B08_Attach_1_MORA_313019_331809_312439_Final_Specifications_App_A.pdf

HAZARDOUS MATERIALS ASSESSMENT

REPORT FOR 11 BUILDINGS AT THE

OHANAPECOSH CAMPGROUND AT MOUNT

RAINIER NATIONAL PARK IN WASHINGTON

98377

Prepared for:

Anderson Hallas Architects, P.C.

715 14th Street

Golden, CO 80401

Prepared by:

Landmark Environmental, Inc.

7881 Shaffer Parkway

Littleton, CO 80127

Landmark Project No. 22040.001.001

PMIS MORA 312439 & 313019

June 15, 2022

CONTENTS

Landmark Project No. 22040.001.001 i

EXECUTIVE SUMMARY ................................................................................................... A

ASBESTOS ................................................................................................................................................. A

LEAD ........................................................................................................................................................ D

REGULATED BUILDING MATERIALS ........................................................................................................ D

BIOLOGICAL HAZARDS ............................................................................................................................ D

1.0 INTRODUCTION ................................................................................................. 1-1

1.1 PURPOSE ..................................................................................................................................... 1-1

1.2 PROJECT SITE DESCRIPTION ....................................................................................................... 1-1

1.3 REPORT ORGANIZATION ............................................................................................................ 1-2

2.0 ASBESTOS ......................................................................................................... 2-1

2.1 ASBESTOS REGULATORY CRITERIA ........................................................................................... 2-1

2.2 ASBESTOS ASSESSMENT TECHNICAL APPROACH ...................................................................... 2-2

2.3 ASBESTOS LABORATORY ANALYSIS .......................................................................................... 2-3

3.0 LEAD................................................................................................................... 3-1

3.1 REGULATORY CRITERIA ............................................................................................................. 3-1

3.2 TECHNICAL APPROACH .............................................................................................................. 3-2

3.3 LEAD LABORATORY ANALYSIS ................................................................................................. 3-3

4.0 REGULATED BUILDING MATERIALS ................................................................. 4-1

5.0 BIOLOGICAL HAZARDS ...................................................................................... 5-1

6.0 FINDINGS ........................................................................................................... 6-1

6.1 AMPHITHEATER .......................................................................................................................... 6-1

6.2 BATHROOM #1 (CS O-304) ........................................................................................................ 6-2

6.3 BATHROOM #2............................................................................................................................ 6-3

6.4 BATHROOM #3............................................................................................................................ 6-4

6.5 BATHROOM #4............................................................................................................................ 6-6

6.6 BATHROOM #5 (CS O-306) ........................................................................................................ 6-7

6.7 BATHROOM #6 (CS O-307) ........................................................................................................ 6-8

6.8 BATHROOM #7 (CS O-309) ...................................................................................................... 6-10

6.9 BATHROOM #8 (CS O-310) ...................................................................................................... 6-11

6.10 BATHROOM #9 (CS O-308) ...................................................................................................... 6-12

6.11 VISITOR'S CENTER .................................................................................................................... 6-14

7.0 RECOMMENDATIONS ......................................................................................... 7-1

Landmark Project No. 22040.001.001 ii

7.1 ASBESTOS ................................................................................................................................... 7-1

7.2 LEAD .......................................................................................................................................... 7-1

7.3 REGULATED BUILDING MATERIALS .......................................................................................... 7-2

7.4 BIOLOGICAL HAZARDS .............................................................................................................. 7-2

8.0 LIMITATIONS ..................................................................................................... 8-1

9.0 ENDORSEMENTS ............................................................................................... 9-1

APPENDICES

APPENDIX A SITE OVERVIEW MAP

APPENDIX B AMPHITHEATER BUILDING INFORMATION

APPENDIX C BATHROOM #1 (CS O-304) BUILDING INFORMATION

APPENDIX D BATHROOM #2 BUILDING INFORMATION

APPENDIX E BATHROOM #3 BUILDING INFORMATION

APPENDIX F BATHROOM #4 BUILDING INFORMATION

APPENDIX G BATHROOM #5 (CS O-306) BUILDING INFORMATION

APPENDIX H BATHROOM #6 (CS O-307) BUILDING INFORMATION

APPENDIX I BATHROOM #7 (CS O-309) BUILDING INFORMATION

APPENDIX J BATHROOM #8 (CS O-310) BUILDING INFORMATION

APPENDIX K BATHROOM #9 (CS O-308) BUILDING INFORMATION

APPENDIX L VISITOR’S CENTER BUILDING INFORMATION

APPENDIX M NPS HANTAVIRUS RISK REDUCTION – WORKER PROTECTION – DECEMBER 2013

APPENDIX N CERTIFICATIONS

Landmark Project No. 22040.001.001 A

EXECUTIVE SUMMARY

Landmark Environmental, Inc. (Landmark) was retained by Anderson Hallas Architects (Client) to conduct a hazardous materials assessment for 11 buildings located at Ohanapecosh Campground at Mount Rainier

National Park (MORA) in Washington (collectively the Project Site) to support the historical rehabilitation work for these buildings (PMIS 312439 & 313019). The 11 structures included in the scope of work for the hazardous materials assessment project included the Amphitheater, Bathroom #1 (Comfort Station [CS] O-

304), Bathroom #2, Bathroom #3, Bathroom #4, Bathroom #5 (CS O-306), Bathroom #6 (CS O-307), Bathroom #7 (CS O-309), Bathroom #8 (CS O-310), Bathroom #9 (CS O-308), and the Visitor’s Center structure. The hazardous materials assessment work included asbestos-containing materials (ACM), lead-containing paint (LCP), regulated building materials (RBM), and biological hazards (including rodents, microbial growth, and water damage) assessments. The purpose of these assessments was to identify and quantify the ACM, LCP, RBM, and other biological hazards to develop cost estimates to support pre-design documentation and schematic design phases of the project.

Asbestos

Asbestos assessment services were performed to identify the presence, location, quantity, friability, and condition of ACM located at the Project Site. Bulk samples were collected and analyzed for suspect ACMs.

One material was confirmed to be ACM at the Amphitheater, including an exterior grey pliable caulking around a metal garage door. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed

ACM are electrical wiring insulation and residual roofing sealant material.

None of the suspect building materials sampled and analyzed from Bathroom #1 (CS O-304) were ACM.

However, two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed ACM include the electrical wiring insulation and residual roofing sealant material.

None of the suspect building materials sampled and analyzed from Bathroom #2 were ACM. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because the sampling would pose a safety hazard. The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

Two materials were confirmed to be ACM at the Bathroom #3 building, including 12" by 12" and 9" by 9"

Executive Summary

Landmark Project No. 22040.001.001 B tan mottled floor tiles with associated black mastic. Two suspect building materials were presumed to be

ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard.

The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

One material was confirmed to be ACM at the Bathroom #4 building, including the 12" by 12" tan mottled floor tiles with associated black mastic. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

One material was confirmed to be ACM at the Bathroom #5 (CS O-306) building, including an interior pliable grey window caulking associated with metal window frames. Three of the suspect building materials were presumed to be ACM and were not sampled either to protect the finishes or because sampling would pose a safety hazard. The three presumed ACM included electrical wiring insulation, residual roofing sealant, and suspect window glazing material associated with the metal window frames.

Two materials were confirmed to be ACM at the Bathroom #6 (CS O-307) building, including exterior brittle white caulking and grey brittle window glazing materials both associated with the metal window frames. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

Two materials were confirmed to be ACM at the Bathroom #7 (CS O-309) building, including exterior brittle white caulking and grey brittle window glazing materials both associated with the metal window frames. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

One material was confirmed to be ACM at the Bathroom #8 (CS O-310) building, including grey brittle window glazing material associated with the metal windows. Two suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The two presumed ACM included the electrical wiring insulation and residual roofing sealant material.

Two materials were confirmed to be ACM at the Bathroom #9 (CS O-308) building, including exterior brittle white caulking and grey brittle window glazing materials both associated with the metal window frames. Two of the suspect building materials were presumed to be ACM and were not sampled to either

Landmark Project No. 22040.001.001 C protect the finishes or because sampling would pose a safety hazard. The two presumed ACM included electrical wiring insulation and residual roofing sealant material.

Two materials were confirmed to be ACM at the Visitor’s Center building, including an off-white brittle window caulking associated with wooden window frames and light grey pipe insulation and elbows. One material was identified as trace-asbestos containing (<1% asbestos), including ½" white composite drywall system materials (wallboard, tape, and joint compound). Three of the suspect building materials were presumed to be ACM and were not sampled to either protect the finishes or because sampling would pose a safety hazard. The three presumed ACM included electrical wiring insulation, suspect adhesive behind wall laminate in the south visitor bathrooms, and roofing sealant material.

Prior to any renovation or demolition activities in any public or commercial building which may disturb greater than 48 square feet or ten linear feet, a notification must be submitted to the Washington Department of Labor and Industries Division of Occupational Safety and Health (DOSH) under the National Emission

Standards for Hazardous Air Pollutants (NESHAP) program. A notification must also be submitted to the

Puget Sound Clean Air Agency for projects involving the removal of ten or more linear feet of friable ACM, removal of 48 or more square feet of friable ACM, and for demolition with a projected roof area greater than 120 square feet. All ACM that will be disturbed during the renovation or demolition work must be removed in accordance with all applicable U.S. Environmental Protection Agency (EPA), the Occupational

Safety and Health Administration (OSHA), DOSH, and Puget Sound Clean Air Agency regulations.

If the ACM is to remain in place, it is recommended that an Asbestos Operations and Maintenance (O&M)

Program be developed. The O&M Program includes a listing of known ACM within these buildings and procedures to minimize the potential for disturbance of ACM. O&M Programs are designed to present the processes for communication and planning regarding ACM management, reduce the potential for unplanned impacts that may cause ACM disturbance or damage, consolidate and organize data collected related to ACM to facilitate planning and management, training requirements, notifications, and monitoring the condition of the ACM over time.

Additionally, damaged ACM pipe insulation and fitting materials were identified underneath a leaking sink in the janitor's closet #3 room at the Visitor’s Center building. The trace-asbestos-containing composite drywall materials in this same room are also water-damaged and had visible mold growth. Access to the janitor's closet #3 room should be restricted, and EPA-trained and state-certified asbestos abatement workers must abate the damaged pipe insulation and elbows, as well as the water-impacted trace-asbestos-containing composite drywall materials.

Landmark Project No. 22040.001.001 D

Lead

Readings of suspect LCPs were collected in a representative manner as determined by the inspector based on identifying testing combinations where the surface color, substrate, or building component were visibly different. The screening was limited to paints and other materials that were visible and readily accessible to the inspector.

Several paints in each of the buildings are LCP or lead-based paint (LBP). Landmark also found several lead-containing materials (LCM), including porcelain fixtures. All LCP, LBP, and LCM were in fair to good condition at the time of this assessment and can remain in place unless impacted by the renovation work activities.

If LCP, LBP, or LCM is impacted during the construction renovation to the extent that dust may be created, then they must be handled by OSHA-trained workers. Before any renovation activities, disclosure to the contractors working in the building is required, and all waste generated that contains an LCP, LBP, or LCM must be profiled, handled appropriately, and properly disposed.

Regulated Building Materials

Typical RBM found throughout these building structures included computer equipment, devices that contain refrigerants (chlorofluorocarbons [CFCs]), smoke detectors (which can contain radiation sources), battery-operated equipment, light bulbs (which can contain mercury), light ballasts (which could contain polychlorinated biphenyls [PCBs]), fire extinguishers, and one 500-gallon propane AST. If these items are to be disposed as part of the renovations, then special disposal and handling requirements will apply. These

RBMs can be managed through removal, disposal, or recycling, depending on the constituent and the local programs.

Biological Hazards

All bathroom (comfort station) structures assessed had evidence of rodent intrusion in the plumbing closets on soil and gravel floors. The plumbing closet areas of each bathroom consisted of a soil floor space covered with gravel. Rodent intrusion was also observed on the floor within the southeast storage room #2 of the

Amphitheater structure and on the floors inside of the Visitor’s Center in the janitor's closet room #3 and north boiler room #9. Renovation activities that occur on or near materials contaminated with rodent feces or rodent nesting will require disinfection prior to the renovation activities. It is recommended that National

Park Service (NPS) Hantavirus Guidelines be followed prior to working in areas with rodent contamination.

Landmark Project No. 22040.001.001 E

The available NPS facilities maintenance team members did not indicate poisonous insects (e.g., black widow and brown recluse spiders) or snakes are known to inhabit the structures located throughout the

Ohanapecosh Campground. Landmark's inspectors did not observe evidence of poisonous insects and snakes at the time of the site reconnaissance work.

Moisture-damaged trace asbestos-containing composite drywall materials with visible surficial mold were observed in the janitor's closet room #3 at the Visitor’s Center building. Similarly, moisture-impacted ACM pipe insulation and fittings were found underneath a leaking sink in the janitor's closet room #3 area. It is thought that the source of moisture in the janitor's closet room #3 is a combination of leaking plumbing components and frequent humidity inside of this unconditioned room. Landmark's inspectors additionally observed and photographed standing water that had pooled up inside of an out-of-service metal heating vent beneath the concrete slab in the naturalist's workshop #8 and boiler room #9 at the Visitor’s Center building. Any areas of the building that house pools of standing water could become reservoirs for mold and should be drained of standing water and cleaned with an antimicrobial cleaning product(s). The moisture-damaged building materials and the below slab metal ductwork with non-asbestos-containing insulation materials should be removed or cleaned, and mitigated in accordance with the Institute of

Inspection Cleaning and Restoration Certification (IICRC) and American National Standards Institute standards for mold and water damage restoration. Visible moisture and humidity were observed on surfaces within all nine of the bathroom structures; however, surficial mold growth was not observed on surfaces inside of the bathroom buildings at the time of Landmark's site visit.

Landmark Project No. 22040.001.001 1-1

1.0 INTRODUCTION

Landmark Environmental, Inc. (Landmark) was retained by Anderson Hallas Architects (Client) to conduct a hazardous materials assessment for 11 buildings located at Ohanapecosh Campground at Mount Rainier

National Park (MORA) in Washington (collectively the Project Site) to support the historical rehabilitation work for these buildings (PMIS 312439 & 313019). The 11 structures included in the scope of work for the hazardous materials assessment project included the Amphitheater, Bathroom #1 (Comfort Station [CS] O-

304), Bathroom #2, Bathroom #3, Bathroom #4, Bathroom #5 (CS O-306), Bathroom #6 (CS O-307), Bathroom #7 (CS O-309), Bathroom #8 (CS O-310), Bathroom #9 (CS O-308), and the Visitor’s Center structure. The hazardous materials assessment work included asbestos-containing materials (ACM), lead-containing paint (LCP), regulated building materials (RBM), and biological hazards (including rodents, microbial growth, and water damage) assessments. The purpose of these assessments was to identify and quantify the ACM, LCP, RBM, and other biological hazards to develop cost estimates to support pre-design documentation and schematic design phases of the project.

1.1 Purpose

The purpose of Landmark's assessment of the Project Site was to assess and identify ACM, LCP, RBM, and biological hazards as part of the design documentation and construction documentation phases of the

MORA planned projects. Accordingly, our screening-level environmental assessment has been designed to provide the appropriate information to support project planning and the budgeting for eventual renovation.

Landmark conducted an assessment of the Project Site and associated 11 buildings between May 3 and 5, 2022.

Landmark identified ACM and RBM that must be removed and properly disposed of prior to renovation activities. Landmark also identified lead-based paint (LBP), LCP, and lead-containing material (LCM), that have handling and disposal requirements if impacted by the renovation work activities. Lastly, Landmark visually assessed the Project Site for water intrusion and biological hazards, which should be addressed as part of the renovations as these can have impacts on occupants and/or workers who are working in the space.

1.2 Project Site Description

Landmark understands from the historical documentation review that the Visitor’s Center, Amphitheater, Bathroom #5 (CS O-306), Bathroom #6 (CS O-307), Bathroom #7 (CS O-309), Bathroom #8 (CS O-310), Introduction

Landmark Project No. 22040.001.001 1-2 and Bathroom #9 (CS O-308) structures were built in the 1960s via the historical Mission 66 program. The

Bathroom #1 (CS O-304), Bathroom #2, Bathroom #3, and Bathroom #4 structures were built in the 1930s as part of the historical Civilian Conservation Corps (CCC) program.

The buildings will undergo major renovations, which are anticipated to impact walls, floors, ceilings, and exterior façade spaces, in addition to mechanical and electrical equipment.

1.3 Report Organization

This report presents the general findings of the assessment and sampling efforts for the Project Site. Further detail is provided on a building-specific basis in Appendices B through L. Each building's Appendix includes an asbestos homogeneous materials summary, asbestos laboratory report, asbestos-containing materials, non-asbestos-containing materials summary tables, sample location figure, ACM location figure, lead paint screening summary table, RBM inventory, and a photograph log.

The National Park Service (NPS) developed guidelines for Hantavirus that are included in Appendix M.

Credentials for the building inspectors are included within Appendix N. The purpose of this format for report organization is to allow for individual presentation of the findings within each building.

Landmark Project No. 22040.001.001 2-1

2.0 ASBESTOS

In this section, the regulatory criteria, technical approach, laboratory analysis, and findings as they pertain to asbestos are discussed.

2.1 Asbestos Regulatory Criteria

Asbestos is a naturally occurring fibrous mineral that was historically used in thousands of construction and commercial applications due to its properties of tensile strength, heat and chemical resistance, non-conductivity, and acoustical absorption. Asbestos is a confirmed human carcinogen that can cause diseases such as asbestosis, lung cancer, and mesothelioma; therefore, asbestos is regulated by the U.S.

Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA).

This brief overview of the certain applicable asbestos regulatory criteria is general and for informational purposes only.

In general, removal/repair of ACM is required by regulation if the potential exists for an airborne release of asbestos fibers or if the ACM will be disturbed. Typically, the potential for an airborne release of asbestos fibers exists in three circumstances:

1. The ACM will be impacted during maintenance, renovation, or demolition.

2. The material has significantly deteriorated to the extent that the asbestos is in poor condition or that asbestos debris is present.

3. The ACM will be subject to future deterioration by vibration, airflow, or weathering.

Applicable asbestos regulations define ACM as material containing greater than 1% asbestos by weight, volume, or visual surface area and also distinguish between friable and non-friable forms of ACM. Friable

ACMs can be crumbled or reduced to powder by hand pressure when dry. Non-friable materials cannot be crumbled, pulverized, or reduced to powder by hand pressure.

The EPA and National Emission Standards for Hazardous Air Pollutants (NESHAP) further classify non-friable ACM as Category I and II. Category I non-friable ACMs include ACM packings, gaskets, resilient floor coverings, and asphalt roofing products. Category II non-friable ACMs are defined as all other non-friable ACM, such as cement board, window putty, etc. Category I non-friable ACMs may remain in the building during demolition if demolition activities do not render the ACMs friable. All other ACMs (non-

Category I) must be removed prior to demolition.

Asbestos

Landmark Project No. 22040.001.001 2-2

The OSHA regulations in 29 Code of Federal Regulations (CFR) 1926.1101 require that building owners inform prospective contractors, employees, and tenants of the presence, location, and quantity of ACM or presumed ACM (PACM) in their buildings and facilities. OSHA requires the protection of workers from exposure to asbestos through notification, training, proper work practices, and the use of personal protective equipment (PPE).

If the amount of ACM that will be disturbed exceeds the following trigger levels, then a certified abatement contractor must remove the ACM prior to renovation or demolition activities. Trigger levels of ACM per the DOSH are 48 square feet or ten linear feet. Although certain non-friable ACM could remain within a building during demolition, the presence of non-friable ACM may impact disposal and will preclude the recycling of materials. Recycling of materials, such as concrete or wood, that are bonded or contaminated with ACM is not permitted.

Demolition of a building structure that has non-friable ACM vinyl asbestos tile (VAT), tar-impregnated roofing materials, or drywall joint compound in composite wallboard systems must be completed without causing the ACM to become friable. Operations such as crushing, pneumatic jacking, etc. that render the

ACM friable are not permitted. When imploding or burning a building, all ACM, regardless of quantity, must be removed prior to these activities.

2.2 Asbestos Assessment Technical Approach

The sampling was conducted in accordance with the EPA Asbestos Hazard and Emergency Response Act

(AHERA) and OSHA 29 CFR 1926.1101 requirements, as well as generally accepted industry standards.

Asbestos activities were conducted by AHERA-accredited personnel. Copies of the inspector's credentials are included in Appendix N.

The assessment included visually assessing the Project Site facilities for homogeneous areas, performing a physical assessment of the materials, and sampling suspect ACMs. Bulk samples of accessible suspect

ACMs were collected in a representative manner as determined by the field inspectors. Bulk material samples were collected by taking representative samples that included all layers within the suspect ACM.

Sampling was limited to materials that were visible and readily accessible to the inspector. No intrusive investigation was conducted. Representative sampling was based on the distribution of the suspect material throughout the homogeneous area and the suspect material's physical characteristics and application.

The friable suspect ACMs were separated into the following three classifications with specific sampling requirements. These classifications and respective sampling requirements are as follows:

Landmark Project No. 22040.001.001 2-3

• Surfacing Materials – Trowel or sprayed applied materials:

o Three samples of each homogeneous area of 1,000 square feet or less.

o Five samples of each homogeneous area which is greater than 1,000 square feet and less than

5,000 square feet.

o Seven samples of each homogeneous area greater than 5,000 square feet.

• Thermal System Insulation (TSI):

o Three samples of each homogeneous area.

o Two samples of a patching material that is less than six feet in length.

• Miscellaneous Materials – Other suspect materials not classified in the above categories:

o Sufficient number to determine asbestos content and a minimum of two samples.

Bulk ACM samples were given unique numeric identifiers for project tracking and identification purposes.

The first set of letters is a building code. Each building was abbreviated to its initials (i.e., the Visitor Center is VC). The second set of numbers represents the room number. This is keyed to the Figures. The third letter/number combinations identify the type of material the bulk sample was collected from and the homogeneous material identifier for the functional space. The last set of numbers represents the sequential sample acquired for the homogeneous material.

As suspect asbestos materials were identified, the materials were also quantified, and the condition of the suspect ACMs was assessed (i.e., friability was assessed, and ACM was evaluated for any damage or deterioration).

2.3 Asbestos Laboratory Analysis

The suspect ACM bulk samples were submitted to EMSL Analytical, Inc. (EMSL), located in Seattle, WA.

EMSL's Seattle, WA location is a National Voluntary Laboratory Accreditation Program (NVLAP) and a

State of Washington Department of Ecology accredited laboratory for Bulk Asbestos Fiber Analysis. The samples were analyzed by utilizing Polarized Light Microscopy (PLM) coupled with dispersion staining techniques as detailed in the EPA's "Interim Method for Determination of Asbestos in Bulk Insulation

Samples" (EPA 40 CFR Part 763 Subpart F, Appendix A). The detection limits for PLM analysis are

Landmark Project No. 22040.001.001 2-4 approximately 1% (by surface area). Materials containing greater than 1% asbestos are classified as ACM.

Asbestos content is reported by the laboratory for each unique layer. Analytical results report asbestos by mineral type and the concentration as a visual estimation of percent by weight both by layer and in the composite sample. An individual asbestos laboratory report was generated per building. Asbestos analytical data is presented by building in Appendices B through L.

Landmark Project No. 22040.001.001 3-1

3.0 LEAD

The regulatory criteria, technical approach, laboratory analysis, and findings as they pertain to lead paint, lead in soil, and additional lead samples are discussed below.

3.1 Regulatory Criteria

The EPA and the U.S. Department of Housing and Urban Development (HUD) regulate LBP abatement work activities in target housing and child-occupied facilities. Target housing is defined as any housing constructed prior to 1978 that is occupied by a child under age six. A child-occupied facility is a building constructed prior to 1978 that is visited regularly by the same child under age six.

The EPA and HUD regulations related to LBP abatement do not apply to the Project Site unless abatement activities occur (specifically designed to permanently remove the LBP). LBP is defined as paint containing

0.5% by weight or 1.0 milligram per square cubic centimeter (mg/cm2) by EPA and HUD. OSHA regulates worker exposure to lead for coatings with any detectable lead.

The EPA also developed a program for renovation activities in child-occupied/target housing and child-care facilities called the Lead Renovation, Repair, and Paint Rule (RRP Rule). This rule requires that firms performing renovation, repair, and painting projects that disturb LBP in homes, child-care facilities, and pre-schools built before 1978 have their firm certified by EPA (or an EPA authorized state), use certified renovators who are trained by EPA-approved training providers, and follow lead-safe work practices.

The EPA and HUD regulate LBP abatement activities in target housing and child-occupied facilities. EPA and HUD regulations related to LBP abatement do not apply to the buildings located at the Project Site as they are not considered to be target housing or child-occupied facilities.

The OSHA lead in construction standard 29 CFR 1926.62 addresses the requirements for sites where the employer has reason to believe that any employee may be exposed to lead in excess of OSHA's action level

(AL) of 30 micrograms per cubic meter (µg/m3) over an eight-hour time-weighted average. This OSHA standard applies to all construction activities that may impact LCP and LCM (any detectable lead).

Any renovation activities involving LBP are subject to the OSHA Construction Industry Standard for Lead

(Title 29 CFR, Part 1926.62). This standard is similar to the other OSHA standards and addresses such issues as worker training, medical evaluations, PPE, exposure assessment, air monitoring, hygiene facilities, and work practices.

Landmark Project No. 22040.001.001 3-2

To comply with EPA air, solid waste, and water quality standards, appropriate work practices, engineering controls, and other precautions should be taken to ensure LCMs are not introduced into the surrounding roadway, soil, road drainage systems, and waterways. The EPA has established screening levels/cleanup criteria for lead in soils based on expected residential usage. The levels are 400 milligrams per kilogram

(mg/kg) for high contact play areas and 1200 mg/kg for non-play area residential yard soil.

Additionally, the LCMs with a total lead content equal to or exceeding 0.01% by weight could exceed the

EPA Resource Conservation and Recovery Act (RCRA) standard and are subject to a hazardous waste determination under EPA regulations. Representative waste characterization should be performed using the

Toxicity Characteristic Leaching Process (TCLP) analytical method. The Toxicity Characteristic (TC) limit for lead is five parts per million (ppm) in the leachate. Materials that exceed this limit must be disposed as hazardous waste. Materials that do not exceed this limit may be disposed as solid waste.

Materials that are reused or recycled, such as metal components, are not subject to waste characterization provisions under the EPA, but proper disclosure of LCMs should be provided to the recycling facility for hazard communication purposes.

The types and locations of LBP and LCP and regulatory requirements should be disclosed to the General

Contractor and building owner's staff to avoid accidental disturbance and for contractor compliance with applicable regulations (to ensure proper worker protection and material disposal).

3.2 Technical Approach

The LCP, LBP, and LCM assessment was performed by a trained lead paint inspector. This assessment was completed utilizing a handheld X-Ray Fluorescence (XRF) meter in the field. Readings of suspect LCPs were collected in a representative manner as determined by the field inspector based on identified testing combinations where the surface color, substrate, or building component were visibly different. Sampling was limited to materials that were visible and readily accessible to the inspector. The XRF equipment was subject to pre-calibration, calibration checks every four hours, and post-calibration as recommended by the manufacturer. The XRF reports the concentration of lead in mg/cm2. Paint is considered LBP when the results are above 1.0 mg/cm2, and paint is considered LCP when the lead is detected by the XRF above its detection limit but below 1.0 mg/cm2. The lead screening results are summarized by building in Appendices

B through L.

Landmark Project No. 22040.001.001 3-3

3.3 Lead Laboratory Analysis

Soil samples were collected from the exterior dripline areas of each of the 11 building structures. The soil samples collected were submitted to the EMSL laboratory in Cinnaminson, NJ. EMSL's Cinnaminson, NJ location is an American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program (LAP) accredited lab for lead in environmental matrices, paint, soil, and wipes through AIHA LAP Environmental

Lead Laboratory Accreditation Program (ELLAP). EMSL's Cinnaminson, NJ laboratory is also accredited by the State of Washington Department of Ecology for lead laboratory analysis. All exterior dripline soil samples were analyzed by the EPA SW 846 3050B/7000B method. Results of lead laboratory analysis were compared to the EPA limit for residential soils (non-child play areas) of 1,200 parts per million (ppm).

Landmark Project No. 22040.001.001 4-1

4.0 REGULATED BUILDING MATERIALS

The regulatory criteria, technical approach, and findings pertaining to RBM are discussed below.

The RBM inventory included visual identification and quantification of the following types of materials:

refrigerants (Chlorofluorocarbons [CFCs]); waste oils or mechanical chemicals; fluorescent bulbs and light ballasts potentially containing mercury and Polychlorinated Biphenyls (PCBs), respectively; utility switches and thermostats potentially containing mercury; high-intensity discharge exterior lighting; any fixtures that contain or may contain batteries, and Aboveground Storage Tanks (ASTs).

This inventory was limited to the materials which were visible and readily accessible to the inspector, and additional RBM may be discovered during renovation or demolition work. An inventory for each building is included in Appendices B through L.

Landmark Project No. 22040.001.001 5-1

5.0 BIOLOGICAL HAZARDS

Landmark conducted limited observations for biological hazards during the Project Site assessment. These observations were primarily limited to rodent or insect infestations, water intrusion, or visual evidence of mold growth through the structures.

Due to the presence of rodent droppings observed in the structures, there is a risk of Hantavirus exposure for anyone handling items inside, outside, or working on the structure. The NPS guidelines for Hantavirus Worker

Protection are included in Appendix M.

Landmark Project No. 22040.001.001 6-1

6.0 FINDINGS

A brief summary of the findings for each category (ACM, LCP, RBM, and biological hazards) are included below. The data tables and more in-depth summaries have been included in Appendices B through L. Each building Appendix includes a summary of homogeneous asbestos materials, asbestos and lead laboratory reports, ACM and non-asbestos-containing materials summary tables, figures depicting sample locations and ACM locations, LCP screening summary, regulated building material inventory, and a photograph log.

6.1 Amphitheater

Asbestos-Containing Materials

A total of four bulk samples of suspect ACMs were collected from two homogeneous materials, and two materials were presumed to contain asbestos.

The following material was confirmed to be ACM:

• Caulking (CK01): Grey pliable exterior caulking associated with a metal garage door contains 7%

Chrysotile asbestos.

The following materials are presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

Lead Paint

XRF readings were collected from 12 different painted components and building materials. The following items are considered LCP:

• Dark brown paint on wooden wall framing, exterior walls, exterior doors, stair railings, and signage is LCP.

• Black paint on a wooden garage door, an exterior door, and a door frame is LCP.

Findings

Landmark Project No. 22040.001.001 6-2

One composite soil sample was collected from the driplines of the Amphitheater structure. The soil sample was analyzed via Flame Atomic Absorption Spectrometry (FAAS) and was found to be below the EPA limit for residential soils (non-child play areas) of 1,200 ppm.

Regulated Building Materials

Some potential RBMs were identified at this structure, including the compact and high-intensity light bulbs

(which can contain mercury) and computer equipment (stereo and other audiovisual equipment).

Biological

Landmark's inspectors found rodent droppings on the floor inside the storage closet #2 area. Signs of moisture intrusion and visible mold growth were not found at the Amphitheater structure at the time of the site reconnaissance work.

6.2 Bathroom #1 (CS O-304)

Asbestos-Containing Materials

A total of ten bulk samples of suspect ACM were collected from five homogeneous materials. Two materials were presumed to be ACM.

The following materials were presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

Lead Paint

XRF readings were taken from 28 different painted and glazed components and building materials. The following items are considered LCP or LCM:

• Dark brown paint on exterior doors is LCP.

• White paint on exterior doors and window frames is LCP.

Landmark Project No. 22040.001.001 6-3

• White porcelain sinks are LCM.

• White paint on wooden bathroom stall partitions is LBP.

• Grey paint on the concrete floor slab is LCP.

One composite soil sample was collected from the driplines of the Bathroom #1 (CS O-304) structure. The soil sample was analyzed by FAAS and was found to be below the EPA limit for residential soils (non-child play areas) of 1,200 ppm.

Regulated Building Materials

Some potential RBM were identified in this building, including compact light bulbs and fluorescent light tubes (which can contain mercury), and light ballasts (that can contain PCBs).

Biological

Rodent droppings were observed on the unfinished soil floor surface area inside plumbing closet room #3.

Visible moisture and humidity were apparent on the wall, ceiling, and floor surfaces inside this bathroom structure due to the spaces being unconditioned. However, visible microbial growth was not observed at the time of Landmark's site visit.

6.3 Bathroom #2

Asbestos-Containing Materials

A total of six samples of suspect ACM were collected from three homogeneous materials. Two materials were presumed to be ACM.

The following materials were presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

Lead Paint

Landmark Project No. 22040.001.001 6-4

XRF readings were collected from 25 different painted and glazed components and building materials. The following items are considered LCP or LCM:

• Grey pipe solder on metal piping is LCM.

• Dark brown paint on wood log façade walls is LCP.

• White paint on concrete walls, bathroom partition stalls, and doors is LCP.

One composite soil sample was collected from the driplines of the Bathroom #2 building structure. The soil sample was analyzed via FAAS and was found to be below the EPA limit for residential soils (non-child play areas) of 1,200 ppm.

Regulated Building Materials

Some potential RBM were identified in this building, including compact light bulbs and fluorescent light tubes (which can contain mercury), and light ballasts (that can contain PCBs).

Biological

Rodent droppings were observed on the unfinished soil floor surface area inside plumbing closet room #3.

Visible moisture and humidity were apparent on the wall, ceiling, and floor surfaces inside this bathroom structure due to the spaces being unconditioned. However, visible microbial growth was not observed at the time of Landmark's site visit.

6.4 Bathroom #3

Asbestos-Containing Materials

A total of 12 samples of suspect ACMs were collected from seven homogeneous materials. Two materials were presumed to be ACM.

The following materials were confirmed to be ACM:

• Floor Tile with Mastic (FTC01): 12" by 12" tan mottled floor tiles with black mastic contains 4%

Chrysotile asbestos.

• Floor Tile and Mastic (FTC02): 9" by 9" tan mottled tiles and black mastic contains 4% Chrysotile asbestos.

Landmark Project No. 22040.001.001 6-5

The following materials were presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

Lead Paint

XRF readings were taken from 24 different painted and glazed components and building materials. The following items are considered LCP, LBP, or LCM:

• White paint on wooden window frames is LCP.

• White paint on wood bathroom partition stalls is LBP.

• Dark brown paint on exterior log façade walls and exterior doors is LCP.

• White porcelain sinks are LCM.

One composite soil sample was collected from the driplines of the Bathroom #3 building structure. The soil sample was analyzed via FAAS and was found to be below the EPA limit for residential soils (non-child play area) of 1,200 ppm.

Regulated Building Materials

Some potential RBMs were identified in this building, including compact light bulbs and fluorescent light tubes (which can contain mercury) and light ballasts (that can contain PCBs).

Biological

Rodent droppings were observed on the unfinished soil floor surface area inside plumbing closet room #3.

Visible moisture and humidity were apparent on the wall, ceiling, and floor surfaces inside this bathroom structure due to the spaces being unconditioned. However, visible microbial growth was not observed at the time of Landmark's site visit.

Landmark Project No. 22040.001.001 6-6

6.5 Bathroom #4

Asbestos-Containing Materials

A total of 12 bulk samples of suspect ACM were collected from six homogeneous materials. Two materials were presumed to be ACM.

The following material was confirmed to be ACM:

• Floor Tile with Mastic (FTC01): 12" by 12" tan mottled floor tiles with black mastic contains 4%

Chrysotile asbestos.

The following materials were presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

Lead Paint

XRF readings were taken from 22 different painted and glazed components and building materials. The following items are considered LCP, LBP, or LCM:

• Dark brown paint on wooden façade walls and exterior doors is LCP.

• White paint on wooden window frames, door frames, and interior walls is LCP.

• White porcelain sinks are LCM.

• White paint on wooden bathroom stall partitions is LBP.

One composite soil sample was collected from the driplines of the Bathroom #4 structure. The soil sample was analyzed via FAAS and was found to be below the EPA limit for residential soils (non-child play areas) of 1,200 ppm.

Landmark Project No. 22040.001.001 6-7

Regulated Building Materials

Some potential RBM were identified in this building, including compact light bulbs and fluorescent light tubes (which can contain mercury), and light ballasts (that can contain PCBs).

Biological

Rodent droppings were observed on the unfinished soil floor surface area inside plumbing closet room #3.

Visible moisture and humidity were apparent on the wall, ceiling, and floor surfaces inside this bathroom structure due to the spaces being unconditioned. However, visible microbial growth was not observed at the time of Landmark's site visit.

6.6 Bathroom #5 (CS O-306)

Asbestos-Containing Materials

A total of ten samples of suspect ACM were collected from five homogeneous materials. Three materials were presumed to be ACM.

The following materials were presumed to contain asbestos:

• Electrical Wiring Insulation (EI01): Electrical wiring insulation can potentially contain asbestos. It should be tested after the electrical system is de-energized and prior to removal. This material was not sampled because it poses safety risks to inspectors and can create a fire hazard post sampling.

• Roofing Sealant (RSL01): Original roofing sealant and other materials underneath the outer roofing system materials were inaccessible to the inspectors and are presumed to be ACM.

• Window glazing (WG01): A grey brittle window glazing material is suspected to be present under the metal window frames but could not be sampled without damaging these window frames.

Lead Paint

XRF readings were collected from 18 different painted and glazed components and building…