Appendix_C_-_ROMO_FR_HazMatAssessReport_022322_FTC_0002.pdf

HAZARDOUS MATERIALS ASSESSMENT

REPORT FOR ROCKY MOUNTAIN NATIONAL

PARK, FALL RIVER ENTRANCE STATION,

ESTES PARK, COLORADO

Prepared for:

Anderson Hallas Architects, PC 715 14th Street Golden, Colorado 80401

Prepared by:

Landmark Environmental, Inc.

7881 Shaffer Parkway Littleton, Colorado 80127

PMIS ROMO 160755

Landmark Project No. 21115.001.001

February 23, 2022

CONTENTS

Landmark Project No. 21115.001.001 i

EXECUTIVE SUMMARY ................................................................................................... A

ASBESTOS........................................................................................................................................... A

REGULATED BUILDING MATERIALS .................................................................................................... B

LEAD .................................................................................................................................................. C

BIOLOGICAL HAZARDS ........................................................................................................................E

1.0 INTRODUCTION ................................................................................................. 1-1

1.1 PURPOSE ............................................................................................................................... 1-1

1.2 SITE DESCRIPTION ................................................................................................................. 1-2

1.3 REPORT ORGANIZATION ........................................................................................................ 1-2

2.0 ASBESTOS ......................................................................................................... 2-1

2.1 REGULATORY CRITERIA ........................................................................................................ 2-1

2.2 TECHNICAL APPROACH ......................................................................................................... 2-2

2.3 LABORATORY ANALYSIS ....................................................................................................... 2-3

3.0 REGULATED BUILDING MATERIALS ................................................................. 3-1

3.1 REGULATORY CRITERIA ........................................................................................................ 3-1

3.2 TECHNICAL APPROACH ......................................................................................................... 3-1

4.0 LEAD-BASED PAINT AND SOIL SURVEY ........................................................... 4-1

4.1 REGULATORY CRITERIA ........................................................................................................ 4-1

4.2 TECHNICAL APPROACH ......................................................................................................... 4-2

4.3 LABORATORY ANALYSIS ....................................................................................................... 4-3

5.0 BIOLOGICAL HAZARDS...................................................................................... 5-1

6.0 FINDINGS ........................................................................................................... 6-1

6.1 KIOSK 1................................................................................................................................. 6-1

6.2 KIOSK 2................................................................................................................................. 6-2

6.3 KIOSK 3................................................................................................................................. 6-3

6.4 OFFICE .................................................................................................................................. 6-4

7.0 CONCLUSIONS AND RECOMMENDATIONS ....................................................... 7-1

7.1 ASBESTOS ............................................................................................................................. 7-1

7.2 REGULATED BUILDING MATERIALS ...................................................................................... 7-1

7.3 LEAD..................................................................................................................................... 7-2

7.4 BIOLOGICAL HAZARDS .......................................................................................................... 7-2

8.0 LIMITATIONS ..................................................................................................... 8-1

Landmark Project No. 21115.001.001 ii

9.0 ENDORSEMENTS ............................................................................................... 9-1

10.0 ACRONYMS ...................................................................................................... 10-1

11.0 REFERENCES ................................................................................................... 11-1

FIGURES

FIGURE 1 SITE OVERVIEW MAP

FIGURE 2 KIOSK 1 – ASBESTOS BULK SAMPLING LOCATIONS

FIGURE 3 KIOSK 1 – LEAD PAINT SCREENING LOCATIONS

FIGURE 4 KIOSK 2 – ASBESTOS BULK SAMPLING LOCATIONS

FIGURE 5 KIOSK 2 – LEAD PAINT SCREENING LOCATIONS

FIGURE 6 KIOSK 3 – ASBESTOS BULK SAMPLING LOCATIONS

FIGURE 7 KIOSK 3 – LEAD PAINT SCREENING LOCATIONS

FIGURE 8 OFFICE – ASBESTOS-CONTAINING MATERIALS LOCATIONS

FIGURE 9 OFFICE – ASBESTOS BULK SAMPLING LOCATIONS

FIGURE 10 OFFICE – LEAD PAINT SCREENING LOCATIONS

APPENDICES

APPENDIX A KIOSK 1

APPENDIX B KIOSK 2

APPENDIX C KIOSK 3

APPENDIX D OFFICE

APPENDIX E NPS - HANTAVIRUS RISK REDUCTION WORKER PROTECTION

APPENDIX F CERTIFICATIONS

Landmark Project No. 21115.001.001 A

EXECUTIVE SUMMARY

Landmark Environmental, Inc. (Landmark) was retained by Anderson Hallas Architects, PC (Client) to conduct a Hazardous Materials Assessment inclusive of asbestos-containing materials (ACM), regulated building materials (RBM), lead-based paint (LBP), and biological hazards for the Fall River Entrance

Station buildings at Rocky Mountain National Park (ROMO) in Estes Park, Larimer County, Colorado

(Project Site).

The purpose of this assessment was to identify and quantify ACM, RBM, LBP, and biological hazards that must be managed during the demolition of the structures and in support of Pre-Design and Schematic

Design Services for the demolition project.

The fieldwork activities for this assessment were conducted on January 11, 12, and 31, 2022.

Asbestos

The asbestos assessment services were performed to identify the presence, location, quantity, friability, and condition of ACMs for the four structures located on the Project Site.

ACMs were identified in the four structures, as shown below.

Kiosk 1:

• No ACM identified.

Kiosk 2:

• No ACM identified.

Kiosk 3:

• No ACM identified.

Office:

• Floor tile (FTC01): 9-inch by 9-inch tan mottled floor tiles were found to contain between 3 and

5% chrysotile asbestos by Polarized Light Microscopy (PLM) analysis. Approximately 148 square feet of the material was observed. The associated black mastic was identified to be none detect for

Executive Summary

Landmark Project No. 21115.001.001 B asbestos via PLM. The FTC01 material is a Category I non-friable material.

Asbestos Summary

The Office building structure contains non-friable Category I ACM that will be impacted during planned demolition activities. This non-friable ACM must be properly abated to avoid disturbing this flooring material during the demolition activities.

This assessment was inclusive of the accessible portions of the Project Site, which included three kiosk structures (Kiosk 1, Kiosk 2, and Kiosk 3) and one office building (Office) for a total of four structures. An intrusive investigation, including exploratory demolition of chases, soffits, enclosures, etc., was performed to the extent practicable due to the Project Site being occupied/in operation as a toll booth and park entrance station. Landmark’s field inspectors did investigate the wall and roof cavity areas with pre-existing damage where the building materials were already exposed. The field inspector also cut an opening into the wall in the office bathroom behind the toilet and sink, and similar openings were cut into the ceilings of the Office and Kiosk 2. Should any unforeseen suspect building materials be encountered during the eventual demolition, then the demolition work must be stopped, and suspect materials need to be sampled and tested for asbestos to characterize them prior to disturbance or presumed to be ACM and abated.

Before any renovation or demolition work activities in a public or commercial building, which may disturb greater than 160 square feet, 260 linear feet, or the equivalent of a 55-gallon drum of friable material or non-friable ACM, which may become friable during the renovation or demolition activities, ACMs must be removed in accordance with all applicable U.S. Environmental Protection Agency (EPA) and Colorado

Department of Public Health and Environment (CDPHE) regulations.

Regulated Building Materials

Landmark also completed an inventory for RBMs during the assessment of the Project Site. The RBMs were identified as shown below.

Kiosk 1:

• Computer equipment (one desktop computer, a cash resgister, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts (likely to contain

Polychlorinated Biphenyls [PCBs]).

Landmark Project No. 21115.001.001 C

Kiosk 2:

• Computer equipment (one desktop computer, a cash resgister, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts (likely to contain PCBs).

Kiosk 3:

• Computer equipment (one desktop computer, a cash resgister, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts (likely to contain PCBs).

Office:

• Fire extinguisher, computer equipment (two desktop computers, desktop printers, security cameras, etc.), refrigerants associated with a small office refrigerator, a smoke detector, and fluorescent light tubes (mercury-containing).

These RBMs have specific management and handling requirements that must be considered prior to the demolition activities if they will be impacted. Management techniques include removal, disposal, recycling, and/or reuse.

Lead

Landmark tested representative sample locations of various painted materials on the interior and exterior of the structures. Areas of exposed soil adjacent to typical painted external building surfaces (e.g., window frames, trim and siding, soffits and fascia boards, etc.), where accessible, were also visually inspected for paint chips. This effort was impacted by recent snowfall obscuring the ground surface, so the visual assessment of the soil was limited. In addition, representative composited soil samples were collected from perimeters of the Kiosk 3 and Office buildings and analyzed for total lead content. The sampling strategy consisted of collecting a composite sample from the drip line of the buildings. LBP, lead-containing paint

(LCP), or lead in soils were identified as shown below.

Kiosk 1:

• White paint on the interior wooden door frame is LCP.

• Light green paint on the interior wooden walls is LCP.

• Bright white paint on the interior wood window frames and interior wooden desk drawers is LCP.

Landmark Project No. 21115.001.001 D

• Tan paint on the exterior wooden wall framing and wooden roof framing is LCP.

• Dark brown paint on an exterior wood door, exterior wooden façade walls, and wooden roof soffit is LCP.

• Brown paint on an exterior wooden window board is LBP.

Kiosk 2:

• Dark tan paint on an exterior wooden door frame, exterior wooden window frames, exterior wall framing, and roof framing is LCP.

• Dark brown paint on an exterior wood door, exterior wooden façade walls, a wood door threshold, and the wooden roof soffit is LCP.

• Brown paint on an exterior wooden window board is LBP.

• Bright white paint on an interior wooden door, an interior wood door frame, interior wooden walls, interior wooden windowsills, interior wood desk drawers, and on the interior wood ceiling is LCP.

Kiosk 3:

• Brown paint on an exterior wooden window board is LBP.

• Dark tan paint on exterior wooden wall framing, wooden roof framing, and an exterior wood door frame is LCP.

• Dark brown paint on exterior wood façade walls, an exterior door frame, an exterior door, a wooden threshold, and roof soffit is LCP.

• Dark brown paint on an interior concrete baseboard is LCP.

• Bright white paint on interior wooden walls, interior wood window frames, an interior wood door, an interior wood ceiling, and wooden desk drawers is LCP.

Office:

• Bright white paint on interior wooden windowsills and interior wood vault framing is LCP.

Landmark Project No. 21115.001.001 E

• Light green paint on interior wooden walls is LCP.

• Tan paint on exterior wall framing, exterior wooden windowsills, wood roof framing, and exterior wooden window framing is LCP.

• Dark brown paint on the exterior wood doors, exterior wooden façade walls, and window frames is LCP.

• Dark brown paint on the exterior wooden roof soffit is LBP.

Renovation or demolition activities that will impact LBP and LCP will require Occupational Health and

Safety Administration (OSHA)-trained workers and safety programs. Personal protective equipment (PPE), including respiratory protection, will be required to handle these items until negative exposure assessments are completed that show work activities do not result in exposures above the OSHA Permissible Exposure

Limit (PEL). In addition, an appropriate waste management plan should be developed for the disposal of the LBP and LCP materials.

Lead soil samples were collected from the drip line surrounding Kiosk 3 and Office building structures with

LBP on the exterior. The Kiosk 1 and Kiosk 2 buildings also had LBP on the exterior, but their buildings were completely surrounded by road asphalt with no available soil at the dripline areas to sample. No lead soil samples exceeded EPA residential screening limits, and no further action is required for soil.

Biological Hazards

Landmark’s field inspector also conducted a limited visual biological hazards assessment of the Project

Site. These observations were primarily limited to rodent or insect infestations, water intrusion, or visual evidence of mold growth throughout the structures.

No biological hazards were identified via a walkthrough visual inspection of the accessible portions of the four building structures located at the Project Site. However, it is possible that rodent infestation could be present within the wall and ceiling cavity areas of these buildings. If rodents are encountered during the demolition process, special precautions to avoid Hantavirus exposure of workers will be required.

Landmark Project No. 21115.001.001 1-1

1.0 INTRODUCTION

Landmark Environmental, Inc. (Landmark) was retained by Anderson Hallas Architects, PC (Client) to conduct an asbestos-containing materials (ACM), regulated building materials (RBM), lead-based paint

(LBP), and biological hazards assessment for the Fall River Entrance Station at Rocky Mountain National

Park (ROMO) in Estes Park, Larimer County, Colorado (Project Site).

This report presents a summary of applicable regulatory criteria, bulk-sampling and laboratory analytical procedures, quality control of the field and laboratory data, ACM, RBM, and LBP tables and assessment findings, and further recommendations. The fieldwork activities for this survey were conducted on January

11, 12, and 31, 2022.

1.1 Purpose

The purpose of this assessment was to identify and quantify ACM, RBM, LBP, and biological hazards that must be managed during and prior to any future renovation or demolition of the structures in support of the

Construction Documentation Phase for the Project Site.

The purpose of the ACM assessment was to identify the locations, quantify, and define the friability and condition of ACM. The objective of the ACM assessment was to identify and qualify ACM that will require abatement prior to impacts of the material.

The purpose of the RBM assessment was to quantify and identify the general locations of those materials that are required to be removed from the structures during demolition. The objective of the RBM assessment was to identify and quantity materials that will require management prior to the demolition activities.

The purpose of the LBP assessment was to assess and identify LBP prior to renovation or demolition of the structures. The objective of the LBP assessment was to identify the general locations of the lead-containing paint (LCP)/LBP materials required to be managed during renovation activities.

The purpose of the biological hazards assessment was to identify evidence of rodent and insect intrusion, moisture infiltration, and any potential mold growth. The objective of the biological hazard assessment was to identify conditions that could pose safety and health risks to workers or future occupants of the buildings, which should be addressed during renovations.

Introduction

Landmark Project No. 21115.001.001 1-2

1.2 Site Description

The Fall River Entrance Station area is located within ROMO in Estes Park, Larimer County, Colorado.

This assessment was inclusive of four buildings at the Fall River Entrance Station area that were constructed sometime in the 1960s, including Kiosk 1, Kiosk 2, Kiosk 3, and the Office.

1.3 Report Organization

This report presents the general findings of assessment and sampling efforts for the Project Site. Further detailed information is provided in Appendixes A through D, by structure. Each structure-specific appendix includes, as applicable, the following items:

• Homogeneous Materials Summary

• Asbestos Laboratory Analytical Report

• Asbestos/Non-Asbestos Summary Tables (if applicable)

• Lead Paint Data Summary Table

• Lead Soil Sample Summary Table (if applicable)

• Lead Soil Laboratory Analytical Report (if applicable)

• RBM Summary Table

• Photograph Log

Additionally, Appendix E includes the National Park Service (NPS) Hantavirus Risk Reduction Worker

Protection document from December 2013. Landmark and individual inspector certifications are included in Appendix F.

Landmark Project No. 21115.001.001 2-1

2.0 ASBESTOS

The asbestos regulatory criteria, technical approach, laboratory analysis, and findings are discussed below.

2.1 Regulatory Criteria

Asbestos is a naturally occurring fibrous mineral that was historically used in thousands of construction and commercial applications due to its properties of tensile strength, heat resistance, non-conductivity, and acoustical absorption. Asbestos is a confirmed human carcinogen that can cause diseases such as asbestosis, lung cancer, and mesothelioma; therefore, asbestos is regulated by the U.S. Environmental Protection

Agency (EPA), Occupational Health and Safety Administration (OSHA), and the Colorado Department of

Public Health and Environment (CDPHE). This brief overview of certain applicable asbestos regulatory criteria is general and for informational purposes only. Asbestos is one of the most widely regulated environmental substances and for specific requirements, refer to the applicable statutes and regulations identified in Section 11 (References).

In general, removal of ACM is not required by regulation unless the asbestos materials will be disturbed during renovation, remodeling, or demolition. The concern is for the potential release of asbestos fibers.

Typically, the potential for an airborne release of asbestos fibers exists in three circumstances:

• The ACM will be impacted during maintenance, renovation, or demolition.

• The material has significantly deteriorated to the extent that asbestos debris is present.

• The ACM will be subject to future deterioration by vibration, airflow, or weathering.

Applicable asbestos regulations define ACM as material containing greater than 1% asbestos by weight, volume, or visual surface area and also distinguish between friable and non-friable forms of ACM. Friable

ACMs can be crumbled or reduced to powder by hand pressure when dry. Non-friable materials cannot be crumbled, pulverized, or reduced to powder by hand pressure.

The EPA National Emission Standards for Hazardous Air Pollutants (NESHAP) further classify non-friable

ACM as Category I and II. Category I non-friable ACMs include asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products. Category II non-friable ACMs are defined as all other non-friable ACM, such as cement board, window putty, etc. Category I non-friable ACMs may remain in a building during demolition if demolition activities do not render the ACMs friable. All other ACMs

Asbestos

Landmark Project No. 21115.001.001 2-2

(non-Category I) must be removed prior to demolition.

The OSHA regulations in 29 Code of Federal Regulations (CFR) 1926.1101 require that building owners inform prospective contractors, employees, and tenants of the presence, location, and quantity of ACM or assumed ACM in their buildings and facilities. OSHA also requires the protection of employees through identification of ACM, training, proper work practices, and the use of personal protection equipment.

If the amount of ACM to be disturbed exceeds the following CDPHE Trigger Levels, then a state-certified abatement contractor must remove the ACM prior to renovation or demolition. Trigger Levels of ACMs are identified as 260 linear feet (lf) on pipes, 160 square feet (sf) on other surfaces, or the volume equivalent of a 55-gallon drum.

2.2 Technical Approach

Landmark collected bulk samples of the suspect ACMs in accordance with the applicable federal and state regulations. The inspectors collected bulk material samples by taking a composite core that included all layers within the suspect ACMs.

The assessment included visually assessing the Project Site facilities for homogeneous areas, performing a physical assessment of the material, and sampling suspect ACM. Bulk samples were collected of suspect non-friable and friable ACMs.

A homogeneous sampling area is defined as an area of ACM or suspect ACM that appears similar in color, texture, and date of application. Materials observed to be from the original building construction of each level and found to be present in multiple areas were placed into the same homogeneous material category types. The samples collected were representative of suspect ACMs for each of the homogeneous materials areas. Samples were collected in compliance with the EPA Asbestos Hazard and Emergency Response Act

(AHERA) 40 CFR, Part 763. Representative sampling was based on the distribution of the suspect material throughout the homogeneous area and the suspect material’s physical characteristics and application.

The results of sample analysis were considered representative of materials in each homogeneous area if:

• They exhibited similar physical characteristics; and

• The application of the sampled material could be clearly correlated to the application of unsampled material.

Landmark Project No. 21115.001.001 2-3

Friable suspect ACMs were separated into the following three classifications with specific sampling requirements. These classifications and respective sampling requirements were as follows:

• Surfacing Materials – Trowel or sprayed applied materials:

o Three samples of each homogeneous area of 1,000 sf or less.

o Five samples of each homogeneous area greater than 1,000 sf and less than 5,000 sf.

o Seven samples of each homogeneous area greater than 5,000 sf.

• Thermal System Insulation (TSI):

o Three samples of each homogeneous area.

• Miscellaneous Materials – Other suspect materials not classified in the above categories:

o A sufficient number of samples to determine asbestos content, with a general requirement of a minimum of two samples.

The bulk ACM samples were given alpha and numeric identifiers for project tracking and identification purposes. The first set of letter/number combinations identifies the building area and the unit number. The second group of letter/number combinations identifies the type of material the sample was collected from and the homogeneous material identifier for the functional space. The last set of identification numbers represents the sequential sample acquired for the homogeneous material.

Sample collection information was documented on Landmark’s homogeneous area forms (Appendix A to

D). Building assessment information and photographs were taken of sample locations.

Landmark performed an internal review of the field data and laboratory analysis reports to ensure that the data generated within this report is accurate and complete. Quality assurance reviews performed by EPA-certified inspectors included cross-referencing inspector field notes and sample logs with the laboratory polarized light microscopy (PLM) bulk sample analysis to confirm sample results, numbering, and material descriptions for each sample.

2.3 Laboratory Analysis

The suspect ACM samples were submitted to Reservoirs Environmental, Inc. (Reservoirs) in Denver, Colorado. Reservoirs is a National Voluntary Laboratory Accreditation Program (NVLAP)-accredited

Landmark Project No. 21115.001.001 2-4 laboratory for Bulk Asbestos Fiber Analysis. Per the EPA NESHAP (40 CFR 61, Subpart M) regulatory guidance, samples containing less than 1% asbestos must be point-counted to be considered a trace-containing material. None of the bulk samples required further point-count analysis, and the asbestos analytical data is presented in Appendices A through D.

Landmark Project No. 21115.001.001 3-1

3.0 REGULATED BUILDING MATERIALS

This section describes the regulatory criteria, technical approach, and findings.

3.1 Regulatory Criteria

RBMs can include used batteries, electronic wastes, equipment that contains mercury, and hazardous waste lamps. For purposes of this report, the term RBM also includes light fixture ballasts that may contain

Polychlorinated Biphenyl (PCBs), refrigerants, used chemicals, and fuel storage. The federal standards for managing RBMs are 40 CFR Part 273. The EPA regulations define three classes of waste management, including a very small quantity generator: small quantity generators and large quantity generators. The classification of and the applicable management requirements for the Client are determined by the quantity of waste generated. The amount of RBMs generated will not be determined until further into the project.

3.2 Technical Approach

The RBMs assessment included visual identification and quantification of RBMs in the structures accessed.

Landmark performed no confirmatory sampling of these materials but did take apart the accessible smoke detectors and light fixtures to check for model numbers and non-PCB containing labels on light ballasts.

Landmark Project No. 21115.001.001 4-1

4.0 LEAD-BASED PAINT AND SOIL SURVEY

In this section, the regulatory criteria, technical approach, laboratory analysis, and findings as they pertain to LBP and LCP are discussed.

4.1 Regulatory Criteria

The EPA and the U.S. Department of Housing and Urban Development (HUD) regulate LBP abatement activities in target housing and child-occupied facilities. LBP is defined as paint containing 0.5% by weight or 1.0 milligram per cubic centimeter (mg/m2) by EPA and HUD. OSHA regulates worker exposure to lead for coatings with any detectable lead described as LCP.

The EPA and HUD regulate LBP abatement activities in target housing and child-occupied facilities. Target housing is defined as any housing constructed prior to 1978 that is occupied by a child under age six. A child-occupied facility is a building constructed prior to 1978 that is visited regularly by the same child under age six for more than two visits per week, three hours per visit, with combined weekly visits lasting at least six hours and totaling at least 60 hours annually.

The EPA also developed a program for renovation activities in child-occupied/target housing and child-care facilities called the Lead Renovation, Repair, and Paint Rule (RRP Rule). This rule requires that firms performing renovation, repair, and painting projects which disturb lead-based paint in homes, child care facilities, and preschools built before 1978 have their firm certified by EPA (or an EPA authorized state), use certified renovators who are trained by EPA-approved training providers, and follow lead-safe work practices.

The EPA and HUD regulate LBP abatement activities in target housing and child-occupied facilities. The

EPA and HUD regulations related to LBP abatement do not apply to the building structures on the Project

Site.

The OSHA Lead in Construction standard 29 CFR 1926.62 addresses requirements for sites where the employer has reason to believe that any employee may be exposed to lead in excess of OSHA’s action level

(AL) of 30 micrograms per cubic meter (30 µg/m3) over an eight-hour time-weighted average. The OSHA standard applies to all construction activities that may impact LCP (any detectable lead).

Any demolition and renovation activities involving LBP are subject to the OSHA Construction Industry

Standard for Lead (Title 29 CFR, Part 1926.62). This standard is similar to other OSHA standards in that it addresses such issues as worker training, medical evaluations, personal protective equipment, exposure

Lead-Based Paint and Soil Survey

Landmark Project No. 21115.001.001 4-2 assessment, air monitoring, hygiene facilities, and work practices.

To comply with EPA air, solid waste, and water quality standards, appropriate work practices, engineering controls, and other precautions should be taken to ensure lead-containing materials are not introduced into the surrounding roadway, soil, road drainage systems, and waterways. The EPA has established screening levels/cleanup criteria for lead in soils based on expected residential usage. The levels are 400 milligrams per kilogram (mg/kg) for high contact play areas and 1200 mg/kg for non-play area residential yard soil.

Additionally, lead-containing materials with a total lead content equal to or exceeding 0.01% by weight could exceed the EPA Resource Conservation and Recovery Act (RCRA) standard and are subject to the hazardous waste determination under EPA regulations. Representative waste characterization should be performed using the Toxicity Characteristic Leaching Process (TCLP) analytical method. The Toxicity

Characteristic (TC) limit for lead is five parts per million (ppm) in the leachate. Materials that exceed this limit must be disposed of as hazardous waste. Materials that do not exceed this limit may be disposed of as solid waste.

Materials that are reused or recycled, such as metal components, are not subject to waste characterization provisions under the EPA, but proper disclosure of lead-containing materials should be provided to the recycling facility for hazard communication purposes.

The types and locations of LBP and LCP and regulatory requirements should be disclosed to the General

Contractor and Owner’s staff to avoid accidental disturbance and for contractor compliance with applicable regulations (to ensure proper worker protection and material disposal).

4.2 Technical Approach

The LBP/LCP survey was performed by a CDPHE LBP Building Inspector/Risk Assessor. The LBP/LCP screening was completed utilizing a handheld X-ray fluorescent (XRF) meter in the field. Readings of suspect LBP/LCP were collected in a representative manner as determined by the field inspector based on identified testing combinations where the surface color, substrate, or building component were visibly different. Sampling was limited to materials that were visible and readily accessible to the inspector. The

XRF equipment was subject to pre-calibration, calibration checks every four hours, and post-calibration as recommended by the manufacturer.

Landmark tested representative sample locations of various painted materials on the interior and exterior of the structures. Areas of exposed soil adjacent to typical painted external building surfaces (e.g., window

Lead-Based Paint and Soil Survey

Landmark Project No. 21115.001.001 4-3 frames, trim and siding, soffits and fascia boards, etc.) were also visually inspected for paint chips.

In addition, representative composited soil samples were collected from the perimeters of the Kiosk 3 and

Office buildings and analyzed for total lead content when the exterior paint of a building was found to be

LCP or LBP. Representative photographs, LBP/LCP screening summary datasheet, and laboratory analysis are included in applicable appendices by building (Appendices A-D).

4.3 Laboratory Analysis

The soil samples collected were submitted to Reservoirs in Denver, Colorado. Reservoirs is an American

Industrial Hygiene Association (AIHA) Laboratory Accreditation Program (LAP)-accredited (AIHA LAP

101533) for lead in environmental matrices, paint, soil, and wipes through the AIHA LAP Environmental

Lead Laboratory Accreditation Program (ELLAP). The samples were analyzed by EPA 7420-M method.

Landmark Project No. 21115.001.001 5-1

5.0 BIOLOGICAL HAZARDS

Landmark conducted limited observations for biological hazards during the walkthrough inspection of the

Project Site. These site observations were limited to rodent or insect infestations, water intrusion, or visual evidence of mold growth throughout the structures. No confirmation testing was performed. Observations by building are discussed in Section 6.0.

Landmark Project No. 21115.001.001 6-1

6.0 FINDINGS

A brief summary of the findings for each category of environmental condition (ACM, LBP/LCP, RBM, and biological hazards) are included by building below. The data tables and more in-depth summaries are included in Appendices A through D. Each building has its own appendix, as applicable, which includes:

1) ACM Summary, 2) ACM Laboratory Reports, 3) LBP/LCP Data Summary, 4) Lead in Soils Lab Report,

5) Lead Photo Log, and 6) RBM Summary Table.

6.1 Kiosk 1

Information related to Kiosk 1 is located in Appendix A.

ACM

Twenty-one samples were collected from nine materials that were considered suspect for asbestos content and submitted to the laboratory for analysis.

• No ACMs were detected in the materials.

RBM

Computer equipment (a desktop computer, cash register, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts that may contain PCBs were found for the Kiosk 1 structure. The exterior light fixture associated with Kiosk 1 could not be taken apart in the field to determine if the ballast is PCB or non-PCB-containing due to the way it was affixed.

LBP

The screening was conducted on 18 different paint combinations using the XRF meter. The following LBP or LCP was detected for Kiosk 1:

• White paint on the interior wooden door frame is LCP.

• Light green paint on the interior wooden walls is LCP.

• Bright white paint on the interior wood window frames and interior wooden desk drawers is LCP.

• Tan paint on the exterior wooden wall framing and wooden roof framing is LCP.

Findings

Landmark Project No. 21115.001.001 6-2

• Dark brown paint on an exterior wood door, exterior wooden façade walls, and wooden roof soffit is LCP.

• Brown paint on an exterior wooden window board is LBP.

Lead in Soils

• No sample was collected for lead in soils outside Kiosk 1 because this structure was surrounded by asphalt pavement and had no available soil to sample.

Biological Hazards

No signs of moisture infiltration, mold growth, rodent or insect infestation were found in the accessible portions of the Kiosk 1 structure. However, it is possible that rodent infestation could be present within the wall and ceiling cavity areas of this building.

6.2 Kiosk 2

Information related to Kiosk 2 is located in Appendix B.

ACM

Fifteen samples were collected from six materials that were considered suspect for asbestos content and submitted to the laboratory for analysis.

• No ACMs were detected in the materials.

RBM

Computer equipment (a desktop computer, cash register, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts (that may contain PCBs) were found for the Kiosk 2 structure. The exterior light fixtures associated with Kiosk 2 could not be taken apart in the field to determine if the ballasts are PCB or non-PCB-containing.

LBP

Screenings were conducted on 28 different painted combinations using the XRF meter. The following LBP or LCP was detected in the Generator House:

Landmark Project No. 21115.001.001 6-3

• Dark tan paint on an exterior wooden door frame, exterior wooden window frames, exterior wall framing, and roof framing is LCP.

• Dark brown paint on an exterior wood door, exterior wooden façade walls, a wood door threshold, and the wooden roof soffit is LCP.

• Brown paint on an exterior wooden window board is LBP.

• Bright white paint on an interior wooden door, an interior wood door frame, interior wooden walls, interior wooden windowsills, interior wood desk drawers, and on the interior wood ceiling is LCP.

Lead in Soils

No sample was collected for lead in soils outside Kiosk 2 because this structure was surrounded by asphalt pavement.

Biological Hazards

No signs of moisture infiltration, microbial growth, rodent or insect infestation were found in the accessible portions of the Kiosk 2 structure. However, it is possible that rodent infestation could be present within the wall and ceiling cavity areas of this building.

6.3 Kiosk 3

Information related to Kiosk 3 is located in Appendix C.

ACM

Fourteen samples were collected from six materials that were considered suspect for asbestos content and submitted to the laboratory for analysis.

• No ACMs were detected in the materials.

RBM

Computer equipment (a desktop computer, cash register, receipt printer, and security cameras), fluorescent light tubes (mercury-containing), and light ballasts (that may contain PCBs) were found for the Kiosk 3 structure. The exterior light fixtures associated with Kiosk 3 could not be taken apart in the field to determine if the ballasts are PCB or non-PCB containing.

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LBP

The screening was conducted on 31 different paint combinations using the XRF meter. The following LBP or LCP was detected at Kiosk 3:

• Brown paint on an exterior wooden window board is LBP.

• Dark tan paint on exterior wooden wall framing, wooden roof framing, and an exterior wood door frame is LCP.

• Dark brown paint on exterior wood façade walls, an exterior door frame, an exterior door, a wooden threshold, and roof soffit is LCP.

• Dark brown paint on an interior concrete baseboard is LCP.

• Bright white paint on interior wooden walls, interior wood window frames, an interior wood door, an interior wood ceiling, and wooden desk drawers is LCP.

Lead in Soils

Laboratory analysis did not identify lead in soils above the EPA screening level/cleanup criteria for child play areas of 400 milligrams per kilogram (mg/kg) for high contact play areas and 1200 mg/kg for non-play area residential yard soil.

Biological Hazards

No signs of moisture infiltration, microbial growth, rodent or insect infestation were found in the accessible portions of the Kiosk 3 structure. However, it is possible that rodent infestation could be present within the wall and ceiling cavity areas of this building.

6.4 Office

Information related to the Office is located in Appendix D.

ACM

Eleven samples were collected from four materials that were considered suspect for asbestos content and submitted to the laboratory for analysis. One ACM was identified at the Office building structure, including the following:

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• Floor tile (FTC01): 9-inch by 9-inch tan mottled floor tiles were found to contain between 3 and

5% chrysotile asbestos by PLM analysis. The associated black mastic was identified to be none detect for asbestos via PLM. The FTC01 material is a Category I non-friable material.

RBM

Fire extinguisher, computer equipment (two desktop computers, desktop printers, security cameras, etc.), refrigerants associated with a small office refrigerator, a smoke detector, and fluorescent light tubes

(mercury-containing) were found in the Office building. The interior light fixtures associated with the

Office building were taken apart by Landmark’s field inspector to confirm that the ballasts are non-PCB-containing. The smoke detector was a System Senor Model No. 5604. According to the manufacturer, the device has between 0.5 and 1.0 microcuries of Americium 241 and can be disposed of without restriction1.

LBP

The screening was conducted on 30 different paint combinations using the XRF meter. The following LBP or LCP was detected at the Office:

• Bright white paint on interior wooden windowsills and interior wood vault framing is LCP.

• Light green paint on interior wooden walls is LCP.

• Tan paint on exterior wall framing, exterior wooden windowsills, wood roof framing, and exterior wooden window framing is LCP.

• Dark brown paint on the exterior wood doors, exterior wooden façade walls, and window frames is LCP.

• Dark brown paint on the exterior wooden roof soffit is LBP.

1 System Sensor. Technical Field Bulletin, Subject: Radioactive material – effects and disposal. Issued 8/02, revised 1/04. https://www.systemsensor.com/en-us/Documents/RadioactiveMaterial_disposal_techbulletin.pdf. Accessed 1/27/2022.

https://www.systemsensor.com/en-us/Documents/RadioactiveMaterial_disposal_techbulletin.pdf

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Lead in Soils

Laboratory analysis did not identify lead in soils above the EPA screening level/cleanup criteria for child play areas of 400 milligrams per kilogram (mg/kg) for high contact play areas and 1200 mg/kg for non-play area residential yard soil.

Biological Hazards

No signs of moisture infiltration, microbial growth, rodent or insect infestation were found in the accessible portions of the Office structure. However, it is possible that rodent infestation could be present within the wall and ceiling cavity areas of this building.

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7.0 CONCLUSIONS AND RECOMMENDATIONS

7.1 Asbestos

The Office building structure contains non-friable Category I ACM that will be impacted during planned demolition activities. This non-friable ACM must be properly abated to avoid disturbing this flooring material during the demolition activities.

This assessment was inclusive of the accessible portions of the Project Site, which included three kiosk structures (Kiosk 1, Kiosk 2, and Kiosk 3) and one office building (Office) for a total of four structures. An intrusive investigation, including exploratory demolition of chases, soffits, enclosures, etc., was performed to the extent practicable due to the Project Site being occupied/in operation as a toll booth and park entrance station. Landmark’s field inspectors did investigate the wall and roof cavity areas with pre-existing damage where the building materials were already exposed. The field inspector also cut an opening into the wall in the office bathroom behind the toilet and sink, and similar openings were cut into the ceilings of the Office and Kiosk 2. Should any unforeseen suspect building materials be encountered during the eventual demolition, then the demolition work must be stopped, and suspect materials need to be sampled and tested for asbestos to characterize them prior to disturbance or presumed to be ACM and abated.

Prior to any renovation or demolition work activities in a public or commercial building, which may disturb greater than 160 sf, 260 lf, or the equivalent of a 55-gallon drum of friable material or non-friable ACM, which may become friable during the renovation or demolition activities, ACMs must be removed in accordance with all applicable U.S. EPA and CDPHE regulations.

7.2 Regulated Building Materials

The identified RBMs must be properly managed and recycled, reused, or removed and properly disposed prior to the demolition in accordance with EPA and CDPHE regulations. Some of the RBMs identified in this assessment may be recycled.

Items such as personal computer equipment, small refrigerators, small containers of commercial cleaners, and other comparable items not considered building components should also be properly disposed/recycled prior to demolition.

Conclusions and Recommendations

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7.3 Lead

Renovation activities that will impact LBP/LCP will require OSHA-trained workers and safety programs.

PPE, including respiratory protection, will be required to handle these items until the negative exposure assessments are completed, which shows the work activities do not result in exposures above the OSHA

Permissible Exposure Limit (PEL). In addition, an appropriate waste management plan should be developed for the disposal of LBP and LCP materials.

Lead soil samples were collected from the drip line surrounding Kiosk 3 and Office building structures with

LBP on the exterior. The Kiosk 1 and Kiosk 2 buildings also had LBP on the exterior, but their buildings were completely surrounded by asphalt road with no available soil at the dripline areas to sample. No lead soil samples exceeded EPA residential screening limits, and no further action is required for soil.

7.4 Biological Hazards

There is a potential presence of rodent droppings in the wall and ceiling cavity areas of the building structures located at the Project Site. If rodents are encountered during the demolition process, special precautions to avoid Hantavirus exposure of workers will be required. Disinfection of any areas found to have visible mouse droppings in wall and ceiling cavity areas must follow National Park Service Hantavirus

Work Protection guidelines, which are attached in Appendix E.

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8.0 LIMITATIONS

Landmark performed the environmental services in a manner consistent with the level of care and expertise exercised by members of the asbestos inspection and assessment profession. Landmark does not imply or guarantee that every suspect ACM, RBM, LBP, LCP, or biological hazard on or in the buildings has been identified or sampled.

This assessment is intended to identify those components that are reasonably suspect and are most likely to be ACM in quantities subject to regulation based on existing industry and regulatory standards. It should be noted that destructive investigation of pipe chases in the office bathroom and ceiling cavities throughout these four structures was not conducted due to these structures being occupied and in operational use at the time of the site assessment fieldwork. An intrusive investigation of the non-accessible areas including but not limited to the pipe chase areas in the office bathroom and ceiling cavities throughout, etc., must also be performed prior to starting the demolition work activities. If any unforeseen suspect building materials are encountered during the eventual demolition, the demolition work must be stopped, and suspect materials need to be sampled and tested for asbestos to characterize them prior to disturbance or presumed to be ACM and abated.

This document is not intended to be used as a bid document for the removal, repair, encapsulation, enclosure, or Operations and Maintenance (O&M) of ACMs or LBP. Quantities of identified ACMs and

LBP should be field-verified by the contractor prior to bidding on any and all work associated with this assessment report. Landmark can prepare a Scope of Work/Project Design, bid documents, removal and repair methods/procedures, specifications, and O&M Plans if desired by the Client. These documents, if requested, will be prepared by EPA-accredited and state-certified individuals.

This report does not warrant against operations or conditions present of a type or at locations not investigated during this assessment. This assessment is intended to identify those components that are reasonably suspect and are most likely to be hazardous or in quantities subject to regulation based on existing industry and regulatory standards.

This report is intended for the sole reliance and use of the Client. The findings presented in this report are professional opinions based solely upon visual observations and supplemental testing of materials within the Project Site. Landmark is not responsible for independent conclusions, opinions, or recommendations made by others regarding the summary of field sampling and laboratory test data presented in this report.

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9.0 ENDORSEMENTS

Field activities and preparation of this report was conducted by the following Landmark personnel:

Lauren Kryszczuk Project Industrial Hygienist Certified Asbestos Inspector and Designer #22230 Certified Lead-Based Paint Inspector/Risk Assessor #25301

Review of this report was conducted by the following Landmark personnel:

Brandy Howard, PE, CIH, CSP Project Manager Certified Asbestos Inspector and Designer #20743 Certified Lead-Based Paint Inspector/Risk Assessor #20678

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10.0 ACRONYMS

ACRONYM Acronym Definition µg/m3 Micrograms per cubic meter of air

ACM Asbestos-Containing Material

AHERA Asbestos Hazard and Emergency Response Act

AIHA American Industrial Hygiene Association

AL Action Level

CABI Certified Asbestos Building Inspector

CDPHE Colorado Department of Public Health and Environment

CFR Code of Federal Regulations

EPA Environmental Protection Agency

HUD U.S. Department of Housing and Urban Development

LBP Lead-Based Paint

LCP Lead-Containing Paint

NESHAP National Emission Standard for Hazardous Air Pollutants

NIOSH National Institute of Occupational Safety and Health

NVLAP National Voluntary Laboratory Accreditation Program

OSHA Occupational Safety and Health Administration

PCB Polychlorinated Biphenyl

PLM Polarized Light Microscopy

RACM Regulated ACMs

RCRA Resource Conservation and Recovery Act

RBM Regulated Building Material

TC Toxicity Characteristic

TCLP Toxicity Characteristic Leaching Procedure

XRF X-ray Fluorescent

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11.0 REFERENCES

Code of Federal Regulations (CFR). OSHA Construction Standards for Asbestos.