

Basement 3 - Mechanical Room; Basement 2 -

Laundry Area Class II Category II -

Non-Friable

W Vinyl Floor Tile 9" Beige Basement 2 - Laundry

Room Table under Vinyl Sheet Flooring

Class II Category I - Non- Friable

X Insulation Gray, Pipe & Fitting, "Air Cell"

Visible: Basement 2 - Laundry, East of Walk-in

Refrigerators, Staff Bedroom 2 and 3;

Basement 1 - Ceiling Plenum above Kitchen

Entrance. Assumed:

Interstitial Spaces to

Radiators, Sinks, Showers and Tubs.

Class I Friable (RACM when Removed)

Y Texture Coat White, Medium Basement 2 - Storage, Staff

Lounge, and Staff Bedrooms

Class II Friable (RACM when Removed)

FF Vinyl Floor Tile 12" Green Basement 2 - Staff Bath Class II Category I - Non- Friable

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ID MATERIAL DESCRIPTION LOCATION CAL/OSHA

CLASS

NESHAPS

CATEGORY

GG Vinyl Floor Tile 12" White Basement 2 - Staff Bath Class II Category I - Non- Friable

MM Vinyl Sheet Flooring

Light Brown, Battle Ship

Basement 1 - Coffee Shop and Kitchen Foyers; 2nd Floor - Central Storage

Class II Friable (RACM when Removed)

ZZ Vinyl Sheet Flooring

Off-White With Gold Flecks 3rd Floor - Room 303 Bath Class II Friable (RACM when Removed)

M3 Insulation White, Fire Door Basement 2 - Stairway to Basement 1; 2nd Floor -

Stairway to 3rd Floor Unclassified Friable (RACM when Removed)

N3 Vinyl Floor Tile Unknown, Beige Basement 1 - Gift Shop Class II Category I - Non- Friable

NESHAPS classifications are based upon the material’s condition at the time of the survey or as rendered as a result of standard manual removal/demolition techniques. The use of “mechanical means”, non-standard or other aggressive removal/demolition techniques may result in a different classification.

Based on the results of the bulk samples collected for asbestos, and analyzed by PLM, detectable concentrations of asbestos were NOT detected in the following sampled materials:

HOMOGENEOUS ID MATERIAL DESCRIPTION # OF SAMPLES

C Mastic Yellow 1

F Mastic Yellow 1

I Concrete Gray, Foundation Walls, Stairs 3

J Gasket Beige, Boiler 1

K Gasket Green Boiler 1

L Gasket Black, Fire Suppression System 1

M Insulation Wire, White 1

N Insulation Wire, Black 1

O Insulation White, Tank 3

P Jacket Beige, 4" OD Pipe 2

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HOMOGENEOUS ID MATERIAL DESCRIPTION # OF SAMPLES

S Vinyl Floor Tile/Mastic 12" Beige with Brown Streaks/ Yellow 1

T Basecove/Mastic 4" White/Brown 2

U Paint/Plaster White/Gray, Rough 5

V Vinyl Sheet Flooring Beige, Square Pattern 1

W Mastic Yellow 1

Z Vinyl Floor Tile/Mastic 12" Green/Yellow 1

AA Basecove/Mastic 4" Green/Beige 1

BB Acoustic Ceiling Tile White & Brown, Ceiling "NuWood", Various Sizes 3

CC Mastic Yellow, Plastic Wainscot 1

DD Vinyl Sheet Flooring Beige, Polygon, Counter 1

FF Mastic Black 1

GG Mastic Black 1

HH Vinyl Floor Tile/Mastic 12" Blue/Beige 1

II Basecove/Mastic 4" Black/ Brown 2

JJ Panels Brown, Wall, Vertical "NuWood" 3

KK Acoustic Ceiling Tiles 12" White, Uniform Hole 1

LL Vinyl Sheet Flooring Beige, Pebble Pattern 1

NN Vinyl Sheet Flooring Off-White, Speckled 1

OO Acoustic Ceiling Tile 12" Non Uniform Hole, Walls & Ceiling 1

PP Vinyl Sheet Flooring Gray, Black Specks 1

QQ Basecove/Mastic 4" Gray/Beige 1

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RR Fire Brick Beige, Fireplace 1

SS Mortar Gray, Fireplace 1

TT Vinyl Sheet Flooring Black, Phone Booth 1

UU Vinyl Sheet Flooring Gray, with Pink Speckles 2

VV Mortar/Grout Gray/White, 4" Ceramic Tile 1

WW Mortar/Grout White/Gray, 4" Ceramic Tile 1

XX Vinyl Sheet Flooring Beige, Small Square Pattern, Shower 1

YY Vinyl Sheet Flooring Brown, Striped 1

A3 Vinyl Floor Tile/Mastic 12" White/Yellow 1

B3 Wallboard/Joint Compound White/White 1

C3 Wallboard/Joint Compound White/White 1

D3 Vapor Paper Black, Exterior Wall 2

E3 Putty White, Window 3

F3 Glazing White, Windows on Doors 2

G3 Underlayment Black, Roof, Under Wood Shingle 2

H3 Vapor Barrier Black, Generator, Overhang 1

I3 Paint/Concrete Masonry Unit/Mortar

Brown/Gray/Gray, Overhang Roof 1

J3 Asphalt Black 3

K3 Flex Connector White/HVAC 1

L3 Jacketing White, Water Heater 1

N3 Mastic Black 1

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O3 Vinyl Floor Tile/Mastic Unknown, White/Black 1

P3 Vinyl Sheet Flooring/Vapor Paper/Mastic Brown/Black/Black 1

Q3 Vapor Barrier Black, Hardwood Floors 1

R3 Panels Brown "Homasote" 1

S3 Wallboard/Joint Compound White/White, Model Room 1

T3 Wallboard/Joint Compound White/White, Staff Kitchen 1

U3 Vinyl Sheet Flooring Dark Brown, Battleship 1

V3 Vinyl Sheet Flooring Beige With Brown Lines, Under

NN 1

W3 Vinyl Sheet Flooring White with Beige Lines, Under V3 and NN 1

X3 Wall Panel White & Brown, Faux Ceramic 1

Y3 Wallboard/Joint Compound White/White, Bathrooms 1

3.2 Lead

Paint and Materials For purposes of this survey, and in accordance with Title 40 CFR 745 and the HUD Guidelines the bulk paint chip sample or XRF direct read instrument results were interpreted as follows:

1. Lead-based paints (LBP) are present when bulk paint chip samples revealed a lead concentration of

≥5,000 milligrams per kilogram (mg/kg) or parts per million (ppm), 0.5% by weight (wt%) or ≥1.0 milligrams per centimeter squared (mg/cm²) via XRF direct read instrument sampling.

2. Lead-containing paints are present when bulk paint chip samples revealed a lead concentration of <5,000 mg/kg or 0.5 wt% down to the analytical detection limit of the analysis, or <1.0 milligrams per centimeter squared (mg/cm²) via XRF direct read instrument sampling down to the detection limit of the device.

3. “No lead detected” was determined when bulk paint chip samples did not reveal a lead concentration above the analytical detection limit of the laboratory or direct read instrument sampling device.

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The bulk paint chip results or XRF direct read instrument results for this survey indicated that the following building components and respective surface coatings have lead concentrations defining them as

LBP:

Floor Room Component Substrate Color Condition Pb Units

B3 Outside Fire Escape Metal Brown Deteriorated 3 mg/cm2

B2 Outside Stairs Metal Brown Intact 10.1 mg/cm2

B2 Staff Dining Wall Concrete White Intact 6.4 mg/cm2

1 102 Door Wood Gray Intact 1.8 mg/cm2

1 102 Window Wood White Intact 7.2 mg/cm2

1 Outside Stairs Metal Brown Intact 4.4 mg/cm2

1 Outside Fire Escape Wood Brown Intact 10.1 mg/cm2

1 Women’s RR Door Frame Wood White Intact 4 mg/cm2

1 Women’s RR Door Wood White Intact 4.6 mg/cm2

2 214 Door Frame Wood White Intact 3.4 mg/cm2

2 214 Door Wood White Intact 3.7 mg/cm2

2 214 Wall Wood White Intact 3.9 mg/cm2

2 214 Window Casing Wood White Intact 4.3 mg/cm2

2 214 Trim Wood White Intact 4.8 mg/cm2

2 214 Window Wood White Intact 6.2 mg/cm2

2 214 Cabinet Wood White Intact 6.6 mg/cm2

2 214 Window Casing Wood White Intact 7.9 mg/cm2

2 215 Door Frame Wood Varnish Intact 1.9 mg/cm2

2 215 Door Wood Varnish Intact 2.2 mg/cm2

2 Stairwell Baseboard Wood Gray Intact 1.5 mg/cm2

3 304 Trim Wood Brown Intact 1.2 mg/cm2

3 304 Window Casing Wood Brown Intact 1.2 mg/cm2

3 304 Window Wood White Intact 1.5 mg/cm2

3 304 Door Frame Wood Gray Intact 1.6 mg/cm2

3 304 Window Casing Wood White Intact 1.7 mg/cm2

3 Storage Door Wood Brown Intact 1.1 mg/cm2

3 Storage Window Wood Brown Intact 1.7 mg/cm2

3 Storage Baseboard Wood Brown Intact 2 mg/cm2

- 11 -

The bulk paint chip sample results or XRF direct read instrument results for this survey indicate that the following building components and respective surface coatings have lead concentrations, in excess of the level for compliance with trigger activities, as defined Title 29 CFR 1926.62:

Floor Room Component Substrate Color Condition Pb Units

B3 Outside Door Wood Brown Deteriorated 0.08 mg/cm2

B3 Outside Door Frame Wood Brown Deteriorated 0.1 mg/cm2

B3 Outside Window Casing Wood Brown Deteriorated 0.02 mg/cm2

B3 Outside Window Sill Wood Brown Deteriorated 0.07 mg/cm2

B3 Outside Wall Wood Brown Deteriorated 0.07 mg/cm2

B2 Outside Door Wood Brown Intact 0.04 mg/cm2

B2 Outside Door Frame Wood Brown Intact 0.3 mg/cm2

B2 Outside Door Frame Wood Brown Intact 0.05 mg/cm2

B2 Outside Door Wood Brown Intact 0.08 mg/cm2

B2 Outside Window Wood Brown Intact 0.07 mg/cm2

B2 Outside Window Casing Wood Brown Intact 0.1 mg/cm2

B1 Outside Window Sill Wood Brown Deteriorated 0.01 mg/cm2

B1 Outside Window Wood Brown Deteriorated 0.14 mg/cm2

B1 Outside Door Wood Brown Intact 0.08 mg/cm2

B1 Outside Door Frame Wood Brown Intact 0.09 mg/cm2

B1 Outside Door Frame Wood Brown Intact 0.04 mg/cm2

B1 Outside Door Wood Brown Intact 0.1 mg/cm2

B1 Outside Window Wood Brown Intact 0.18 mg/cm2

B1 Outside Window Frame Wood Brown Deteriorated 0.02 mg/cm2

1 Outside Door Wood Brown Intact 0.03 mg/cm2

1 Outside Door Frame Wood Brown Intact 0.06 mg/cm2

1 Outside Window Wood Brown Intact 0.08 mg/cm2

1 Outside Window Sill Wood Brown Intact 0.22 mg/cm2

1 Outside Fascia Wood Brown Intact 0.04 mg/cm2

1 Outside Window Wood Brown Intact 0.09 mg/cm2

1 Outside Window Sill Wood Brown Intact 0.12 mg/cm2

2 Outside Window Sill Wood Brown Intact 0.12 mg/cm2

- 12 -

2 Outside Window Sill Wood Brown Intact 0.06 mg/cm2

2 Outside Screen Wood Brown Intact 0.02 mg/cm2

3 Outside Window Wood Brown Intact 0.07 mg/cm2

3 Outside Window Sill Wood Brown Deteriorated 0.29 mg/cm2

3 Outside Window Sill Wood Brown Deteriorated 0.07 mg/cm2

3 Outside Window Wood Brown Deteriorated 0.1 mg/cm2

3 Outside Window Wood Brown Deteriorated 0.04 mg/cm2

3 Outside Window Sill Wood Brown Deteriorated 0.16 mg/cm2

3 Outside Beam Wood Brown Deteriorated 0.09 mg/cm2

3 304 Door Wood Brown Intact 0.14 mg/cm2

3 304 Door Frame Wood Brown Intact 0.03 mg/cm2

3 304 Baseboard Wood Brown Intact 0.3 mg/cm2

3 304 Window Wood Brown Intact 0.4 mg/cm2

3 304 Radiator Metal Silver Intact 0.13 mg/cm2

3 304 Door Wood Gray Intact 0.8 mg/cm2

3 304 Pipe Metal Beige Intact 0.11 mg/cm2

3 304 Wainscot Wood Beige Intact 0.01 mg/cm2

3 304 Tub Porcelain White Intact 0.01 mg/cm2

3 Hall Door Nuwood Gray Intact 0.04 mg/cm2

3 Hall Door Frame Wood Gray Intact 0.03 mg/cm2

3 Hall Baseboard Wood Gray Intact 0.8 mg/cm2

3 304 Window Wood Brown Intact 0.08 mg/cm2

3 304 Window Casing Wood Brown Intact 0.29 mg/cm2

3 304 Door Wood Brown Intact 0.03 mg/cm2

3 304 Door Frame Wood Brown Intact 0.05 mg/cm2

3 304 Floor Wood Varnish Intact 0.01 mg/cm2

3 304 Sink Porcelain White Intact 0.01 mg/cm2

3 304 Wall Nuwood Beige Intact 0.28 mg/cm2

3 Closet Floor Vinyl Brown Intact 0.28 mg/cm2

3 Closet Door Frame Wood Brown Intact 0.01 mg/cm2

3 Storage Door Frame Wood Brown Intact 0.9 mg/cm2

3 Storage Trim Wood Brown Intact 0.8 mg/cm2

- 13 -

3 Storage Window Casing Wood Brown Intact 0.4 mg/cm2

2 Hall Door Metal Red Intact 0.16 mg/cm2

2 Hall Door Wood Gray Intact 0.12 mg/cm2

2 Hall Door Frame Wood Gray Intact 0.02 mg/cm2

2 Hall Radiator Metal Silver Intact 0.05 mg/cm2

2 Hall Pipe Metal Beige Intact 0.07 mg/cm2

2 Hall Baseboard Wood Gray Intact 0.08 mg/cm2

2 Hall Trim Wood Gray Intact 0.1 mg/cm2

2 202 Wall Plastic Beige Intact 7.6 mg/cm2

2 209 Wall Plastic White Intact 3.8 mg/cm2

2 209 Door Wood Gray Intact 0.11 mg/cm2

2 209 Door Frame Wood Gray Intact 0.16 mg/cm2

2 209 Baseboard Wood Gray Intact 0.1 mg/cm2

2 209 Floor Wood Gray Intact 0.02 mg/cm2

2 209 Window Wood Gray Intact 0.5 mg/cm2

2 209 Window Sill Wood Brown Intact 0.12 mg/cm2

2 209 Wall Ceramic Beige Intact 0.01 mg/cm2

2 215 Window Sill Wood Gray Intact 0.6 mg/cm2

2 215 Window Wood Gray Intact 0.12 mg/cm2

2 202 Window Wood White Intact 0.6 mg/cm2

2 202 Wall Ceramic Beige Intact 0.04 mg/cm2

2 202 Trim Wood Beige Intact 0.4 mg/cm2

2 Stairwell Door Metal Red Intact 0.04 mg/cm2

2 Stairwell Door Frame Wood Gray Intact 0.7 mg/cm2

2 214 Wall Ceramic Tan Intact 7.2 mg/cm2

2 214 Wall Plastic White Intact 0.03 mg/cm2

1 102 Window Wood Gray Intact 0.6 mg/cm2

1 102 Window Casing Wood Gray Intact 0.01 mg/cm2

1 102 Door Frame Wood Gray Intact 0.01 mg/cm2

1 102 Wall Ceramic Beige Intact 0.08 mg/cm2

1 105 Wall Plastic Beige Intact 4.6 mg/cm2

1 Lobby Column Wood Varnish Intact 0.01 mg/cm2

- 14 -

1 Lobby Trim Wood Brown Intact 0.01 mg/cm2

1 Lobby Phone Booth Wood Brown Intact 0.09 mg/cm2

1 Lobby Counter Vinyl Black Intact 0.01 mg/cm2

1 Lobby Counter Vinyl Brown Intact 0.02 mg/cm2

1 Lobby Window Wood Brown Intact 0.01 mg/cm2

1 Lobby Window Casing Wood Brown Intact 0.01 mg/cm2

1 Lobby Door Wood Brown Intact 0.04 mg/cm2

1 Lobby Door Frame Wood Brown Intact 0.01 mg/cm2

1 Women’s Lounge Door Wood Brown Intact 0.01 mg/cm2

1 Women’s Lounge Window Wood Brown Intact 0.02 mg/cm2

B1 Dining Room Door Frame Wood Brown Intact 0.01 mg/cm2

B1 Coffee Shop Counter Wood Brown Intact 0.02 mg/cm2

B1 Coffee Shop Door Wood Brown Intact 0.01 mg/cm2

B1 Coffee Shop Floor Vinyl Brown Intact 0.5 mg/cm2

B1 Kitchen Wall Plaster White Intact 0.14 mg/cm2

B1 Kitchen Column Wood White Intact 0.25 mg/cm2

B1 Kitchen Window Wood White Intact 0.6 mg/cm2

B1 Kitchen Window Casing Wood White Intact 0.4 mg/cm2

B1 Kitchen Door Wood White Intact 0.4 mg/cm2

B1 Kitchen Door Frame Wood White Intact 0.18 mg/cm2

B1 Kitchen Wainscot Wood White Intact 0.05 mg/cm2

B2 Stairwell Wall Wood White Intact 0.13 mg/cm2

B2 Stairwell Tread Wood White Intact 0.01 mg/cm2

B2 Stairwell Column Concrete White Intact 0.01 mg/cm2

B2 Walk Ins Door Metal Red Intact 0.13 mg/cm2

B2 Laundry Door Wood White Intact 0.1 mg/cm2

B2 Laundry Door Frame Wood White Intact 0.17 mg/cm2

B2 Laundry Baseboard Wood Gray Intact 0.6 mg/cm2

B2 Staff RR Wall Concrete Gray Intact 0.09 mg/cm2

B2 Staff RR Wall Drywall Gray Intact 0.05 mg/cm2

- 15 -

B2 Staff RR Pipe Metal Gray Intact 0.26 mg/cm2

B2 Storage Door Frame Wood White Intact 0.03 mg/cm2

B2 Storage Door Wood Red Intact 0.4 mg/cm2

B2 Staff Dining Door Wood Red Intact 0.05 mg/cm2

B2 Staff Dining Door Frame Wood Green Intact 0.07 mg/cm2

B2 Staff Dining Wall Drywall White Intact 0.01 mg/cm2

B2 Staff Dining Window Wood White Intact 0.05 mg/cm2

B2 Staff Dining

Window Casing Wood White Intact 0.09 mg/cm2

B2 Staff Dining Door Wood White Intact 0.03 mg/cm2

B2 Staff Dining Door Frame Wood White Intact 0.07 mg/cm2

B2 Staff Lounge Door Frame Wood White Intact 0.02 mg/cm2

B2 Staff Lounge Door Wood White Intact 0.02 mg/cm2

B3 Mechanical Room Door Metal Gray Intact 0.04 mg/cm2

B3 Mechanical Room Door Wood Brown Intact 0.01 mg/cm2

B3 Mechanical Room Cabinet Wood Beige Intact 0.01 mg/cm2

Preliminary Waste Characterization Estimate (based the EPA TCLP analysis procedure for lead)

Sample # Building Materials Pb Units

3.3 Other Hazardous Materials

Fluorescent Light Tubes Universal Waste 338 Fluorescent Tubes (4' Length) Universal Waste 152

Compact Fluorescent Universal Waste 17 Batteries: Emergency Lights, Exit Signs & Back-up Universal Waste 18

Light Fixture Ballasts Polychlorinated Biphenyls 76 Refrigerators/Freezers Ozone Depleting Chemicals 8

- 16 -

Chemical Name State Estimated Quantity Location Other

Information

Acrylic Glaze Liquid 1 Gallon B3: Mechanical Room - Flammable Cabinet Classic Color

No-Rinse TSP Liquid 1 Gallon B3: Mechanical Room - Flammable Cabinet Jasco

Orange Power Degreaser Liquid 1 Gallon B3: Mechanical Room -

Flammable Cabinet NA

Air Compressor Oil Liquid 1 Quart B3: Mechanical Room - Flammable Cabinet NA

CitrusStrip Liquid 3 Quarts B3: Mechanical Room - Flammable Cabinet Stripping Gel

Paint Thinner Liquid 2 Gallons B3: Mechanical Room - Flammable Cabinet Sunnyside

Cement Additive Liquid 1 Gallon B3: Mechanical Room - Flammable Cabinet Acryl 60

Stain Liquid 3 Gallons B3: Mechanical Room - Flammable Cabinet NA

Lacquer Thinner Liquid 1 Gallon B3: Mechanical Room - Flammable Cabinet NA

Gasoline Liquid 5 Gallons B3: Mechanical Room - Flammable Cabinet NA

Polyurethane Liquid 1 Gallon B3: Mechanical Room - Flammable Cabinet NA

Rubbing Alcohol Liquid 1/2 Gallon B3: Mechanical Room - Other Haz Mats Cabinet NA

Window Cleaner Liquid 1/2 Gallon B3: Mechanical Room - Other Haz Mats Cabinet NA

Liquid Drain Cleaner Liquid 1/2 Gallon B3: Mechanical Room - Other Haz Mats Cabinet NA

Metal Polish Liquid 8 oz. B3: Mechanical Room - Other Haz Mats Cabinet Brasso

Penetrating Oil Liquid 16 oz. B3: Mechanical Room - Other Haz Mats Cabinet WD-40

PVC Pipe Glue Liquid 16 oz. B3: Mechanical Room - Other Haz Mats Cabinet NA

Pipe Joint Compound Liquid 8 oz. B3: Mechanical Room - Other Haz Mats Cabinet NA

Anti-Seize Lubricant Liquid 8 oz. B3: Mechanical Room - Other Haz Mats Cabinet NA

Solder Weld Solid 7.1 grams B3: Mechanical Room - Other Haz Mats Cabinet NA

- 17 -

Chemical Name State Estimated Quantity Location Other

Information

Spray Paint Liquid 3,900 grams B3: Mechanical Room Shelf NA

Paint/Primer Liquid 9 Gallons B2: Staff Dining Room NA

Oven Cleaner Liquid 128 oz. B2: Laundry Storage Keystone Sysco

Degreaser Liquid 2 Gallon B2: Laundry Storage Reliance Sysco

Pot & Pan Degreaser Liquid 2 Gallon B2: Laundry Storage Reliance Sysco

Heavy Duty Degreaser Solid 5 Gallon B2: Laundry Storage Keystone

Orange Surface Cleaner Solid 2 Gallon B2: Laundry Storage Sysco Keystone

Aerosol Contact Insecticide Liquid 90 oz. B2: Laundry Storage Sysco Keystone

Germicidal Ultra Bleach Liquid 3 Gallons B2: Laundry Storage Sysco Keystone

Floor Cleaner & Conditioner Liquid 4 Gallons B2: Laundry Storage First Street

Lime Away Liquid 1 Gallon B2: Laundry Storage Keystone Sysco

High Traffic Floor Polish Liquid 2 Gallons B2: Laundry Storage Zep

Pine Multi-Surface Cleaner Liquid 2 Gallons B2: Laundry Storage Keystone Sysco

The Hazardous Materials Summary, Asbestos Sampling Inventory, Asbestos Sample and Materials Locations Drawings, Photo Documentation, Asbestos Analytical Reports, Lead XRF Sequential Reports, and Lead Preliminary Waste Characterization Analytical Reports for each building can be found in Appendix A – Hazardous Materials Data.

The documents found in the appendices are not stand-alone documents and should not be separated from this report. Quantities and locations listed in the tables are order of magnitude estimates and are not to be used for bidding purposes. This survey and report has been prepared prior to the demolition scope of the renovation being completed to allow more focused quantification of impacted hazardous materials. It is the sole responsibility of the contractor to verify quantities and locations of hazardous materials in the

- 18 -path of construction through site visits and review of the contractual bid set documents, including, but not limited to all specifications, drawings, and addenda. Any discrepancies between the contractual bid set documentation and site visits must be submitted in writing to the Owner or Owner’s representative, prior to bidding.

4.0 RECOMMENDATIONS

4.1 Asbestos

The results of the survey indicate that asbestos-containing materials are present in the anticipated path of construction at the Project Site. The actual location and extent of identified asbestos-containing materials to be disturbed and undergo abatement will depend on the demolition and construction plans to be developed during the construction document phase.

Work performed during any activities that disturb the asbestos-containing materials identified in this report must be done in compliance with the most recent edition of all applicable federal, state, and local regulations, standards, and codes governing abatement, transport, and disposal of asbestos-containing materials. These include, but are not limited to, the following:

• Title 40 CFR Part 61 - Subpart A and Subpart M, USEPA, National Emission Standards for Hazardous Air Pollutants (NESHAPS)

• Title 29 CFR 1926.1101 - Asbestos in Construction

• Title 40 CFR Part 763 - Subpart E, Asbestos Containing Materials in Schools (AHERA)

• Oregon Department of Environmental Quality (DEQ) Chapter 340, Division 248, Asbestos

Requirements

All asbestos abatement work must be conducted by an Oregon Department of Environmental Quality (DEQ) licensed contractor under the provisions of OAR 340-248-0120.

Should the removal of identified regulated friable asbestos-containing materials involve > 3 square feet or > 3 linear feet then a 10 day advance notification (Form ASN 1) to the DEQ is required under the provisions of OAR 340-248-0260. For removal of non-friable asbestos a 5 day advance notification (Form ASN 6) is required to the DEQ under the provisions of OAR 340-248-0260.

Suspect asbestos-containing materials encountered in the building that are not part of this report must be properly sampled for the content of asbestos or assumed to be asbestos containing prior to any disturbance. Any newly discovered suspect asbestos-containing materials must be immediately reported

- 19 -to the National Park Service (NPS) project manager prior to disturbance to allow for an evaluation by a qualified asbestos inspector for the NPS or NPS project team.

4.2 Lead

The results of this survey indicate that lead-based and lead-containing paint and materials are present in the anticipated path of construction at the Project Site. The preliminary waste characterization results indicate that the materials tested were below 5 mg/l, the Federal RCRA level for lead.

All activities involving potential and identified lead-based and lead-containing paints, coatings, and materials should be conducted in accordance with the most recent edition of all applicable federal, state, and local regulations, standards, and codes governing abatement, transport, and disposal of lead-containing materials. These include, but are not limited to, the following:

• Title 40 CFR Part 745 - Lead-Based Paint Poisoning Prevention In Certain Residential Structures (EPA Lead Renovation, Repair and Painting Rule)

• Title 29 CFR 1926.62 – Lead in Construction

• U.S. Department of Housing and Urban Development Guidelines For the Evaluation and

Control of Lead-Based Paint Hazards in Housing pursuant to Title X of the Housing and Community Development Act of 1992 (HUD Guidelines)

• Title 29 CFR 1926.353 Ventilation and Protection in Welding, Cutting and Heating

• Title 29 CFR 1926.354 Welding, Cutting, and Heating in Way of Preservative Coatings

After demolition, the resulting wastes may be hazardous under federal RCRA standards for lead and/or other metals and therefore require proper handling, packaging, labeling, and transportation under a proper manifest to a permitted hazardous waste storage, treatment and disposal facility.

Analytical data from analysis of bulk materials or surface content of lead can be helpful in evaluation of lead-related environmental risks in general but cannot be used to calculate worker exposures and are not a substitute for employee exposure monitoring. As a result of the above, any employee that works around potential lead-based or lead-containing coatings must have HAZCOM training for lead paint hazards at the site and employees that disturb such coatings require training in accordance with the OSHA lead construction standard (Title 29 CFR 1926.62) as well as other applicable state and federal regulation. In addition, personal exposure air monitoring and certain work practices are required for lead-disturbing construction work to ensure worker protection. Because this facility provides lodging for the public including families with young children, lead-related construction work should be performed by a contractor certified under the EPA Lead Renovation, Repair, and Painting (RRP) Program and adhering at minimum to lead work practices required by that program and the requirements of the contact documents.

- 20 -

4.3 Other Hazardous Materials

All potential and identified other Hazardous Materials impacted by the work should be removed and disposed of in accordance with Title 40 CFR 260 to 263 – RCRA and state of Oregon regulation.

All potential and identified Universal Waste materials (UW) impacted by the work should be removed and recycled or disposed of in accordance with Title 40 CFR 273. Universal wastes include but are not limited to batteries; mercury containing thermostats & gauges; high intensity/sodium vapor and fluorescent lighting tubes; electronic components, and other items.

All suspect (pre-1979) PCB ballasts must be visually inspected prior to disposal to determine if they contain PCB’s. Those ballasts marked No PCB’s or PCB Free can be considered as such and should be treated as UW - electronic waste. All PCB-containing devices, including, but not limited to ballasts should be removed or have the oils removed and properly handled, collected, stored, transported and recycled or disposed of by an approved recycling or disposal facility in accordance with the requirements of Title 40, CFR 761.

Devices containing ozone depleting chemicals, low level radioactive sources, paint or other chemicals, should be collected, waste characterized, disposed or recycled according to Oregon and Federal rules and regulations which ever is more stringent.

5.0 LIMITATIONS & EXCLUSIONS

The survey did not include access of areas and sampling of materials which would have required demolition or large scale destructive testing. Vista made a good faith effort using accepted industry standards to access all areas and potentially impacted finishes and components in order to assess their potential for having hazardous materials. However additional suspect hazardous materials may be concealed and later revealed during demolition and disconnection activities associated with the project.

Should any new or different suspect materials be discovered, stop work immediately and notify the appropriate NPS project management personnel to allow proper evaluation and testing as may be required and appropriate before disturbing the suspect material.

The waste characterization estimate data found in this report are estimates only and cannot be used in place of waste characterization sampling after selective demolition and the resulting waste streams are segregated.

- 21 -

All material quantities…