Attachment_G_Hazards_Materials_Survey-Ozette_Ranger_Station_Report_0001.pdf

WHITE SHIELD, INC. Page i Phone: (888) 882-1142 | info@whiteshieldinc.com

Hazards Materials Survey - Ozette Ranger Station - 05032023

May 10, 2023

National Park Service, Olympic National Park 600 E Park Avenue Port Angeles, WA 98362

Attention: Jeffrey Dorland

Re: Hazardous Materials Survey

Ozette Ranger Station, Clallam Bay, WA 98326

Mr. Doryland, White Shield Inc., per your request, completed a hazardous materials survey on the Ozette Ranger Station.

The structures consisted of two Single-story wood framed Boat house and workshop.

White Shield Environmental Professional and Licensed AHERA Building Inspector and Lead Paint Risk Assessor Kyle Spencer completed the site reconnaissance and sampling on May 3, 2023. Asbestos was confirmed to be present in the Concrete Asbestos Board on the outside of both buildings. Lead-based paint was Not Encountered. Light fixtures with potentially PCB containing ballasts and mercury containing bulbs and switches were observed and should be removed prior to demolition. The following report documents the work completed, provides analytical findings and recommendations.

We appreciate the opportunity to provide environmental services for you on this project.

Best Regards, Kyle A. Spencer Environmental Scientist

AAI Qualified Environmental Professional Licensed AHERA Building Inspector & Risk Assessor

Hazardous Materials Survey Ozette Ranger Station, Clallam Bay, WA 98326 May 10, 2023

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Purpose and Scope

1.2 Hazardous Materials

1.2.1 Asbestos

1.2.2 Lead-based Paint (LBP)

1.2.3 Additional Hazardous Materials / Universal Wastes

2.0 HAZARDOUS MATERIALS SURVEY

2.1 Methodology

2.1.1 Visual Inspection

2.1.2 Asbestos

2.1.3 Lead-based Paint – XRF Testing Protocol

2.1.4 Additional Hazardous Materials

3.0 SURVEY RESULTS

3.1 Asbestos

3.2 Lead-Based Paint

3.3 Additional Hazardous Materials

4.0 CONCLUSIONS

4.1 Asbestos

4.2 Lead-based Paint

4.3 Additional Hazardous Materials

5.0 LIMITATIONS

List of Tables:

Table 1: Positive Asbestos Results Table 2: List of Additional Potential Hazardous Materials

List of Appendices:

Appendix A: Project Figures

• Figure 1 – Project Location Map

• Figure 2 – Sample Location Map

Appendix B: Project Tables

• Asbestos Sample Survey Log

• XRF Results

Appendix C: Project Analytical Results

• Laboratory Report - Bulk Asbestos PLM Analysis

• Chain of Custody

Appendix D: Project Documentation

• Sample Collection Requirements

• EPA / AHERA Certification

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

1.0 INTRODUCTION

On May 3, 2023, White Shield environmental professional Kyle Spencer completed a Hazardous Materials Survey on the Ozette Ranger Station (the Subject Property). The site consisted of two buildings, one boat house and one workshop. The property overall was in fair condition.

1.1 Purpose and Scope

The purpose of this hazardous materials survey (survey) was to assess, sample and analyze suspect hazardous materials including asbestos-containing materials (ACM), suspect lead-based paint (LBP) and complete a visual inspection to identify mercury-containing equipment, fluorescent lights and ballasts, Polychlorinated Biphenyl (PCB) - containing equipment, chlorofluorocarbons (CFCs) - containing equipment as well as any other potentially hazardous materials that may be present in the building which could present an exposure risk during demolition activities.

1.2 Hazardous Materials

1.2.1 Asbestos

Asbestos refers to a group of six types of naturally occurring minerals. Asbestos minerals are made up of fine, durable fibers and are resistant to heat, fire, and many chemicals. These minerals are commonly found in building materials for fireproofing and added durability. Building materials such as vinyl flooring, drywall/ texturing, and wall insulations/ Thermal System Insulation (TSI) among others. Asbestos was ultimately banned in 1989 from general use due to its lung cancer-causing side-effects and lung related diseases such as asbestoses when it becomes air-born. This ban on use has not prevented new building materials imported from other countries from containing asbestos. It remains a potential hazard even in new construction.

The ACM most likely to release asbestos fibers are those which are in a friable state. Friability describes the condition of asbestos. The definition of friable is any material, when dry, that is capable of being crumbled, pulverized, or reduced to powder by hand pressure (40 CFR 763).

Non-friable sources of asbestos are materials containing a cement or asphalt binder which may become friable and release fibers if the sources are exposed to actions such as abrasion, drilling, cutting, fracturing, or hammering. Non-friable sources of asbestos do not typically pose a significant exposure risk if they remain in good condition and are not disturbed. During renovation or demolition activities, non-friable sources may become friable and thus may pose an exposure risk.

The PLM method is the most commonly used method to analyze building materials for the presence of asbestos. This method utilizes the optical properties of minerals to identify the selected constituent. The use of this method enables identification of the type and the percentage of asbestos in a given sample.

The detection limit of the PLM method for asbestos identification is typically one percent (1%) asbestos.

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

1.2.2 Lead-based Paint (LBP)

Lead was used as an additive in paint until 1978 when it was banned for use in homes and schools because it caused lead-poisoning and other diseases when there was exposure to the paint and paint dust.

Although production was banned in 1978, existing stocks of paint could still be used up. As a result, lead-based paint may be present in many structures. A lead-based paint inspection is a surface-by-surface investigation to determine the presence of lead-based paint and provide a report explaining the results of the investigation.

In general, there are many other building materials which can contain lead in the average building.

Therefore, when conducting construction or demolition activities which disturb lead in any amount or create the potential for exposure to workers, the employer is required to provide worker protection and conduct exposure assessments. Employers should consult Federal Occupational Safety and Health Administration (OSHA) Regulations at 29 CFR 1926.62, “Lead in Construction” standards for complete requirements prior to construction or demolition activities.

Notification must be given to all other contractors at the work site prior to the start of activities that may create a lead hazard. Characterization and disposal of lead-containing waste materials (LCWMs) must comply with federal, state, and local authorities.

Contractors must maintain current licenses as required by applicable state or local jurisdictions for the removal, transport, disposal of LCWMs, or other regulated lead-based paint activities.

1.2.3 Additional Hazardous Materials / Universal Wastes

Mercury-containing Equipment

The Environmental Protection Agency (EPA) regulates the management of hazardous waste through the Resource Conservation and Recovery Act (RCRA) Subtitle C (40 CFR Part 260 through 270). The RCRA hazardous waste program regulates commercial businesses and government facilities that generate, transport, treat, store, or dispose of hazardous waste. Mercury-containing equipment, fluorescent lights are considered hazardous waste when disposed of by commercial businesses and government facilities and are regulated under RCRA.

Polychlorinated Biphenyl (PCB)-containing Equipment

Historically PCBs were used in electrical equipment and various types of oils. The production and use of PCBs was banned in 1978, however the equipment was not required to be replaced and may remain present in some equipment. Commercial disposal of PCB-containing material such as fluorescent light ballasts, PCB-containing hydraulic oils, and PCB-containing electrical transformer and capacitor oils are regulated under the Toxic Substances Control Act (TSCA) (40 CFR Parts 700 through 799).

Chlorofluorocarbons (CFCs)-containing Equipment

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

CFCs were and are still used as a refrigerant in heating and cooling systems and as propellants in aerosol containers. In 1978, the use of CFCs such as Freon in aerosol cans was banned. However, it is still used in heating and cooling systems and as refrigerants. The manufacture, use, and disposal of refrigerants and other CFC- containing materials is regulated under the Clean Air Act regulations (40 CFR Part 82.1 through Part 82.306).

Tritium-containing Signage

Radioactive sources such as tritium-containing signage cannot be disposed of as normal trash. They are regulated by the Untied State Nuclear Regulatory Commission under 10 CFR Part 31.5.

A visual survey was conducted to evaluate the following hazardous materials in terms of presence, number, and configuration. An inventory was compiled for the various materials encountered.

• Mercury light ballasts, fluorescent lights, mercury light switches, and thermostat bulbs.

• Radioactive sources such as tritium-containing signage.

• PCB-containing equipment including elevator hoists, switching equipment and panels, electrical transformers, hydraulic lifts.

• CFC-containing equipment such as HVAC pumps and compressors.

Paints, Solvents & Cleaning Materials

Commercial facilities commonly have various paints and solvents along with cleaning materials used in the operation and maintenance of the facility. These materials can pose a potential threat if not stored and maintained correctly.

2.0 HAZARDOUS MATERIALS SURVEY

2.1 Methodology

Sampling or sample collection is the process of selecting representative samples from the materials / media being surveyed. This is done through observation and select sample collection by properly trained and certified environmental professionals.

2.1.1 Visual Inspection

White Shield environmental professionals completed an inspection of accessible areas of the Subject Property for the presence of hazardous materials. The purpose of this assessment is for Renovation.

Regardless of the thoroughness of a survey, the possibility exists that some areas containing hazardous materials such as ACM and/or LBP may be present but inaccessible.

2.1.2 Asbestos

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

Suspect asbestos-containing materials observed at the time of the inspection were sampled and analyzed for asbestos content. Suspect ACMs were sampled according to the guidelines set forth in 40 CFR Part 763, and later analyzed using the Polarized Light Microscopy (PLM) method in accordance with the United States Environmental Protection Agency (EPA) Method for Determination of Asbestos in Bulk Building Materials (EPA 600/R-93/116).

The regulations (40 CFR 763), require that a minimum number of representative samples be collected from each homogeneous area. If asbestos is identified in any of the samples from a homogeneous area, the entire homogeneous area is considered to contain asbestos. Homogeneous areas, as defined by 40 CFR 763 are “an area of surfacing material, thermal system insulation material, or miscellaneous material that is uniform in color and texture.”

The aforementioned testing and analytical constraints can affect the findings and recommendations of this survey. Specifically, no assurance is given regarding the asbestos content of the samples beyond these parameters. Further investigation is not recommended unless the client can determine it is cost-effective to do so.

The survey also established whether any of the substrates sampled could be considered friable and/or significantly damaged and capable of immediate worker exposure.

2.1.3 Lead-based Paint – XRF Testing Protocol

During the course of the property visit, Kyle Spencer performed a review of accessible areas of the buildings on the Subject Property for the presence of suspect LBP. The purpose of this assessment is for renovation. The painted/finished surfaces containing suspect LBP were analyzed and the data was recorded using an x-ray fluorescence instrument (XRF).

The XRF uses a Cadmium 109 (Cd) isotope radioactive source to ‘excite’ the atomic structure of painted surfaces. Once lead (Pb) atoms are “excited”, they emit unique x-ray fluorescence radiation energy. The radiation detector within the XRF then translates these x-rays into a quantitative measure of lead concentration. If present, the XRF will determine the amount of lead in paint with a 95% confidence level.

The lead concentrations are reported in milligrams per square centimeter (mg/cm2). XRF analysis yields the total lead content of a painted surface, thereby not distinguishing between individual concentrations of painted layers. The XRF was calibrated with a National Institute of Standards and Testing (NIST) calibration surface prior to and post analysis of painted surfaces.

Measurements were taken at locations representative of all painted or varnished surfaces for each different testing combination in the areas inspected. In order to obtain a reading, the XRF analyzer is placed with the face of the instrument flush against the surface to be tested. It is then held in place for the duration of the sample, approximately 4 to 16 source seconds, or until the measurement has reached the acceptable range of accuracy. The sampling time is dependent on the age of the radioactive source inside the XRF.

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

The building’s orientation was described using the United States Department of Housing and Urban Development’s (HUD’s) recommended guidelines, assigning the letters A, B, C and D to each side of a structure. Side A corresponds to the main entrance of each building. The remaining side identifications are assigned in a clockwise manner. Each tested component location is identified using the building’s assigned letter as a reference point.

The HUD Guidelines for lead-containing paint require a lead hazard abatement activity in cases where lead content is above one half of one percent (0.5%) by weight or equal to or in excess of one milligram per square centimeter (1.0 mg/cm2). This requirement for lead hazard abatement only applies to housing that is administrated or funded by HUD.

Section 1017 of the HUD Guidelines, Residential LBP Reduction Act of 1992, otherwise known as “Title X”, defines a lead-based paint hazard as:

“…any condition that causes exposure to lead that would result in adverse human health effects resulting from lead-contaminated dust, bare lead-contaminated soil, and/or lead-contaminated paint that is deteriorated or present on accessible, friction, or impact surfaces.”

Therefore, under Title X, intact LBP on most walls and ceilings would not be considered a “hazard” However, the paint should be maintained, and its condition monitored to ensure that it does not deteriorate and become a hazard.

2.1.4 Additional Hazardous Materials

A visual inspection was conducted to review and identify current and/or past evidence of hydraulic lifts, mercury-containing equipment, fluorescent lights and ballasts, PCB- and CFC-containing equipment, and any other regulated materials that may be present in the building. Further confirmation involving disassembly and/or testing may be required to confirm the existence of hazardous materials.

3.0 SURVEY RESULTS

3.1 Asbestos

A total of sixteen (16) bulk samples of presumed ACM were collected for analysis. The samples were assigned individual sample numbers, sealed in plastic bags, and transported/shipped under proper chain-of-custody documentation to EMSL Analytical, Inc in Seattle, WA for analysis. EMSL is an American Industrial Hygiene Association (AIHA)-accredited laboratory that participates in the National Volunteer Laboratory Accreditation Program (NVLAP) quality assurance/quality control program.

Five of the suspect ACM samples collected from the buildings contained asbestos greater than 1%.

Refer to Appendix A for analytical data.

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

Table 1: Positive Asbestos Results

Sample

ID

Estimated Quantities Laboratory Layer Description

PLM Analytical Results Discrete

Condition / Friable

Photograph

Ozette Ranger Station, Clallam Bay, WA 98326

S4-CB

400 SqFt

Boat House – Concrete Board 30% Chrysotile Fair/No

S5-CB Boat House – Concrete Board 30% Chrysotile Fair/No

S6-CB Boat House – Concrete Board 30% Chrysotile Fair/No

S1-CB

S3-CB

Documentation of the laboratory results should be retained as a reference for future renovation/ demolition activities.

3.2 Lead-Based Paint

A representative number of interior and exterior painted surfaces/components were tested for LBP on the building(s) at the Subject Property.

A total of 49 XRF readings (including 6 calibration readings) were collected throughout the building at the Subject Property. None of the 43 actual readings contained lead at levels greater than 1.0 milligrams per cementer squared (mg/cm). Please see Appendix B, XRF Results for Lead-Based Paint Inspection Results.

Documentation of the results should be retained as a reference for future renovation/ demolition activities.

3.3 Additional Hazardous Materials

The following hazardous materials were observed at the site:

Table 2: List of Additional Potential Hazardous Materials

Location Type of Material Quantity Container

Interior Fluorescent Light Bulbs & Ballast ~24 Bulbs 12 Fixtures Light Fixture

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS

4.0 CONCLUSIONS

4.1 Asbestos

Asbestos was confirmed to be present in the Concrete asbestos board on the exterior of both structures Ozette Ranger Station, Clallam Bay, WA 98326. Asbestos containing building materials should be removed prior to demolition by a licensed Asbestos abatement contractor.

During demolition and/or renovation activities, the potential exists for additional suspect ACM to be exposed. Such materials should be sampled and analyzed for asbestos content prior to any renovation and/or demolition activities that could impact these materials.

4.2 Lead-based Paint

No LBP was identified in the interior or exterior of the buildings.

4.3 Additional Hazardous Materials

The visually identified hazardous materials should be confirmed where necessary, and properly removed and segregated prior to renovation/demolition activities. Proper packaging and disposal should be conducted in compliance with federal, state, and local regulations. Certain restrictions regarding packaging methods (lab packs), transportation (hazmat certification & manifesting) and disposal (landfill regulations) of hazardous materials could apply.

It is possible that other / additional hazardous materials are present within the buildings at locations out of sight and not readily accessible. As with all demolition / remodeling projects, caution should be taken, and the work area inspected prior to any invasive work.

5.0 LIMITATIONS

White Shield subcontracted with EMSL Laboratories to perform the asbestos analysis. No warranties expressed or implied, are made by White Shield or its subcontractor EMSL Laboratories, or their employees as to the use of any information, apparatus, product or process disclosed in this report. Every reasonable effort has been made to assure correctness. If an asbestos contractor or other demolition/construction contractor is employed, such contractor should bring any discrepancies found in this report as it relates to current site conditions or newly discovered site conditions to the immediate attention of White Shield.

This report should not be used solely for asbestos abatement bidding purposes. Any quantities of ACM listed are estimates only and not meant to be used to solicit abatement quotations. These quantities should be confirmed by abatement contractors prior to submitting bids for abatement.

State-of-the-art practices have been employed to perform this hazardous materials survey. The scope of this evaluation was limited to areas that were considered reasonably accessible (i.e., less than 15 feet from the floor), or within range of a visual inspection through reasonable means. No demolition or product

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Hazards Materials Survey - Ozette Ranger Station – 05032023 SMS research was performed in attempts to reveal material compositions. The services consist of professional opinions and recommendations made in accordance with generally accepted engineering principles/practices. These services are designed to provide an analytical tool to assist the client. White Shield and its subcontractor EMSL and their employees/representatives bear no responsibility for the actual condition of the structure or safety of this site pertaining to asbestos and/or lead contamination regardless of the actions taken by the survey team or the

Appendix A: Project Figures Figure 1 – Project Location Map Figure 2 – Sample Location Map

Figure 3 – Site Photographs

Appendix B: Project Tables Asbestos Sample Survey Log

XRF Results Log

Appendix C: Project Analytical Results Laboratory Report - Bulk Asbestos PLM Analysis

Chain of Custody

Appendix D: Project Documentation Sample Collection Requirements

EPA / AHERA Certification

List of Appendices

Li st o f

A p p e n d ic e s

Appendix A

Appendix A: Project Figures

Figure 1 – Project Location Map

Figure 2 – Sample Location Map Figure 3 – Site Photographs A p p e n d ix

A P ro je ct F ig u re s

Figure No.:

Date:

Completed By:

Reviewed By.:

Version:

Project No.:

N

May 4th, 2023

K. Spencer

S. Spencer

WSI-001

0506-31-02 Sheet 01 of 04

Not To ScaleNot To Scale

Site Loca�on Oze�e Ranger Sta�on, Clallam Bay, WA 98326

Sample Loca�ons Hazards Materials Survey

Oze�e Ranger Sta�on, Clallam Bay, WA 98326

Explanation Sample Location <1%

Sample Location >1%

Room Numbers

Figure No.:

Date:

Completed By:

Reviewed By.:

Version:

Project No.:

May 4th, 2023

K. Spencer

S. Spencer

WSI-001

0506-31-02 Sheet 02 of 04

Sample Loca�ons Hazards Materials Survey

Oze�e Ranger Sta�on, Clallam Bay, WA 98326

Sample Location >0% <1%

S1-RF

S2-RF

S4-CB

S5-CB

S6-CB

S7-I

S8-I

S9-I

S3-RF

S1-CBS2-CB

S3-CB

S4-I S5-I

S6-FP

Date:

Completed By:

Reviewed By.:

Version:

Project No.:

May 4th, 2023

K. Spencer

S. Spencer

WSI-001

0506-31-02 Sheet 03 of 04

Sample Loca�ons Hazards Materials Survey

Oze�e Ranger Sta�on, Clallam Bay, WA 98326

Photograph One: Exterior Boat House

Photograph Three: Exterior Boat House

Photograph Five: Boat House Attic

Photograph Two: Exterior Boat House

Photograph Four: Boat House

Photograph Six: Interior Boat house storage

Date:

Completed By:

Reviewed By.:

Version:

Project No.:

May 4th, 2023

K. Spencer

S. Spencer

WSI-001

0506-31-02 Sheet 04 of 04

Sample Loca�ons Hazards Materials Survey

Oze�e Ranger Sta�on, Clallam Bay, WA 98326

Photograph Seven: Exterior Shop

Photograph Nine: Interior Shop

Photograph Eleven: Gas and Mower Shed

Photograph Eight: Exterior Shop

Photograph Ten: Interior Shop

Appendix B: Project Tables

Asbestos Sample Survey Log XRF Results Log

A p p e n d ix B

P ro je ct

T ab le sAppendix B

Project:

Project Information:

Client: AHERA Inspector:

Contact: Certification No.:

Phone: Date: May 3rd 2023

Site Address: Ozette Ranger Station, Clallam Bay, WA 98326 ECI Project No 0506-31-02

Sample ID Location / Description PLM Analytical Results Discrete Friable Condition Photograph

S1-RF Boat House - Felt Paper None Detected Yes Fair NA

S2-RF Boat House - Felt Paper None Detected Yes Fair NA

S3-RF Boat House - Felt Paper None Detected Yes Fair NA

S4-CB Boat House - Concrete Board 30% Chrysotile No Fair NA

S5-CB Boat House - Concrete Board 30% Chrysotile No Fair NA

S6-CB Boat House - Concrete Board 30% Chrysotile No Fair NA

S7-I Boat House - Insulation None Detected Yes Fair NA

158623

Lake Ozette

Kyle Spencer

Table 1: Asbestos Survey Log

Ozette Ranger Station, Clallam Bay, WA 98326

*ACM= Asbestos Containing Material, L = LayerND = None detected Page 1 of 2

Project:

Project Information:

Client: AHERA Inspector:

Contact: Certification No.:

Phone: Date: May 3rd 2023

Site Address: Ozette Ranger Station, Clallam Bay, WA 98326 ECI Project No 0506-31-02

Sample ID Location / Description PLM Analytical Results Discrete Friable Condition Photograph

158623

Lake Ozette

Kyle Spencer

Table 1: Asbestos Survey Log

Ozette Ranger Station, Clallam Bay, WA 98326

S8-I Boat House - Insulation None Detected Yes Fair NA

S9-I Boat House - Insulation None Detected Yes Fair NA

S1-CB Shop - Concrete Board 30% Chrysotile No Fair NA

S2-CB Shop - Concrete Board None Detected No Fair NA

S3-CB Shop - Concrete Board 30% Chrysotile No Fair NA

S4-I-Insulation Shop - Insulation None Detected Yes Fair NA

S4-I-Paper Shop - Insulation None Detected Yes Fair NA

S5-I Shop - Insulation None Detected Yes Fair NA

S6-FP Shop - Insulation None Detected Yes Fair NA

RED: Sample Reported Exceedin 1% Asbestos, Blue: Sample Reported Greater Than Detection, Less than 1% Asbeston

*ACM= Asbestos Containing Material, L = LayerND = None detected Page 2 of 2

Index Type Units Sequence Component Substrate Side Condition Color Building Floor Room Results PbC PbC Error PbL PbL Error PbK PbK Error Depth

Index

1 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration 2.38 0 0.38 0 0 0

2 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration Positive 1 0.1 1 0.1 < LOD 0.59 1.11

3 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration Positive 1 0.1 1 0.1 < LOD 0.6 1.11

4 Paint mg / cm ^2 Final WALL WOOD A FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.32 1

5 Paint mg / cm ^2 Final WINDOW WOOD A FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 2.97 1

6 Paint mg / cm ^2 Final DOOR WOOD A FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 5.79 1

7 Paint mg / cm ^2 Final DOOR WOOD B FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.54 1

8 Paint mg / cm ^2 Final WALL WOOD B FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.56 1

9 Paint mg / cm ^2 Final WALL WOOD C FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.37 1

10 Paint mg / cm ^2 Final WINDOW WOOD C FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.1 1

11 Paint mg / cm ^2 Final WALL WOOD D FAIR GREEN Boat House FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.49 1

12 Paint mg / cm ^2 Final WALL WOOD A FAIR GREEN Boat House FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.26 1

13 Paint mg / cm ^2 Final WALL WOOD B FAIR GREEN Boat House FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.16 1

14 Paint mg / cm ^2 Final WALL WOOD A FAIR WHITE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.57 1

15 Paint mg / cm ^2 Final WINDOW WOOD A FAIR WHITE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.63 1

16 Paint mg / cm ^2 Final WALL WOOD C FAIR WHITE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.46 1

17 Paint mg / cm ^2 Final CEILING WOOD C FAIR WHITE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 2.84 1

18 Paint mg / cm ^2 Final FLOOR WOOD C FAIR BLUE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.48 1

19 Paint mg / cm ^2 Final ROOF WOOD C FAIR BLUE Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 4.65 1

20 Paint mg / cm ^2 Final GUTTER WOOD C FAIR BLUE Boat House FIRST 2 Negative < LOD 0.04 < LOD 0.04 < LOD 4.81 1

21 Paint mg / cm ^2 Final SOFFITE WOOD C FAIR GREEN Boat House FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.53 1

22 Paint mg / cm ^2 Final SOFFITE WOOD D FAIR GREEN Shop FIRST 2 Negative < LOD 0.08 < LOD 0.08 < LOD 3.25 2.26

23 Paint mg / cm ^2 Final WALL WOOD D FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.6 1

24 Paint mg / cm ^2 Final DOOR WOOD D FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.39 1

25 Paint mg / cm ^2 Final GUTTER WOOD A FAIR GREEN Shop FIRST Exterior Negative < LOD 1.86 < LOD 0.12 < LOD 1.86 3.6

26 Paint mg / cm ^2 Final ROOF WOOD A FAIR GREEN Shop FIRST Exterior Negative < LOD 1.66 < LOD 0.06 < LOD 1.66 2.36

27 Paint mg / cm ^2 Final WALL WOOD A FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.38 1

28 Paint mg / cm ^2 Final WALL WOOD B FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.48 1

29 Paint mg / cm ^2 Final WINDOW WOOD B FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 3.7 1

30 Paint mg / cm ^2 Final DOOR WOOD B FAIR GREEN Shop FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 4.66 1

31 Paint mg / cm ^2 Final WALL WOOD C FAIR GREEN Shop FIRST Exterior Negative < LOD 0.04 < LOD 0.04 < LOD 3.42 1.07

32 Paint mg / cm ^2 Final WALL WOOD A FAIR WHITE Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.21 1

33 Paint mg / cm ^2 Final WALL WOOD D FAIR WHITE Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.42 1

34 Paint mg / cm ^2 Final WALL WOOD B FAIR WHITE Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.42 1

35 Paint mg / cm ^2 Final WALL WOOD C FAIR WHITE Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.3 1

36 Paint mg / cm ^2 Final DOOR WOOD B FAIR WHITE Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 4.41 1

37 Paint mg / cm ^2 Final FLOOR WOOD B FAIR BROWN Shop FIRST 1 Negative < LOD 0.03 < LOD 0.03 < LOD 3.43 1

38 Paint mg / cm ^2 Final FLOOR WOOD B FAIR BLUE Shop FIRST 1 Null < LOD 0.06 < LOD 0.06 < LOD 7.15 1

39 Paint mg / cm ^2 Final FLOOR WOOD B FAIR BLUE Shop FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.45 1

40 Paint mg / cm ^2 Final WALL WOOD A FAIR WHITE Shop FIRST 2 Negative < LOD 0.06 < LOD 0.06 < LOD 2.86 1.53

41 Paint mg / cm ^2 Final WALL WOOD B FAIR WHITE Shop FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.07 1

42 Paint mg / cm ^2 Final WINDOW WOOD B FAIR WHITE Shop FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.12 1

43 Paint mg / cm ^2 Final WINDOW WOOD C FAIR WHITE Shop FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.64 1

44 Paint mg / cm ^2 Final CEILING WOOD C FAIR WHITE Shop FIRST 2 Negative < LOD 0.03 < LOD 0.03 < LOD 3.42 1

45 Paint mg / cm ^2 Final FUEL SHED WOOD FAIR GREEN Fuel Shed FIRST Exterior Negative < LOD 0.09 < LOD 0.09 < LOD 2.96 2.08

46 Paint mg / cm ^2 Final MOWER SHED WOOD FAIR GREEN Mower Shed FIRST Exterior Negative < LOD 0.03 < LOD 0.03 < LOD 2.87 1

47 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration Positive 1.1 0.1 1.1 0.1 < LOD 1.49 1.11

48 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration Positive 1.1 0.1 1.1 0.1 1.2 0.6 1.03

49 Paint mg / cm ^2 Final Calibration Calibration Calibration Calibration Calibration Calibration Calibration Calibration Positive 1.1 0.1 1.1 0.1 1 0.6 1.15

Ozette Ranger Station, Clallam Bay, WA 98326

Calibration

Calibration

Table 2: XRF Analysis Results Ozette Ranger Station, Clallam Bay, WA 98326

May 3rd 2023

Inspected by: Kyle A.

Spencer - Certified Lead

Explanation Red Highlight - Lead Based Paint Blue Highlight - Lead Cantaing Paint Gray Highlight - Reading was Interupted

Appendix C: Project Analytical Results Laboratory Report - Bulk Asbestos PLM Analysis

Chain of Custody

A p p e n d ix C

P ro je ct

A n al yt ic al

R es u lt sAppendix C

EMSL Analytical, Inc.

5009 Pacific Highway East, Unit 19 Fife, WA 98424

Tel/Fax: (253) 319-5658 / http://www.emsl.com / tacomalab@EMSL.com

742300169EMSL Order:

Customer ID: ECIE42

Customer PO:

Project ID:

Attention: Phone:Kyle Spencer (253) 921-7059

Fax:ECI Environmental

Received Date:PO Box 153 04/28/2023 12:00 PM

Analysis Date:Fox Island, WA 98333 05/02/2023

Collected Date:

Project: Ozette Shop and Boat

Test Report: Asbestos Analysis of Bulk Materials via AHERA Method 40CFR 763 Subpart E

Appendix E supplemented with EPA 600/R-93/116 using Polarized Light Microscopy

Sample Description Appearance % Fibrous % Non-Fibrous

Non-Asbestos Asbestos

% Type

S1-RF

742300169-0001

None DetectedNon-fibrous (Other)5%Cellulose95%Black

Fibrous

Homogeneous

Boat House - Felt

Paper

S2-RF

742300169-0002

None DetectedNon-fibrous (Other)5%Cellulose95%Black

Fibrous

Homogeneous

Boat House - Felt

Paper

S3-RF

742300169-0003

None DetectedNon-fibrous (Other)5%Cellulose95%Black

Fibrous

Homogeneous

Boat House - Felt

Paper

S4-CB

742300169-0004

30% ChrysotileNon-fibrous (Other)70%Gray/White

Fibrous

Homogeneous

Boat House - Cove

Base

S5-CB

742300169-0005

30% ChrysotileNon-fibrous (Other)70%Gray/White

Fibrous

Homogeneous

Boat House - Cove

Base

S6-CB

742300169-0006

30% ChrysotileNon-fibrous (Other)70%Gray/White

Fibrous

Homogeneous

Boat House - Cove

Base

S7-I

742300169-0007

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Boat House -

Insulation

S8-I

742300169-0008

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Boat House -

Insulation

S9-I

742300169-0009

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Boat House -

Insulation

S1-CB

742300169-0010

30% ChrysotileNon-fibrous (Other)70%Gray/White

Fibrous

Homogeneous

Shop - Concrete

Board

S2-CB

742300169-0011

None DetectedQuartz

Non-fibrous (Other)

10%

70%

Cellulose20%Brown/Gray

Fibrous

Homogeneous

Shop - Concrete

Board

S3-CB

742300169-0012

30% ChrysotileNon-fibrous (Other)70%Gray/White

Fibrous

Homogeneous

Shop - Concrete

Board

S4-I-Insulation

742300169-0013

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Shop - Insulation

S4-I-Paper

742300169-0013A

None DetectedNon-fibrous (Other)5%Cellulose95%Brown/Black

Fibrous

Homogeneous

Shop - Insulation

S5-I

742300169-0014

None DetectedNon-fibrous (Other)5%Glass95%Yellow

Fibrous

Homogeneous

Shop - Insulation

S6-FP

742300169-0015

None DetectedNon-fibrous (Other)5%Cellulose95%Black

Fibrous

Homogeneous

Shop - Insulation

Initial report from: 05/02/2023 18:44:44

Page 1 of 2ASB_PLM_0008_0001 - 1.78 Printed: 5/2/2023 3:44 PM

EMSL Analytical, Inc.

5009 Pacific Highway East, Unit 19 Fife, WA 98424

Tel/Fax: (253) 319-5658 / http://www.emsl.com / tacomalab@EMSL.com

742300169EMSL Order:

Customer ID: ECIE42

Customer PO:

Project ID:

Analyst(s)

Claire Byers (16)

EMSL maintains liability limited to cost of analysis . Interpretation and use of test results are the responsibility of the client. This report relates only to the samples reported above, and may not be reproduced, except in full, without written approval by EMSL. EMSL bears no responsibility for sample collection activities or analytical method limitations . The report reflects the samples as received.

Results are generated from the field sampling data (sampling volumes and areas, locations, etc.) provided by the client on the Chain of Custody. Samples are within quality control criteria and met method specifications unless otherwise noted. The above analyses were performed in general compliance with Appendix E to Subpart E of 40 CFR (previously EPA 600/M4-82-020 “Interim Method”) but augmented with procedures outlined in the 1993 (”final”) version of the method. This report must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST or any agency of the federal government. Non- friable organically bound materials present a problem matrix and therefore EMSL recommends gravimetric reduction prior to analysis . Unless requested by the client, building materials manufactured with multiple layers (i.e. linoleum, wallboard, etc.) are reported as a single sample. Estimation of uncertainty is available on request.

Samples analyzed by EMSL Analytical, Inc. Fife, WA NVLAP Lab Code 600324-0, WA C1075

Initial report from: 05/02/2023 18:44:44

Page 2 of 2ASB_PLM_0008_0001 - 1.78 Printed: 5/2/2023 3:44 PM

OrderID: 742300169

Appendix D: Project Documentation Sample Collection Requirements

EPA / AHERA Certification

Appendix D

A p p e n d ix D

P ro je ct

D o cu m en ta ti o n