2_SOW_GFO_DM_disposal_haz_mat_abatement.pdf

STATEMENT OF WORK

BLM Glennallen Field Office Demolition and Hazard Abatement Project

A. Introduction: This project is to abate asbestos and other hazards, and demolition and deconstruction of the Bureau of Land Management’s (BLM) Old District Manager’s House at Glennallen Field Office (GFO). Contractor shall provide all labor, materials, equipment, and all necessary permits and fees and licenses to successfully accomplish the project. The work is to be conducted following the process and requirements of the Asbestos Hazard Emergency Response Act (AHERA) as codified in 29 CFR, 40 CFR, and applicable State of Alaska regulations.

A.1. Project Location: Glennallen Field Office, Glennallen, Alaska

A.2. Property description:

The Old DM House, BLM Property Number L4686, is a log structure with stud walls and other wood structural elements, for a total size of approximately 1,600 square feet.

The 2011 asbestos survey is Attachment 1.

In 2023, BLM contracted for a pre-disposal hazard materials assessment of the facility, that report is Attachment 2.

Non-redacted documents shall be provided to the awardee upon request.

B. Contract Tasks:

B1. General Requirements

1. Work on site is limited to 7:00am to 6:00pm, Monday through Friday. No work is permitted on weekend or federal holidays without prior written approval from the BLM on-site representative.

2. All wastes and debris must be properly recycled or disposed off-site at an appropriately permitted facilities.

3. Contractor shall obtain all necessary permits/make all necessary filings to accomplish this project.

4. Execution of this project shall comply with National Environmental Policy Act (NEPA) policy by preventing and controlling invasive non-native plant and noxious weed introduction or spreading per Executive Order 13112. The contractor shall observe the standard practice of decontaminating all equipment and personnel before mobilization to, and before demobilization from the site. The contractor shall thoroughly clean all vehicles, transport equipment used in access and construction, and Personal Protective Equipment (PPE) used by the on-site crew prior to moving equipment across or onto BLM managed lands to ensure it is weed and weed seed free. The contractor’s cleaning shall include high pressure washing where practical to treat the insides of bumpers, wheel wells, undercarriages, inside belly plates, excavating blades, buckets, tracks, rollers, drills, buckets, shovels, any digging tools, and any other equipment to remove potential weeds and weed seed carrying soil, greasy dirt, and vegetative material.

Execution of this project shall comply with NEPA policy by preventing and controlling invasive non-native plant and noxious weed introduction or spreading per Executive Order 13112.

5. Perform Hazardous Material removal and encapsulation work in the project work areas without damage or contamination of adjacent work. The Hazardous Materials contractor shall secure necessary permits

BLM Alaska - Solicitation #140L6324Q0014 and shall provide timely notification of such actions as may be required by federal, state, and local authorities.

6. Utilities are available as is where is.

7. A review and comment period by BLM shall occur for each deliverable listed in section C below.

8. The contractor shall comply with the requirements in the BLM Environmental Assessment:

Environmental Assessment DOI-BLM-AK-A020-2022-0002-EA. The contractor shall acquire the services of a professional bat removal company to determine the presence of bats, and mold and guano associated with bats, and removal of bats and mold and guano because of the bat habitat in the structure.

Bats shall not be harmed but removed and located to an acceptable area as authorized by the GFO wildlife biologist or GFO manager.

B2. Demolition

• Demolition shall not commence until the presence of bats has been determined, and the bats have been removed and their mold and guano removed.

• Clearly delineate the work zone with fencing.

• BLM has identified 3 logs to salvaged and provide to BLM at the site.

• Protect adjacent trees from damage with fencing.

• Terminate and cap all utilities at building footprint before demolition.

• Coordinate with local staff on utility disconnects.

• Comply with all EPA notification requirements and copy BLM on all such correspondence.

• Remove any foundations.

• Grade site and level.

• Storage and sale of items on site is not permitted.

• Burning of debris on site is not permitted.

• Remove and properly dispose all interior finishes, utilities, and structure.

• All demolition waste becomes the property of the contractor.

• If historic items are found, provide to BLM.

• The BLM administrative compound will be operational during this project.

C. Administrative :

C1. Pre-Bid Site Conference: The contractor shall arrange for a time to visit the site, if desired.

C2. Invoicing: In addition to required electronic invoicing using the DOI’s Internet Payment Platform (IPP), vendor shall simultaneously provide a brief written progress report describing work accomplished and billing during the period covered by the corresponding IPP invoice. The progress statement shall be delivered to the BLM Contracting Officer and Contracting Officers Representative via email or in hardcopy on the same day the IPP invoice is submitted.

C3. Draft work plan: Internal review of all draft work plans with allowance for at least 10 workdays for BLM to review and make comment. Work plans shall include a Health and Safety Plan and disposal report. This document shall be in MS Word; BLM comment will be made using “Track Changes” function.

C4. Final work plans with all necessary permits: At least 20 workdays prior to start of field work (3 hardcopies and 1 in PDF format).

C5. Draft summary reports: Internal review of all summary reports with allowance for at least 10 workdays for BLM to review and make comment. This document shall be in MS Word; BLM comment will be made using “Track Changes” function.

C6. Final report: Delivered to BLM within 120 days of completing demolition (pdf format).

END OF SECTION

ASBESTOS-CONTAINING MATERIAL (ACM) SURVEY AND

ABATEMENT COST ESTIMATE

L4686 – Glennallen Log Bunkhouse - Old DM House

62.10976 / -145.5463

Glennallen Field Office, Alaska

Report Date September 18, 2011 Site Survey Date June 28, 2011

ACM Identified in Building?* Yes ACM Abatement Cost Estimate* *Subject to the assumptions and limitations as described in the following report.

Submitted by:

Aarcher, Inc.

910 Commerce Road Annapolis, Maryland 21401

Program Manager:

Submitted to:

U.S. Department of the Interior Bureau of Land Management (BLM) Building 50, Denver Federal Center Denver, Colorado 80225-0047 Attn: Redacted vendor details

Redacted vendor details

Redacted

RedactedRedacted

Redacted

BLM Alaska - Solicitation #140L6324Q0014

ATTACHMENT 1

Tetra Tech

3801 Automation Way, Suite 100, Fort Collins, Colorado 80526 www.tetratech.com

September 18, 2011

Aarcher, Inc.

Vice President 910 Commerce Road Annapolis, Maryland 21401

RE: Asbestos-Containing Materials Survey and Asbestos Abatement Cost Estimates L4686 – Glennallen Log Bunkhouse - Old DM House Glennallen Field Office, Alaska Tetra Tech Project Number 114-182187, Task 100

Dear :

Tetra Tech is pleased to submit the attached Asbestos-Containing Materials Survey and Asbestos Abatement Cost Estimates report for the above-referenced site. This report includes the scope of work, procedures and methodologies, tables, figures, analytical laboratory results, and abatement cost estimate for each asbestos-containing material identified during this survey.

Tetra Tech appreciates the opportunity to perform these services for Aarcher, Inc. (AARCHER) and we look forward to working with you in the future.

Sincerely, Tetra Tech

Ryan Egan Mark Daley AHERA Building Inspector AHERA Building Inspector Management Planner Management Planner Project Designer/Supervisor

Daniel Lawrence AHERA Building Inspector

Redacted vendor details

Redacted vendor details

Redacted

Redacted

Redacted

Redacted

Redacted

L4686 – Glennallen Log Bunkhouse - Old DM House Glennallen Field Office, Alaska i

TABLE OF CONTENTS

1.0 PURPOSE AND SCOPE OF SERVICES

2.0 GENERAL SITE CONDITIONS

3.0 REGULATORY STANDARDS

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES

4.1 Homogeneous Materials

4.2 Hazard Assessment Factors

4.3 Sampling Strategy

4.4 Suspect Asbestos-Containing Material

4.5 Laboratory Analytical Results

5.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES SUMMARY TABLE

6.0 CONCLUSIONS

7.0 ASSUMPTIONS AND LIMITATIONS

LIST OF APPENDICES

Appendix A: ACM Laboratory Analytical Results Appendix B: Site Drawing Appendix C: Inspector and Laboratory Accreditations Appendix D: ACM Photographs

1.0 PURPOSE AND SCOPE OF SERVICES

The purpose of this project was to conduct an Asbestos-Containing Materials (ACM) survey and provide Asbestos Abatement Cost Estimates for identified ACM located in the L4686 – Glennallen Log Bunkhouse - Old DM House located at Glennallen Field Office, Alaska. Tetra Tech provided services as outlined below:

Conduct a representative asbestos survey of the identified building, which includes the following:

1. Review existing asbestos reports for the building areas, if provided;

2. Survey all of the interior and exterior areas of the building, including building roofs;

3. Identify accessible suspect ACMs using Environmental Protection Agency (EPA) Asbestos

Hazard Emergency Response Act (AHERA) protocols;

4. Collect and analyze bulk samples of suspect friable and non-friable materials to eliminate suspect materials as asbestos containing;

5. Quantify ACMs, including material condition and location; and

6. Provide ACM abatement cost estimates for ACM identified during the survey of the building.

2.0 GENERAL SITE CONDITIONS

The building is a two story, wood framed structure, situated on a stilt foundation, covered by a metal roof. Reportedly, the building was constructed in 1960 and is approximately 1,700 gross square feet. Interior finishes include vinyl sheet flooring and wood. Exterior finishes consist of wood.

3.0 REGULATORY STANDARDS

The survey was performed in accordance with Federal, State and local rules for conducting asbestos surveys to meet Occupational Safety and Health Administration (OSHA) and United States Environmental Protection Agency (EPA) / National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements. The work was also performed in general accordance with AARCHER Subcontract Number 522-S004, dated May 27, 2010 and Task Order 522- S004-005, dated May 27, 2011.

4.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS

ABATEMENT COST ESTIMATES

Tetra Tech representatives Mr. Ryan Egan, Mr. Daniel Lawrence, and/or Mr. Mark Daley conducted the asbestos survey of the building on June 28, 2011. Mr. Egan is an AHERA accredited Building Inspector, Management Planner, Project Designer and Supervisor.

Mr. Daley is an AHERA accredited Building Inspector and Management Planner, and Mr.

Lawrence is an AHERA accredited Building Inspector. All field work was performed by and/or under the guidance of Mr. Ryan Egan.

The scope of the Asbestos-Containing Materials Survey included all accessible suspect building materials and finishes of the interior and exterior areas of the building, including building roofs.

Additional samples were collected from areas in which partial demolition and renovations were planned. The boiler room was previously inspected by BLM personnel, and was excluded from the scope of this building survey. If ACM was identified in the building, Asbestos Abatement Cost Estimates were provided for each identified material.

Previous ACM survey reports for the building were not made available for review.

The building areas were visually inspected for the presence of building materials that are suspected to contain asbestos. Bulk samples of identified suspect ACMs were collected and placed into individual containers for transport to a National Voluntary Laboratory Accreditation Program (NVLAP)/American Industrial Hygiene Association (AIHA)-accredited laboratory for analysis. Materials visibly identified as non-asbestos (fibrous glass, foam rubber, wood, metal, etc.) were not sampled. The asbestos survey consisted of three basic procedures: 1) conducting a visual inspection of the structure and identifying functional spaces; 2) identifying homogeneous material areas of suspect surfacing, thermal system insulation, and miscellaneous materials; and 3) sampling accessible, friable and non-friable suspect materials.

4.1 Homogeneous Materials

Prior to collecting any samples, homogenous materials were identified and listed to develop a sampling strategy. A homogeneous material sampling area can be described as one or more areas of material that are similar in appearance and texture and that have the same installation date and function. The actual number of samples collected from each homogeneous sampling area was based upon criteria detailed in the following sections.

4.2 Hazard Assessment Factors

From the list of suspect homogeneous materials, a physical assessment was performed for each material on the list. A physical assessment includes evaluating the condition, assessing the potential for disturbance, and determining the friability of each material. Friability is a term used to describe the ease in which a building material inherently lends itself to disturbance. By definition, "friable" materials are those that can be crumbled or reduced to powder by hand pressure when dry. Each material on the list was further classified into one of three categories, which have specific sampling requirements for each category.

Surfacing Materials Refers to spray-applied or troweled surfaces such as plaster ceilings and walls, fireproofing, textured paints, textured plasters, and spray applied acoustical surfaces.

Thermal System Insulation Refers to insulation used to inhibit heat gain or loss on pipes, boilers, tanks, ducts, and various other building components.

Miscellaneous Materials Refers to friable and non-friable products and materials that do not fit in any of the above two categories such as resilient floor covering, baseboards, mastics, adhesives, roofing material, caulking, glazing, and siding. This category also contains wallboard and joint compound wall systems and acoustical ceiling tile.

All confirmed ACMs were then assessed by their condition as good (no visible damage or showing only very limited damage or deterioration), damaged (less than 25% localized damage or 10% distributed damage), significantly damaged (25% or greater localized damage or 10% or greater distributed damage) per Title 40 Code of Federal Regulations Part 63.

The sample identification codes for surfacing materials generally begin with "S". Additional substrate materials, such as wall board and joint compound, may be included in surfacing material samples. The sample identification codes for thermal system insulation generally begin with "T". Sample identifiers for miscellaneous materials excluding flooring generally begin with "M", and the sample identification codes for flooring materials generally begin with "F".

4.3 Sampling Strategy

The asbestos inspection was conducted in general accordance with the AHERA requirements using a minimum number of samples collected for each homogenous material, which also meet the sampling requirement found in 29 CFR 1926.1101.

If the analytical results indicated that all the samples collected per homogenous material did not contain asbestos, then the homogenous material would be considered a non-ACM. However, if the analytical results of one or more of the samples collected per homogenous material indicate that asbestos is present in quantities of greater than 1 percent asbestos by weight (as defined by EPA), all of the homogenous material would be treated as an ACM regardless of any other analytical results. Material which can visually be determined to be non-asbestos (i.e., fibrous glass, foam rubber, metal, etc.) by the accredited inspector are not required to be sampled.

Miscellaneous materials require adequately representative sampling, which is typically done by collecting from one to three samples per material. Inspectors typically rely on other survey observations such as the condition, friability, and quantity of material to determine what would be a sufficient amount of samples to accurately evaluate the presence or absence of asbestos content. For this survey, three samples per each homogenous miscellaneous material were collected.

Actual collection of a bulk asbestos sample involves physically removing a small piece of material and placing it in a marked, airtight container. Sample containers are marked with a unique identification number, which is also noted in the field notes.

4.4 Suspect Asbestos-Containing Material

14 bulk asbestos samples were collected from the building and 18 sample layers were analyzed by Polarized Light Microscopy (PLM) based on the number of distinct layers (materials) associated with each bulk sample. For example, floor tile and associated mastic are collected as one bulk sample but are analyzed as two distinct materials by the asbestos laboratory, as required by NVLAP.

4.5 Laboratory Analytical Results

Bulk samples were analyzed by Reservoirs Environmental analytical laboratories located in Denver, Colorado, using PLM according to EPA method 600/R-93/116. This laboratory participates in the NVLAP, a quality assurance program for PLM.

Any material that contains greater than 1 percent (>1%) asbestos by PLM is considered an ACM and must be handled according to OSHA, EPA, and applicable state and local regulations.

In addition, the U.S. Occupational Safety and Health Administration (OSHA) define asbestos as building materials containing between one tenth of one percent and one percent (0.1%-1%).

For friable materials, when the amount of asbestos in the sample material is reported as “None- Detected” by PLM analysis, no further verification of the sample results by Point Counting Methodology is recommended.

For friable materials, when the amount of asbestos in the sample material is reported as “Trace Asbestos Detected” or less than 10% asbestos by PLM analysis, the client may either assume the amount to be greater than 1% and treat the material as ACM or require further verification of the amount by Point Counting Methods. If the result obtained by Point Counting is different from the result obtained by PLM analysis, the Point Count Method result should be used.

For non-friable materials, when the amount of asbestos in the sample material is reported as greater than 1% asbestos by PLM analysis, no further verification of the sample results by alternative methods of identification such as Transmission Electron Microscopy (TEM) Chatfield Method is recommended.

For non-friable materials such as vinyl/asphaltic products (floor tiles/floor sheeting, mastics, shingles, etc.), where small, thin asbestos fibers may have been potentially milled into the nonorganic binder matrix, when the amount of asbestos in the sample material is reported as “None-Detected” by PLM analysis, due to the difficulty in analyzing such small, thin asbestos fibers in resinously bound materials by PLM analysis, EPA recommends but does not require that these types of materials, which were reported as non-ACMs by PLM, be further analyzed using TEM Chatfield Method. Tetra Tech did not conduct such analysis.

The results of the laboratory analysis are summarized in tabular form in Section 5.0. The laboratory analytical report and corresponding chain-of-custody documents are included in Appendix A. Results are reported in percent asbestos by volume and indicate the types of asbestos. Other common non-asbestos components may also be noted on the analytical reports. A drawing(s) showing bulk sample locations is provided in Appendix B. Inspector and laboratory accreditations are provided in Appendix C, and Appendix D presents photographs of all ACM’s identified in the building (if present).

5.0 ASBESTOS-CONTAINING MATERIALS SURVEY AND ASBESTOS ABATEMENT COST

ESTIMATES SUMMARY TABLE

ACM Bulk Sampling Results

L4686 – Glennallen Log Bunkhouse - Old DM House

Glennallen Field Office, Alaska

Homogeneous

Material

Material

Category

Required

Number of

Samples to be

Collected

Number of

Samples

Collected

Sample

Number(s) Location of Material Condition

Friable

(Yes/No)

Approximate

Material

Quantity

Asbestos

Content

ACM

Abatement

Cost

Estimate

Vinyl Sheet

Flooring with

Inseparable Felt

Backing

M N/A 3 F1.1A, B, C Kitchen and Laundry G Yes 340 SF ND $0.00

Vinyl Sheet

Flooring with

Inseparable Felt

Backing

M N/A 3 F1.2A, B, C Restrooms D Yes 120 SF ND $0.00

Tar Paper M N/A 1 M1.1 Exterior Walls D Yes 1,680 SF ND $0.00

Log Chinking M N/A 1 M7.1 Exterior Walls D No 170 SF 15% $2,740.00

Cove Base &

Mastic M N/A 3

M11.1A, B, C Throughout Structure G No 45 SF ND $0.00

AHERA Guidelines for Determining the Number of Samples to Collect ND = None Detected N/A = Not Applicable

MATERIAL CATEGORY:

M = Miscellaneous Material

SM = Surfacing Material

TSI = Thermal System Insulation

APPROXIMATE MATERIAL QUANTITIES:

SF = Square Feet

LF = Linear Feet

Ea = Each

CONDITION:

G = Good

D = Damaged

SD = Significantly Damaged

Homogeneous Material

Category

Homogeneous

Material Quantity Number of Samples Required

Surfacing Materials

<1000 SF 3

1000 - 5000 SF 5

>5000 SF 7 or more

Thermal System Insulation No Stipulation 3 (Must also sample all repair patches)

Miscellaneous Materials No Stipulation

Per AHERA, these materials must be sampled "in a manner sufficient to determine whether or not they contain asbestos." To satisfy National Emission

Standards for Hazardous Air Pollutants (NESHAP) requirements, a minimum of 3 samples were collected if site conditions allowed.

6.0 CONCLUSIONS

The results of the asbestos survey conducted at the L4686 – Glennallen Log Bunkhouse - Old DM House, Glennallen Field Office, Alaska facility building indicate that: one of the accessible suspect building materials sampled were found to contain more than 1% asbestos.

Contractors and employees working in this building should be made aware of the possibility that concealed ACMs may be found during demolition/renovation. They should be advised not to disturb known or suspect ACMs without owner approval.

Any concealed building materials discovered during maintenance or renovation activities, which are suspected to contain asbestos, should be sampled and analyzed to confirm the presence of asbestos prior to disturbing.

The EPA has not prohibited the manufacture and import of miscellaneous materials, such as vinyl floorings, mastics, roofing materials, etc. As a result, any future replacement materials should be checked for the presence of asbestos prior to installation.

7.0 ASSUMPTIONS AND LIMITATIONS

The results, findings, conclusions, and recommendations expressed in the report are based only on conditions that were noted during Tetra Tech’s inspection of the L4686 – Glennallen Log Bunkhouse - Old DM House located at the Glennallen Field Office, Alaska.

The selection of sample locations and frequency of sampling was based on Tetra Tech’s observations and the assumption that like materials in the same area are homogeneous in content. Limited destructive investigation was conducted as needed. Concealed ACMs may exist in concealed areas not investigated or identified.

The report is designed to aid the client in understanding the extent of ACM issues as they pertain to the “Recognition and Measurement of Asbestos-Related Cleanup Costs,” Technical Bulletin 2006-1, prepared by the Federal Accounting Standards Advisory Board, dated September 28, 2006 and to the renovation/demolition areas of the facility building areas. It should be noted that this report is not a complete Asbestos Abatement Specification or Work Plan.

Our professional services have been performed, our findings obtained, and our conclusions prepared in accordance with customary principles and practices in the fields of environmental science and engineering. This statement is in lieu of other statements either expressed or implied. This report does not warrant against future operations or conditions, nor does it warrant against operations or conditions present of a type or at a location not investigated.

Asbestos abatement cost estimates were obtained from asbestos abatement contractors who have not visited the site and have not seen the ACM to be abated. The costs provided herein, are magnitude estimates of costs with the following assumptions made:

Assumes free and clear access to the work area during working hours.

Assumes one mobilization to complete the abatement of one ACM.

Assumes both Power and water at no cost to contractor.

Assumes protect in place all above ceiling electrical wiring, fire alarm, and WiFi cables.

Does not include the demolition of any building components other than ACM.

Pricing assumes that any required inspections and air testing is provided by the building owner or owner’s representative.

Assumes that no special conditions are added by any State or local regulatory agency.

Work hours 7:00 AM to 5:00 PM Monday through Friday.

Not be held responsible for packaging, moving or damage to items being moved, nor for providing storage and/or inventory of these items. If storage or inventory is needed the owner will provide what is necessary. Responsibility of any personal items is the owner’s.

No delays interfering with the diligent execution of the work beyond the contractor’s control will be encountered.

APPENDIX A

ACM LABORATORY ANALYTICAL RESULTS

Laboratory Code: RES Subcontract Number: NA Laboratory Report: RES 216509-1 Project # / P.O. # 114-182187 Task 100 Project Description:

Ryan Egan

RES 216509-1

Sincerely, Anita Grigg Robert R. Workman Jr.

Bethany Nichols Jennifer Jones Anya Angst

July 22, 2011

Analyst(s): _________________________ Paul D. LoScalzo Wenlong Liu Michael Scales Adam Humphreys is the job number assigned to this study. This report is considered highly confidential and the sole property of the customer. Reservoirs Environmental, Inc. will not discuss any part of this study with personnel other than those of the client. The results described in this report only apply to the samples analyzed. This report must not be used to claim endorsement of products or analytical results by NVLAP or any agency of the U.S. Government. This report shall not be reproduced except in full, without written approval from Reservoirs Environmental, Inc. Samples will be disposed of after sixty days unless longer storage is requested. If you have any questions about this report, please feel free to call 303-964-1986.

Jeanne Spencer Orr President

Dear Customer, Reservoirs Environmental, Inc. is an analytical laboratory accredited for the analysis of Industrial Hygiene and Environmental matrices by the National Voluntary Laboratory Accreditation Program (NVLAP), Lab Code 101896-0 for Transmission Electron Microscopy (TEM) and Polarized Light Microscopy (PLM) analysis and the American Industrial Hygiene Association (AIHA), Lab ID 101533 - Accreditation Certificate #480 for Phase Contrast Microscopy (PCM) analysis. This laboratory is currently proficient in both Proficiency Testing and PAT programs respectively.

Reservoirs Environmental, Inc. has analyzed the following samples for asbestos content as per your request. The analysis has been completed in general accordance with the appropriate methodology as stated in the attached analysis table. The results have been submitted to your office.

Tetra Tech (Ft. Collins) 3801 Automation Way Ft. Collins CO 80525

BLM-L4686 / Glennallen- Log Bunkhouse-Old DM House

P: 303-964-1986 F: 303-477-4275

5801 Logan Street, Suite 100 Denver, CO 80216

1-866-RESI-ENV

www.reilab.com

TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Analyzed:

Client Non Non- Sample Sub Asbestos Fibrous Number Physical Part Fibrous Components

Description (%) Mineral Visual Components (%) Estimate (%) (%)

F1.1A EM 764824 A White sheet vinyl w/ white fibrous backing

& white mastic

100 ND 20 80

F1.1B EM 764825 A White sheet vinyl w/ white fibrous backing & white mastic

100 ND 18 82

F1.1C EM 764826 A White mastic 1 ND TR 100 B White sheet vinyl w/ white fibrous backing 99 ND 16 84

F1.2A EM 764827 A White mastic w/ black material 12 ND 3 97 B White sheet vinyl 88 ND 0 100

F1.2B EM 764828 A White mastic w/ black/brown debris 7 ND 6 94 B White sheet vinyl 93 ND 0 100

F1.2C EM 764829 A White mastic w/ black/brown debris 10 ND 5 95 B White sheet vinyl 90 ND 0 100

M11.1A EM 764830 A Colorless resinous material 2 ND 0 100 B Off-white mastic 10 ND 0 100 C Light gray cove base 88 ND 0 100

M11.1B EM 764831 A Light gray cove base 100 ND 0 100

M11.1C EM 764832 A Off-white mastic 1 ND 0 100 B Light gray cove base 99 ND 0 100

RESERVOIRS ENVIRONMENTAL, INC.

NVLAP Lab Code 101896-0

TDH Licensed Laboratory # 30-0136

ID Number L A Y E R

Lab

PLM, Short Report 3-5 Day

Asbestos Content

RES 216509-1

July 21, 2011

114-182187 Task 100 BLM-L4686 / Glennallen-Log Bunkhouse-Old DM House

Tetra Tech (Ft. Collins)

July 13, 2011

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite Note: Further analysis by TEM is recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Data QA

TABLE PLM BULK ANALYSIS, PERCENTAGE COMPOSITION BY VOLUME

RES Job Number:

Client:

Client Project Number / P.O.:

Client Project Description:

Date Samples Received:

Analysis Type:

Turnaround:

Date Analyzed:

Client Non Non- Sample Sub Asbestos Fibrous Number Physical Part Fibrous Components

Description (%) Mineral Visual Components (%) Estimate (%) (%)

RESERVOIRS ENVIRONMENTAL, INC.

NVLAP Lab Code 101896-0

TDH Licensed Laboratory # 30-0136

ID Number L A Y E R

Lab

PLM, Short Report 3-5 Day

Asbestos Content

RES 216509-1

July 21, 2011

114-182187 Task 100 BLM-L4686 / Glennallen-Log Bunkhouse-Old DM House

Tetra Tech (Ft. Collins)

July 13, 2011

M1.1 EM 764833 A Black felt 100 ND 60 40

M7.1 EM 764834 A Black fibrous tar 100 Chrysotile 15 0 85

ND=None Detected TR=Trace, <1% Visual Estimate Trem-Act=Tremolite-Actinolite Note: Further analysis by TEM is recommended for organically bound material (i.e. floor tile) if PLM results are <1%.

Data QA

Redacted

Redacted

Redacted

APPENDIX B

SITE DRAWING

(101)

(102)

(103)

(104)

(105)

(107)

(108)

(100)

(106)

(112)

(113) (114)

(111)(110)(109)

M1.1

M7.1

F1.1AF1.1B

F1.1C

F1.2A

F1.2B

F1.2C

M11.1C

M11.1A

M11.1B

Figure 1 Glennallen Log Bunkhouse - Old DM House - Building L4686

Sample Location Map

NORTH

June 2011Project No. 114-182187

Sample Location

(101)

(102)

(103)

(104)

(105)

(107)

(108)

(100)

(106)

(112)

(113) (114)

(111)(110)(109)

Figure 2 Glennallen Log Bunkhouse - Old DM House - Building L4686

ACM Tar Sealant Location Map

NORTH

June 2011Project No. 114-182187

ACM Log Chinking

APPENDIX C

INSPECTOR AND LABORATORY ACCREDITATIONS

APPENDIX D

ACM PHOTOGRAPHS

Site & ACM Photographs L4686 – Glennallen Log Bunkhouse - Old DM House

Glennallen Field Office - Alaska

Photograph 1 – ACM Log Chinking

Glennallen Field Office P.O. Box 147

Glennallen, AK 99588

District Manager Log House Demolition Environmental Assessment DOI-BLM-AK-A020-2022-0002-EA

1.0 Introduction

1.1 Summary of Proposed Project

The Bureau of Land Management (BLM) proposes to abate, deconstruct, and remove the District Manager (DM) Log House from the Glennallen Field Office (GFO) compound (Fig. 1).

Glennallen BLM is currently unable to occupy or make use of the structure due to unsafe conditions including rot, mold, and the presence of hazardous materials. The DM Log house was utilized as a housing unit for BLM staff and has most recently been used for excess storage of supplies and equipment for various resource and recreation programs at GFO. The structure was evaluated in 2011 for asbestos-containing materials (ACM) which were confirmed in the tar sealant chinking between the logs. Lead-based paint was documented in the kitchen cabinets in March of 2022. Deconstruction of the DM Log House will not require new ground disturbance, including but not limited to parking lots, staging areas, removal of vegetation (to include trees).

The contractor shall be required to make use of existing parking areas for all stages of the project to include mobilization, removal, staging, and/or closeout of the project.

Potential additional issues include wildlife concerns over bats occupying the structure; air quality issues associated with mold and feces from bats and/or rodents; and other potential hazmat sources from lead-based paint (LBP) and Polychlorinated Biphenyls (PCB) lighting ballasts. All these identified issues will become a requirement of the abatement and removal plan for testing prior to the removal of the structure. The contractual work will specifically address identified issues and receive further investigation to determine its presence, appropriate mitigation, and disposal protocols. Logs that can be salvaged during the demolition process will be set aside and stored onsite for future use at similar historic cabins.

BLM Alaska - Solicitation #140L6324Q0014

ATTACHMENT 2

Figure 1. Map of the proposed action, removal of the DM log house, and Glennallen administrative site in Glennallen, AK (BLM 2021).

1.2 Purpose and Need

The purpose for the DM Log House removal is based on the inability to occupy or make use of the structure due to unsafe conditions including rot, mold, and the presence of hazardous materials. The need for removal is to protect human health and the environment from risks associated with the unused and deteriorating structure which contains asbestos-containing material (ACM) in the walls of the exterior log tar sealant chinking, and the potential for the presence of bats occupying the structure; air quality issues associated with mold and feces from bats and/or rodents; and other hazmat sources from lead-based paint (LBP) and Polychlorinated Biphenyls (PCB) lighting ballasts.

Due to the state of disrepair and inability to utilize the structure for housing, there is no support to spend funds to repair and rehabilitate the structure. Moreover, the location of the DM log house may be considered for the future location of a newly constructed warehouse and maintenance complex that would reduce the overall warehouse footprint, improve the working environment for employees, reduce utility costs, and eliminate/reduce deferred maintenance backlog log of existing buildings.

1.3 Decision to be Made

The decision to be made is whether to authorize the Glennallen BLM Field Office to remove the DM Log House as proposed, as proposed with modifications, or not at all.

The Glennallen BLM Field Office would develop a contract for work to conduct confirmation sampling of the DM Log House structure, identify the areas of concern and requirements for abatement and removal and disposal prior to deconstruction, and in accordance with all applicable laws and regulations.

1.4 Land Use Plan Conformance

The proposed action conforms to the following direction from the 2007 East Alaska Resource Approved Resource Management Plan/Record of Decision (ARMP/ROD). Although the proposed action is not specifically mentioned, it is consistent with the objectives listed below:

H-1: Hazardous Materials

• H-2: Management Actions

• Comply with all appropriate laws and regulations regarding hazardous materials.

• Do not permit unauthorized storage, treatment, or disposal of hazardous waste on public lands.

• Protect humans and the environment from exposure to hazardous materials.

• Protect relevant and important values and apply special management where standard or routine management is not adequate to protect the values from risks or threats of damage/degradation or to provide for public safety from natural hazards.

I-6: Access I-6-b: Management Actions (Access)

• Manage facilities, including trails and roads, to provide public access or administrative needs, while maintaining or protecting resource values and in coordination with other Federal and state agencies and private landowners.

1.5 Relationship to Statutes, Regulations, and other NEPA Documents (If Applicable) This project will follow all applicable state and federal laws and regulations that relate to the identification, testing, abatement, and removal of hazardous materials.

Laws related to Hazardous Materials

1. Asbestos Containing Materials (ACM) must be removed, managed, and disposed of in compliance with the Environmental Protection Agency (EPA) National Emissions Standards for Hazardous Air Pollutants (NESHAP) requirements [40 CFR 61, subpart M], the Occupational Safety and Health Administration (OSHA) Regulations for Asbestos Abatement Regulations [8 AAC 61.600-720], and Alaska Department of Environmental Conservation (ADEC) Asbestos Disposal Regulations [18 AAC 60.450].

2. Lead is a pollutant regulated by many laws administered by EPA, including the Toxic Substances Control Act (TSCA) [15 U.S.C. §2601 et seq.], Residential Lead-Based Paint Hazard Reduction Act of 1992 [Title X 42 U.S.C § 4851 Section 1021], Clean Air Act (CAA) [42 U.S.C. §7401 et seq.], Clean Water Act (CWA) [33 U.S.C. §1251 et seq.], Safe Drinking Water Act (SDWA) [42 U.S.C. §300f et seq.], Resource Conservation and Recovery Act (RCRA) [42 U.S.C. §6901 et seq.] , and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) [42 U.S.C. §9601 et seq.] Alaska regulations require proper handling and disposal of lead-based paint as outlined in 18 AAC 75 Oil and Other Hazardous Substances Pollution Control.

Laws related to Historic properties Compliance

1. National Historic Preservation Act as Amended 1992 [36 CFR 800].

2. Paleontological Resources Preservation Act of 2009 [16 USC 470aaa].

Laws related to wildlife

1. Migratory Bird Treaty Act (MBTA)

2. The Lacey Act of 1900

3. Endangered Species Act of 1973

1.6 Issues Identified for Analysis

The following three DM Log House removal-related issues were identified for further analysis, which follows in Chapter 3.

Issue 1 – Hazardous Materials, Human Health, and Safety

Issue 2 – Cultural: How would the proposed action have an adverse effect on properties Eligible for the National Register of Historic Places?

Issue 3 – Wildlife: How would the proposed action affect wildlife?

1.7 Issues Identified but Eliminated from Further Analysis (If Applicable) Since the proposed action would include removal of an existing administrative building, the following general issues are eliminated from further analysis:

Minerals

No minerals are located within the GFO compound; therefore, the issue was not carried forward for analysis.

Visual Resources

Visual Resource Classification IV has been reserved for the GFO compound being the least restrictive classification within the EARMP (EARMP 2007). No visual resources were identified to occur within the GFO compound; therefore, the issue is not carried forward for analysis.

Threatened and/or Endangered Species

On December 22, 2021, BLM engaged the USFWS through their on-line Information for Planning and Consultation platform in which a list of threatened, endangered or candidate species were provided. The list included zero species and no critical habitat identified within the project area. As such, the proposed activity will have no effect on T&E species or their critical habitat.

Subsistence and ANILCA Section 810

The GFO compound is identified as unencumbered land; however, it is an administrative site;

therefore, hunting and subsistence activities do not occur within the GFO boundaries.

Hydrology, Riparian, and Fisheries

No streams and/or rivers are located within the GFO compound; therefore, hydrology, riparian, and/or fisheries were found in this assessment.

Recreation

There are no recreational opportunities within the GFO compound; therefore, recreation was not included in this assessment.

Forestry/Vegetation

The “National Park Rustic” built style is shared with the remaining GFO buildings and contributes to the aesthetics environment. Also contributing to the “National Park Rustic” built style of the DM house’s surroundings are four locally rare Tamarack (Larix laricina) and paper birch (Betula papyrifera) which were planted by Alaska Fire Control Service employees in the 1960s or 1970s. In keeping with the locally rare trees there will be no new ground disturbance at all, including staging, etc., and the contractor is required to make use of existing parking areas for the project. No trees shall be removed from the site as part of the mobilization, removal, staging, or closeout of the project.

Paleontological Resources

The proposed action will involve mainly surface disturbance in an area dominated by Holocene and late Pleistocene Lake sediments, with no known paleontological resources. The Potential Fossil Yield Classification (PFYC) in this area is 2 or low probability. Therefore, paleontological resources will not be carried forward for further analysis.

Air quality

Current ACM is nonfriable and secured in the tar sealant chinking material. Current LBP is secured in the paint on the kitchen cabinets. The proposed action will require the contractor to utilize safety protocols and personal protective equipment (PPE) to mitigate any air quality issues during phases of deconstruction, demolition, and disposal. Therefore, due to the secured and non-friable ACM and application of PPE, no further detailed analysis is required.

2.0 Alternatives

2.1 Alternative 1 – No Action Alternative

Under the No Action Alternative, the DM log house would remain in place and continue to be maintained in a condition to potentially support restricted use as a storage area. No demolition would occur and issues with the current building would continue to occur and be addressed on a case-by-case basis; for instance, maintenance and repairs would continue to be done at higher costs due to asbestos abatement. The building would continue to degrade, require maintenance, surveillance, and monitoring to keep it stabilized in its present state. Air quality would further degrade due to unhealthy levels of guano produced by any presence of bats.

2.2 Alternative 2 - Proposed Action Alternative

The BLM proposes a complete removal of the GFO DM log house including, interior mechanical, electrical, architectural systems and components, and removal of physical structures, including concrete foundations, walls, windows, roofing materials and abatement of any hazmat items, and transportation of waste materials to approved disposal facilities.

A hazardous materials assessment will commence to sample the structure, identify the areas of concern and requirements for abatement, removal, and disposal prior to demolition and in accordance with all Federal and state standards. Identified logs that may be salvaged would be stored onsite and used for future log structure renovations. The existing utilities would be abandoned at the edge of the building footprint. There are two options for the final grade, the first is to leave the site as-is if it is identified as an area that would include the future warehouse construction. The second possibility would be to level to pre-construction condition as the final grade and either: 1) provide drainage, grass seed with approved seed mix, and mulch with certified weed-free straw, or 2) cover in crushed aggregate to provide an additional vehicle parking area. The logs removed from the structure that can be salvaged will be saved and used in recreation and resources programs to reduce overall construction demolition debris needed to be disposed of.

Deconstruction of the building structure would include disconnecting all building utilities if any, removing salvageable equipment or materials, removing the building and foundations, removing and disposing of resultant waste, and restoring the area. During removal, dust dispersion would be controlled to reduce releases into the atmosphere and exposure to both involved and noninvolved workers at and around the worksite. Small amounts of liquid waste may result from the removal, as supply and discharge water systems may contain residual volumes of liquid.

After testing for contamination, this wastewater would be treated and compliantly discharged or, if levels of allowable contamination are exceeded, it would be collected, treated, and properly disposed of per comparable waste disposal contractor document. Any contaminated liquids encountered while draining pipes or tanks would be processed in accordance with Federal and state requirements (e.g., evaporated or solidified for off-site disposal). Removal would be conducted in the open air.

2.3 Comparison of Alternatives Table

Table 1: Comparison of Alternatives

Issues/Indicators Alternative 1—No Action

Alternative 2—Proposed Action

Hazardous Materials/Indicator(s)

Haz mat would remain on site and pose safety issues to human health and the environment.

Haz mat would be removed and disposed of offsite in a manner to eliminate the threat of exposure to known safety and health concerns to human health and the environment.

Cultural and Historic/Indicator(s)

The building would remain Eligible for the National Register of Historic Places, however, a lack of maintenance would result in the building deteriorating and becoming a health and safety hazard.

The building would be demolished, and it would suffer a direct, adverse effect on its National Register Eligibility.

Issues/Indicators Alternative 1—No Action

Alternative 2—Proposed Action

Bats /Indicator(s) No change from existing conditions.

Bats would be relocated. Bats would no longer contribute to poor air quality by reducing the production of guano.

Impacts on migratory birds

No change from existing conditions.

Consistent with the Migratory Bird Treaty Act, operations that require vegetation removal will avoid the migratory bird nesting period of April 15 to July 15; these avoidance timing dates will be refined per specific region and habitat type (of individual projects) within GFO based on U.S.

Fish and Wildlife Service’s recommended guidelines. (FWS 2017). The Proposed action would not result in “unintentional take” of individuals during proposed activities.

Nesting habitat for migratory birds would not be reduced by the removal of the structure.

3.0 Affected Environment and Environmental Consequences

The DM Log House currently occupies 1,700 square foot section of land within the GFO compound (Photo 1). It was last used as housing for staff in 2006. It has been unsuitable to serve as BLM staff housing since that time and has been used as gear and equipment storage for staff.

Photo 1. Front view of DM log house from 2021.

3.1 Hazardous Materials, Human Health, and Safety

3.1.1 Affected Environment

The DM Log house was utilized as a housing unit for BLM staff in the past and more recently for excess storage of supplies and equipment for various resource and recreation programs at GFO. The structure was evaluated in 2011 specifically for asbestos-containing material (ACM).

The scope of the ACM Survey included all accessible suspect building materials and finishes of the interior and exterior areas of the building, including building roofs. Additional samples were collected from areas in which partial demolition and renovations were planned. The boiler room was previously inspected by BLM personnel and was excluded from the scope of the building survey. ACM was confirmed in the tar sealant chinking material between the exterior logs (Aarcher, Inc. 2011). Figures 1 and 2 and Photo 2 Show sampling results from the 2011 inspection.

Testing conducted by on March 29, 2022, confirmed asbestos-containing material (ACM) in the exterior tar chinking material and detected lead-based paint in the kitchen cabinets of a level that will require special treatment and disposal. There is also detectable lead in all the rooms of the building, but not at high enough levels to warrant special disposal.

However, it was recommended it be noted for the demolition and disposal contract so that workers are informed and can use personal protective equipment and other safety measures for removal and disposal ( . 2022).

Asbestos-containing material and lead-based paint are hazardous to human health and pose a risk to human health and safety. Due to lack of use in conjunction with housing or any other integral operation capacity at Glennallen Field Office and costs to abate and renovate the structure, the decision has been made to have the structure deconstructed and disposed of.

BLM Alaska - Solicitation #140L6324Q0014

Figure 1: Sample Location Map 2011 Aarcher inspection

Figure 2: ACM Tar Sealant Location 2011 Aarcher inspection

Photo 2: ACM tar sealant chinking material in exterior logs on DM house from 2011 Aaracher inspection

3.1.2 Environmental Impacts—No Action Alternative

Impacts to human health safety and the environment would continue to be present under no action. No current maintenance is done to the structure, and it would continue to deteriorate from lack of maintenance and upkeep. Exposure factors would still exist to staff or members of the public that may encounter Asbestos containing materials or lead based paint identified in the structure. The continued lack of maintenance would also pose a physical threat as the integrity of the structure would decline and would eventually collapse in on itself while leaving the hazards in place in the collapsed building debris.

3.1.3 Environmental Impacts—Proposed Action

The removal action will involve abatement, deconstruction, and disposal of the structure in accordance with applicable regulations regarding hazardous materials. In this case, specifically, asbestos containing material (ACM) found in the log tar sealant chinking material and lead-based paint (LBP) that was identified in the kitchen cabinets during the contractor site inspection. The ACM present within the building to be demolished will be removed in a manner which complies with all federal and State of Alaska regulations for demolition of asbestos.