A06_20-048_1-B_Mtn_Consulting__PD-ACM-LBP_Survey_Report.pdf

Mountain Consulting Services 9922 E Montgomery Drive, Suite 9 Spokane Valley, WA 99206 509-924-9236 Office 509-924-2287 Fax

May 22, 2020

Turnbull National Wildlife Refuge c/o: Ms. Lisa Wilson 26010 South Smith Road Cheney, WA 99004-9326

Project Number: 20-048.1-B

Dear Ms. Wilson, Mountain Consulting Services (Mountain Consulting) is pleased to provide of the enclosed Pre- Demolition “Good-Faith” Asbestos Materials & Lead Coatings Survey Report conducted for the Single-Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road in Cheney, Washington.

An electronic copy of this document has previously been provided via e-mail.

All tested suspect building materials present with the residence & both outbuildings for this project were proven to be free of asbestos (ACM-Free); Four (4) tested coatings were proven to be regulated lead-based paints (Regulated LBPs); Five (5) tested coatings were proven to not be regulated for lead content; and, Lead-TCLP Waste-Streams Testing has proven that the demolition waste-streams may be disposed of as Standard Construction Waste. This report must be kept on the site during demolition operations for worker and regulatory review.

If you have any questions or concerns, please call me at (509) 924-9236. It was a pleasure working with you on this project, and we look forward to working with you again in the future.

Sincerely, Samuel W. Bailey Jr.

Operations Manager sbailey@mountainconsultingllc.com mailto:sbailey@mountainconsultingllc.com

PRE-DEMOLITION “GOOD-FAITH” ASBESTOS

MATERIALS & LEAD COATINGS SURVEY REPORT

PREPARED FOR THE

SINGLE-FAMILY RESIDENCE AND TWO (2) OUTBUILDING

STRUCTURES RESIDING ON THE RURAL PROPERTY

ADDRESSED AT

26206 SOUTH CHENEY-SPANGLE ROAD

CHENEY, WASHINGTON

Project No: 20-048.1-B

Prepared for Turnbull National Wildlife Refuge

26010 South Smith Road Cheney, WA 99004-9326

(509) 559-3021

Prepared By

9922 East Montgomery Drive, Suite 9 Spokane Valley, WA 99206

(509) 924-9236

May 22, 2020

PROJECT NO: 20-048.1-B

PD-ACM/LBP SURVEY

May 22, 2020 Mountain Consulting Services

TOC

CONTENTS

REPORT SUMMARY ..............................................................................................Section 1

PRE-DEMOLITION ASBESTOS MATERIALS SURVEY .......................................Section 2

PRE-DEMOLITION LEAD COATINGS SURVEY ...................................................Section 3

APPENDICES

A: Certifications and Accreditations B: Asbestos Bulk Sampling Analysis Report C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Sampling Analysis Report E: Lead Bulk Sampling Locations Drawing F: Survey Project Photographs

SECTION 1

REPORT SUMMARY

May 22, 2020 S-1 Mountain Consulting Services

PRE-DEMOLITION ACM & LBP SURVEYS; SINGLE-FAMILY RESIDENCE & TWO (2)

OUTBUILDING STRUCTURES; 26206 S. CHENEY-SPANGLE ROAD; CHENEY, WA

REPORT SUMMARY

The Turnbull National Wildlife Refuge of Cheney, Washington contracted Mountain Consulting Services (Mountain Consulting) to perform a Pre-Demolition “Good-Faith” Asbestos Materials & Lead Coatings Survey for the Single-Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road outside of Cheney, Washington.

This survey project was conducted to facilitate the total demolition of the Single-Story Residence (w/ attached wood deck), detached N. Shop/Garage, and detached N. Small Water Well Pump Shed Structures residing on the rural farm land type property. No prior survey documentation was provided for these structures.

The field survey activities for this project were conducted on May 12th of 2020 by Mr. Todd A.

Lewis, EPA-AHERA Building Inspector; and, Mr. David A. Jones, WA State Lead Risk Assessor.

SITE DESCRIPTION

The Main Single-Family Residence is a 1 story, wood framed structure built on a CMU block foundations wall/open soil floored crawl-space foundation with attached large covered wood deck.

The residence site is approximately 1,500 square feet (ft²) of occupiable space. Interior finishes consist of fiberboard, sheetrock & wood wall paneling’s; exposed wood & sheetrock ceilings;

various types of hard-wood, vinyl, ceramic tile & carpeted floorings; and, fiberglass bat insulations with inner exterior walls. Exterior finishes consist of painted wood siding, metal roofing and wood framed window & entry door units. HVAC is supplied by a fire-place & electric air-conditioning units; and, hot water is supplied by an electric tank.

The 1st Outbuilding Structure present with the site is a detached Small wood-framed Water Well Pump Shed located approx. 145’ Northwest of the Main Residence. Interior finishes are exposed wood framing & fiberglass insulation. Exterior finishes consist of painted wood trims, metal siding and metal roofing. This structure is approximately 20 ft² in size.

The 2nd Outbuilding Structure present with the site is a detached wood-framed, Pole-Barn Shop/Garage Structure built on a concrete foundation located approx. 26’ North of Outbuilding #1.

The interior of the structure is exposed wood framing and concrete floor. Exterior finishes consist of metal siding and roofing. This structure is approximately 865 ft² in size.

This rural residential site is located approximately 7 miles southwest of the city of Cheney, Washington bounded by either undeveloped rural land and a moderate sized pond on all sides with South Cheney-Spangle Road to the west of the main residence.

May 22, 2020 S-2 Mountain Consulting Services

ASBESTOS MATERIALS SURVEY SUMMARY

Mountain Consulting performed destructive bulk materials testing of the suspect building materials present with the Main Residence and 2 Outbuilding Structures included for survey for the presence of asbestos minerals. Mountain Consulting submitted for analysis 32 bulk material samples collected from 17 different homogeneous suspect building materials targeted for asbestos content testing. Laboratory analysts sub-divided 2 submitted bulk samples, resulting in a total of 34 bulk material samples analyzed for this project.

PROVEN REGULATED ACM MATERIALS

All sampled and analyzed suspect building materials tested from the main residence and both outbuilding structure for this pre-demolition asbestos survey project, were proven to be free of asbestos minerals (ACM-Free). Refer to the following section for detailed lists of suspect building materials tested.

MATERIALS PROVEN TO BE ASBESTOS-FREE

The following sampled homogeneous building materials tested from the Main Residence & Two (2) Outbuilding Structures detailed by building name were proven to be free of asbestos minerals by laboratory analysis (ACM-Free): Samples 20-048.1-B-

26206 SOUTH CHENEY-SPANGLE ROAD (MAIN SITE RESIDENCE)

White 4” Ceramic Floor Tile, Gray Grout & White Adhesive (of both RRs) (Samples 01, 02, 03 & 04)

Wood-Grain Vinyl Sheet Flooring (VSF) & Clear Mastic (of kitchen) (Samples 05 & 06) Tan Pebble-Pattern VSF & Brown Mastic (hidden flooring in kitchen) (Samples 07 & 08) Sheetrock Wallboard Paneling (of kitchen & RR areas) (Samples 09 & 10) Joint & Taping Compound Mud (of interior sheetrock) (Sub-samples 09A & 10A) Gray Adhesive (of S. RR tub surround) (Samples 11 & 12) Gray Mortar (of fire-place stack) (Samples 13 & 14) Black Tarpaper (under exterior metal roofing) (Samples 15 & 16) Black Tarpaper (under exterior wood siding) (Samples 17 & 18) Brown Fiberboard Wall Paneling (of majority interior walls) (Samples 19 & 20) Beige Formica & Yellow Adhesive (of kitchen countertops) (Samples 21 & 22) Gray Mortar (of CMU block foundation walls) (Samples 23 & 24) Foil-Paper Backed Fiberglass Bat Insulation (of inner ext. walls) (Samples 25 & 26) Gray Mortar (of drive-way field-stone retaining wall) (Samples 27 & 28)

Outbuilding #1 (Detached N Small Water Well Pump Shed)

Foil-Paper Backed Fiberglass Bat Insulation (throughout interior) (Samples 29 & 30)

Outbuilding #2 (Detached N Pole-Barn Shop/Garage Structure)

Gray Concrete (of foundation) (Samples 31 & 32)

May 22, 2020 S-3 Mountain Consulting Services

ASBESTOS CONTENT HANDLING REQUIREMENTS

Building Materials proven to be Free of Asbestos (ACM-Free) maybe impacted without any specialized personnel training and disposed of as standard construction waste. The building owner or tenant is responsible, under OSHA & WISHA regulations, to notify all maintenance and custodial workers of the presence and location of Regulated ACMs.

LEAD COATINGS SURVEY SUMMARY

Mountain Consulting performed destructive bulk testing of suspect coatings (Paint Films & Glazed Ceramic Tile Materials) present with the Main Residence and Both Outbuilding Structures associated with the rural residential site included for demolition survey, for the presence of total lead-metals content.

Mountain Consulting collected a combined total of Nine (9) Bulk Coating Samples for this project.

The results of the bulk coating samples collected for this project are listed as follows by building ID, color, component type and results:

26206 SOUTH CHENEY-SPANGLE ROAD (MAIN SITE RESIDENCE) 20-048.1-B-PB

1. Yellow Paint (of interior wood components) 500 ppm

2. Gold Varnish (of interior wood components) 330 ppm

3. White Paint (on interior sheetrock) <80 ppm

4. Orange Paint (on interior wood components) <80 ppm

5. Lt. Gray Paint (on exterior wood components) 1,700 ppm

6. Dk. Gray Paint (on exterior wood components) 1,300 ppm

7. White Glazed 4” Ceramic Floor Tile (of RRs) 47 ppm

Outbuilding #1 (Detached N Small Pump Shed Structure) 20-048.1-B-Pb

8. Red Paint (on exterior wood components) <80 ppm

Outbuilding #2 (Detached N Pole-Barn Garage Structure) 20-048.1-B-Pb

9. Red Paint (on exterior wood components) <480 ppm

The bolded italicized identified coatings present with the site structures are considered TO NOT BE Regulated for Lead Content. All other listed paint coatings are considered to be Regulated Lead Based Paints (R-LBPs). The R-LBP coated building components may pose potential lead exposure hazards. Contractors working with or around these coatings should be informed of the potential lead hazards and lead contents.

The bulk coating samples collected for this project were submitted following proper chain of custody procedures to EMSL Analytical, Inc. located in Cinnaminson, New Jersey for analysis by method SW846, 3050B/7000B. EMSL is an ACGIH accredited analytical laboratory.

May 22, 2020 S-4 Mountain Consulting Services

LEAD WASTE-STREAM TCLP SAMPLING

The Washington State Dangerous Waste Regulation (WAC 173-303) requires that demolition waste streams must be assumed to be lead-hazardous waste, until testing for leachable lead content by, toxic characterization leeching procedure (TCLP) bulk waste-stream sampling prove otherwise. The Lead-TCLP characterization threshold is 5 ppm.

Since the residential site structures for this project are slated for total demolition to be conducted at the same time by an awarded bidding contractor, Mountain Consulting collected (2) representative Lead-TCLP waste-stream sample for this project.

The results of the Lead-TCLP waste stream sample collected for this project is listed as follows:

26206 South Cheney-Spangle Road – Residence & 2 Outbuildings Lead TCLP Waste-Stream Sampling Results

Sample # Sample Make-Up Results ppm

20-048.1-B-TCLP1 Single-Family Residence Structure; Whole Building Lead Containing Demolition Waste-Stream

Non-Detect (for leachable lead content)

20-048.1-B-TCLP Representative of 2 Wood-Framed Outbuilding Support Structures Demolition Waste-Stream Non-Detect

The composite bulk Lead-TCLP waste stream samples collected for this project were submitted following proper chain of custody procedures to Anatek Labs, Inc. located in Spokane, Washington for analysis by EPA Method SW846-1311 (for Lead-TCLP). Anatek is an accredited analytical laboratory by the Washington State Department of Ecology (WDOE).

EXPLANATIONS OF LEAD REGULATIONS ARE DETAILED AS FOLLOWS:

The Occupational Safety and Health Administration (OSHA) 29 CFR 1926.62 and Washington State Department of Labor & Industries (L&I) WAC 296-155-176 lead in construction standards do not define a definition for lead based coatings but do establish safe airborne exposure limits for employees working with lead containing materials, by permissible exposure limit (PEL).

So, if any material or coating contains lead in excess of >100 ppm then abatement, renovation or demolition contractors must demonstrate worker health and safety due diligence. This includes “lead in construction” awareness training for all affected employees, establishing the use of employee personnel protective equipment (PPE), proper demarcation of effected demolition work areas and performance of exposure assessment (EA) lead air monitoring prior to downgrading established PPE.

The Washington State Dangerous Waste Regulation WAC 173-303 requires that lead containing waste streams with a lead content above >100 ppm threshold be treated as lead hazardous waste, until toxic characterization leeching procedure (TCLP) bulk waste stream sampling proves otherwise.

May 22, 2020 S-5 Mountain Consulting Services

Pre-Demolition Lead TCLP waste-streams testing has been conducted for this project and the demolition waste-streams that are anticipated to be generated by this project are proven to be standard construction waste.

The State & Federal Lead-TCLP waste-stream disposal threshold limit is 5 parts per million (ppm).

If TCLP results are below 5ppm than the waste-stream is standard construction/demolition waste, but if TCLP results are in excess of 5ppm than the waste is considered to be Lead-Dangerous Waste.

LIMITING CONDITIONS

A complete discussion of survey parameters and applied methods are enclosed in the following sections of this report. Only general conclusions should be made from the information provided within this summary. During this regulated/hazard assessment, Mountain Consulting endeavored to observe, inventory, and sample (if appropriate) potentially regulated and or hazardous materials associated with the structure areas included for renovation/demolition activities.

During demolition activities for the included structure(s), if any unidentified suspect materials are encountered that were not observed during this assessment may warrant additional sampling, analysis or assumption.

CLOSURE

The results, conclusions, and recommendations presented in this report were prepared following our inspection of suspected materials at the subject property. Methods used by Mountain Consulting for this study are consistent with the standard of care and professionalism normally exercised by consultants in the environmental science and engineering fields.

The Client acknowledges that Mountain Consulting has been retained for the sole purpose of assisting the Client in identifying Regulated and Hazardous Materials, if any, associated with the subject facility. It is agreed that Mountain Consulting has assumed responsibility only for performing this assessment and presenting this report and conclusions to the Client.

The Client acknowledges that Mountain Consulting is not acting as an “agent” for the Client, or any other user or entity, for work associated with any regulated and/or hazardous materials.

Mountain Consulting does not act or have authority to act for or in place of the Client or its successors or assigns. Mountain Consulting does not represent the Client nor does it authorize or allow any construction, renovation, remodeling, maintenance, repair, or demolition work by performing this assessment. Mountain Consulting is not a licensed contractor or licensed abatement contractor.

SECTION 2

PRE-DEMOLITION ASBESTOS

MATERIALS SURVEY

May 22, 2020 TOC Mountain Consulting Services

PRE-DEMOLITION ASBESTOS SURVEY – TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 SCOPE OF WORK

3.0 ASSESSMENT SURVEY PARAMETERS

3.1 HOMOGENEOUS AREAS

3.2 BULK SAMPLING

3.3 LABORATORY AND ANALYTICAL METHODS

4.0 RESULTS

4.1 MATERIAL CONTAINING 1% OR MORE ASBESTOS

4.2 MATERIALS ASSUMED TO CONTAIN ASBESTOS

4.3 MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1%

4.4 NON-ACM MATERIALS IDENTIFIED

4.5 MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 CONCLUSIONS

5.2 RECOMMENDATIONS

APPENDICES

A: Certifications and Accreditations B: Asbestos Bulk Sampling Analysis Report C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Sampling Analysis Report

PRE-DEMO ACM SURVEY

May 22, 2020 ACM - Page 1 Mountain Consulting Services

ASBESTOS MATERIALS SURVEY REPORT

1.0 INTRODUCTION

The Turnbull National Wildlife Refuge of Cheney, Washington contracted Mountain Consulting Services (Mountain Consulting) to perform a Pre-Demolition “Good-Faith” Asbestos Materials Survey for the Single-Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road in Cheney, Washington.

This survey project was conducted to facilitate the total demolition of the Single-Story Residence (w/ attached wood deck), detached N. Shop/Garage, and detached N. Small Water Well Pump Shed Structures residing on the rural farm land type property. No prior survey documentation was provided for these structures.

The field survey activities for this project were conducted on May 12th of 2020 by Mr. Todd A.

Lewis, EPA-AHERA Building Inspector; and, Mr. David A. Jones, WA State Lead Risk Assessor.

Mr. Todd A. Lewis, EPA-Accredited AHERA Building Inspector, certification BIR20190823-01, expiration 8-23-2020, conducted the field survey for this project on May 12th of 2020. (See Appendix A for inspector certifications and laboratory accreditations.)

2.0 SCOPE OF WORK

The scope of work was designed to meet the requirements for asbestos inspection and due diligence notification as defined within the Occupational Safety & Health Administration (OSHA) Asbestos Standard (29 CFR 1926.1101); Washington Industrial Safety & Health Act (WISHA) standard (WAC 296-62-077); National Emission Standards for Hazardous Air Pollutants (NESHAP 40 CFR 61);

applicable portions of the Asbestos Hazardous Emergency Response Act (AHERA 40 CFR 763);

and, the Spokane Regional Clean Air Agency (SRCAA) Regulation I, Article IX.

The survey was conducted through visual evaluation, classification and analysis of suspected asbestos containing materials (ACMs) used in the construction or remodeling of the surveyed site structures included for total demolition.

The survey included the following tasks:

Visual survey and assessment of the location and condition of suspected materials.

Collection and analysis of bulk samples from suspected asbestos containing materials.

Preparation of a report summarizing the identification and assessment of any asbestos containing materials and material found not to contain asbestos.

May 22, 2020 ACM - Page 2 Mountain Consulting Services

3.0 ASSESSMENT SURVEY PARAMETERS

3.1 HOMOGENEOUS AREAS

Homogeneous materials are those considered to be consistent throughout an area based on color, texture, and construction era. For the purpose of this survey, homogeneous areas were delineated using the construction era, material composition, and material location as the primary considerations.

Material appearance, texture, size, color, and analytical results may support assumptions about each material’s homogeneity.

3.2 BULK SAMPLING

Suspected ACMs were collected according to guidelines in 40 CFR 763.85 and were sampled to determine the type and percentage of asbestos by volume. At least two samples were collected from selected miscellaneous materials; at least three samples from thermal system insulation materials;

and, suspect surfacing materials were sampled according to the AHERA “3/5/7 rule.”

For other types of suspect materials, or materials assumed to be non-ACM, regulations require the on-site AHERA building inspector to determine the appropriate number of samples. The quantity of material present, manufacturer’s labels, appearance, construction or renovation era, and inspector’s expertise were used to determine the number of samples. A homogeneous material is an ACM if one or more sample results are equal to or greater than 1% asbestos.

The EPA recommends that at least three samples be analyzed by polarized-light microscopy (PLM) for the following types of materials to prevent false negative results (less than 1% asbestos):

Materials that contain low concentrations of asbestos fibers (less than 10%);

Materials with asbestos fibers tightly bound in a matrix;

Materials with milled asbestos fibers (fine fibers);

Materials with hand-mixed asbestos fibers; and Materials with a combination of these characteristics.

All bulk samples must have results below 1% asbestos before the material may be classified in accordance with AHERA rules as not being an ACM. However, if asbestos is detected in the material at less than 1%, WISHA worker health and safety regulations still apply.

3.3 LABORATORY AND ANALYTICAL METHODS

Mountain Consulting performed destructive bulk materials testing of the suspect building materials present with the main site residence and 2 outbuilding structures included for survey to determine the presence or absence of asbestos minerals content.

Mountain Consulting submitted for analysis 32 bulk material samples collected from 17 different homogeneous suspect building materials targeted for asbestos content testing. Laboratory analysts sub-divided 2 submitted bulk samples, resulting in a total of 34 bulk material samples analyzed for this project.

May 22, 2020 ACM - Page 3 Mountain Consulting Services

All samples were submitted for analysis to Mountain Laboratories of Spokane, Washington using chain of custody procedures. Mountain Laboratories participates in the national voluntary laboratory accreditation program (NAVLAP) and is a NAVLAP accredited asbestos testing laboratory, NAVLAP code: 101890-0.

All samples were analyzed to determine asbestos type and content using PLM with dispersion staining in accordance with the following methods:

EPA EPA 600/R-93/116, “Method for the Determination of Asbestos in Bulk Building Materials” (July 1993).

EPA “Interim Method for the Determination of Asbestos in Bulk Insulation Samples” (40 CFR Part 763, Subpart F, Appendix A; May 27, 1982).

ASTM Draft “Standard Method of Testing for Asbestos Containing Materials by Polarized Light Microscopy” (ASTM Committee D22.05; January 14, 1988).

4.0 RESULTS

This section describes suspect materials that were found to be asbestos containing (Regulated ACM) or proven to be free of asbestos minerals (ACM-Free). (Refer to the bulk sampling analysis report in Appendix B for specific sample composition and Appendix C for sampling location drawings).

4.1 MATERIAL CONTAINING 1% OR MORE ASBESTOS

ACMs are materials proven to contain at least 1% asbestos or greater. AHERA and NESHAP regulations distinguish between friable and nonfriable forms of ACM. A friable material is defined as one that can be “crumbled, pulverized, or reduced to powder by hand pressure when dry.”

Friability is an indication of a material’s ability to release asbestos fibers into the air. Regulated ACMs are defined by NESHAP as all friable ACM and nonfriable ACM that may be disturbed by renovation or demolition.

PROVEN REGULATED ACM MATERIALS

All sampled and analyzed suspect building materials tested from the main residence and both outbuilding structure for this pre-demolition asbestos survey project, were proven to be free of asbestos minerals (ACM-Free). Refer to Section 4.4 for detailed lists of suspect building materials proven to be free of asbestos content.

4.2 MATERIALS ASSUMED TO CONTAIN ASBESTOS

No homogeneous suspect building materials were ASSUMED to contain asbestos during this good-faith asbestos survey project.

May 22, 2020 ACM - Page 4 Mountain Consulting Services

4.3 MATERIALS WITH ASBESTOS CONCENTRATIONS OF LESS THAN 1%

No sampled building materials were proven to contain less than one percent (<1%) asbestos by laboratory analysis during this pre-demolition asbestos survey project.

4.4 NON-ACM MATERIALS IDENTIFIED

The following sampled homogeneous building materials tested from the Main Residence & Two (2) Outbuilding Structures detailed by building name were proven to be free of asbestos minerals by laboratory analysis (ACM-Free): Samples 20-048.1-B-

26206 SOUTH CHENEY-SPANGLE ROAD (MAIN SITE RESIDENCE)

White 4” Ceramic Floor Tile, Gray Grout & White Adhesive (of both RRs) (Samples 01, 02, 03 & 04)

Wood-Grain Vinyl Sheet Flooring (VSF) & Clear Mastic (of kitchen) (Samples 05 & 06) Tan Pebble-Pattern VSF & Brown Mastic (hidden flooring in kitchen) (Samples 07 & 08) Sheetrock Wallboard Paneling (of kitchen & RR areas) (Samples 09 & 10) Joint & Taping Compound Mud (of interior sheetrock) (Sub-samples 09A & 10A) Gray Adhesive (of S. RR tub surround) (Samples 11 & 12) Gray Mortar (of fire-place stack) (Samples 13 & 14) Black Tarpaper (under exterior metal roofing) (Samples 15 & 16) Black Tarpaper (under exterior wood siding) (Samples 17 & 18) Brown Fiberboard Wall Paneling (of majority interior walls) (Samples 19 & 20) Beige Formica & Yellow Adhesive (of kitchen countertops) (Samples 21 & 22) Gray Mortar (of CMU block foundation walls) (Samples 23 & 24) Foil-Paper Backed Fiberglass Bat Insulation (of inner ext. walls) (Samples 25 & 26) Gray Mortar (of drive-way field-stone retaining wall) (Samples 27 & 28)

Outbuilding #1 (Detached N Small Water Well Pump Shed)

Foil-Paper Backed Fiberglass Bat Insulation (throughout interior) (Samples 29 & 30)

Outbuilding #2 (Detached N Pole-Barn Shop/Garage Structure)

Gray Concrete (of foundation) (Samples 31 & 32)

4.5 MATERIALS ASSUMED NOT TO CONTAIN ASBESTOS

The following materials were assumed not to contain asbestos, based on manufacturers’ labels, age, appearance, or inspector’s expertise:

Glass – exterior and interior.

Wood – natural interior and exterior Metal – structural support, furnace/ducting and tanks.

Fiberglass insulation – attic, walls and pipes.

May 22, 2020 ACM - Page 5 Mountain Consulting Services

5.0 CONCLUSIONS AND RECOMMENDATIONS

Our findings are based strictly on information obtained from our site observations during field survey activities; review of related asbestos survey reports and from current sample analysis.

Consistent with our knowledge and understanding of environmental regulations, particularly as they apply to the potential liabilities associated with asbestos-containing building materials, we present the following conclusions and recommendations:

5.1 CONCLUSIONS

ACM-Free Materials: The materials proven not to contain asbestos (ACM-Free) require no further action in regard to asbestos regulations. These materials may be impacted without any specialized personnel training and disposed of in a landfill that accepts standard construction debris.

5.2 RECOMMENDATIONS

If any materials not identified in this survey are uncovered during demolition operations, they must be considered to asbestos containing until sampling and analysis proves otherwise. ACM must be handled in accordance with OSHA, WISHA, NESHAP, and local SRCAA regulations.

The Spokane Regional Clean Air Agency (SRCAA), the local building department, and the local fire department should be contacted regarding possible permit requirements.

May 22, 2020 ACM - Page 6 Mountain Consulting Services

STATEMENT OF PROFESSIONALISM

Mountain Consulting Services hereby certifies that the Pre-Demolition “Good-Faith” Asbestos Building Materials Survey conducted for the suspect building materials present with the Single- Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road in Cheney, Washington was conducted under modified protocols of 40 CFR 763.85. All policies and procedures described in 40 CFR 763 have been followed. All work and statements contained herein are certified true and correct to the best of Mountain Consulting’s ability.

Inspector: ______________________________ Date: May 22, 2020

Todd A. Lewis AHERA Building Inspector Certification: BIR20190823-01 Expiration: August 23, 2020

This report was prepared for the exclusive use by the Turnbull National Wildlife Refuge of Cheney, Washington and/or representatives thereof. It may be reproduced only in full and with the written permission of Mountain Consulting. The accuracy of this report is void unless the document remains unaltered and unabridged.

SECTION 3

PRE-DEMOLITION LEAD

COATINGS SURVEY

Pre-Demo LBP Survey

May 22, 2020 TOC Mountain Consulting Services

LEAD COATINGS SURVEY – TABLE OF CONTENTS

1.0 INTRODUCTION AND SITE DESCRIPTION

2.0 SCOPE OF WORK

2.1 Homogeneous Coatings

2.2 Bulk Sampling

2.3 TCLP Bulk Sampling

3.0 RESULTS

3.1 Lead Bulk Sample Results

3.2 TCLP Bulk Sample Results

4.0 RECOMMENDATIONS

5.0 HEALTH EFFECTS OF LEAD EXPOSURE

APPENDICES

A: Certifications and Accreditations B: Asbestos Bulk Sampling Analysis Report C: Asbestos Bulk Sampling Locations Drawing D: Lead Bulk Sampling Analysis Report

October 8, 2013 Lead Page 1 Mountain Consulting Services

LEAD COATINGS SURVEY REPORT

1.0 INTRODUCTION

The Turnbull National Wildlife Refuge of Cheney, Washington contracted Mountain Consulting Services (Mountain Consulting) to perform a Pre-Demolition “Good-Faith” Lead Coatings Survey for the Single-Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road in Cheney, Washington.

This survey project was conducted to facilitate the total demolition of the Single-Story Residence (w/ attached wood deck), detached N. Shop/Garage, and detached N. Small Water Well Pump Shed Structures residing on the rural farm land type property. No prior survey documentation was provided for these structures.

Mr. David A. Jones, Washington State Lead Risk Assessor, Certification 0567; Expiration February 16, 2022, conducted the field survey activities for this project on May 12th of 2020. [See Appendix A for inspector certifications and laboratory accreditations.]

This survey complies with all applicable state and federal regulations and is provided to help the property owner determine the impact of lead coating/material hazards for the scheduled demolitions project.

2.0 SCOPE OF WORK

The tested coatings were sampled in accordance with the requirements for lead based paint testing and due diligence notification as per Chapter 296-62, Washington Administrative Code (WAC), General Occupational Health Standards; Chapter 296-62-0721, Part I, WAC, Lead; Chapter 296- 155, Safety Standard for Construction Work; 29 CFR 1926.62 OSHA Lead in Construction Work;

and 29 CFR 1910.1025 OSHA Lead General Industry Standards.

The sampling included visual evaluation, classification and analysis of suspected Lead coatings (Paint Films & Glazed Ceramic Tile Materials) present throughout the Main Site Residence and Both Outbuilding Structures included for survey.

The sampling included the following tasks:

Visual survey and assessment of the location and condition of suspected coating(s).

Collection and analysis of bulk sample(s) from suspected coating(s).

Preparation of a report summarizing the identification and assessment of lead coatings.

October 8, 2013 Lead Page 2 Mountain Consulting Services

2.1 HOMOGENEOUS COATINGS

Homogeneous coatings are those considered to be consistent throughout an area based on color, texture, and construction era. For the purpose of this survey, homogeneous coatings were delineated using the construction era, coating color, and coating location as the primary considerations.

Coating appearance, texture, and analytical results may support assumptions about each coating(s) homogeneity.

2.2 BULK PAINT SAMPLING

Destructive bulk coatings sampling was conducted by Mountain Consulting for this project.

Mountain Consulting collected a total of Nine (9) Bulk Coating Samples for this project (8 paint films and 1 glazed ceramic tile). The bulk samples consisted of all the paint material that could be scrapped or removed from an area of approximately 4 square inches (in²) for each targeted suspect coating site.

The samples were submitted following proper chain-of-custody procedures to EMSL Analytical in Cinnaminson, New Jersey, for analysis by methods SW846 3050B/7000B*. EMSL Analytical, Inc.

(phone 1-800-220-3675) is accredited by the American Industrial Hygiene Association. Their accreditation certificate is provided in Appendix A.

2.3 TCLP BULK SAMPLING

The Washington State Dangerous Waste Regulation WAC 173-303 requires that lead containing materials with a lead content above 100 ppm (parts per million) threshold be treated as lead hazardous waste, until Toxic Characterization Leeching Procedure (TCLP) bulk waste stream sampling proves otherwise. The TCLP lead characterization threshold is 5 ppm.

Since the residence and associated outbuildings included for survey contain non-recyclable building materials coated with regulated lead-based paints (LBPs), Mountain Consulting collected Two (2) composite building materials Lead - TCLP waste-stream samples for this project.

A representative TCLP sample consists of the collection of various components of a waste stream generated by a renovation, demolition or abatement project in the same weight proportion as is found in the entire bulk of the waste. As such, a representative sample should contain a sample of all major items found in the proposed waste stream, in an approximate weight proportion.

The sampler must estimate the approximate total weight or mass (in percent) of the debris before it is removed or generated. Samples are then collected so that each major component of the debris is present in approximately the correct proportion, including the entire cross-section of the substrate.

The collected TCLP sample consisted of at least 4 ounces of LBP coated building materials to meet the minimum requirements for TCLP sampling.

October 8, 2013 Lead Page 3 Mountain Consulting Services

The following table lists the percentage of sampled building components: The total of which equals 100% of the proposed whole building demolitions waste-stream:

20-048.1-B-TCLP1 (MAIN SITE RESIDENCE; LEAD DEMOLITION WASTE-STREAM)

Waste Stream Components Percentage of

Waste Stream Unpainted Wood Framing 30% Painted Wood Components 5% Painted Sheetrock Wallboard 5% Varnished Wood Components 30% Carpet, Ceramic & Vinyl Floorings 3% Fiberglass Insulation 1% Glass & Tarpaper 1% Brick, CMU Block & Mortar 25%

Total Percentage: 100%

20-048.1-B-TCLP2 (2 OUTBUILDING STRUCTURES; LEAD DEMOLITION WASTE-STREAM)

Waste Stream Components Percentage of

Waste Stream Unpainted Wood Framing 40% Painted Wood Components (exterior trims & doors) 10% Unpainted Concrete 30% Corrugated Metal Siding & Roofing 20%

Total Percentage: 100%

The Lead-TCLP samples were submitted following proper chain of custody procedures to Anatek Labs, Inc. located in Spokane, Washington for analysis by EPA Method SW846-1311. Anatek Labs, Inc. (phone 509-838-3999) is accredited by the Washington State Department of Ecology (WDOE).

[A copy of their accreditation certificate is provided in Appendix A.]

3.0 RESULTS

3.1 BULK PAINT SAMPLE RESULTS

The Occupational Safety and Health Administration (OSHA) and the Washington State Industrial Safety and Health Administration (WISHA) do not define by regulation a definition for lead coatings.

The Housing & Urban Development (HUD) Federal Regulation action limit for the presence of lead by bulk coating analysis is 0.5 percent by weight (%wt.) for target housing only and therefore does not apply to renovation or demolition projects.

Bulk coating samples (paint films & glazed ceramic tile materials) were collected from majority coatings present with the Main Site Residence and Both Outbuilding Structures included for survey located on the rural property addressed at 26206 S. Cheney-Spangle Road in Cheney, Washington for this project.

October 8, 2013 Lead Page 4 Mountain Consulting Services

Mountain Consulting collected a combined total of Nine (9) Bulk Coating Samples for this project.

The results of the bulk coating samples collected for this project are listed as follows by building ID, color, component type and results:

26206 SOUTH CHENEY-SPANGLE ROAD (MAIN SITE RESIDENCE) 20-048.1-B-PB

1. Yellow Paint (of interior wood components) 500 ppm

2. Gold Varnish (of interior wood components) 330 ppm

3. White Paint (on interior sheetrock) <80 ppm

4. Orange Paint (on interior wood components) <80 ppm

5. Lt. Gray Paint (on exterior wood components) 1,700 ppm

6. Dk. Gray Paint (on exterior wood components) 1,300 ppm

7. White Glazed 4” Ceramic Floor Tile (of RRs) 47 ppm

Outbuilding #1 (Detached N Small Pump Shed Structure) 20-048.1-B-Pb

8. Red Paint (on exterior wood components) <80 ppm

Outbuilding #2 (Detached N Pole-Barn Garage Structure) 20-048.1-B-Pb

9. Red Paint (on exterior wood components) <480 ppm

The bolded italicized identified coatings present with the site structures are considered TO NOT BE Regulated for Lead Content. All other listed paint coatings are considered to be Regulated Lead Based Paints (R-LBPs). The R-LBP coated building components may pose potential lead exposure hazards. Contractors working with or around these coatings should be informed of the potential lead hazards and lead contents.

3.2 TCLP SAMPLE RESULTS

The result of the Lead Composite Building Materials Lead-TCLP bulk waste-stream samples collected for this project are provided in the following table: [Refer to Appendix D for laboratory report and chain of custody].

26206 South Cheney-Spangle Road – Residence & 2 Outbuildings Lead TCLP Waste-Stream Sampling Results

Sample # Sample Make-Up Results ppm

20-048.1-B-TCLP1 Single-Family Residence Structure; Whole Building Lead Containing Demolition Waste-Stream

Non-Detect (for leachable lead content)

20-048.1-B-TCLP Representative of 2 Wood-Framed Outbuilding Support Structures Demolition Waste-Stream Non-Detect

The Federal & State Lead-TCLP disposal threshold limit for bulk building components is 5 ppm.

October 8, 2013 Lead Page 5 Mountain Consulting Services

The lead containing demolitions waste-streams that are anticipated to be generated by this project are classified as Category I Low Lead Wastes that can be disposed of in a landfill that accepts standard construction waste as per the requirements of 40 CFR Part 261 and WAC 173-303 for the determination of lead leachable waste characterization.

All non-recyclable building components anticipated to be impacted by the scheduled demolitions project were included in the Bulk Coating/Lead-TCLP sampling scheme.

4.0 RECOMMENDATIONS

Any coating identified as containing lead at concentrations greater than >100 ppm (parts per million) from bulk analysis associated with this project are regulated by Federal and Washington State regulations.

EXPLANATIONS OF REGULATIONS ARE DETAILED AS FOLLOWS:

The Occupational Safety and Health Administration (OSHA) 29 CFR 1501.62 and the Washington State Industrial Safety and Health Administration (WISHA) WAC 296-155 lead in construction standards do not define by regulation a definition for LBP but do establish safe airborne exposure limits for employees working with lead containing materials to include paint films by PEL (permissible exposure limit).

The current PEL for airborne lead is 50 ug/m³ (micrograms per cubic meter) and the current action limit (AL) is 30 ug/m³. If any material contains lead above 100 ppm by Flame Atomic Absorption (FAA) analysis or assumed lead containing then abatement, renovation or demolition contractors must demonstrate worker health and safety due diligence and lead safe work practices.

This would include lead awareness training for all affected employees, establishing proper employee personnel protective equipment (PPE), proper demarcation of effected work areas and performance of negative exposure assessment (NEA) lead air monitoring prior to downgrading any PPE.

The Washington State Dangerous Waste Regulation (WAC 173-303) requires that any lead containing waste-streams with a lead content above 100 ppm threshold be treated as lead hazardous waste, until toxic characterization leeching procedure (TCLP) bulk waste stream sampling proves otherwise. The current TCLP lead leaching threshold is 5 ppm.

Lead Waste-Stream TCLP sampling has been conducted for project and the anticipated lead containing demolitions waste stream for this Single-Family Residence to include all 6 Outbuilding Structures can be disposed of as standard construction debris.

Metal components coated with LBP can either be abated prior to impacting or recycling as clean steel; or can be recycled at a facility that accepts metal materials with LBP present (typically called dirty steel). If recycling is conducted full documented disclosure by all affected parties is recommended.

October 8, 2013 Lead Page 6 Mountain Consulting Services

5.0 HEALTH EFFECTS OF LEAD EXPOSURE

For information concerning lead-based paint and the health effects of lead, contact the National Lead Information Clearing House at 1-800-424-Lead.

Lead can be absorbed into the body by inhalation (breathing) and ingestion (eating or drinking).

Inhaling or ingesting even small amounts of lead can be harmful.

Lead poisoning can occur at high exposure concentrations (acute) or at low exposure concentrations over a long period of time (chronic) and can cause either temporary or permanent damage.

Lead is a poison that accumulates in the blood, bones, and organs, including the kidneys, brain, and liver. It stays in the bones for decades and may be released slowly over time to cause toxic effects.

An increasing blood-lead level usually means that there has been recent exposure and that lead is building up in the body faster than it is being eliminated. The early effects of lead poisoning are not specific and resemble flu-like illnesses.

Cumulative exposure to lead, which is typical in-home settings, may result in damage to the blood, nervous system, kidneys, bones, heart, and reproductive system and contributes to high blood pressure. It is especially toxic to young children and women of childbearing age.

The symptoms of lead poisoning include the following:

• Headache • Sleeplessness

• Poor appetite • Hyperactivity

• Dizziness • Weakness

• Irritability or anxiety • Reproductive difficulties

• Constipation • Nausea

• Pallor • Fine tremors

• Excessive tiredness • Insomnia

• Numbness • “Lead line” on the gums

• Metallic taste in the mouth • “Wrist drop” [muscle weakness]

• Muscle or joint pain or soreness

October 8, 2013 Lead Page 7 Mountain Consulting Services

STATEMENT OF PROFESSIONALISM

Mountain Consulting Services hereby certify that, to the best of our knowledge and ability that the Pre-Demolition “Good-Faith” Lead Coatings Survey conducted for the suspect coatings present with the Single-Family Residence and Two (2) Outbuilding Structures residing on the rural property addressed at 26206 South Cheney-Spangle Road in Cheney, Washington, reflects an accurate level of lead content for the identified coating included for testing associated with this project.

________________________________________ May 22, 2020 David A. Jones Date Certified EPA/WA ST Lead Risk Assessor Certificate: 0567 Expiration: February 16, 2022

This report was prepared for the exclusive use by Turnbull National Wildlife Refuge of Cheney, Washington and/or representatives thereof. It may be reproduced only in full and with the written permission of Mountain Consulting. The accuracy of this report is void unless the document remains unaltered and unabridged.

Project No. 20-048.1-B PD-ACM/LBP Survey

APPENDIX A

CERTIFICATIONS AND

ACCREDITATIONS

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Effective: 10/14/2016 Scope_ELLAP_R7

AIHA Laboratory Accreditation Programs, LLC

SCOPE OF ACCREDITATION

EMSL Analytical, Inc. Laboratory ID: 100194 200 Route 130 North, Cinnaminson, NJ 08077 Issue Date: 11/30/2018

The laboratory is approved for those specific field(s) of testing/methods listed in the table below. Clients are urged to verify the laboratory’s current accreditation status for the particular field(s) of testing/Methods, since these can change due to proficiency status, suspension and/or withdrawal of accreditation.

The EPA recognizes the AIHA-LAP, LLC ELLAP program as meeting the requirements of the National Lead Laboratory Accreditation Program (NLLAP) established under Title X of the Residential Lead-Based Paint Hazard Reduction Act of 1992 and includes paint, soil and dust wipe analysis. Air and composited wipes analyses are not included as part of the NLLAP.

Environmental Lead Laboratory Accreditation Program (ELLAP)

Initial Accreditation Date: 01/18/1995

A complete listing of currently accredited Environmental Lead laboratories is available on the AIHA-LAP, LLC website at:

http://www.aihaaccreditedlabs.org

Field of Testing (FoT) Technology sub-type/

Detector Method Method Description

(for internal methods only)

Paint EPA SW-846 3050B

EPA SW-846 7000B

Soil EPA SW-846 3050B

EPA SW-846 7000B

Settled Dust by Wipe EPA SW-846 3050B

EPA SW-846 7000B

Airborne Dust NIOSH 7082

Composited Wipes EPA SW-846 3050B

EPA SW-846 7000B

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APPENDIX B

ASBESTOS BULK SAMPLING

ANALYSIS REPORT

9922 East Montgomery Suite 13 TESTING Spokane Valley, WA 99206 NVLAP LAB CODE 101890-0

(509) 922-1365 ● Fax (509) 922-1380

Polarized Light Microscopy, NVLAP Accreditation

May 19, 2020

Mountain Consulting Services, LLC Project: 26206 South Cheney-Spangle Road, Cheney

Todd Lewis Project #: 20-048.1-B

9922 E. Montgomery Avenue, Suite 9

Dear Mr. Lewis, The enclosed report details results for the analysis of the bulk sample(s) submitted to Mountain Laboratories on May 12, 2020. Sample analysis was performed to determine asbestos type and content using Polarized Light Microscopy, supplemented by Dispersion Staining (PLM/DS).

This report includes a summary of the analytical results and chain of custody. Analytical results are only reflective of the samples, which were tested and presented in this report. Mountain Laboratories limits warranty to proper analysis methods and takes no responsibility for sample procurement.

It has been our pleasure providing you with these analytical services. If you have any questions regarding this report, please do not hesitate to call us at (509) 922-1365.

Sincerely, Heidi L. Porret Laboratory Manager Mountain Laboratories Mountain Laboratories NW, Inc.

Enclosure: 1023.19780.19811H

MOUNTAIN LABORATORIES

BULK SAMPLE ANALYSIS FOR ASBESTOS

9922 E. Montgomery Avenue, Suite 9

Spokane Valley, WA 99206

Test Method: EPA-600/R-93/116: Interim Method for the Determination of Asbestos in Bulk Building Materials. Customer #: 1023

Laboratory No. B20-19780 B20-19781 B20-19782

Sample ID No. 20-048.1-B-01 20-048.1-B-02 20-048.1-B-03

Sample Description Ceramic Tile w/Grout & Thin Set

Ceramic Tile w/Grout & Thin Set

Ceramic Tile w/Grout & Thin Set

Sample Treatment Teased/Crushed Heated

Teased/Crushed Heated

Teased/Crushed Heated

Homogeneous No No No

Layered Yes Yes Yes

Fibrous Yes Yes Yes

Sample Color White/Dark Gray Gray/Off White

White/Dark Gray Gray/Off White

White/Dark Gray Off White

Asbestos Present No No No

Asbestos Type and Percentage

Ceramic Tile: N.D.

White Mastic: N.D.

Grout: N.D.

Thin Set: N.D.

Ceramic…