Attachment_4_-_East_Troublesome_Wildfire_SAP_Draft_Final_0001.pdf

East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior

Source: NPS, 2020

Sampling and Analysis Plan

Rocky Mountain National Park

EDL #: NA

East Troublesome Wildfire Structural Fire Debris Sites Site Investigation and Post-Removal Confirmation Sampling

Contract Number: 140D0419A0020

Task Order: 140P1221F0008

Prepared by:

BB&E, Inc.

235 E. Main Street, Unit 107 Northville, MI 48167

May 4, 2023

SAP for East Troublesome Wildfire Structural Fire Debris Sites May 4, 2023 Page | i

East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Signatories

Signatory Signature Date Signed

[NAME],

Federal Government Lead

Cleanup Lead

Legal Lead

Regional Coordinator

Environmental Compliance and Cleanup Division

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Table of Contents List of Tables ............................................................................................................................... iv

List of Figures .............................................................................................................................. iv

List of Appendices ........................................................................................................................ v

1 Introduction .......................................................................................................................... 1-1

1.1 CERCLA, NPS, and State Authority ........................................................................ 1-2

1.2 Purpose of Field Sampling ........................................................................................ 1-3

1.3 Site Location ............................................................................................................. 1-4

2 Site Description, Previous Investigations, and Conceptual Site Model ........................... 2-1

2.1 Key Site Features ...................................................................................................... 2-1

2.1.1 Site Description .................................................................................................... 2-1

2.1.2 Operational History ............................................................................................. 2-1

2.1.3 Waste Characteristics ........................................................................................... 2-2

2.1.4 Site Geology and Hydrogeology ........................................................................... 2-3

2.1.5 Site Hydrology ...................................................................................................... 2-3

2.1.6 Local Climate ....................................................................................................... 2-4

2.1.1 Vegetation and Wildlife ........................................................................................ 2-4

2.1.2 Sensitive Environments ......................................................................................... 2-4

2.2 Summary of Previous Investigations ........................................................................ 2-5

2.2.1 Data Quality/Usability ......................................................................................... 2-8

2.2.2 Preliminary Identification of Data Gaps .............................................................. 2-9

2.2.3 Contaminants of Potential Concern ..................................................................... 2-9

2.2.4 Media of Potential Concern ............................................................................... 2-10

2.3 Current and Future Property Use Scenarios ............................................................ 2-10

2.4 Conceptual Site Model ............................................................................................ 2-10

3 DQO Planning Team and Stakeholders ............................................................................. 3-1

3.1 DQO Planning Team................................................................................................. 3-1

3.2 Decision Makers ....................................................................................................... 3-1

3.3 Stakeholders .............................................................................................................. 3-2

4 Data Quality Objectives ....................................................................................................... 4-1

4.1 State the Problem ...................................................................................................... 4-1

4.2 Identify the Goal of the Investigation ....................................................................... 4-1

4.2.1 Principal Investigation Questions ........................................................................ 4-2

4.3 Identify Information Inputs ....................................................................................... 4-3

4.3.1 Previous Data Usability ....................................................................................... 4-3

4.3.2 Data to be Collected in the Current Investigation ............................................... 4-4

4.4 Define the Boundaries of the Investigation .............................................................. 4-6

4.4.1 Spatial Boundaries ............................................................................................... 4-6

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4.4.2 Temporal Boundaries ........................................................................................... 4-7

4.4.3 Decision Units ...................................................................................................... 4-7

4.4.4 Sampling Units ..................................................................................................... 4-8

4.5 Develop the Analytic Approach................................................................................ 4-9

4.5.1 Decision or Estimation Parameters ..................................................................... 4-9

4.5.2 Action Levels ...................................................................................................... 4-10

4.6 Performance or Acceptance Criteria ....................................................................... 4-11

4.6.1 Quality Assurance/Quality Control .................................................................... 4-11

4.6.2 Decision Error Limits and Uncertainty Evaluation ........................................... 4-14

4.6.3 Data Validation and Usability ........................................................................... 4-17

4.7 Plan for Obtaining the Data .................................................................................... 4-18

5 Field Sampling Plan ............................................................................................................. 5-1

5.1 General Site Procedures ............................................................................................ 5-1

5.1.1 Site Preparation, Preparation, and Restoration Procedures ............................... 5-1

5.1.2 Archeological Recordation ................................................................................... 5-1

5.1.3 Equipment Decontamination Procedures ............................................................ 5-2

5.1.4 Mapping and Surveying ........................................................................................ 5-2

5.1.5 Dust, Vapor, Odor, and Noise Control ................................................................ 5-2

5.1.6 Damage to Site Structures .................................................................................... 5-3

5.2 Sample Handling ....................................................................................................... 5-3

5.2.1 Sample Labeling ................................................................................................... 5-4

5.2.2 Sample Handling and Chain-of-Custody ............................................................. 5-4

5.2.3 Documentation and Records ................................................................................ 5-5

5.3 Investigation-Derived Waste Sampling and Disposal .............................................. 5-5

5.4 Health and Safety ...................................................................................................... 5-6

5.5 Ash/Soil Investigation ............................................................................................... 5-6

5.5.1 Ash/Soil Sampling Locations ................................................................................ 5-6

5.5.2 Ash/Soil Sampling Protocol .................................................................................. 5-7

5.5.3 Ash/Soil Field Measurements ............................................................................... 5-9

5.5.4 Soil Analytical Measurements/Methods ............................................................... 5-9

6 Data Management ................................................................................................................ 6-1

6.1 Documentation Control Systems .............................................................................. 6-1

6.1.1 Project Document Control System ....................................................................... 6-1

6.1.2 Data Recording .................................................................................................... 6-1

6.1.3 Field Audit and Response Actions ........................................................................ 6-1

6.2 Data Quality Assurance Procedures .......................................................................... 6-1

6.2.1 Laboratory Data Transmittal ............................................................................... 6-2

6.2.2 Data Storage and Retrieval .................................................................................. 6-2

7 Assessment and Oversight ................................................................................................... 7-1

7.1 Assessment and Corrective Actions.......................................................................... 7-1

7.1.1 Laboratory Audit and Response Actions .............................................................. 7-1

7.2 Quality Assessment Reporting .................................................................................. 7-1

7.2.1 Data Verification .................................................................................................. 7-1

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7.2.2 Data Validation .................................................................................................... 7-1

7.3 Reconciliation with DQOs and Data Usability ......................................................... 7-2

8 Investigation Outputs ........................................................................................................... 8-1

8.1 Daily Reports ............................................................................................................ 8-1

8.2 Field Activities Report .............................................................................................. 8-1

8.3 Draft, Draft Final, and Final Site Investigation Report (Phase I only) ..................... 8-1

8.4 Draft, Draft Final, and Removal Action Completion Report (Phase II only) ........... 8-2

9 References .......................................................................................................................... 9-1

List of Tables Tables in Text:

Table 3.1: DQO Planning Team .................................................................................................. 3-1

Attached Tables:

Table 1A Former Building Location Details Table 1B Soil Sampling Location Details Table 2A Phase I - Sample Types and Total Number of Containers for Environmental Soil

Sampling Table 2B Phase II – Draft Sample Types and Total Number of Containers for

Environmental Confirmation Soil Sampling Table 3 Personnel Roles and Responsibilities Table 4 Standard Operating Procedures Table 5A Sample Containers, Preservation, and Hold Times Table 5B Sample Nomenclature Table 6A Phase I - Project Action Limits and Laboratory-Specific Detection/Reporting

Limits for Soil Table 6B Phase II - Project Action Limits and Laboratory-Specific Detection/Reporting

Limits for Confirmation Soil Sampling Table 7 Site-Specific Background Concentrations Table 8 Hazardous Waste Characterization Criteria Table 9 Laboratory Quality Control and Data Validation Criteria Table 10 Laboratory Data Deliverables Table 11 Data Verification and Validation Procedures

List of Figures Figure 1 East Site District Building Locations Figure 2 Colorado River District Building Locations

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior

Figure 3a-3f Background Locations Figure 4 Preliminary Conceptual Site Model

List of Appendices Appendix 1 – Field Forms Appendix 2 – Health and Safety Plan Appendix 3 – Site Photos Appendix 4 – CDPHE East Troublesome Fire Guidance Documents

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List of Abbreviations and Acronyms α Alpha (Type I error probability; false rejection) ACM Asbestos Containing Material (ACM) β Beta (Type II error probability, false acceptance) bgs Below ground surface CABI Certified Asbestos Building Inspector CCR Code of Colorado Regulations CDPHE Colorado Department of Public Health and Environment CERCLA Comprehensive Environmental Response, Compensation, and Liability Act COC Contaminant of Concern COPEC Contaminant of Potential Ecological Concern CRD Colorado River District CSM Conceptual Site Model DQI Data Quality Indicator DQO Data Quality Objective DU Decision Unit EDD Electronic Data Deliverable EDL Environmental and Disposal Liabilities EPA U.S. Environmental Protection Agency ESD East Side District ESV NPS Ecological Screening Value FSP Field Sampling Plan GPS Global Positioning System HASP Health and Safety Plan H0 Null Hypothesis HA Alternative Hypothesis IDW Investigation-Derived Waste ISM Incremental Sampling Methodology ITRC Interstate Technology and Regulatory Council LCS Laboratory Control Sample LCSD Laboratory Control Sample Duplicate LIMS Laboratory Information Management System

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MD Matrix Spike Duplicate MDL Method Detection Limit mg/kg Milligram per Kilogram MS Matrix Spike NCP National Oil and Hazardous Substances Pollution Contingency Plan (AKA, National Contingency Plan) NPS National Park Service NRCS Natural Resources Conservation Service PAH Polycyclic Aromatic Hydrocarbons PCB Polychlorinated Biphenyls PCOPC Preliminary Contaminant of Potential Concern PDF Portable Document Format PVC Polyvinyl Chloride RCRA Resource Conservation and Recovery Act.

RSL Regional Screening Level QA Quality Assurance QAPP Quality Assurance Project Plan QC Quality Control RCRA Resource Conservation and Recovery Act RL Reporting Limit ROMO Rocky Mountain National Park SAP Sampling and Analysis Plan SI Site Investigation SOP Standard Operating Procedure SU Sampling Unit TCLP Toxicity Characteristic Leaching Procedure TCRA Time Critical Removal Action TEF Toxic Equivalency Factor TEQ Toxic Equivalency Quotient TSCA Toxic Substances Control Act U.S.C. United States Code

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior

1 Introduction The National Park Service (NPS) is conducting a Site Investigation (SI) to determine the applicability of a Time Critical Removal Action (TCRA) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the framework provided in the National Oil and Hazardous Substances Pollution Contingency Plan (also known as the National Contingency Plan, NCP) to address possible contamination in East Troublesome Wildfire Structural Fire Debris Sites (the Site), located within the Rocky Mountain National Park (ROMO or the Park) near Denver, Colorado. The site includes 26 burned structures.

This SAP will be used to document the sampling approach at 26 burn sites to be performed during a Site Inspection (SI) used to support the need for a TCRA under CERCLA. The SAP includes confirmation sampling post removal action to determine if removal goals have been attained at sites where removal actions are performed.

Based upon NPS experience at other structure burn sites resulting from wildfire, release of certain CERCLA hazardous substances above applicable screening levels and risk-based removal goals has been nearly ubiquitous, and removal actions required. Assuming this holds true at the ROMO sites, a TCRA will be performed in general accordance with NPS Memorandum:

Adoption of Presumptive Remedy for Contaminated Sites (NPS, 2021c) and the Colorado Department of Public Health and Environment (CDPHE) East Troublesome Wildfire October 2020 Cleanup Handouts (CDPHE, 2020). The intent of the removal action is to return the sites to baseline conditions by removing hazardous substances released into the environment at or from the Site that are initially present at concentrations that exceed NPS accepted screening levels and also exceed naturally occurring site-specific background concentrations. NPS may choose to perform human health and ecological risk assessments at the Site to establish risk-based removal goals.

The historical presence of building materials, maintenance and cleaning chemicals, and batteries on the Site, suggest the potential presence of hazardous substances including metals, PCBs, dioxins/furans, and asbestos, defined under CERCLA. Possible releases of these contaminants may have occurred when the structures burned during the East Troublesome Wildfire in October 2020. The Park’s records and field observations indicate that maintenance and cleaning liquids, fluorescent lights and light ballasts, small amounts of fuel or fuel containing equipment (e.g.

generators), and/or batteries were stored or used in various buildings within the Site. There is the potential that some of these items released CERCLA hazardous substances during the fire, while others may have been incinerated and not released to soil or present in ash.

In 2021, the Park performed limited ash sampling of debris from four burned structures and determined there was some indication that concentrations of metals are potentially hazardous.

Previous asbestos building surveys were completed on eight structures with asbestos containing material (ACM) identified in two of the eight. The Park plans to remove building debris and ash

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior so they do not pose a health and safety risk to workers and visitors, and to limit potential releases of CERCLA hazardous substances through wind and water erosion.

NPS will complete a SI utilizing Incremental Sampling Methodology (ISM) to sample ash and soil as described in this Sampling and Analysis Plan (SAP) to evaluate if a TCRA under CERCLA is appropriate and necessary. The SAP will be executed in two phases, an initial “presence/absence” sampling event of each burn site and site-specific background locations to document post-fire site conditions (Phase I) and a post-removal confirmation sampling to determine if removal goals are met and closure is warranted (Phase II). Both phases are outlined in this SAP.

The Phase I sampling event was conducted between September 26 and October 6, 2022, in accordance with this Draft SAP dated September 22, 2022. This SAP was updated to include the Phase I sampling data results and refine the Phase II confirmation sampling approach.

1.1 CERCLA, NPS, and State Authority

NPS is authorized under CERCLA, 42 United States Code (U.S.C.) §§ 9601 et seq. and Executive Order 12580, as amended by Executive Order 13016, to respond as the federal Lead Agency to any release or threatened release of hazardous substances, and/or any release or threatened release of a pollutant or contaminant that may present an imminent and substantial danger to public health or welfare, on or from land under the jurisdiction, custody, or control of

NPS.

In addition, NPS has a number of substantive requirements that apply to response actions addressing releases of hazardous substances on NPS land (see NPS, 2014) including the NPS Organic Act of 1916 (54 U.S.C. §§100101 et. seq.), which requires NPS to manage parks in order to conserve the scenery, natural and historic objects, and wildlife and to provide for their enjoyment by such means as will leave them unimpaired for the enjoyment of future generations.

NPS Management Policies 2006 further requires that NPS protect park resources and values from unacceptable impacts, including impacts associated with contamination.

In October 2020, the CDPHE issued guidance for addressing asbestos in Residential and Public and Commercial structures completely destroyed by the East Troublesome Wildfire where only ash and debris remain. The CDPHE Guidance is included in Appendix 4. CDPHE enforces asbestos requirements under Colorado Regulation No. 8, Part B and has also been delegated the authority and obligation to enforce the federal National Emission Standards for Hazardous Air Pollutants (NESHAP) regarding asbestos in public and commercial buildings. For residential properties and public and commercial buildings the CDPHE is waiving some of the asbestos requirements of Colorado Regulation 8, Part B. CDPHE has confirmed that the NPS structures destroyed during the East Troublesome Fire can be addressed under the CDPHE guidance.

According to the CDPHE guidance, the ash and debris at burn sites can be removed and properly

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior disposed of without requiring pre-removal or post-removal asbestos sampling. The guidance provides specific requirements for the cleanup of the burn sites associated with the East Troublesome Fire. Except for two burn sites (Vault Toilet and Grand Lake Entrance Station) that were sampled in accordance with a CDPHE-approved plan, NPS has elected to not perform asbestos sampling prior to the removal action, as advised by CDPHE. Asbestos sampling will be included in this SAP as a component of the confirmation sampling only.

CERCLA’s implementing regulations, codified in the NCP, 40 Code of Federal Regulations Part 300, establish the framework for responding to such releases and threatened releases. The NCP prescribes two similar processes for responding to releases: removal actions and remedial actions (see NCP Sections 300.400 through 300.440). In accordance with the NCP (40 CFR Part 300, Subpart §300.415), the following factors are used in considering the appropriateness of a removal action:

1. Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances, pollutants, or contaminants

2. Actual or potential contamination of drinking water supplies or sensitive ecosystems

3. Hazardous substances, pollutants, or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release

4. High levels of hazardous substances, pollutants, or contaminants in soil largely or near the surface that may migrate

5. Weather conditions that may cause hazardous substances, pollutants, or contaminants to migrate or be released

6. Threat of fire or explosion

7. The availably of other appropriate federal or state response mechanisms to respond to the release

8. Other situations or factors that may pose threats to public health or welfare of the

United States or the environment.

If environmental samples are to be collected under either process, a SAP is required (see NCP Sections 300.415 and 300.430).

The SAP for SI activities includes the Field Sampling Plan (FSP) and the Quality Assurance Project Plan (QAPP). The FSP describes the number, types, analyses, and locations of samples.

The QAPP describes the investigation’s organization, functional activities, and measures necessary to achieve the goals of the investigation.

1.2 Purpose of Field Sampling

The former buildings within the Site included an office, rustic staff seasonal accommodations, barns, a garage, a ranger station, and outdoor toilets. None of these buildings were used for industrial purposes. Small quantities of cleaning chemicals, fuels, batteries, and building

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior materials containing CERCLA hazardous substances may have been stored in the buildings.

Some historical building materials or equipment may have also contained hazardous substances like polychlorinated biphenyls (PCBs), lead-based paint, and asbestos. Uncontrolled releases of the CERCLA hazardous substances may have occurred during the East Troublesome Wildfire, and these substances may remain in ash or the underlying soil. The purpose of the SI is to assess building debris, ash, and soil for suspected Preliminary Contaminants of Potential Concern (PCOPC) including metals, PCBs, and dioxin and furan contamination at the Site to establish whether a release or potential release of hazardous substances, pollutants, or contaminants has occurred (presence or absence of contamination above NPS screening levels and baseline conditions). The SI will also establish site-specific background/reference concentrations for PCOPCs at six locations representative of the burned building sites but unaffected by structural fires. The SI results will be used to determine whether a TCRA or other response action under CERLCA is appropriate. Additionally, data will be utilized to evaluate probable disposal requirements. Confirmation sampling will be conducted after the removal action to evaluate metals, asbestos, and dioxin and furan contamination and compare the concentrations of Contaminants of Concern (COC) with site-specific background/reference concentrations collected from six independent background locations, promulgated state soil standards, or risk-based removal goals that may be established through human health and ecological risk assessments.

This SAP describes NPS’s sampling program. Data obtained from this investigation will be used to address the data quality objectives (DQOs) detailed in Section 4 of this SAP. Data collected during the SI will be used to determine if Site conditions warrant removal. Post-removal confirmation data will be used to determine if removal goals are met.

1.3 Site Location

The following information can be used to locate the Site:

• Site name: East Troublesome Wildfire Structural Fire Debris Sites

• Site address: No addresses;

o East Side District (ESD)/Big Thompson Watershed: two developed areas off Fern

Lake Road in Larimer County (see Figure 1) o Colorado River District (CRD): five areas along the Trail Ridge Road corridor in

Grand County (See Figure 2)

• Site Environmental and Disposal Liabilities (EDL) number: Not Available

• Coordinates: Longitude and latitude (approximate) o ESD: Fern Lake Road area in an east-west corridor from 40.3543 degrees north, -

105.5846 degrees west

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Rocky Mountain National Park U.S. Department of the Interior o CRD: Trail Ridge Road corridor in a north-south corridor from 40.3076 degrees north, -105.8419 degrees west to 40.2729 degrees north, -105.8352 degrees west o Coordinates for each individual structure can be found in Table 1A

• United States Geological Survey 7.5-minute quadrangles: Trail Ridge Road area on Grand Lake, Colorado (2019); Fern Lake Road area on McHenry’s Peak, Colorado (2019)

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Rocky Mountain National Park U.S. Department of the Interior

2 Site Description, Previous Investigations, and Conceptual Site Model

The development and ongoing update/refinement of a clear and thorough conceptual site model (CSM) is a critical component for verifying that key Site elements are considered before samples are collected and to assist the planning team in developing the DQOs (Section 4), as well as assisting the field team in making decisions. Figure 4 is a graphical depiction of the preliminary CSM, identifying potential exposure pathways.

2.1 Key Site Features

2.1.1 Site Description

ROMO spans nearly 266,000 acres of mountains and forest located northwest of Denver, Colorado. The mountain ridges near the center of ROMO form the top of the Continental Divide, and the ground elevation in the Park ranges from 7,600 feet to 14,259 feet (NPS, 2021a). ROMO was established in 1915 with the stated purpose “to preserve the high-elevation ecosystems and wilderness character of the southern Rocky Mountains within its borders and to provide the freest recreational use of and access to the park’s scenic beauties, wildlife, natural features and processes, and cultural objects” (NPS, 2013). Many of the buildings within ROMO were constructed by ranchers before or after the Park was established to serve the growing tourism industry and were rented to guests into the 1950s (NPS, 2015).

Between October 21 and 24, 2020, the East Troublesome Fire spread from west to east across ROMO (NPS, 2021b). The wildfire destroyed three buildings in the ESD and 23 buildings on the western side of the Park, also known as the CRD. The burned building names, structure numbers, construction dates, and locations are listed in Table 1A. The most recent use of the building is given in the building name. The buildings were typically located in subalpine forests or meadows.

2.1.2 Operational History

Barns, tack sheds, lodges, and cottages reflect the ranching and dude ranch tourism history of the Park. After the 1960s, the lodges and cottages were converted to seasonal staff housing, whereas barns, garages, and sheds stored materials and equipment for livestock management and trails maintenance, and other material storage, including historic artifacts. There is no history of industrial use within ROMO since 1915.

One building destroyed during the fire, the Grand Lake Entrance Station (Building 1141), hosted offices and restrooms. Another was a modern vault toilet at the Harbison Meadow Picnic Area (Building 1183).

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior

NPS prepared an inventory of burned buildings in early 2021 (NPS, 2021b). The inventory report includes photographs of each building before and after the fire, and a building and site condition assessment that records each building’s historic status, size, potential hazards, and floor structure (e.g., concrete slab, foundation walls, or piers).

After the fire event, burn areas were fenced off to limit access, erosion barriers were placed on downgradient slopes, and the Fern Lake Patrol Cabin Site (014) was covered by a tarp. Due to their front country locations, proximity to areas of public access, and physical safety hazards, NPS removed remaining standing structures, building debris and ash from the Grand Lake Entrance Station (1141) and Harbison Meadow Picnic Area Vault Toilet (1183) in 2021. A concessionaire removed ash and building debris from the Moraine Stables Bunkhouse (893) and Moraine Stables Dorm (1086) shortly after the fire in 2020. To reduce physical safety hazards, NPS removed large debris from the Fern Lake Patrol Cabin (014), leaving smaller debris and ash. A concrete slab and other hard surfacing remain at the Grand Lake Entrance Station (1141).

In 2022, Harbison Meadow Picnic Area Vault Toilet (1183) was completely removed and rebuilt in approximately its original location. Shallow surface soils within an approximate five-to-eight-foot buffer surrounding concrete surfaces and structures at the Grand Lake Entrance Station (1141) and Harbison Meadow Picnic Area Vault Toilet (1183) were removed to a depth of approximately six inches during debris removal activities. Construction activity near the Timber Creek Road Camp Barn Tack Shed (572) resulted in the placement of a small amount of fill material within the burn site. It does not appear that potential contaminated debris or soil was removed from the Tack Shed area.

2.1.3 Waste Characteristics

With limited to no industrial history in the Park, the releases from the wildfire are primarily related to building materials. As shown in Table 1A, most of the buildings were constructed between 1925 and 1945, with some constructed in the 2010s. The buildings were typically rustic wood construction with stained exteriors, limited interior finishes, and electrical power. The vault toilet (1183), Fern Lake Patrol Cabin (014), and several buildings in the Green Mountain Ranch (GMR) - Onahu Ranch Areas had no running water and/or electricity. Because it was commonly contained in older building materials, asbestos may be present in ash. Building components in some older structures may have been covered with lead-based paint. NPS has identified two buildings, the Timber Creek Road Camp Barn (783) and the northern portion of the Betty Dick Garage (831), where fluorescent lighting was known or suspected to be installed.

At least ten light ballasts were observed in the Betty Dick Garage (831) debris. Older fluorescent light ballasts may contain PCBs. Although plastic is not hazardous, some plastics, including polyvinyl chloride (PVC), contain chlorine and can form dioxins when burned. There are no records or reports of chlorine-based solvents (another possible dioxin source) stored in the buildings, and no reason to suspect their presence. Various metals may have been present in building materials or in items that were stored in the buildings, including batteries, wiring, piping, white goods, etc. Petroleum and greases may have been stored in some buildings, but

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East Troublesome Wildfire Structural Fire Debris Sites National Park Service

Rocky Mountain National Park U.S. Department of the Interior these are more likely to have burned than to have been released to the ground. Asbestos was previously detected in buildings GMR Mineral Cottage (731) and GMR Arapaho Cottage (733).

Other potential hazardous materials such as custodial chemicals, aerosols, and compressed gasses (e.g., propane) may have been present in small quantities, and likely consumed by the fire.

Polynuclear aromatic hydrocarbons (PAHs) will have been released as the buildings burned, but because burning forests also release PAHs, NPS presumes that a cleanup of other hazardous substances will also address building-related PAHs.

CERCLA hazardous substances may be present in ash or in soil at the former buildings. Based on the types of contaminants (metals, asbestos, PCBs, and dioxins/furans), the absence of water application during the fire, and the knowledge that NPS has not disturbed the ash at most locations, NPS expects impacts to be limited to shallow surface soil.

2.1.4 Site Geology and Hydrogeology

Surface soil at the burned building sites consists of three general types classified by the Natural Resources Conservation Service (NRCS; United States Department of Agriculture, 2021). On the western side of the Park, all buildings south of the Betty Dick Garage (831), the soil in the top 6 inches below ground surface (bgs) is very sandy to very stony loam with parent material derived from granite and/or gneiss and/or schist. Mucky peat is mapped on the fringes of the building areas but is likely not similar to the soil at the buildings.

At the northern end of the western side of the Park, the Betty Dick Garage (831) is surrounded on two sides by the Colorado River. Soil here is mapped by NRCS as mucky peat with parent material derived from alluvium over sandy and gravelly glaciofluvial deposits derived from granite and/or gneiss and/or schist. Thus, soil around the Betty Dick Garage (831) is finer than at other western locations.

On the eastern side of the Park, NRCS maps the soil as very gravelly sandy loam derived from granite and/or gneiss and/or schist. Around the Fern Lake (014) cabin site, the surface soil contains mostly decomposed plant material. Therefore, concentrations of metals are expected to be naturally lower in these surface soils than at other locations where more rocks are present.

2.1.5 Site Hydrology

The Betty Dick Garage (831) is bordered on its north and west sides by the Colorado River, the cabins in the northern portion of the GMR area are near a small unnamed pond, and the Fern Lake Ranger Station (014) is near the shore of Fern Lake. Migration of ash or evidence of stormwater runoff from burn sites has not been observed during multiple site visits and impacts to surface water are not anticipated. If ash and building debris have been mobilized by rainwater runoff or flooding, NPS will evaluate those impacts in a separate investigation phase. Erosion mitigation methods have been installed at several of the structures.

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Rocky Mountain National Park U.S. Department of the Interior

2.1.6 Local Climate

With elevations typically above 8,000 feet, the wildfire debris sites at ROMO are often snow covered. On the western side of the Park, mean annual precipitation is approximately 19 inches, in the form of rain or snow, whereas the eastern side of the Park receives an average of 13 inches (NPS, 2017). NRCS reports the frost-free period is between 40 and 60 days at elevations lower than 9,000 feet (e.g., the Betty Dick Garage) and between 20 and 50 days at higher elevations (e.g., the Fern Lake area) (United States Department of Agriculture, 2021). July and August bring warm daytime temperatures in the 70s and 80s in degrees Fahrenheit, although nights are close to freezing.

2.1.1 Vegetation and Wildlife

ROMO has an abundance of diverse biotic communities. Both natural and man-made disturbances such as fire, non-native species invasions, and disturbed lands from historic homesteading, ranching, and logging activities have all impacted the biodiversity of ROMO.

Based on a search of the NPS ROMO species list database, approximately 756 invertebrates, 1113 different vascular plants, 273 birds, and 70 mammals that are or may be present at various periods of the year within ROMO (NPSpecies - The National Park Service biodiversity database.

https://irma.nps.gov/npspecies/). The wide diversity of bird and mammals cover the full range of potential ecological receptors including both avian and mammalian herbivores, insectivores, omnivores, and carnivores. No vascular plants are federally or state listed as threatened or endangered. A list of mammal and bird species federally and/or state-listed as threatened or endangered is provided below:

Mammals

• Lynx (Lynx canadensis) – Federal Threatened, State Endangered

• Wolverine (Gulo gulo) – State Endangered

• River Otter (Lontra canadensis) – State Threatened

Birds

• Yellow-billed Cuckoo (Coccyzus americanus) – Federal Threatened

2.1.2 Sensitive Environments

National park land is recognized as a sensitive environment worthy of the highest levels of protection. However, the former building sites are not in otherwise ecologically sensitive environments. Several structures, including the Fern Lake Ranger Station (014) and many of the buildings in the GMR and Onahu Ranch areas were historic, and several building sites contain chimneys and stone foundation materials that are culturally significant. Numerous historic artifacts remain within the burned footprint of the Betty Dick Garage (831) and are likely present

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Rocky Mountain National Park U.S. Department of the Interior at the Onahu Lodge (575) site. Numerous historic sites are located in the near vicinity of the Fern Lake Ranger Station (014).

2.2 Summary of Previous Investigations

There is no history of suspected contaminant releases at the former buildings prior to the fire.

Previous investigations are summarized below:

Asbestos Building Surveys 2005

Four asbestos building surveys were conducted in 2005 at buildings GMR Mineral Cottage (731), GMR Parika Cottage (732), GMR Arapaho Cottage (733) and the Onahu Ranch Lodge (575). It is unknown if the samples were collected by a CABI or in accordance with an approved SAP. It is also unknown if the surveys were comprehensive to address all potential suspect asbestos containing materials (ACM) or were limited in scope. Results were analyzed by the Division of Federal Occupational Health (DFOH) National Environmental Reference Laboratory (NERL) in compliance with guidelines established by EPA in method EPA-600/R-93-116.

Laboratory reports and cover letters were produced titled BLDG 731, 732, & 733 (CRD), February 21, 2005, and BLDG 575 (CRD), August 8, 2005. Asbestos was non-detect for material collected from the Onahu Lodge (575) and the Parika Cottage (732). Asbestiform mineral fibers indicative of Chrysotile was detected at 2-4% in the wall board compound in the Mineral Cottage

(731) and the Arapaho Cottage (733).

Broadbent Asbestos and Metals Sampling 2021

In January of 2021, samples of homogeneous suspected ACM and/or ash and debris were collected at the Grand Lake Entrance Station (1141), Harbison Meadow Picnic Area Vault Toilet (1183), Timber Creek Road Camp Barn (783), and the Timber Creek Road Camp Barn Tack Shed (572). Sampling results were presented in a report by Broadbent and Associates titled Limited Hazardous Building Material Survey, February 28, 2021. Limited Asbestos and metals sampling was conducted. Some asbestos samples were collected by a CABI in accordance with Broadbent’s Sampling and Analysis Plan, January 22, 2021, approved by CDPHE. A total of 36 bulk samples of suspect ACM, 24 from the Grand Lake Entrance Station (1141), 9 from the Vault Toilet (1183), and 3 from the Tack Shed (572), were collected on January 27, 2021 and submitted to EMLab P&K Labs, LLC of Arvada, Colorado, for analysis. EMLab is a CDPHE-registered asbestos laboratory and is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP No. 200525-0) for bulk asbestos fiber analysis. A total of 6 composite ash/debris samples were collected (3 five-point aliquot composite samples from the Vault Toilet [1183], 1 eight-point aliquot composite sample from the Tack Shed [572], and 2 eight-point aliquot composite samples from the Barn [783]) on January 27, 2021, and submitted to EMLab P&K Labs, LLC for analysis. The ash/debris samples were analyzed for the presence/absence of asbestos by Transmission Electron Microscopy (TEM) via method ASTM D7521- 16. No asbestos was detected in any sample. Of the composite ash samples collected, May 4, 2023 Page | 2-6

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Rocky Mountain National Park U.S. Department of the Interior only those from the Vault Toilet (1183) were included in the CDPHE-approved sampling plan.

While the ash results for the Barn (783) and Tack Shed (572) suggest asbestos is not present, CDPHE does not consider these data suitable to make a defensible presence/absence determination.

Broadbent also collected a total of 5 ash/debris samples for RCRA 8 metals analysis on January 27, 2021, and submitted to Eurofins Test America of Denver, Colorado. One eight-point aliquot composite sample was collected from each of the following three buildings: Grand Lake Entrance Station (1141), Vault Toilet (1183), and Tack Shed (572). Two eight-point aliquot composite samples were collected from the Barn (783). The samples were analyzed for Total Metals (ICP) in accordance with EPA SW-846 Method 6010C and for total mercury (CVAA) in accordance with EPA SW-846 Method 7471B. Lead was detected at 130 milligrams per kilogram (mg/kg) and 210 mg/kg in ash samples from the Barn (783) and Tack Shed (572), respectively, and one Barn (783) sample contained 150 mg/kg of arsenic. The Barn (783) and Tack Shed (572) samples were analyzed by TCLP. No arsenic was detected by TCLP in the Barn

(783) sample. The Barn (783) sample was reported to contain 0.024 milligrams per liter (mg/L) lead which is less than the TCLP Limit of 5.0 mg/L. The Tack Shed (572) sample was reported to contain 10 mg/L Lead by TCLP which exceeds the regulatory limit. The analytical report indicates detection of lead in the laboratory method blank. Therefore, this result may be biased high.

BB&E SI 2022 (Phase I of this SAP)

BB&E completed the Phase I SI sampling event in accordance with the draft SAP between September 27 and October 6, 2022. All 26 burned structures and six background locations were sampled using ISM. Surface samples (0 to 3-inches) were collected from 40 equal weight aliquots, where soil/ash was present and accessible, at each sampling unit (SU) and combined to make one ISM replicate sample. If soil/ash was not present or accessible within an aliquot it was not sampled, and a larger quantity of soil/ash was collected from other aliquots to gather enough material for analysis. Structures where less than 40 aliquots were collected include:

• Structure 853 Green Mountain Ranch Pumphouse – three (3) aliquots from the center of the structure footprint were not sampled due to presence of concrete pad with no soil/ash on surface. The collection of 37 aliquots provides a representative sampling of soil/ash at the site. The exclusion of three (3) aliquots is not anticipated to impact data results.

• Structure 587 Onahu Ranch Pumphouse – eight (8) aliquots were not sampled due to lack of accessibility (deep well pit). The soil/ash samples collected from 32 aliquots around the structure pit are assumed to be representative of the site, however, samples were not collected from bottom of pit.

• Structure 572 Timber Creek Road Camp Barn Tack Shed – three (3) aliquots were not sampled due to the presence of unknown non-native fill; this was in accordance with the SAP. Based on the initial site visit NPS elected to exclude three (3) aliquots in the

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Rocky Mountain National Park U.S. Department of the Interior southwest corner of the structure footprint due to concerns that this material was placed at the site after the fire. The area was excluded from sampling to mitigate the chance of unknown fill material impacting the ISM replicate. The collection of 37 aliquots provides a representative sampling of soil/ash at the site. The exclusion of three (3) aliquots is not anticipated to impact data results.

• Structure 1183 Harbison Vault Toilet - 18 aliquots were not sampled due to the presence of new construction on site footprint. The soil/ash samples collected from 22 aliquots around the new construction are assumed to be representative of the site. The footprint covered by the new construction is not exposed to human or ecological receptors.

• Structure 1141 Grand Lake Entrance Remit Office - 11 aliquots from the center of the structure footprint were not sampled due to presence of concrete pad with no soil/ash on surface. The collection of 29 aliquots provides a representative sampling of soil/ash at the site. The exclusion of 11 aliquots is not anticipated to impact data results.

At each background/reference location and at the Grand Lake Entrance Station (1141) three replicates were collected. The background/reference ISM replicates were used to calculate a site-specific background/reference concentration using the Interstate Technology Regulatory Council’s (ITRC’s) updated Microsoft Excel workbook ISM 95% calculator. If an analyte was reported as not detected, then one half of the detection limit for that analyte was used for the purposes of calculating the 95% UCL.

Based on the results of sampling conducted at 26 burned structures and six background/reference locations, it has been determined that concentrations of one or more metals exceed the risk-based screening levels (RBSL) (i.e. lowest of the Environmental Protection Agency (EPA) Regional Screening Level for Residential exposure from Soil or the NPS Screening Level Risk Assessment (SLERA) Constituent of Potential Ecological Concern (COPEC) Selection Ecological Screening Value (ESV) for soil), identified in Table 6A, and background/reference concentrations at all 26 sites. Beryllium was not detected above project RBSLs at any site. No PCBs or hexavalent chromium were detected above method detection limits at any location.

The total dioxin/furan toxic equivalency quotient (TEQ) exceeded RBSL and background/reference concentrations at 19 of the 26 sites.

Eight burned structures were analyzed for TCLP metals; only the Timber Creek Road Camp Tack Shed (572) burned structure failed TCLP analysis for lead. Therefore, the ash/soil at this site should be classified as hazardous waste.

Table 2A on this SAP provides the methods and sample counts for the Phase I sampling event.

Table 6A provides the project action limits and laboratory-specific…