Attachment 16 NEPA and NHPA Auto Shop Report_0004.pdf

State of Washington • Department of Archaeology & Historic Preservation

P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa.gov

August 7, 2020

Mr. Dave Conca US National Park Service 600 E Park Ave Port Angeles, WA 98362

In future correspondence please refer to:

Project Tracking Code: 2020-08-04961 Property: Correct HQ Fuel Tank and Auto Shop Deficiencies Re: NO Adverse Effect

Dear Mr. Conca:

Thank you for contacting the State Historic Preservation Officer (SHPO) and Department of Archaeology and Historic Preservation (DAHP) regarding the above referenced proposal. This action has been reviewed on behalf of the SHPO under provisions of Section 106 of the National Historic Preservation Act of 1966 (as amended) and 36 CFR Part 800. Our review is based upon documentation contained in your communication.

First, we agree with the Area of Potential Effect (APE) as mapped in the survey report. We also concur that the current project as proposed will have "NO ADVERSE EFFECT" on historic properties within the APE that are listed in, or determined eligible for listing in, the National Register of Historic Places. As a result of our concurrence, further contact with DAHP on this proposal is not necessary. However, if new information about affected resources becomes available and/or the project scope of work changes significantly, please resume consultation as our assessment may be revised. Also, if any archaeological resources are uncovered during construction, please halt work immediately in the area of discovery and contact the appropriate Native American Tribes and DAHP for further consultation.

Thank you for the opportunity to review and comment. Please ensure that the DAHP Project Number (a.k.a. Project Tracking Code) is shared with any hired cultural resource consultants and is attached to any communications or submitted reports. If you have any questions, please feel free to contact me.

Sincerely, Holly Borth Project Compliance Reviewer

(360) 586-3533 holly.borth@dahp.wa.gov

National Park Service U.S. Department of the Interior

Olympic National Park

Date: 02/03/2021

ASSESSMENT OF ACTIONS HAVING AN EFFECT ON HISTORIC

PROPERTIES

A. DESCRIPTION OF UNDERTAKING

1. Park: Olympic National Park

2. Project Description:

Project Name: Correct HQ Fuel Tank and Auto Shop Deficiencies Prepared by: David Conca Date Prepared: 08/10/2020 Telephone: (360) 565-3053 PEPC Project Number: 95909 Locations:

County, State: Clallam, WA Describe project:

The UST fuel tanks in the headquarters maintenance yard are in violation of Clean Water Act per findings of 2014 EPA inspection. There are electrical code violations in the auto shop, the HVAC system does not work properly, emergency lighting is needed, the current lighting is antiquated, restrooms and offices are not accessible, and there are exterior envelope deficiencies.

The proposed action is to replace non-compliant above-ground fuel tanks and fuel dispensing pumps to meet current code compliance. Construct the fueling station under a roof covering. Tie the drain/overspill into new the grease interceptor that was installed in 2017 prior to oil/water separator. Correct all electrical deficiencies not meeting code compliance in the auto shop. Correct all auto shop HVAC, vehicle exhaust, and plumbing deficiencies not meeting code compliance, and correct accessibility deficiencies to meet ABAAS compliance standards. Reorganize various rooms and activity locations in the building to provide a more efficient use of space. Install floor drainage at the bay doors in the auto shop. Replace the main auto shop electrical panel, unit heaters, receptacles, and lighting. Repair and upgrade the building's thermal envelope for improved weather resistance, durability of existing materials, and energy efficiency.

See the attached Basis of Design Report (PDF labeled 228422 OLYM Fuel Tank & Auto Shop_BDR Report) for details on the proposed action.

Project implementation would occur over approximately six months beginning in the spring of 2021.

Area of potential effects (as defined in 36 CFR 800.16[d])

3. Has the area of potential effects been surveyed to identify historic properties?

No

X Yes

Source or reference:

4. Potentially Affected Resource(s):

Archeological Resources Present: No

Historical Structures/Resources Present: Yes

Cultural Landscapes Present: Yes

Ethnographic Resources Present: No

5. The proposed action will: (check as many as apply)

No Destroy, remove, or alter features/elements from a historic structure

No Replace historic features/elements in kind

No Add non-historic features/elements to a historic structure

No Alter or remove features/elements of a historic setting or environment (inc. terrain)

No Add non-historic features/elements (inc. visual, audible, or atmospheric) to a historic setting or cultural landscape

No Disturb, destroy, or make archeological resources inaccessible

No Disturb, destroy, or make ethnographic resources inaccessible>

No Potentially affect presently unidentified cultural resources

No Begin or contribute to deterioration of historic features, terrain, setting, landscape elements, or archeological or ethnographic resources

No Involve a real property transaction (exchange, sale, or lease of land or structures)

Other (please specify):

6. Supporting Study Data:

(Attach if feasible; if action is in a plan, EA or EIS, give name and project or page number.)

B. REVIEWS BY CULTURAL RESOURCE SPECIALISTS

The park 106 coordinator requested review by the park's cultural resource specialist/advisors as indicated by check-off boxes or as follows:

[ X ] 106 Advisor Name: David Conca Date: 08/10/2020

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

[ X ] Archeologist Name: David Conca Date: 08/10/2020

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

[ X ] Historical Architect Name: Kathleen (Kate) Johnson Date: 07/07/2020 Comments: The project calls for the construction of a new element within the District, which will require a four-step review. The new tanks and canopy are located within the utilitarian maintenance part of the district and somewhat behind the Auto Shop, which will minimize the impact to view sheds. The new structure is utilitarian in construction and appearance and will not overwhelm or detract from the existing historic structures. Proposed repairs and rehabilitation of the existing Auto Shop call, for the most part, for repair and/or replacement in kind. With the inclusions/revisions in the recommendations section below, the proposed project should not have an adverse effect on the the Auto Shop or the District.

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Streamlined Review Recommendations for conditions or stipulations: The Basis for Design (BFD) document notes that the existing wood window frames will be retained and new glazing will be installed. The Schematic drawings call for new windows.

Retention of the existing frames is recommended. The BFD calls for replacing the existing "K" type gutter with a new K gutter. The molded (ogee) shape of a K gutter is not in keeping with the existing angular, utilitarian design of the building. If the internal gutter will not be reintroduced and the existing gutter is to be replaced I recommend a rectangular "H" type gutter.

Doc Method: Standard 4-Step Process

[ X ] Historical Landscape Architect Name: Vida Germano Date: 07/07/2020 Comments: The modifications to the building and addition of the shelter over new fuel pumps in the location of the existing pumps will have no adverse effect to the cultural landscape. The changes are compatible with the historic character of the maintenance area.

Check if project does not involve ground disturbance [ ] Assessment of Effect: No Potential to Cause Effect No Historic Properties Affected X No Adverse Effect Adverse Effect Streamlined Review Recommendations for conditions or stipulations:

Doc Method: Standard 4-Step Process

No Reviews From: Curator, Historian, Other Advisor, Anthropologist

C. PARK SECTION 106 COORDINATOR'S REVIEW AND RECOMMENDATIONS

1. Assessment of Effect:

No Potential to Cause Effects

No Historic Properties Affected

X No Adverse Effect

Adverse Effect

2. Documentation Method:

[ X ] A. Standard 36 CFR Part 800 Consultation Further consultation under 36 CFR Part 800 is needed.

[ ] B. Streamlined Review Under the 2008 Servicewide Programmatic Agreement (PA) The above action meets all conditions for a streamlined review under section III of the 2008 Servicewide PA for Section 106 compliance.

Applicable Streamlined Review Criteria (Specify 1-16 of the list of streamlined review criteria.)

[ ] C. Undertaking Related to Park Specific or Another Agreement The proposed undertaking is covered for Section 106 purposes under another document such as a park, region or statewide agreement established in accord with 36 CFR 800.7 or 36 CFR 800.14.

[ ] D. Combined NEPA/NHPA Process Process and documentation required for the preparation of an EA/FONSI or an EIS/ROD to comply with Section 106 is in accord with 36 CFR 800.8.c.

[ ] E. Memo to Project File

3. Consultation Information

SHPO Required: Yes SHPO Sent: Aug 5, 2020 SHPO Received: Aug 7, 2020

THPO Required: No THPO Sent:

THPO Received:

SHPO/THPO Notes:

Advisory Council Participating: No Advisory Council Notes:

Additional Consulting Parties: No

4. Stipulations and Conditions: Following are listed any stipulations or conditions necessary to ensure that the assessment of effect above is consistent with 36 CFR Part 800 criteria of effect or to avoid or reduce potential adverse effects.

5. Mitigations/Treatment Measures: Measures to prevent or minimize loss or impairment of historic/prehistoric properties: (Remember that setting, location, and use may be relevant.)

Required Mitigations - For the proposed project actions to be within compliance requirements during construction and/or project implementation, the following mitigations must be adhered to:

Any fill material brought in from an off-site location must be from a source that has been certified by Clallam County or the park's Vegetation Branch Chief as being free of noxious weeds.

All work conducted on historic properties shall follow the Secretary of the Interior's Standards of Historic Properties. Information on the Secretary of the Interior's Standards can be found at https://www.nps.gov/tps/standards/four-treatments.htm and https://www.nps.gov/tps/standards/treatment-guidelines-2017.pdf.

Care will be taken not to disturb any wildlife species (reptiles, migratory birds, raptors, or bats) found nesting, hibernating, estivating, or otherwise living in, or immediately nearby, worksites.

To reduce noise and pollution emissions, construction equipment will not idle any longer than is necessary for safety and/or mechanical reasons.

Hazardous spill clean-up material shall be onsite at all times. This measure is designed to avoid/minimize the introduction of chemical contaminants associated with machinery (fuel, oil, hydraulic fluid, etc.) used in project implementation.

Prior to starting work each day, all machinery will be inspected for leaks (fuel, oil, hydraulic fluid, etc.) and all necessary repairs will be made before the commencement of work.

Any safety violations shall be corrected immediately.

Project leader shall notify the environmental protection specialist prior to any changes in scope for the project.

The Basis for Design (BFD) document notes that the existing wood window frames will be retained and new glazing will be installed. The Schematic drawings call for new windows. Retention of the existing frames is recommended.

The BFD calls for replacing the existing "K" type gutter with a new K gutter. The molded (ogee) shape of a K gutter is not in keeping with the existing angular, utilitarian design of the building. If the internal gutter will not be reintroduced and the existing gutter is to be replaced I recommend a rectangular "H" type gutter.

Comment: These recommendations are from the PWR Historical Architects

6. Assessment of Effect Notes:

D. RECOMMENDED BY PARK SECTION 106 COORDINATOR:

Compliance Specialist:

NHPA Specialist David Conca Date:

E. SUPERINTENDENT'S APPROVAL

The proposed work conforms to the NPS Management Policies and Cultural Resource Management Guideline, and I have reviewed and approve the recommendations, stipulations, or conditions noted in Section C of this form.

Signature

Superintendent: Date:

Sarah Creachbaum

Olympic National Park Date: 02/03/2021

Mitigations List Form

Date: February 3, 2021

Park: Olympic National Park Project: Correct HQ Fuel Tank and Auto Shop Deficiencies PEPC Project Number: 95909 Project Description:

The UST fuel tanks in the headquarters maintenance yard are in violation of Clean Water Act per findings of 2014 EPA inspection. There are electrical code violations in the auto shop, the HVAC system does not work properly, emergency lighting is needed, the current lighting is antiquated, restrooms and offices are not accessible, and there are exterior envelope deficiencies.

The proposed action is to replace non-compliant above-ground fuel tanks and fuel dispensing pumps to meet current code compliance. Construct the fueling station under a roof covering. Tie the drain/overspill into new the grease interceptor that was installed in 2017 prior to oil/water separator. Correct all electrical deficiencies not meeting code compliance in the auto shop. Correct all auto shop HVAC, vehicle exhaust, and plumbing deficiencies not meeting code compliance, and correct accessibility deficiencies to meet ABAAS compliance standards. Reorganize various rooms and activity locations in the building to provide a more efficient use of space. Install floor drainage at the bay doors in the auto shop. Replace the main auto shop electrical panel, unit heaters, receptacles, and lighting. Repair and upgrade the building's thermal envelope for improved weather resistance, durability of existing materials, and energy efficiency.

See the attached Basis of Design Report (PDF labeled 228422 OLYM Fuel Tank & Auto Shop_BDR Report) for details on the proposed action.

Project implementation would occur over approximately six months beginning in the spring of 2021.

Project Locations:

Location County: Clallam State: WA District:

Section:

Geo. Marker: Other:

Tract ID:

Funding Source(s):

PMIS

Number(s):

228422

Mitigation(s):

(the following is a complete list of all mitigations that will be incorporated into the above-referenced project)

• Other : Any fill material brought in from an off-site location must be from a source that has been certified by Clallam County or the park's Vegetation Branch Chief as being free of noxious weeds.

• Other : All work conducted on historic properties shall follow the Secretary of the Interior's Standards of Historic Properties. Information on the Secretary of the Interior's Standards can be found at https://www.nps.gov/tps/standards/four-treatments.htm and https://www.nps.gov/tps/standards/treatment-guidelines- 2017.pdf.

• Other : Care will be taken not to disturb any wildlife species (reptiles, migratory birds, raptors, or bats) found nesting, hibernating, estivating, or otherwise living in, or immediately nearby, worksites.

• Other : To reduce noise and pollution emissions, construction equipment will not idle any longer than is necessary for safety and/or mechanical reasons.

• Other : Hazardous spill clean-up material shall be onsite at all times. This measure is designed to avoid/minimize the introduction of chemical contaminants associated with machinery (fuel, oil, hydraulic fluid, etc.) used in project implementation.

• Other : Prior to starting work each day, all machinery will be inspected for leaks (fuel, oil, hydraulic fluid, etc.) and all necessary repairs will be made before the commencement of work.

• Other : Any safety violations shall be corrected immediately.

• Other : Project leader shall notify the environmental protection specialist prior to any changes in scope for the project.

• Assessment of Effect : The Basis for Design (BFD) document notes that the existing wood window frames will be retained and new glazing will be installed. The Schematic drawings call for new windows. Retention of the existing frames is recommended. The BFD calls for replacing the existing "K" type gutter with a new K gutter. The molded (ogee) shape of a K gutter is not in keeping with the existing angular, utilitarian design of the building. If the internal gutter will not be reintroduced and the existing gutter is to be replaced I recommend a rectangular "H" type gutter.

Comment: These recommendations are from the PWR Historical Architects

Recommendations for Conditions or Stipulations:

None

Olympic National Park Date: 02/03/2021

Categorical Exclusion Documentation Form (CE Form)

Project: Correct HQ Fuel Tank and Auto Shop Deficiencies PEPC Project Number: 95909 Description of Action (Project Description):

The UST fuel tanks in the headquarters maintenance yard are in violation of Clean Water Act per findings of 2014 EPA inspection. There are electrical code violations in the auto shop, the HVAC system does not work properly, emergency lighting is needed, the current lighting is antiquated, restrooms and offices are not accessible, and there are exterior envelope deficiencies.

The proposed action is to replace non-compliant above-ground fuel tanks and fuel dispensing pumps to meet current code compliance. Construct the fueling station under a roof covering. Tie the drain/overspill into new the grease interceptor that was installed in 2017 prior to oil/water separator. Correct all electrical deficiencies not meeting code compliance in the auto shop. Correct all auto shop HVAC, vehicle exhaust, and plumbing deficiencies not meeting code compliance, and correct accessibility deficiencies to meet ABAAS compliance standards. Reorganize various rooms and activity locations in the building to provide a more efficient use of space. Install floor drainage at the bay doors in the auto shop. Replace the main auto shop electrical panel, unit heaters, receptacles, and lighting. Repair and upgrade the building's thermal envelope for improved weather resistance, durability of existing materials, and energy efficiency.

See the attached Basis of Design Report (PDF labeled 228422 OLYM Fuel Tank & Auto Shop_BDR Report) for details on the proposed action.

Project implementation would occur over approximately six months beginning in the spring of 2021.

Project Locations:

Location County: Clallam State: WA

Mitigation(s):

• Any fill material brought in from an off-site location must be from a source that has been certified by Clallam County or the park's Vegetation Branch Chief as being free of noxious weeds.

• All work conducted on historic properties shall follow the Secretary of the Interior's Standards of Historic Properties. Information on the Secretary of the Interior's Standards can be found at https://www.nps.gov/tps/standards/four-treatments.htm and https://www.nps.gov/tps/standards/treatment-guidelines-2017.pdf.

• Care will be taken not to disturb any wildlife species (reptiles, migratory birds, raptors, or bats) found nesting, hibernating, estivating, or otherwise living in, or immediately nearby, worksites.

• To reduce noise and pollution emissions, construction equipment will not idle any longer than is necessary for safety and/or mechanical reasons.

• Hazardous spill clean-up material shall be onsite at all times. This measure is designed to avoid/minimize the introduction of chemical contaminants associated with machinery (fuel, oil, hydraulic fluid, etc.) used in project implementation.

• Prior to starting work each day, all machinery will be inspected for leaks (fuel, oil, hydraulic fluid, etc.) and all necessary repairs will be made before the commencement of work.

• Any safety violations shall be corrected immediately.

• Project leader shall notify the environmental protection specialist prior to any changes in scope for the project.

• The Basis for Design (BFD) document notes that the existing wood window frames will be retained and new glazing will be installed. The Schematic drawings call for new windows. Retention of the existing frames is recommended.

The BFD calls for replacing the existing "K" type gutter with a new K gutter. The molded (ogee) shape of a K gutter is not in keeping with the existing angular, utilitarian design of the building. If the internal gutter will not be reintroduced and the existing gutter is to be replaced I recommend a rectangular "H" type gutter.

Comment: These recommendations are from the PWR Historical Architects

CE Citation: C.19 Construction or rehabilitation in previously disturbed or developed areas, required to meet health or safety regulations, or to meet requirements for making facilities accessible to the handicapped.

CE Justification:

Decision: I find that the action fits within the categorical exclusion above. Therefore, I am categorically excluding the described project from further NEPA analysis. No extraordinary circumstances apply.

Signature

Superintendent: Date:

Sarah Creachbaum

Extraordinary Circumstances:

If implemented, would the proposal... Yes/No Notes A. Have significant impacts on public health or safety? No B. Have significant impacts on such natural resources and unique geographic characteristics as historic or cultural resources; park, recreation, or refuge lands; wilderness areas; wild or scenic rivers; national natural landmarks; sole or principal drinking water aquifers; prime farmlands; wetlands (Executive Order 11990);

floodplains (Executive Order 11988); national monuments; migratory birds; and other ecologically significant or critical areas?

No

C. Have highly controversial environmental effects or involve unresolved conflicts concerning alternative uses of available resources (NEPA section 102(2)(E))?

No

D. Have highly uncertain and potentially significant environmental effects or involve unique or unknown environmental risks?

No

E. Establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects?

No

F. Have a direct relationship to other actions with individually insignificant, but cumulatively significant, environmental effects?

No

G. Have significant impacts on properties listed or eligible for listing on the National Register of Historic Places, as determined by either the bureau or office?

No

H. Have significant impacts on species listed or proposed to be listed on the List of Endangered or Threatened Species, or have significant impacts on designated Critical Habitat for these species?

No

I. Violate a federal, state, local or tribal law or requirement imposed for the protection of the environment? No J. Have a disproportionately high and adverse effect on low income or minority populations (EO 12898)? No K. Limit access to and ceremonial use of Indian sacred sites on federal lands by Indian religious practitioners or adversely affect the physical integrity of such sacred sites (EO 130007)?

No

L. Contribute to the introduction, continued existence, or spread of noxious weeds or non-native invasive species known to occur in the area or actions that may promote the introduction, growth, or expansion of the range of such species (Federal Noxious Weed Control Act and Executive Order 13112)?

No