Attchmt 23_Option 8-Kleiva Property Report.pdf

LIMITED LEAD AND ASBESTOS SURVEY REPORT

NATIONAL PARKS SERVICE – OLYMPIC NATIONAL PARK

LAKE OZETTE - KLEIVA PROPERTY

East Shore of Lake Ozette

Forks, Washington 98331

November 10th, 2017

Prepared For:

Jeff Doryland

Deputy Chief of Facility Management

Olympic National Park

600 E. Park Avenue, Port Angeles, WA 98273 ii

Limited Lead and Asbestos Survey Report

National Park Service – Olympic National Park

Lake Ozette - Kleiva Property

East Shore of Lake Ozette

Forks, Washington

EHSI Project No.: # 11035

The material and data in this report were prepared under the supervision and direction of the undersigned.

Brett Racine

Lead AHERA Building Inspector

Derica Escamilla

Principal of Hazardous Materials

Services iii

TABLE OF CONTENTS

Acronym List .................................................................................... iv

1.0 EXECUTIVE SUMMARY

1.1 BACKGROUND

1.2 EXTENT OF CURRENT SURVEY

1.3 ACM MATERIALS FOUND

1.4 OPINIONS AND RECOMMENDATIONS

1.5 LIMITATIONS/DISCLAIMER

2.0 LIMITED LEAD AND ASBESTOS SURVEY REPORT

2.1 BACKGROUND

2.2 BUILDING DESCRIPTION

2.3 SAMPLING METHODOLOGY

2.3.1 Asbestos-Containing Materials

2.3.2 Lead-Containing Paint/Lead-Containing Materials

2.4 SAMPLING RESULTS

2.4.1 Asbestos-Containing Materials

2.4.2 Lead-Containing Paint and Building Materials

2.4.3 Toxicity Characteristic Leaching Procedure Sampling

2.4.4 Polychlorinated Biphenyls

2.4.5 Mercury-Containing Fluorescent Light Tubes and CFL Bulbs

3.0 LIMITATIONS

4.0 STANDARD OF CARE

5.0 CERTIFIED AHERA BUILDING INSPECTORS

APPENDICES

A........................ Asbestos Laboratory Reports and Field Data Forms

B........................ Lead Laboratory Reports and Field Data Forms

C........................ Certified AHERA Building Inspector Certificates

D ....................... Laboratory Certifications for Asbestos and Lead Analysis

E ........................ Sample Location Drawings for Asbestos, Lead, and TCLP

F ........................ Lead TCLP Laboratory Reports and Field Data Forms

G ....................... Abatement Cost Estimate iv

ACRONYM LIST

ACM.......................Asbestos-Containing Material

AHERA ................... Asbestos Hazard Emergency Response Act AIHA ...................... American Industrial Hygiene Association

CFL ........................ Compact Fluorescent Light CFR ....................... Code of Federal Regulations

DOSH.....................Washington State Department of Labor and Industries, Division of

Occupational Safety and Health Ecology .................. Washington State Department of Ecology

EHSI ...................... EHS-International, Inc.

ELLAP .....................Environmental Lead Laboratory Accreditation Program

GWB ...................... Gypsum Wall Board Hg ......................... Mercury

HID........................High Intensity Discharge LCM ....................... Lead-Containing Material

LCP........................Lead-Containing Paint

L&I ........................ Washington State Department of Labor and Industries mg/cm2 .................. Milligrams Per Square Centimeters mg/L......................Milligrams Per Liter N/A ........................Not Applicable

ND.........................None Detected NVL ....................... NVL Laboratories, Inc.

NVLAP .................... National Voluntary Laboratory Accreditation Program OD.........................Outside Diameter

ORCAA ................... Olympic Region Clean Air Agency

OSB ....................... Orient Strand Board OSHA ..................... US Occupational Safety and Health Administration

Pb ......................... Lead PCBs ...................... Polychlorinated Biphenyls

PLM ....................... Polarized Light Microscopy ppm.......................Parts per Million

QA ......................... Quality Assurance RCW ...................... Revised Code of Washington

SAT ....................... Seattle Asbestos Test, LLC

SF ......................... Square Feet SVF........................Sheet Vinyl Flooring

TCLP ...................... Toxicity Characteristic Leaching Procedure WAC ...................... Washington Administrative Code

WT ........................ Weight w/ ......................... With

XRF ....................... x-ray fluorescence

NPS – Lake Ozette - Kleiva Property

EHSI Project 11035 November 10th, 2017

1.0 EXECUTIVE SUMMARY

1.1 BACKGROUND

The National Parks Service (NPS) plans to demolish the existing structures on the Kleiva

Property located on the East Shore of Lake Ozette, Forks, Washington. The NPS has contracted EHS-International, Inc. (EHSI), a hazardous materials and industrial hygiene consulting firm, to conduct a Limited Lead and Asbestos Survey of the Kleiva Property in preparation for this project. The intent of the survey is to specifically identify and quantify asbestos-containing building materials (ACM), lead-containing paint (LCP), other lead-containing building materials (LCM), to collect a lead toxicity characteristic leaching procedure (TCLP) sample representative of all materials that may be in the assumed waste stream, and to inspect and quantify fluorescent light fixtures that may contain polychlorinated biphenyl (PCB)-containing ballasts, and mercury (Hg)-containing fluorescent light tubes, compact fluorescent light (CFL) bulbs, and high intensity discharge (HID) lamps, that may be impacted by the demolition.

1.2 EXTENT OF CURRENT SURVEY

EHSI inspected all accessible interior and exterior materials potentially impacted by the proposed project. Accessible suspect materials were sampled including, but not limited to:

interior and exterior wall systems, window systems, and mechanical systems. EHSI accomplished a representative destructive inspection.

1.3 ACM MATERIALS FOUND

SUMMARY OF ASBESTOS-CONTAINING MATERIALS

NATIONAL PARKS SERVICE

OZETTE LAKE – KLEIVA PROPERTY

ASBESTOS MATERIAL DESCRIPTION LOCATION

Non-ACM Beige and brown SVF (w/ large broken rock pattern) w/ ACM gray paper backing w/ ACM tan mastic on wood [Sample # 01]

Bedroom 1

Non-ACM SVF (w/ geometric pattern) w/ ACM gray paper backing w/

ACM tan mastic on OSB on non-ACM black mastic on wood [Sample # 08]

Kitchen/ Living room

KEY: ACM = asbestos containing material, bold = bold text indicates asbestos-containing layer, OSB = oriented strand board, SVF = sheet vinyl flooring w/ = with

1.4 OPINIONS AND RECOMMENDATIONS

The project includes demolition of the existing structures at the Kleiva Property; therefore, EHSI recommends that all impacted ACM identified in paragraph 1.3 be removed and disposed of prior to renovation and demolition activities.

Any suspect materials not identified as having been surveyed in this report must be treated as an ACM until determined otherwise by a Certified Asbestos Building Inspector and NVLAP certified laboratory.

EHSI Project 11035 November 10th, 2017

Washington State Department of Labor and Industries (L&I) Division of Occupational Safety and Health (DOSH) and the US Occupational Safety and Health Administration (OSHA) require employers to conduct a hazard assessment and take appropriate worker protection precautions whenever building materials are disturbed that have detectable quantities of lead. Since the type of work planned (e.g., demolition) will disturb the LCP, the contractor should perform an initial exposure assessment to determine if the additional personal protective measures and work practices are required beyond that of initial assessment. Special care should be taken to reduce potential employee exposure to lead when demolishing porcelain bathroom fixtures and painted metal, including reducing airborne dust (eq., water misting and use of hand tools, and/or local exhaust ventilation).

EHSI did not observe any mercury-containing fluorescent light tubes, CFL bulbs, or HID lamps on the Kleiva property.

1.5 LIMITATIONS/DISCLAIMER

This report does not represent a comprehensive hazardous materials investigation for the subject property. This investigation has been conducted by EHSI under a specific scope of work authorized by the NPS for a specific purpose. This report and accompanying appendices include the supporting information for this executive summary.

EHSI Project 11035 November 10th, 2017

2.0 LIMITED LEAD AND ASBESTOS SURVEY REPORT

2.1 BACKGROUND

The NPS plans to demolish the existing structures at the Kleiva Property. In conjunction with the planned demolition, the NPS has contracted EHSI to accomplish a pre-demolition limited lead and asbestos survey of the existing structures and to collect a lead-TCLP sample representative of the anticipated demolition debris. For the limited lead and asbestos survey, EHSI was tasked to use applicable federal, state, and local guidelines in the accomplishment of its survey. EHSI was further tasked to provide a written survey report including:

identification of all suspect materials; a determination of whether suspect materials were:

ACM, LCP, and LCM, and to provide analytical reports indicating the presence and quantity of the hazardous materials.

On October 4th, 2017, EHSI conducted a Limited Lead and Asbestos Survey Report that meets the Washington State “Good Faith Survey” requirements as cited in Revised Code of

Washington (RCW) 49.26.016 and implemented by L&I DOSH regulation, Washington Administrative Code (WAC) 296-62-07721, and Regulation Section 570 of the Olympic Region

Clean Air Agency (ORCAA).

2.2 BUILDING DESCRIPTION

The Kleiva Property is located on the East Shore of Lake Ozette, Forks, Washington. The property includes a single-story single occupancy residential house.

The house is a wood-framed structure with a post and pier foundation. The building has a partially collapsed wood shingle roof and a wood siding exterior. The entire south facing exterior wall has also collapsed, destroying most of what was once bedroom 2 and the kitchen area of the living room. Remaining and remnant interior floor finishes include: sheet vinyl flooring (SVF), carpet, and possibly ceramic tile. Remaining and remnant interior wall finishes include: wood fiberboard panels and possibly GWB. The interior ceilings were finished with wood paneling. Windows are aluminum-framed; most but not all remaining windows are operable. Hot water was provided by a domestic hot water tank. Heating appears to have been provided by the wood stove fireplace. Interior lighting consists of incandescent ceiling fixtures and natural light from the windows.

2.3 SAMPLING METHODOLOGY

2.3.1 Asbestos-Containing Materials

The EHSI field inspectors are asbestos Building Inspectors, certified under the requirements of the United States Environmental Protection Agency (USEPA) AHERA regulation 40 Code of

Federal Regulations (CFR) 763, Subpart E. Copies of their certificates are provided in Appendix C. The number of bulk samples collected and their locations are based on the AHERA regulation and the guidelines provided by the USEPA Document 560/5-85-030a, October

1985, Asbestos in Buildings: Simplified Sampling Scheme for Friable Surfacing Materials.

EHSI Project 11035 November 10th, 2017

EHSI collected samples and obtained analytical data for suspect ACM identified on the property. Once collected, each bulk sample was sealed in an unadulterated plastic bag to eliminate the possibility of cross-contamination. “Chain-of-Custody” tracking was followed to maintain sample integrity during handling and data reporting at EHSI and the analytical laboratory. As specified in 40 CFR Chapter 1 (1-1-87 edition) Part 763, Subpart F, and Appendix A, each sample was analyzed using polarized light microscopy (PLM) / dispersion staining techniques, in accordance with USEPA Method 600/R-93/116. Samples were analyzed for asbestos content by Seattle Asbestos Test, LLC (SAT) located in Seattle, Washington. SAT participates in the National Institute for Standards and Technology (NIST) National Voluntary Laboratory Accreditation Plan (NVLAP). Only materials containing more than 1% total asbestos were classified as “asbestos-containing” based on USEPA, state, and local regulations.

Samples in the report labeled as ##QA are quality assurance (QA) samples. Split samples were taken from the same location and they were sent to separate laboratories. QA samples were submitted to, NVL Laboratories, Inc. (NVL) in Seattle, WA, another NVLAP laboratory.

Copies of both laboratories’ NVLAP certifications are included in Appendix D.

2.3.2 Lead-Containing Paint/Lead-Containing Materials

EHSI used an Olympus Delta-Pro x-ray fluorescence (XRF) Spectrum Analyzer to measure lead content on interior and exterior paint coatings and other suspect LCM. Measurements were representative of all layers of paint and/or LCM. A summary of Lead Paint XRF results is provided in Table 3. Bulk quality assurance samples were taken for a representative number of LBP and LCM and were sent to NVL located in Seattle, Washington, an accredited laboratory for Atomic Absorption Spectroscopy (USEPA Method-7000B) by the American Industrial Hygiene Association (AIHA) under the Environmental Lead Laboratory Accreditation Program

(ELLAP). Copies of laboratory reports and field data forms for lead are in Appendix B.

2.4 SAMPLING RESULTS

2.4.1 Asbestos-Containing Materials

Twenty-two (22) bulk samples of suspect ACM were collected as part of the survey. Two (2) of those samples were split for quality assurance analyses. Limited destructive inspection was conducted to identify hidden and/or concealed materials. Copies of the asbestos analytical laboratory results are included in Appendix A. Asbestos and lead sample location drawings are provided in Appendix E. Asbestos sampling information including: sample number, material description, sample location, and analytical results are summarized in Table 1. The ACM and assumed ACM identified during this survey, including the quantity and location, is summarized in Table 2. All suspect materials were accessible for sampling.

EHSI Project 11035 November 10th, 2017

TABLE 1

SUMMARY OF ASBESTOS BULK SAMPLING AND ANALYTICAL RESULTS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

SAMPLE

NUMBER

SAMPLE

LOCATION

MATERIAL DESCRIPTION

ASBESTOS

TYPE OF

ASBESTOS

11035-

KLE-01

Bedroom

Layer 1: Beige and brown SVF (w/ large broken rock pattern)

Layer 2: Gray paper backing w/ tan mastic

Layer 3: Wood

L1: ND

L2: 53%

L3: ND

N/A

Chrysotile

N/A

11035-KLE-

Bedroom 1

Layer 1: Pink fiberglass batt insulation

Layer 2: Black paper/mastic

L1: ND

L2: ND

N/A

N/A

11035-KLE-

Bedroom 1

Layer 1: 3”x4” Brown ceramic tile

Layer 2: Trace brown grout Layer 3: Beige mastic

Layer 4: Wood window sill

L1: ND

L2: ND

L3: ND

L4: ND

N/A

N/A N/A

N/A

11035-KLE-

Bedroom 1

Black rubber window glazing gasket (on 4’x3’ metal-framed window)

ND N/A

11035-KLE-

Restroom

Layer 1: 4”x4” White/yellow ceramic tile

Layer 2: Yellow ceramic tile

Layer 3: Yellow mastic Layer 4: Trace brown fibrous material

L1: ND

L2: ND

L3: ND

L4: ND

N/A

N/A

N/A N/A

11035-KLE-

Restroom Black rubber window glazing gasket (on 3’x2’ metal-framed window)

ND N/A

11035-KLE-

Restroom

Layer 1: Black plastic sink drain gasket

Layer 2: Black fibrous rubber sink drain gasket

Layer 3: Yellow/clear mastic (on enamel coated metal sink)

L1: ND

L2: ND

L3: ND

N/A

N/A

N/A

11035-

KLE-08

Kitchen/ Living room

Layer 1: Brown SVF (w/ geometric pattern) Layer 2: Gray paper backing w/ tan mastic Layer 3: OSB

Layer 4: Wood (beneath black mastic) Layer 5: Black mastic

L1: ND

L2: 52%

L3: ND

L4: ND

L5: ND

N/A

Chrysotile

N/A

N/A

N/A

11035-KLE-

Kitchen/ Living room

Layer 1: 4”x4” White ceramic tile (w/ gray specks) and white grout

Layer 2: Orange mastic (strewn about as loose debris)

L1: ND

L2: ND

N/A

N/A

EHSI Project 11035 November 10th, 2017

TABLE 1

SUMMARY OF ASBESTOS BULK SAMPLING AND ANALYTICAL RESULTS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

SAMPLE

NUMBER

SAMPLE

LOCATION

MATERIAL DESCRIPTION

ASBESTOS

TYPE OF

ASBESTOS

11035-KLE-

Kitchen/

Living room

Layer 1: Red brick w/ black coating (in places)

Layer 2: Gray mortar (strewn about as loose debris)

L1: ND

L2: ND

N/A

N/A

11035-KLE-

Exterior, Roof

Layer 1: Rolled down black asphaltic roofing w/ black granules and black asphaltic tar

Layer 2: Rolled down black asphaltic roofing w/ black granules and black asphaltic tar

(under wood roof shingles)

L1: ND

L2: ND

N/A

N/A

11035-KLE-

Exterior, Roof

Layer 1: Rolled down black asphaltic roofing w/ black granules and black asphaltic tar Layer 2: Rolled down black asphaltic roofing w/ black granules and black asphaltic tar

(under wood roof shingles) Layer 3: Trace white substance

L1: ND

L2: ND

L3: ND

N/A

N/A

N/A

11035-KLE-

Kitchen/

Living room

Off-white bare GWB (strewn about as loose debris)

ND N/A

11035-KLE-

Kitchen/ Living room

2” OD white plastic gasket (associated w/ hot water tank inlet/outlet)

ND N/A

11035-KLE-

Kitchen/ Living room

Off-white/gray pipe dope (on 1” OD pipe connections to hot water tank)

ND N/A

11035-KLE-

Kitchen/ Living room

Black rubber window glazing gasket (on 3’x4’ metal-framed window)

ND N/A

11035-KLE-

17QA

Kitchen/

Living room

Black rubber window glazing gasket w/ woven fibrous interior (on 4’x5’ metal-framed window)

ND N/A

11035-KLE-

Exterior, Beneath Kitchen/

Living room

Light gray/gray pipe dope (on

2” OD metal drain pipe connections)

ND N/A

EHSI Project 11035 November 10th, 2017

TABLE 1

SUMMARY OF ASBESTOS BULK SAMPLING AND ANALYTICAL RESULTS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

SAMPLE

NUMBER

SAMPLE

LOCATION

MATERIAL DESCRIPTION

ASBESTOS

TYPE OF

ASBESTOS

11035-KLE-

Bedroom 1

Layer 1: Silver foil Layer 2: White paper wrap w/ fibrous mesh reinforced interior Layer 3: Yellow fiberglass TSI

Layer 4: Wood w/ debris (unused insulation, stacked above bed)

L1: ND

L2: ND

L3: ND

L4: ND

N/A N/A

N/A

N/A

11035-KLE-

Restroom

Layer 1: Green carpet Layer 2: Off-white foam backing w/ brown mesh (loose roll, not installed)

L1: ND

L2: ND

N/A N/A

11035-KLE-

Kitchen/ Living room

Layer 1: Multi-colored carpet

Layer 2: Off-white mastic

Layer 3: Beige backing Layer 4: Tan mastic w/ woven backing Layer 5: Silver tape (on wood)

L1: ND

L2: ND

L3: ND

L4: ND

L5: ND

N/A

N/A

N/A N/A

N/A

11035-KLE-

22QA

Kitchen/

Living room

Brown wood patterned coating on white contact paper w/paint

ND N/A

KEY: bold = bold text indicates asbestos-containing layer, GWB = gypsum wall board, ND = non-detect, N/A = not applicable, OD = outer diameter, OSB = oriented strand board, SVF = sheet vinyl flooring, w/ = with

Table 2 summarizes materials identified by EHSI as containing greater than 1% asbestos fibers during its survey, and un-sampled materials assumed to be ACM. The Table 2 Summary of Asbestos Containing Materials is for engineering cost estimating purposes and is not intended for bid quantifications.

TABLE 2

SUMMARY OF ASBESTOS-CONTAINING MATERIALS

NATIONAL PARK SERVICE

LAKE OZETTE – KLEIVA PROPERTY

ASBESTOS MATERIAL DESCRIPTION LOCATION QUANTITY

Non-ACM Beige and brown SVF (w/ large broken rock pattern) w/ ACM gray paper backing w/ ACM tan mastic on wood [Sample # 01]

Bedroom 1 125 SF

Non-ACM SVF (w/ geometric pattern) w/ ACM gray paper backing w/ ACM tan mastic on OSB on non-ACM black mastic on wood [Sample # 08]

Kitchen/

Living room

550 SF

KEY: ACM = asbestos containing material, bold = bold text indicates asbestos-containing layer, OSB

= oriented strand board, SF = square feet, SVF = sheet vinyl flooring, w/ = with

ACM identified in this survey should not be disturbed unless handled by personnel who are properly trained and certified in asbestos work. Demolition and/or renovation activities by contractors may expose concealed suspect ACM. Contractors should be aware of the potential

EHSI Project 11035 November 10th, 2017 for concealed suspect ACM and have pre-planned contingencies for the handling of suspect

ACM discovered during renovation and/or demolition work. Any concealed suspect ACM material that was not sampled or was assumed to be ACM and included in this report, must be treated as ACM until proven otherwise by a Certified AHERA Building Inspector and a certified laboratory. Contingency plans should include stopping work on identification of concealed suspect ACM, evacuation of the area, and sampling by a Certified AHERA Building

Inspector. Concealed suspect material may include, but is not limited to: non-fiberglass pipe or roof drain insulation; spray-applied coatings; cementitious board; asphalt or paper vapor barriers; vinyl floorings and mastics.

2.4.2 Lead-Containing Paint and Building Materials

Thirteen (13) samples were analyzed for lead using the X-Ray fluorescence (XRF) analyzer.

Results marked with “< LOD” are less than the limit of detection. XRF paint sample results ranged from 5 milligrams of lead per square centimeter (mg Pb/cm2) to < LOD mg Pb/cm2.

Bolded results indicate materials coated with “lead-based paint” (e.g., 1.0 mg/cm2) as defined by USEPA regulation 40CFR745 and Washington State Commerce regulation WAC 365-230. The results are provided in Table 3 of this report.

Table 3 summarizes XRF lead samples, including sample number, material description, substrate, color, location and analytical results.

TABLE 3

XRF SAMPLING

SUMMARY OF PAINTED COMPONENTS AND MATERIALS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

Read

Component Substrate Color Building Room

Lead Conc.

(mg/cm2)

1 NIST Check Wood Red Kleiva Property N/A 0.98

2 NIST Check Wood Red Kleiva Property N/A 0.99

3 NIST Check Wood Red Kleiva Property N/A 0.99

4 Structural Beam Wood Dark Brown Kleiva Property Kitchen/Living

Room

<LOD

5 Door Frame Wood Dark Brown Kleiva Property Kitchen/Living

Room

<LOD

6 Window Frame Ceramic Brown Kleiva Property Kitchen/Living

Room

7 Wall Fiber Board Light Brown Kleiva Property Kitchen/Living

Room

<LOD

8 Door Fiber Board Brown Kleiva Property Hall <LOD

9 Counter Ceramic Off White Kleiva Property Bathroom 5

Toilet Base

Framing Wood Brown Kleiva Property Bathroom

<LOD

11 Cabinet Wood Brown Kleiva Property Bathroom <LOD

12 Shelf Metal White Kleiva Property Bathroom <LOD

13 Fascia Wood Dark Brown Kleiva Property Exterior <LOD

14 Gutter Plastic Brown Kleiva Property Exterior <LOD

EHSI Project 11035 November 10th, 2017

TABLE 3

XRF SAMPLING

SUMMARY OF PAINTED COMPONENTS AND MATERIALS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

Read

Component Substrate Color Building Room Lead Conc.

(mg/cm2)

15 NIST Check Wood Red Kleiva Property N/A 0.9

16 NIST Check Wood Red Kleiva Property N/A 0.91

17 NIST Check Wood Red Kleiva Property N/A 0.89

18 NIST Check Wood Red Kleiva Property N/A 0.94

19 NIST Check Wood Red Kleiva Property N/A 0.91

20 NIST Check Wood Red Kleiva Property N/A 0.93

21 Wall Wood Dark Brown Kleiva Property Exterior <LOD

22 Window Trim Wood Dark Brown Kleiva Property Exterior <LOD

23 NIST Check Wood Red Kleiva Property N/A 0.89

24 NIST Check Wood Red Kleiva Property N/A 0.89

25 NIST Check Wood Red Kleiva Property N/A 0.9

26 NIST Check Wood Red Kleiva Property N/A 0.94

27 NIST Check Wood Red Kleiva Property N/A 0.92

28 NIST Check Wood Red Kleiva Property N/A 0.9

Key: N/A = not applicable, <LOD = less than the limit of detection

In addition to the XRF samples, EHSI collected two (2) bulk QA samples for laboratory analysis. The bulk sample results were both less than the reporting limit. Building materials and paint containing detectable levels of lead are considered regulated by DOSH. Any contractors disturbing materials with detectable amounts of lead should conduct training and a negative exposure assessment in accordance with DOSH regulations.

Table 4 summarizes bulk QA lead samples, including sample number, material description, substrate, color, location, and analytical results.

Copies of the analytical laboratory report and field data forms for lead paint are included in

Appendix B of this report.

TABLE 4

SUMMARY OF LEAD BULK SAMPLING AND ANALYTICAL RESULTS

NATIONAL PARKS SERVICE

LAKE OZETTE – KLEIVA PROPERTY

SAMPLE NUMBER LOCATION

COMPONENT/

SUBSTRATE

COLOR

RESULTS

% Pb by WT

11035-KLE-Pb01 Exterior Chimney/ Brick & Mortar Red &

Gray <0.0066

11035-KLE-Pb02 Exterior Siding & Trim/ Wood Brown <0.0028 Key: Pb = lead, WT = weight

EHSI Project 11035 November 10th, 2017

DOSH requires employers to conduct a hazard assessment and take appropriate worker protection precautions whenever disturbing materials that have detectable quantities of lead.

Since the type of work planned (e.g., sawing, grinding, demolition) will disturb the lead-containing materials, the contractor should perform an initial exposure assessment to determine if additional personal protective measures and work practices are required beyond the initial exposure assessment.

2.4.3 Toxicity Characteristic Leaching Procedure Sampling

Ecology requires testing using the “toxicity characteristic leaching procedure” (TCLP) and segregation of construction debris if it is potentially contaminated with dangerous waste (e.g., lead-containing paint/lead-containing materials). Ecology has set a dangerous waste threshold for leachable lead at 5.0 milligrams of lead per liter (mg/L).

At the request of the NPS, a TCLP was conducted by EHSI as part of the Limited Lead and Asbestos Survey. The results of that lead-TCLP analysis indicate leachable lead present in the anticipated demolition waste stream at a concentration of <0.5 mg/L. A detailed list of the materials included in the TCLP sample are provided in Appendix F.

It should be noted that this TCLP was done on behalf of NPS for disposal cost estimating purposes. It is recommended that the contractor take their own TCLP test of their demolition waste stream including the option to not TCLP specific materials based on the ability to recycle metal and concrete painted building materials.

2.4.4 Polychlorinated Biphenyls

Ballasts

EHSI did not observe any ballasts associated with fluorescent light fixtures on the Kleiva property.

2.4.5 Mercury-Containing Fluorescent Light Tubes and CFL Bulbs

EHSI did not observe any mercury-containing fluorescent light tubes, CFL bulbs, or HID lamps on the Kleiva property.

3.0 LIMITATIONS

This survey was limited to those materials accessible using standard survey methods. Limited representative destructive inspection was accomplished. All suspect materials present were accessible for sampling.

This survey was limited to the chemicals and materials identified herein. No effort was made to identify hazardous materials in soil, water, or air, other than those listed herein. Any survey regardless of how extensive can miss concealed materials. Contractors should be aware of the potential that demolition activities may expose concealed suspect ACM and should have preplanned contingencies for handling these materials when discovered during demolition work. Any concealed, suspect ACM material that was not sampled or that was assumed to be

ACM by this survey report when encountered must be treated as ACM until sampled by a Certified AHERA Building Inspector and analyzed by a certified laboratory.

EHSI Project 11035 November 10th, 2017

4.0 STANDARD OF CARE

The recommendations and conclusions contained in this report represent the professional opinions of EHSI. These opinions are derived in accordance with federal, state, and local environmental and health and safety laws and regulations. This survey was accomplished in accordance with applicable federal, state, and local regulations and industry standards in effect at the time. Other than this, no other warranty is implied or intended.

5.0 CERTIFIED AHERA BUILDING INSPECTORS

The Certified AHERA Building Inspectors listed below surveyed the property on October 4th, 2017, in accordance with federal, state, and local requirements.

Brett Racine Mike Ruark

Certified AHERA Building Inspector Certified AHERA Building Inspector Certificate Number: 1628680 Certificate Number: 163007

Expiration Date: July 26, 2018 Expiration Date: September 6, 2018

Appendix A

APPENDIX A

Asbestos Analytical Laboratory Report and Field Data Forms

Nick Ly, Technical Director

Client Project: 11035-03

Location: Kleiva Property

Dear Mr. Peterson, Enclosed please find test results for the 2 sample(s) submitted to our laboratory for analysis on

10/10/2017.

Examination of these samples was conducted for the presence of identifiable asbestos fibers using polarized light microscopy (PLM) with dispersion staining in accordance with both EPA 600/M4-82-020, Interim Method for the Determination of Asbestos in Bulk Insulation Samples and EPA 600/R-93/116

Method for the Determination of Asbestos in Bulk Building Materials.

For samples containing more than one separable layer of materials, the report will include findings for each layer (labeled Layer 1 and Layer 2, etc. for each individual layer). The asbestos concentration in the sample is determined by calibrated visual estimation.

For those samples with asbestos concentrations between 1 and 10 percent based on visual estimation, the EPA recommends a procedure known as point counting (NESHAPS, 40 CFR Part 61). Point counting is a statistically more accurate means of quantification for samples with low concentrations of asbestos.

The detection limit for the calibrated visual estimation is <1%, 400 point counts is 0.25% and 1000 point counts is 0.1%

Samples are archived for two weeks following analysis. Samples that are not retrieved by the client are discarded after two weeks.

Thank you for using our laboratory services. Please do not hesitate to call if there is anything further we can assist you with.

Sincerely, Enc.: Sample Results

October 13, 2017

Nick L T hnical D

Rory Peterson

EHS International

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

RE: Bulk Asbestos Fiber Analysis; NVL Batch # 1717972.00

< Client:

Address:

Attention: Mr. Rory Peterson

Kleiva Property

Client Project #: 11035-03

Samples Received: 2

By Polarized Light Microscopy

Bulk Asbestos Fibers Analysis

EHS International

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Method: EPA/600/R-93/116

& EPA/600/M4-82-020

Samples Analyzed: 2

Project Location:

Batch #: 1717972.00

Date Received: 10/10/2017

17098187Lab ID: Client Sample #:

Location: Kleiva Property

11035-KLE-17QA

Layer 1 of 1 Description: Black flexible material with fibrous elements

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Calcareous binder 8%Synthetic fibers None Detected ND

17098188Lab ID: Client Sample #:

Location: Kleiva Property

11035-KLE-22QA

Layer 1 of 1 Description: White fibrous paper material with paint

Non-Fibrous Materials: Other Fibrous Materials:% Asbestos Type: %

Binder/Filler, Paint 77%Cellulose None Detected ND

Note: If samples are not homogeneous, then subsamples of the components were analyzed separately. All bulk samples are analyzed using both EPA

600/R-93/116 and 600/M4-82-020 Methods with the following measurement uncertainties for the reported % Asbestos (1%=0-3%, 5%=1-9%, 10%=5-15%, 20%=10-30%, 50%=40-60%). This report relates only to the items tested. If sample was not collected by NVL personnel, then the accuracy of the results is limited by the methodology and acuity of the sample collector. This report shall not be reproduced except in full, without written approval of NVL

Laboratories, Inc. It shall not be used to claim product endorsement by NVLAP or any other agency of the US Government

Client

Jacob LaugesonAnalyzed by:

Nick LyReviewed by:

10/12/2017 Date:

10/13/2017Date:

Sampled by:

EHS International 1717972.00

Company NVL Batch Number

Total Number of Samples

Kleiva Property

5 DaysTAT

10/17/2017Due Date 9:25 AMTime

(206) 254-4279Fax roryp@ehsintl.comEmail

Project Manager Mr. Rory Peterson

(206) 381-1128

(425) 766-8342Cell

Phone

Rush Samples

Rush TAT

NoAH

11035-03Project Name/Number: Project Location:

Sample ID Description A/RLab ID

ASBESTOS LABORATORY SERVICES

Subcategory

Item Code

PLM Bulk

Metals

ASB-02 EPA 600/R-93-116 Asbestos by PLM <bulk>

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Address

11035-KLE-17QA1 A17098187

11035-KLE-22QA2 A17098188

Office Use Only Print Name Company Date TimeSignature

Faxed Emailed

Company Date TimeSignature

ClientSampled by

Umer KhanReceived by

ClientRelinquished by

Jacob LaugesonAnalyzed by

Results Called by

NVL

NVL

10/10/17

10/12/17

Print Name

Entered By: Umer Khan

Date: 10/10/2017

Time: 9:30 AM

Special

Instructions:

Appendix B

APPENDIX B

Lead Laboratory Reports and Field Data Forms

RE: Metals Analysis; NVL Batch # 1717978.00

Dear Mr. Peterson, October 13, 2017

EHS International

Rory Peterson

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Enclosed please find the test results for samples submitted to our laboratory for analysis.

Preparation of these samples was conducted following protocol outlined in EPA Method SW 846

-3051 unless stated otherwise. Analysis of these samples was performed using analytical instruments in accordance with U.S. EPA, NIOSH, OSHA and other ASTM methods.

For matrix materials submitted as paint, dust wipe, soil or TCLP samples, analysis for the presence of total metals is conducted using published U.S. EPA Methods. Paint and soil results are usually expressed in mg/Kg which is equivalent to parts per million (ppm). Lead (Pb) in paint is usually expressed in mg/Kg (ppm) , Percent (%) or mg/cm by area. Dust wipe sample results are usually expressed in ug/wipe and ug/ft . TCLP samples are reported in mg/L (ppm). For air filter samples, analyses are conducted using NIOSH and OSHA Methods. Results are expressed in ug/filter and ug/m . Other matrix materials are analyzed accordingly using published methods or specified by client. The reported test results pertain only to items tested and are not blank corrected.

For recent regulation updates pertaining to current regulatory levels or permissible exposure levels, please call your local regulatory agencies for more details.

This report is considered highly confidential and will not be released without your approval.

Samples are archived for two weeks following analysis. Samples that are not retrieved by the client are discarded after two weeks.

Thank you for using our laboratory services. if you need further assistance please feel free to call us at 206-547-0100 or 1-888-NVLLABS.

Sincerely, Shalini Patel, Laboratory Analyst

Analysis Report Total Lead (Pb)

Kleiva Property

EHS InternationalClient:

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Mr. Rory PetersonAttention:

Address:

Project Location: Samples Received: 2

Samples Analyzed: 2

Client Project #: 11035-03

Batch #: 1717978.00

Date Received: 10/10/2017

Lab ID Client Sample #

Sample

Weight (g)

Results in mg/Kg

Results in percent

RL in mg/Kg

Matrix: Paint

Method: EPA 3051/7000B

17098199 11035-KLE-Pb01 0.1517 66 < 66 0.0066<

17098200 11035-KLE-Pb02 0.3614 28 < 28 0.0028<

ClientSampled by:

Yasuyuki HidaAnalyzed by:

Shalini PatelReviewed by:

10/13/2017Date Analyzed:

10/13/2017Date Issued:

Bench Run No: 2017-1013-2 mg/ Kg =Milligrams per kilogram RL = Reporting Limit

Percent = Milligrams per kilogram / 10000 '<' = Below the reporting Limit Note : Method QC results are acceptable unless stated otherwise.

Unless otherwise indicated, the condition of all samples was acceptable at time of receipt.

Shalini Patel, Laboratory Analyst

EHS International 1717978.00

Company NVL Batch Number

Total Number of Samples

Kleiva Property

5 DaysTAT

10/17/2017Due Date 9:25 AMTime

(206) 254-4279Fax roryp@ehsintl.comEmail

Project Manager Mr. Rory Peterson

(206) 381-1128

(425) 766-8342Cell

Phone

Rush Samples

Rush TAT

NoAH

11035-03Project Name/Number: Project Location:

Sample ID Description A/RLab ID

LEAD LABORATORY SERVICES

Subcategory

Item Code

Flame AA (FAA)

Metals

FAA-02 EPA 7000B Lead by FAA <paint>

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Address

11035-KLE-Pb011 A17098199

11035-KLE-Pb022 A17098200

Office Use Only Print Name Company Date TimeSignature

Faxed Emailed

Company Date TimeSignature

ClientSampled by

Umer KhanReceived by

ClientRelinquished by

Yasuyuki HidaAnalyzed by

Results Called by

NVL

NVL

10/10/17

10/13/17

Print Name

Entered By: Umer Khan

Date: 10/10/2017

Time: 9:40 AM

Special

Appendix C

APPENDIX C

Certified AHERA Building Inspector Certificates

Appendix D

APPENDIX D

Laboratory Certifications for Asbestos and Lead Analysis acknowledges that

NVL Laboratories, Inc.

General Requirements for the Competence of Testing and Calibration Laboratories

LABORATORY ACCREDITATION PROGRAMS

INDUSTRIAL HYGIENE

ENVIRONMENTAL LEAD

ENVIRONMENTAL MICROBIOLOGY

FOOD

UNIQUE SCOPES

Scope of Accreditation

Scope of Accreditation

William Walsh, CIH

Chairperson, Analytical Accreditation Board

Cheryl O. Morton

Managing Director, AIHA Laboratory Accreditation Programs, LLC

NVL Laboratories, Inc. 101861

Industrial Hygiene Laboratory Accreditation Program (IHLAP)

Initial Accreditation Date: 04/01/1997

IHLAP Scope

Category

Field of Testing (FoT) Technology sub-type/

Detector

Published Reference

Method/Title of In-house Method

Method Description or Analyte for internal methods only)

Spectrometry Core

Asbestos/Fiber

Microscopy Core

Miscellaneous Core

NVL Laboratories, Inc. 101861

Environmental Lead Laboratory Accreditation Program (ELLAP)

Initial Accreditation Date: 02/07/1997

Field of Testing (FoT) Technology sub-type/

Detector Method

Method Description for internal methods only)

Paint

Soil

Settled Dust by Wipe

Airborne Dust

Appendix E

APPENDIX E

Sample Location Drawings for Asbestos, Lead, and TCLP

KITCHEN

BEDROOM 2 BEDROOM 1BATH

OVEN

TANK

SL-1

KLEIVA

HOUSE

PROJECT NORTH

KLEIVA HOUSE

NOT TO SCALE

EHSI PROJECT #:

SCALE:

SURVEY DATES:

DRAWN BY:

INSPECTORS:

PROJECT MANAGER:

ISSUE DATE:

K

LE

IV

A

P R

O P

E R

TY

E

A S

T S

H O

R E

LA

K

E O

ZE

TT

E

U S

D E

P A

R

TM

E N

T O

F

TH

E

IN

TE

R

IO

R

N P

S P

O R

T A

N G

E

LE

S , W

A

GENERAL NOTES

1. DRAWING IS SCHEMATIC AND SAMPLE LOCATIONS ARE

APPROXIMATE.

2. REFER TO REPORT FOR MORE INFORMATION ABOUT

THE SAMPLED MATERIALS.

1011 SW Klickitat Way, Suite 104

Seattle, Washington 98134

Ph: 206.381.1128

Fax: 206.254.4279

EHS-International, Inc.

SAMPLE LEGEND

BULK ASBESTOS SAMPLE LOCATIONS11035-KLE-XX

P R

O

JE

C T

P R

O P

E R

T Y

I D

S A

M P

L E

# PROPERTY ID:

HAU = HAUBRICH

KLE = KLEIVA

BULK LEAD SAMPLE LOCATIONS11035-KLE-PbXX

BULK TCLP SUB-SAMPLE11035-KLE-TCLP-XXA

11035-KLE-TCLP-01D

11035-KLE-TCLP-01H

11035-KLE-21 11035-KLE-17

11035-KLE-16

11035-KLE-18

11035-KLE-10 11035-KLE-TCLP-01I

11035-KLE-11

11035-KLE-14

11035-KLE-TCLP-01F 11035-KLE-TCLP-01A

11035-KLE-Pb02

11035-KLE-TCLP-01C

11035-KLE-09

11035-KLE-13

11035-KLE-08

11035-KLE-01

11035-KLE-22

11035-KLE-03

11035-KLE-TCLP-01E

11035-KLE-TCLP-01J

11035-KLE-TCLP-01B

11035-KLE-12

11035-KLE-TCLP-01E

11035-KLE-05

11035-KLE-TCLP-01G 11035-KLE-19

11035-KLE-07

11035-KLE-06

11035-KLE-20

11035-KLE-Pb01

11035-KLE-04

11035-KLE-02

11035-KLE-15

Appendix F

APPENDIX F

Lead TCLP Laboratory Reports and Field Data Forms

RE: Metals Analysis; NVL Batch # 1717976.00

Dear Mr. Peterson, October 12, 2017

EHS International

Rory Peterson

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Enclosed please find the test results for samples submitted to our laboratory for analysis.

Preparation of these samples was conducted following protocol outlined in EPA Method SW 846

-3051 unless stated otherwise. Analysis of these samples was performed using analytical instruments in accordance with U.S. EPA, NIOSH, OSHA and other ASTM methods.

For matrix materials submitted as paint, dust wipe, soil or TCLP samples, analysis for the presence of total metals is conducted using published U.S. EPA Methods. Paint and soil results are usually expressed in mg/Kg which is equivalent to parts per million (ppm). Lead (Pb) in paint is usually expressed in mg/Kg (ppm) , Percent (%) or mg/cm by area. Dust wipe sample results are usually expressed in ug/wipe and ug/ft . TCLP samples are reported in mg/L (ppm). For air filter samples, analyses are conducted using NIOSH and OSHA Methods. Results are expressed in ug/filter and ug/m . Other matrix materials are analyzed accordingly using published methods or specified by client. The reported test results pertain only to items tested and are not blank corrected.

For recent regulation updates pertaining to current regulatory levels or permissible exposure levels, please call your local regulatory agencies for more details.

This report is considered highly confidential and will not be released without your approval.

Samples are archived for two weeks following analysis. Samples that are not retrieved by the client are discarded after two weeks.

Thank you for using our laboratory services. if you need further assistance please feel free to call us at 206-547-0100 or 1-888-NVLLABS.

Sincerely, Lab ID Client Sample #

Results in mg/L

RL

mg/ L

Results in ppm

Analysis Report

Kleiva Property

EHS InternationalClient:

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Mr. Rory PetersonAttention:

Address:

Project Location: Samples Received: 1

Samples Analyzed: 1

Client Project #: 11035-03

Batch #: 1717976.00

Date Received: 10/10/2017

Toxicity Characteristic Leaching Procedure - Lead (Pb)

Matrix: Bulk

Method: EPA 1311/7000B

17098196 11035-KLE-TCLP-01 0.5 < 0.5 < 0.5

ClientSampled by:

Yasuyuki HidaAnalyzed by:

Nick LyReviewed by:

Note : Method QC results are acceptable unless stated otherwise.

mg/ L =Milligrams per liter RL = Reporting Limit ppm = parts per million '<' = Below the reporting Limit

10/12/2017Date Analyzed:

10/12/2017Date Issued:

Bench Run No: 2017-1011-4

Unless otherwise indicated, the condition of all samples was acceptable at time of receipt.

EHS International 1717976.00

Company NVL Batch Number

Total Number of Samples

Kleiva Property

5 DaysTAT

10/17/2017Due Date 9:25 AMTime

(206) 254-4279Fax roryp@ehsintl.comEmail

Project Manager Mr. Rory Peterson

(206) 381-1128

(425) 766-8342Cell

Phone

Rush Samples

Rush TAT

NoAH

11035-03Project Name/Number: Project Location:

Sample ID Description A/RLab ID

LEAD LABORATORY SERVICES

Subcategory

Item Code

Flame AA (FAA)

Metals

TCLP-1 EPA 1311/7000B Lead by FAA <TCLP>

1011 SW Klickitat Way. Suite 104

Seattle, WA 98134

Address

11035-KLE-TCLP-011 A17098196

Office Use Only Print Name Company Date TimeSignature

Faxed Emailed

Company Date TimeSignature

ClientSampled by

Umer KhanReceived by

ClientRelinquished by

Yasuyuki HidaAnalyzed by

Results Called by

NVL

NVL

10/10/17

10/12/17

Print Name

Entered By: Mohammed Jamal

Date: 10/10/2017

Time: 9:38 AM

Special