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HAZARDOUS MATERIALS SURVEY REPORT

HURRICANE RIDGE DAY LODGE

OLYMPIC NATIONAL PARK

3002 MOUNT ANGELES ROAD

PORT ANGELES, WASHINGTON 98362

Prepared for:

Anderson Hallas Architects, P.C.

715 Fourteenth Street Golden, Colorado 80401

Prepared by:

Landmark Environmental, Inc.

7881 Shaffer Parkway Littleton, Colorado 80127

Landmark Project No. 21034.001.001

Issued 7/23/21

Revised 5/25/22

CONTENTS

Landmark Project No. 21034.001.001 i

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

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

LEAD ........................................................................................................................................................ B

REGULATED BUILDING MATERIALS ........................................................................................................ C

FUEL OIL UNDERGROUND STORAGE TANK ............................................................................................. C

BIOLOGICAL HAZARDS ............................................................................................................................ D

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

1.1 SCOPE OF WORK ........................................................................................................................ 1-1

1.2 PROJECT SITE DESCRIPTION ....................................................................................................... 1-1

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

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

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

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

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

2.4 FINDINGS .................................................................................................................................... 2-4

2.4.1 Asbestos-Containing Materials .......................................................................................... 2-4

2.4.2 Presumed Asbestos-Containing Materials ......................................................................... 2-4

2.4.3 Identified Non-Asbestos Materials ..................................................................................... 2-6

3.0 LEAD................................................................................................................... 3-1

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

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

3.3 LEAD LABORATORY ANALYSIS ................................................................................................. 3-2

3.4 FINDINGS .................................................................................................................................... 3-2

3.4.1 Lead-Based Paint ............................................................................................................... 3-2

3.4.2 Lead-Containing Paint ....................................................................................................... 3-2

4.0 REGULATED BUILDING MATERIALS ................................................................. 4-1

4.1 FUEL OIL UNDERGROUND STORAGE TANK REGULATORY CRITERIA ....................................... 4-2

4.2 FUEL OIL UNDERGROUND STORAGE TANK ............................................................................... 4-2

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

5.1 FINDINGS .................................................................................................................................... 5-1

6.0 RECOMMENDATIONS ......................................................................................... 6-1

Landmark Project No. 21034.001.001 ii

6.1 ASBESTOS ................................................................................................................................... 6-1

6.2 LEAD .......................................................................................................................................... 6-1

6.3 REGULATED BUILDING MATERIALS .......................................................................................... 6-1

6.4 FUEL OIL UNDERGROUND STORAGE TANK ............................................................................... 6-2

6.5 BIOLOGICAL HAZARDS .............................................................................................................. 6-2

7.0 LIMITATIONS ..................................................................................................... 7-1

8.0 ENDORSEMENTS ............................................................................................... 8-1

APPENDICES

APPENDIX A: ASBESTOS INFORMATION

APPENDIX B: LEAD INFORMATION

APPENDIX C: REGULATED BUILDING MATERIALS INFORMATION

APPENDIX D: BIOLOGICAL HAZARDS INFORMATION

APPENDIX E: CREDENTIALS

Landmark Project No. 21034.001.001 A

EXECUTIVE SUMMARY

This Hazardous Materials Survey Report for the Hurricane Ridge Day Lodge (Project Site) in Olympic

National Park in Washington has been prepared by Landmark Environmental, Inc. (Landmark) for

Anderson Hallas Architects, P.C. (Anderson Hallas). The Project Site is located at 3002 Mount Angeles

Road in Port Angeles, Washington 98362. Landmark conducted the survey of the Project Site on June 22 and 23, 2021.

Asbestos

Confirmed Asbestos-Containing Materials

The following materials were found to contain more than 1% asbestos by laboratory analysis:

• Roofing Material (RF02): Black and brown fibrous tar-impregnated paper felt material adhered to the outside of the existing western fireplace structure associated with the original roofing materials accessible from the attic space was identified to contain 25% chrysotile asbestos by Polarized Light

Microscopy (PLM) laboratory analysis.

• Sink Undercoating (UC01): Off-white friable sink undercoating material located on the bottom of two metal sinks within the main floor employee kitchen (Room 59) was identified as 4% chrysotile asbestos by PLM laboratory analysis.

Presumed Asbestos-Containing Materials

The following presumed asbestos-containing materials (PACM) were not sampled for one of three reasons:

1) sampling the material would have affected the integrity of the system, 2) sampling the material would have damaged the finish of material not easily repaired or replaced, or 3) sampling could not be performed because the material was inaccessible (i.e., too high for safe ladder access). These materials must be treated as asbestos and should be sampled before they are impacted:

• Boiler Insulation (BI01): Insulation material present inside of older type boilers may be asbestos-containing material. The boiler located within the basement level boiler room was active at the time of this survey and could not be taken apart and sampled without causing damages. The insulation should be sampled if the boiler will be disposed of as part of the planned renovation activities.

Executive Summary

Landmark Project No. 21034.001.001 B

• Duct Sealant (DS02): Black sealant on metal ductwork was visible in a historic roofing cavity area in the northwest corner of attic space 60. This duct sealant material was not found by Landmark’s field inspector at the time of the Project Site visit and was discovered by Anderson Hallas’s mechanical engineering sub-consultant for the project.

• Electrical Wiring Insulation and Panels (EI01): Electrical systems were energized during the survey and could not be sampled. Several components have the potential to contain asbestos and should be sampled once the systems are de-energized and before they are disassembled.

• Fire Door Material (FDM01): Fire doors occasionally have asbestos insulation in their core. Fire doors cannot be sampled before they are removed as sampling affects their integrity as fire doors.

These doors should be sampled if they will be disposed of during renovation activities.

• Gasket Material (GM01): The pipe flange gaskets may contain asbestos. Various sizes and types of gaskets existing within active piping systems throughout the building. These were not sampled to protect the integrity of the piping systems. These gaskets should be sampled if and when the piping systems are disassembled.

• Elevator Door Insulation (OT02): The insulation material inside elevator doors is occasionally asbestos-containing material. Elevator doors cannot be bulk sampled before they are removed as sampling affects the integrity of these doors, as well as any potential fire rating. These doors should be sampled if they will be disposed of during renovation activities.

• Elevator Brake Pads (OT09): Brake pads occasionally contain asbestos. If this system will not be reused in another location and will be disposed, sampling of the brake pads should occur. Landmark could not sample the elevators’ brake pads as this material was not accessible to the site inspector at the time of fieldwork.

• Pipe Insulation (PI03): Suspect asbestos-containing pipe insulation materials on inaccessible pipes associated with the radiant heat system, wherever components of this system are present throughout the building.

Lead

Bulk paint chip samples were collected from areas with existing delineating paint, including thirty interior and exterior painted surfaces. Lead-Based Paint (LBP) is paint that contains more than 0.5% lead by laboratory analysis. Lead-Containing Paint (LCP) is paint that contains detectable levels of lead but less

Landmark Project No. 21034.001.001 C than 0.5% lead by laboratory analysis. Three of the paints sampled contain detectable amounts of lead via

Flame Atomic Absorption Spectrometry (FAAS) laboratory analysis and are considered to be LCP. The

LCP materials identified at the Project Site are summarized below.

Lead-Containing Paint

The following paint combinations were found to be LCP:

• Paint Chip-16: A green-grey paint on a concrete foundation wall within 22 basement exterior storage room.

• Paint Chip-17: A green paint coating the wooden handrailing located at the western exterior porch and staircase areas.

• Paint Chip-23: A brown paint coating the wooden railings located at the western exterior porch and staircase areas.

Renovation activities that will impact LCP require Occupational Safety and Health Administration

(OSHA)-trained workers and safety programs. Personal Protective Equipment (PPE) 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). Additionally, an appropriate waste management plan should be developed for the disposal of the LCP materials. Some components were identified as having LCP in poor condition. The LCP listed in poor condition should be repaired/removed by OSHA-trained workers as part of the renovation activities. Any LCP in good condition that will not be impacted by renovation activities can be left in the building.

Regulated Building Materials

The Regulated Building Materials (RBMs) were cataloged by area. Renovation activities that will impact

RBMs will require proper removal, disposal, and management. These items must be either reused, recycled, or disposed, and handled in accordance with applicable regulations.

Fuel Oil Underground Storage Tank

The existing heating, ventilation, and air-conditioning (HVAC) system consists of a fuel oil-fired boiler that supplies a hydronic system which distributes heat. The associated fuel oil underground storage tank

(UST) is past its expected lifespan. The dimensions of the UST are estimated to be approximately 30-feet

Landmark Project No. 21034.001.001 D

(ft) long by 7-ft in diameter. The estimated volume is approximately 10,000 gallons (gals). Before the UST is removed, the waste fuel oil should be removed for disposal at an approved waste oil disposal facility.

Prior to disconnecting and/or cutting the associated piping and appurtenances, the UST interior atmosphere should be tested. The soil surrounding the UST should be inspected as it is removed during the excavation.

Soil which appears to be contaminated (visual, odor etc.) with fuel oil should be excavated and sampled for waste profiling and acceptance as a special waste.

Biological Hazards

The Park Service’s facilities maintenance staff indicated that rainwater and snowmelt frequently enter the building interior via louvers that are located on the northern and western sides of the exterior façade. These louvers are associated with the eastern portion of the attic as well as the west heating, ventilation, and air-conditioning (HVAC) and storage room areas located on the main level. Similarly, the Park Service personnel and Anderson Hallas indicated concerns regarding moisture intrusion and mold growth within various interstitial spaces located at the joining of the different building additions. Landmark’s inspector did not observe recent signs of moisture and mold damage from the surface of previously mentioned areas of the building. However, recent moisture damage was observed throughout the eastern portion of the basement level at pipe penetrations for the cast iron pipes and in a central doorway located in 03 storage and break room. More moisture damage, similar to the damage present within the central doorway in 03 storage and break room, was observed in the central doorway of 10 hallway. Anderson Hallas and the Park

Service indicated an exploratory investigation of the previously mentioned interstitial spaces might likely occur as a separate task and during a future investigation project.

On June 24, 2021, and after Landmark’s field inspector had left the Project Site, Anderson Hallas found another accessible attic space located above the basement 20 southeast retail storeroom and concession.

Visible moisture damage was apparent on building materials in this attic space, including water staining on the north wood wall. Anderson Hallas was unable to see further past this north wall and into the main retail storeroom 19 and southwest retail storeroom 21 due to curtain walls in this area of the building. However, it is suspected that similar type moisture damage and possibly mold growth is present in the attic and ceiling cavities above basement retail storerooms 19 and 21.

Damaged or improperly sealed exterior windows are another potential source of moisture and mold damage at the Hurricane Ridge Day Lodge building. Although, conspicuously visible signs of water damage and mold growth were not apparent from the outside areas surrounding the exterior windows at the time of the fieldwork.

Landmark Project No. 21034.001.001 E

Rodent droppings were also observed by Landmark in areas located throughout the entire building. Due to the presence of rodent droppings, there is a potential risk of Hantavirus exposure for anyone handling items within the structure. Work practices for the renovation should follow the National Park Services Hantavirus

Risk Reduction – Work Protection guidelines updated in December 2013.

Landmark Project No. 21034.001.001 1-1

1.0 INTRODUCTION

This Hazardous Materials Survey Report for the Hurricane Ridge Day Lodge (Project Site) in Olympic

National Park in Washington has been prepared by Landmark Environmental, Inc. (Landmark) for

Anderson Hallas Architects, P.C. (Anderson Hallas). The Project Site is located at 3002 Mount Angeles

Road in Port Angeles, Washington 98362. Landmark conducted the survey of the Project Site on June 22 and 23, 2021.

The purpose of Landmark’s inspection of the Project Site was to assess and identify hazardous materials as part of the planning phase of the Design Documentation (DD) and Construction Documentation (CD) being prepared by Anderson Hallas for the National Park Service (NPS). Accordingly, Landmark’s screening-level environmental surveys are designed to provide the appropriate information to support the development of design and construction documentation and budgeting for future renovation.

1.1 Scope of Work

As per the Scope of Work document used in the bidding process, Landmark’s scope of work included assessing the Project Site for asbestos-containing materials (ACM), lead-containing paint (LCP), lead-based paint (LBP), and other potentially hazardous materials/conditions. The other potentially hazardous materials/conditions that were specifically assessed were mold growth, polychlorinated biphenyls (PCBs) in fluorescent light ballasts, fluorescent light tubes, transformers, mercury light switches, and miscellaneous containers of unknown substances. Landmark also assessed the Project Site for evidence of any rodent intrusion and moisture infiltration.

1.2 Project Site Description

Most of the Project Site was constructed in 1951, and the building was originally designed to be used as a ski lodge. Anderson Hallas provided copies of the 1951 original design drawings to Landmark for review.

In 1983, the Project Site was renovated, and this renovation included adding more garage space, a theater, and an exhibit room on the main level. A central elevator appears to have been constructed sometime between the early 1950s and the middle 1980s. In the 1990s, additional renovation work was performed at the Project Site, which included heating, ventilation, and air conditioning (HVAC) system upgrades and the construction of a new roofing system above the older roofing system. Anderson Hallas additionally provided copies of the 1983 and 1999 construction drawings for Landmark’s review. The Project Site’s existing HVAC system consists of a fuel oil-fired boiler that supplies a hydronic system which distributes heat. This system was installed during the 1983 remodel. The fuel oil underground storage tank (UST) is

Introduction

Landmark Project No. 21034.001.001 1-2 past its expected lifespan. The planned project will replace all components of the HVAC system and upgrade the fuel oil-fired boiler to a high efficiency diesel boiler. The existing unmonitored single wall fiberglass fuel oil UST will be replaced.

1.3 Report Organization

This report presents the findings and recommendations following the survey and sampling efforts at the

Project Site. Appendix A contains all the asbestos-related information, including a materials summary form, laboratory data, summary tables of ACM and non-ACM materials, and asbestos sample location figures.

Appendix B contains the lead paint data summary tables, laboratory data, and lead sample location figures.

Appendix C contains a summary table of the Regulated Building Materials (RBMs) present in the building during the survey work. Appendix D contains the NPS Hantavirus Risk Reduction – Work Protection guidelines. Appendix E contains the inspector credentials.

Landmark Project No. 21034.001.001 2-1

2.0 ASBESTOS

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

2.1 Asbestos 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; and therefore, asbestos is regulated by the Environmental Protection

Agency (EPA) and Occupational Safety and Health Administration (OSHA). This brief overview of certain applicable asbestos regulatory criteria is general and for informational purposes only.

In general, removal/repair of ACM is required by regulation if the potential exists for an airborne release of asbestos fibers or if the ACM will be disturbed. 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 the asbestos is in poor condition or that asbestos debris is present.

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

Applicable asbestos regulations define asbestos-containing material (ACM) as material containing greater than 1% asbestos by weight, volume, or visual surface area and 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) regulations 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 (non-Category I) must be removed prior to demolition.

Landmark Project No. 21034.001.001 2-2

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 workers from exposure to asbestos through notification, training, proper work practices, and the use of personal protection equipment.

If the amount of ACM to be disturbed exceeds the following trigger levels, then a certified abatement contractor must remove the ACM prior to renovation or demolition. Trigger levels of ACMs are 260-linear feet (lf) on pipes, 160-square feet (sf) on other surfaces, or the volume equivalent of 35-cubic feet. Although certain non-friable ACMs may remain in a building during demolition, the presence of non-friable ACM might impact disposal and will preclude the recycling of materials. Recycling of materials, such as concrete or wood that are bonded or contaminated with ACM is not permitted.

Demolition of a building that has non-friable asbestos-containing vinyl asbestos tile (VAT), tar-impregnated roofing materials, or drywall joint compound in composite wallboard systems must be completed without causing the ACMs to become friable. Operations such as crushing, pneumatic jacking, etc., that renders the ACM friable are not permitted. When imploding or burning a building structure, all

ACM, regardless of quantity, must be removed prior to these activities.

2.2 Technical Approach

Bulk sampling was conducted in accordance with the EPA Asbestos Hazard and Emergency Response Act

(AHERA) and OSHA 29 CFR 1926.1101 requirements, as well as generally accepted industry standards.

Asbestos activities were conducted by AHERA-accredited personnel. Copies of the inspector’s credentials are included in Appendix E.

The inspection included visually assessing the Project Site facilities for homogeneous areas, performing a physical assessment of the material, and sampling suspect ACM. Bulk samples of accessible suspect ACMs were collected within a representative manner as determined by the inspector. Bulk material samples were collected by taking representative samples that included all layers within the suspect ACM. Sampling was limited to materials that were visible and readily accessible to the inspector. No intrusive investigation was conducted. Representative bulk sampling was based on the distribution of the suspect ACM throughout the homogeneous area and the suspect ACM’s physical characteristics and application.

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

• Surfacing Materials – Trowel or sprayed applied materials:

Landmark Project No. 21034.001.001 2-3 o Three samples of each homogeneous area 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.

o Two samples of a patching material which is less than 6-ft in length.

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

o Sufficient number to determine asbestos content (minimum of two samples).

Bulk ACM samples were given unique numeric identifiers for project tracking and identification purposes.

The first set of numbers is the building number. The second set of letters/numbers identifies the room or area where the sample was collected. The third set of letter/number combinations identifies the type of material the sample was collected from and the homogenous material identifier for the functional space.

The last set of numbers represents the sequential sample acquired for the homogeneous material.

As suspect ACMs were identified, the materials were also quantified, and the condition of the suspect ACM was assessed (i.e., friability was assessed, and ACM was evaluated for damage or deterioration).

2.3 Asbestos Laboratory Analysis

The bulk suspect ACM samples were submitted to EMSL Analytical, Inc. (EMSL) laboratory located in

Seattle, Washington. EMSL’s Seattle laboratory is a National Voluntary Laboratory Accreditation Program

(NVLAP) accredited laboratory for Bulk Asbestos Fiber Analysis. The bulk samples were analyzed by utilizing Polarized Light Microscopy (PLM) coupled with dispersion staining techniques as detailed in the

EPA’s Interim Method for Determination of Asbestos in Bulk Insulation Samples (EPA 40 CFR Part 763

Subpart F, Appendix A). Detection limits for the PLM analysis are approximately 1% (by surface area).

Materials containing greater than 1% asbestos are classified as ACM.

Asbestos content is reported by the laboratory for each unique layer. Analytical results report asbestos by mineral type and concentration as a percent by weight both by layer and in the composite sample. A copy of the analytical report is included in Appendix A.

Landmark Project No. 21034.001.001 2-4

2.4 Findings

Landmark collected 131 bulk samples from a total of 50 suspect materials. An addition eight materials were presumed to contain asbestos. These presumed asbestos items were not sampled for one of three reasons:

1) sampling the material would have affected the integrity of the system, 2) sampling the material would have damaged the finish of material not easily repaired or replaced, or 3) sampling could not be performed because the material was inaccessible (i.e., too high for safe ladder access).

Two of the 50 suspect materials sampled contained asbestos. The asbestos data, including homogeneous material form, laboratory data, and a sample location figure, are located within Appendix A.

2.4.1 Asbestos-Containing Materials

The following materials were found to contain more than 1% asbestos by laboratory analysis:

• Roofing Material (RF02): Black and brown fibrous tar-impregnated paper felt material adhered to the outside of the existing western fireplace structure associated with the original roofing materials accessible from the attic space was identified to contain 25% chrysotile asbestos by PLM laboratory analysis. It is estimated there are about 300 sf of RF02 located between the original roof and western fireplace.

• Sink Undercoating (UC01): Off-white friable sink undercoating material located on the bottom of two metal sinks within the main floor 59 employee kitchen room was identified as 4% chrysotile asbestos by PLM laboratory analysis. Two metal sinks with UC01 were found in this kitchen.

2.4.2 Presumed Asbestos-Containing Materials

These items were not sampled for the reasons listed above. These presumed materials must be treated as asbestos and should be sampled before they are impacted:

• Boiler Insulation (BI01): Insulation material present inside of older type boilers may be asbestos-containing material. The boiler located within the basement level boiler room was active at the time of this survey and could not be taken apart and sampled without causing damages. The insulation should be sampled if the boiler will be disposed of as part of the planned renovation activities. One boiler with suspect BI01 was found in 16 basement boiler room.

• Duct Sealant (DS02): Black sealant on metal ductwork was visible in a historic roofing cavity area in the northwest corner of attic space 60. This duct sealant material was not found by Landmark’s

Landmark Project No. 21034.001.001 2-5 field inspector at the time of the site visit and was discovered by Anderson Hallas’s mechanical engineering sub-consultant for the project. An estimated quantity of the DS02 could not be provided; however, it is assumed that this material might be present on inaccessible ductwork components located throughout the building.

• Electrical Wiring Insulation and Panels (EI01): Electrical systems were energized during the survey and could not be sampled. Several components have the potential to contain asbestos and must be sampled once the system is de-energized and before they are disassembled. An estimated 1,780 lf of EI01 is suspected to be located throughout the building.

• Fire Door Material (FDM01): Fire doors occasionally have asbestos insulation in their core. Fire doors cannot be sampled before they are removed as sampling affects their integrity as fire doors.

These doors should be sampled if they will be disposed of during renovation activities. An estimated 35 fire doors are present in various areas located throughout the building.

• Gasket Material (GM01): The pipe flange gaskets may contain asbestos. Various sizes and types of gaskets existing within active piping systems throughout the building. These were not sampled to protect the integrity of the piping systems. These gaskets should be sampled if and when the piping systems are disassembled. An estimated ten gaskets were found in the basement 16 boiler room.

• Elevator Door Insulation (OT02): The insulation material inside elevator doors is occasionally asbestos-containing material. Elevator doors cannot be bulk sampled before they are removed as sampling affects the integrity of these doors, as well as any potential fire rating. These doors should be sampled if they will be disposed of during renovation activities. It is estimated that one elevator door is present.

• Elevator Brake Pads (OT09): Brake pads occasionally contain asbestos. If this system will not be reused in another location and will be disposed, sampling of the brake pads should occur. Landmark could not sample the elevators’ brake pads as this material was not accessible to the site inspector at the time of fieldwork. It is estimated that one elevator brake pad is present.

• Pipe Insulation (PI03): Suspect asbestos-containing pipe insulation materials on inaccessible pipes associated with the radiant heat system, wherever components of this system are present throughout the building. It is unknown what the approximate amount of PI03 is for radiant heat system pipes located within the inaccessible wall cavities located throughout the building.

Landmark Project No. 21034.001.001 2-6

2.4.3 Identified Non-Asbestos Materials

The following materials were sampled, analyzed, and found not to contain asbestos:

• Baseboards and Baseboard Adhesives (BBA01, BBA02, BBA03, BBA04, and BBA05): Various

4-inches to 6-inches type multi-colored baseboards with associated adhesives.

• Carpet Adhesives (CA01, CA02, and CA03): Various colored carpet adhesives with floor fillers.

• Composite Drywall Systems (CDW01, CDW02, and CDW03): Grey and white drywall with brown paper backing, off-white tape, and texture throughout all building levels.

• Caulking (CK01): Exterior caulking material associated with wooden components of the building façade.

• Ceiling Tile Adhesive (CTA01): White fissured 12-inches by 12-inches ceiling tiles with a brown adhesive.

• Duct Sealant (DS01): Grey sealant on metal HVAC ductwork.

• Fire Brick Materials (FB01 and FB02): The fire bricks inside of the metal oven and mortar material between bricks comprising the main fireplace structure.

• Floor Tiles and Associated Mastics (FTC01, FTC02, FTC03, and FTC04): Various multi-colored

12-inches by 12-inches floor tiles with associated mastics.

• Lay-In-Place Ceiling Tiles (LIP01): White fissured 12-inches by 12-inches nailed-in ceiling tiles.

• Mastic Materials (MA01 and MA02): Residual mastic materials adhered to the concrete building foundation and concrete floor slab on the main level.

• Stair Treads and Rolled Rubber Flooring with Adhesives (OT01, OT04, and OT05): Multi-colored stair treads and rolled rubber sheet flooring materials with associated adhesives.

• Ceramic Floor and Wall Tiles (OT03 and OT06): 1-inch by 1-inch ceramic floor tiles, grout and adhesive, and 4-inches by 4-inches ceramic wall tiles with grout and adhesive.

• Fibrous Wallpaper (OT07): Brown fibrous wallpaper/covering material.

Landmark Project No. 21034.001.001 2-7

• Fibrous Oven Gasket Material (OT08): White grey fibrous gasket/rope material inside of the edges of the metal oven.

• Paper Felt Material (PFM01): Black and brown felt paper with black tar adhered to the concrete building foundation.

• Pipe Insulations (PI01 and PI02): Fiberglass with associated paper/foil and adhesive and cloth pipe insulation materials.

• Pipe Sealant (PS01): White pliable pipe sealant on fiberglass pipe insulation throughout.

• Pipe Wrap (PW01, PW02, and PW03): Various types of pipe wraps and patches on fiberglass pipe insulation.

• Roofing Materials (RF01, RF03, and RF04): Tan foam board with black paper, black pliable tars intermixed with stone ballast, and another tar-impregnated felt material.

• Sheet Vinyl Floorings (SVF01, SVF02, SVF03, SVF04, and SVF05): Multi-color sheet vinyl floor materials with associated mastics.

• Texture Surfacing Materials on Drywall Systems (TS01, TS02, and TS03): White texture surfacing materials applied over the three different types of composite drywall systems (CDW01, CDW02, and CDW03).

Landmark Project No. 21034.001.001 3-1

3.0 LEAD

The regulatory criteria, technical approach, laboratory analysis, and findings as they pertain to lead-based paint are discussed below.

3.1 Regulatory Criteria

EPA and U.S. Department of Housing and Urban Development (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.

The EPA and HUD regulations related to LBP abatement do not apply to the Project Site unless abatement activities occur (specifically designed to permanently remove any LBP). LBP is defined as paint containing

0.5% by weight or 1.0-milligram per square centimeter (mg/cm2) by the EPA and HUD. OSHA regulates worker exposure to lead for coatings with any detectable lead.

The EPA also developed a program for renovation activities in child-occupied/target housing and childcare facilities called the Lead Renovation, Repair, and Paint Rule (RRP Rule). This rule requires that firms performing renovation, repair, and painting projects that disturb LBP in homes, childcare facilities ,and pre-schools built before 1978, have their firm certified by the 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 Project Site since the building is not considered target housing or a child-occupied facility (not visited regularly by the same child under age six).

The OSHA lead in construction standard 29 CFR 1926.62 addresses the 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).

3.2 Technical Approach

The LBP/LCP survey was performed by an EPA Lead Inspector, Risk Assessor, and Washington-licensed

LBP Risk Assessor. The LCP/LBP survey work was conducted concurrently with the ACM survey. The

Landmark Project No. 21034.001.001 3-2

LCP portion of this survey was performed by a trained LBP Inspector utilizing paint chip sampling in the field. Chip samples of suspect lead paint were collected in a representative manner as determined by the inspector based on the identified testing combinations where the surface color, substrate, or building components were visibly different. The sampling was limited to materials that were visible and readily accessible to Landmark’s inspector. Representative photographs, a paint inventory by room/area, paint chip summary datasheet, laboratory analysis, and sample location figures are included in Appendix B.

3.3 Lead Laboratory Analysis

The suspect lead-based and lead-containing samples were submitted to EMSL and analyzed via FAAS to determine the concentration of lead as a percentage by weight. EMSL is an accredited laboratory under the

American Industrial Hygiene Association (AIHA) Environmental Lead Laboratory Accreditation Program

(ELLAP, AIHA LAP 101533). The lead laboratory results are included in Appendix B.

3.4 Findings

Bulk paint chip samples were collected from areas with existing delineating paint, including thirty interior and exterior painted surfaces. Three of the samples contained detectable amounts of lead and are considered to be LCP. The LCP identified at the Project Site is summarized below. Eight of the paint chip samples that were collected (Paint Chips 02, 04, 05, 07, 08, 14, 20, and 24) included an insufficient weight of material necessary for analysis, as reported by EMSL. However, a sufficient amount of the representative paint chip samples needed to provide data for the major testing combinations was still provided via the 22 samples which were analyzed.

3.4.1 Lead-Based Paint

The following paint combinations were found to be LBP:

• None.

3.4.2 Lead-Containing Paint

The following paint combinations were found to be LCP:

• Paint Chip-16: A green-grey paint on a concrete foundation wall within 22 basement exterior storage room.

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• Paint Chip-17: A green paint coating the wooden handrailing located at the western exterior porch and staircase areas.

• Paint Chip-23: A brown paint coating the wooden railings located at the western exterior porch and staircase areas.

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4.0 REGULATED BUILDING MATERIALS

The regulatory criteria and technical approach as they pertain to RBMs are discussed below.

The RBM survey work included the visual identification and quantification of the following: refrigerants chlorofluorocarbons (CFCs); waste oils or chemicals; fluorescent bulbs and ballasts potentially containing mercury and PCBs, respectively; transformers which potentially contain PCBs; utility switches and thermostats potentially containing mercury; high-intensity discharge exterior lighting potentially containing mercury; and fixtures that may contain batteries or radiation sources.

This inventory was limited to the RBMs which were visible and readily accessible to the inspector, including some of the following items:

• Canisters of compressed carbon dioxide gas.

• Commercial cleaning products.

• Construction and maintenance chemicals, such as paints, varnishes, oils, and degreasers.

• Computer and other electronic equipment.

• CFCs including refrigerators, freezers, and ice machines.

• Emergency lighting.

• Exist signs and exist signs with built-in emergency lighting.

• Fire extinguishers (handheld).

• Gasoline for staff vehicles and landscaping equipment.

• Compact light bulbs.

• Fluorescent light bulbs (tubes 2 to 4-ft in length).

• Light ballasts containing suspect PCBs.

• Mechanical equipment fluids, including the fuel oil UST, oils and hydraulic fluids.

Regulated Building Materials

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• Miscellaneous flammable chemicals in a locked/inaccessible cabinet within the main level garage.

• Propane gas canisters.

• Smoke detectors with batteries.

• Transformers containing suspect PCBs in the electrical rooms.

A complete RBMs inventory by room/area is included in Appendix C.

4.1 Fuel Oil Underground Storage Tank Regulatory Criteria

The State of Washington Department of Ecology enforces state regulations Chapter 173-360A Washington

Administrative Code (WAC), and Chapter 90.76 Revised Code of Washington (RCW) related to USTs.

However, removal of the heating oil UST at the Project Site is exempt from the state UST regulations used solely for heating structures on the property where the system is located. Listed below are the planned activities associated with the UST removal:

• Removal and disposal of accumulated liquid and sludge from the tank and piping,

• UST removal and disposal,

• Piping and appurtenances removal and disposal,

• Soil removal and inspection for contamination,

• Soil testing if such contamination is identified, and

• Backfill, compact and final mulch to grade.

4.2 Fuel Oil Underground Storage Tank

The estimated dimensions for the existing fuel oil UST are 30-feet (ft) in length by 7-ft in diameter. The estimated volume is approximately 10,000 gallons (gals).

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5.0 BIOLOGICAL HAZARDS

Landmark conducted limited observations for potential biological hazards during the Project Site walkthrough. These observations were primarily limited to rodent or insect infestations, water intrusion, or visual evidence of mold growth through the structure.

5.1 Findings

The Park Service’s facilities maintenance staff indicated that rainwater and snowmelt frequently enter the building interior via louvers that are located on the northern and western sides of the exterior façade. These louvers are associated with the eastern portion of the attic as well as the west HVAC and storage room are located on the main level. Similarly, the Park Service personnel and Anderson Hallas indicated concerns regarding moisture intrusion and mold growth within various interstitial spaces located at the joining of the different building additions. Landmark’s inspector did not observe recent signs of moisture and mold damage from the surface of previously mentioned areas of the building. However, recent moisture damage was observed throughout the eastern portion of the basement level at pipe penetrations for the cast iron pipes and in a central doorway located in the storage and break room (Room 03 on Figures). More moisture damage, similar to the damage present within the central doorway in the storage and break room (Room 03 on Figures), was observed in the central doorway of the hallway (10 on Figures). Anderson Hallas and the

Park Service indicated an exploratory investigation of the previously mentioned interstitial spaces might likely occur as a separate task and during a future investigation project.

On June 24, 2021, and after Landmark’s field inspector had left the Project Site, Anderson Hallas found another accessible attic space located above the basement 20 southeast retail storeroom and concession.

Visible moisture damage was apparent on building materials in this attic space, including water staining on the north wood wall. Anderson Hallas was unable to see further past this north wall and into the main retail storeroom 19 and southwest retail storeroom 21 due to curtain walls in this area of the building. However, it is suspected that similar type moisture damage and possibly mold growth is present in the attic and ceiling cavities above basement retail storerooms 19 and 21.

Damaged or improperly sealed exterior windows are another potential source of moisture and mold damage at the Hurricane Ridge Day Lodge building. Although, conspicuously visible signs of water damage and mold growth were not apparent from the outside surficial areas of the exterior windows at the time of the fieldwork.

Biological Hazards

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Rodent droppings were also observed by Landmark in areas located throughout the entire building. Due to the presence of rodent droppings, there is a potential risk of Hantavirus exposure for anyone handling items within the structure. The NPS Hantavirus Risk Reduction – Work Protection guidelines are included in

Appendix D.

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6.0 RECOMMENDATIONS

A summary of the findings for each hazardous material assessed is described below. Data tables and more in-depth summaries are included within Appendices A through D for each constituent.

6.1 Asbestos

The identified ACMs should be removed in accordance with all local, state, and federal regulations, if renovation activities will disturb these materials or if demolition is planned for the structure. Abatement of

ACM requires EPA-certified/trained workers and permits. Abatement must include the appropriate controls and waste disposal at a certified landfill.

If ACM is to remain in place, it is recommended that an Operations and Maintenance (O&M) Program be adopted. The O&M Program includes a listing of the known asbestos within the buildings and procedures to minimize the potential for disturbance of ACM. O&M Programs are designed to present processes for communication and planning regarding ACM management, reduce the potential for unplanned impacts that might cause ACM disturbance or damage, and consolidate and organize the data collected related to ACM to facilitate planning and management, training requirements, notifications, and monitor the condition of

ACM over time.

6.2 Lead

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

PPE will be required to handle these items until negative exposure assessments are completed that show the work activities do not result in exposures above the OSHA PEL. In addition, an appropriate waste management plan should be developed for the disposal of the LBP/LCP materials. Some components were identified as having lead-containing paint in poor condition. The LBP/LCP listed in poor condition should be repaired/removed by OSHA-trained workers as part of the renovation activities. Any LBP/LCP in good condition that will not be impacted by renovation activities may remain in the building.

6.3 Regulated Building Materials

Renovation activities that will impact RBMs will require proper removal, disposal, and management. These items must be either reused, recycled, or disposed of and handled in accordance with applicable regulations.

Recommendations

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6.4 Fuel Oil Underground Storage Tank

Before the UST is removed, the waste fuel oil and any associated rinse solutions should be removed for disposal at an approved waste oil disposal facility. Prior to disconnecting and/or cutting the associated piping and appurtenances, the UST interior atmosphere should be tested and dry ice or nitrogen used to fill the interior of the UST with inert gas, such as carbon dioxide (dry ice) or nitrogen. A four gas monitor should be used to measure oxygen levels within the UST to ensure that oxygen levels are below the Lower

Explosive Limits (LEL) of 19.5% prior to cutting with a demolition saw or cutting torch.

The soil surrounding the UST should be inspected as it is removed during the UST excavation. Clean soil as evidenced by visual and odor assessment and Photo Ionization Detector (PID) headspace readings should be collected to assess for petroleum vapors from excavated soils stockpiled in a cleared area at a minimum of 10 ft from the excavation walls. Soil that appears to be contaminated (visual and odor assessment and headspace readings using the PID) with fuel oil should be excavated and placed on plastic at a minimum of

10 ft from the excavation walls.

Soil contaminated with fuel oil should be sampled for waste profiling and acceptance as a special waste and analyzed for Benzene, Toluene, Ethylbenzene, Xylene (BTEX). After this fuel oil UST is removed it is recommended that clean backfill be provided and compacted.

6.5 Biological Hazards

The previously discussed louvers located on the north and west sides of the exterior building façade should be further investigated and repaired to prevent water from entering the buildings’ interior via these louvers.

Anderson Hallas and the Park Service facilities maintenance staff are considering an exploratory investigation of the interstitial spaces located between the original structure and various building additions to check for moisture damage and mold growth.