B08_Attachment_05_Asbestos_and_Lead_Survey_Report_-_Restroom_Loop_B_Rev__1.pdf

www.forensicanalytical.com Forensic Analytical Consulting Services

February 12, 2024

Asbestos and Lead Coatings Survey Report

Heart O’ the Hills Campground – Comfort Station Loop B 3002 Mt. Angeles Road Port Angeles, WA 98362

Prepared for:

Kurtis McGowan Maintenance Mechanic Supervisor Olympic National Park 541-252-1981 | Kurtis_McGowan@nps.gov

Prepared By:

Emily Ricker Forensic Analytical Consulting Services 17700 SW Upper Boones Ferry Rd., Suite 130 Portland, OR 97224 503-595-1001 | Emily.Ricker@FACS.com

FACS Project #PJ79970 www.forensicanalytical.com Forensic Analytical Consulting Services

Contents Executive Summary

Introduction

Methodology

Site Characterization

Findings

Conclusions and Recommendations

Limitations

Appendix A: Asbestos Sample Inventory Table

Appendix B: Lead Paint Sample Inventory Table

Appendix C: Sample Locations Diagrams

Appendix D: Sample Photograph Narrative

• Asbestos

• Lead Paint

Appendix E: Laboratory Reports and Chain of

Custody Forms

Appendix F: Glossary of Terms

Appendix G: Accreditation

Asbestos and Lead in Paint Survey (02/12/2024) Heart O’ the Hills Campground – Comfort Station Loop B www.forensicanalytical.com Forensic Analytical Consulting Services

Executive Summary

Forensic Analytical Consulting Services, Inc. (FACS) was retained by Kurtis McGowan of National Park Service to perform an asbestos and lead coatings survey for the planned renovation at the Loop B Comfort Station (Building 753) located at 3002 Mt. Angeles Road in Port Angeles, Washington. The survey included the building interior for asbestos sampling and the interior and exterior for lead sampling of coatings. FACS conducted the site visit on December 20, 2023.

Results of sampling indicated that asbestos was detected in the following materials:

• Brown adhesive on 6” black vinyl cove base

The following materials were identified as having less than 1% asbestos using the point count method:

• Gray mortar underneath 1”x1” tan and brown ceramic floor tile

Results of sampling indicated that the following were identified as lead-containing paints:

• White paint on plywood covered walls

• Gray paint on exterior walls

• Peach paint on metal restroom stalls

Hazardous building materials that may be disturbed during renovation activities should be handled by appropriately licensed contractors in accordance with local, state, and federal regulations. A more detailed discussion of findings and conclusions is provided below.

www.forensicanalytical.com Forensic Analytical Consulting Services

Introduction

Forensic Analytical Consulting Services, Inc. (FACS) performed an asbestos and lead coatings survey of the Heart O’ the Hills Campground Comfort Station in Loop B located at 3002 Mt. Angeles Road in Port Angeles, Washington. Allison Krein, FACS' AHERA Accredited Asbestos Building Inspector and working under the direction of Jon Curtis, Washington Lead Risk Assessor, conducted the site visit on December 20, 2023 at the request of Kurtis McGowan of the National Park Service. The scope of the asbestos and lead coatings survey was determined by verbal communication with the project contact. The purpose of this inspection was to identify and test suspect asbestos-containing or lead-containing materials prior to renovation or demolition.

Methodology

Asbestos

The scope of the asbestos survey, which identified the suspect building materials that may be impacted, was determined by verbal communication with the project contact. The asbestos survey consisted of a visual and tactile inspection followed by sampling of suspect asbestos containing materials (ACMs) throughout the interior of the building. Suspect materials were grouped and classified as homogeneous materials based on their appearance, texture, usage, and the age of the building.

Representative samples of homogenous areas of material suspected of containing asbestos were collected in accordance with the Federal EPA AHERA protocols (40 CFR 763 Subpart E). Materials determined by the inspector to be non-suspect, such as wood, metal, glass, and fiberglass insulation, were not sampled.

Additional suspect building materials may be present in areas that were inaccessible, unsafe to inspect, or obscured from view during the inspection process.

Samples were collected in a manner to minimize the potential release of asbestos fibers, if present. Material type, sample number, sample location and other pertinent information were recorded at the time of sampling. Each sample was placed in a sample container labeled with a unique sample number, sealed, and submitted to the SGS-Forensic Laboratories (SGS-FL), an NVLAP accredited laboratory for analysis under chain of custody documentation. Samples were analyzed in accordance with EPA Method 600/R-93- 116, using polarized light microscopy (PLM) with dispersion staining and using visual area estimation to determine percent asbestos content. This method allows for the identification of the primary type(s) of asbestos used in building materials. The lower limit of quantification for this method is one percent. Samples containing less than one percent asbestos by PLM with visual area estimation are reported as Trace.

Materials identified as containing Trace amounts of asbestos by PLM are still considered as containing greater than 1% asbestos unless reanalyzed by the point count method. Unlike the PLM method, the Point Count 400 analysis method can reliably determine if a material contains less than 1% asbestos. The advantage of establishing that a material contains less than 1% asbestos is that it will no longer be an asbestos-containing material (ACM) as defined by the EPA and may include cost savings with regard to notification, disposal, and contractor selection.

Lead-Containing/Lead Based Paint

Representative samples of the predominant painted surfaces that will be impacted by potential future demolition or renovation activities were collected for laboratory analysis. Additional suspect painted surfaces may be present in areas that were inaccessible, unsafe to inspect, or obscured from view during the sampling process.

www.forensicanalytical.com Forensic Analytical Consulting Services

Samples were collected in such a manner as to minimize release of the material into the surroundings. Paint color, sample number, sample location and other pertinent information were recorded at the time of sampling. Each sample was placed in a sample container labeled with a unique sample number, sealed, and submitted for analysis to SGS-FL, an NLLAP accredited laboratory, for analysis under chain of custody documentation. Samples were analyzed in accordance with EPA Method 3050B/7000B, to determine percent by weight content of lead.

Site Characterization

The subject property is a national campground restroom single-story building with a wood siding exterior.

The interior is divided into a men’s restroom, women’s restroom, storage/sink area and electrical room.

The roof is pitched corrugated metal. Interior walls and ceilings are primarily painted plywood and fiberglass reinforced plastic. The flooring is ceramic floor tile with vinyl cove base.

The following suspect materials were determined to potentially be within the scope of work for the planned renovation/demolition:

Suspect Asbestos-Containing Materials:

• Pink insulation with paper and foil backing

• 4” brown cove base and brown adhesive

• 6” black cove base and brown adhesive

• 1”x1” ceramic floor tile tan and brown with gray mortar and brown grout

• Tan fiberglass reinforced plastic with adhesive

• White caulk

• Black woven wire sheathing, painted

Suspect Lead-Containing Coatings:

• Yellow with light yellow and green paint on wood door

• White paint on plywood covered wall

• Gray paint on plywood covered wall

• Peach paint on metal restroom stall

• Gray paint on metal window frame

• Brown paint on metal and plastic door mechanism

Findings

Asbestos:

Results of sampling indicated that asbestos was detected in the following materials:

• Brown adhesive on 6” black vinyl cove base

The following materials were identified as having less than 1% asbestos using the point count method:

• Gray mortar underneath 1”x1” tan and brown ceramic floor tile

A detailed sampling data table including sample locations, material description, and results is presented in Appendix A, and laboratory reports are provided in Appendix E.

www.forensicanalytical.com Forensic Analytical Consulting Services

Lead Paint:

The EPA defines “lead-based” paint as paint which contains 0.5% lead by weight, or 5000 parts per million (ppm) by weight.

The following were identified as lead-based paints:

• Gray paint on exterior walls

The following were identified as lead-containing paints:

• White paint on plywood covered walls

• Peach paint on metal restroom stalls

Lead sampling results are summarized in Appendix B, and laboratory reports are provided in Appendix E.

Conclusions and Recommendations

Asbestos:

Local, State, and Federal regulatory agencies define asbestos-containing materials (ACM) as those that contain greater than 1% asbestos. Twelve (12) samples were collected from 7 different homogeneous materials during this inspection.

Results of sampling indicated that asbestos was detected in the following materials:

• Gray mortar underneath 1”x1” tan and brown ceramic floor tile (<1% by point count)

• Brown adhesive on 6” black vinyl cove base

Removal of materials containing asbestos should be performed by properly trained and qualified personnel only, in accordance with federal, state, and local regulations. Other requirements, such as notification, disposal, and contractor licensing will also apply.

If any other suspect materials are encountered during future renovation of the site that are not reflected in this survey, such material(s) shall not be disturbed until further sampling can determine whether or not it is asbestos containing. Alternatively, these materials may be assumed to be ACM and removed by a licensed asbestos abatement contractor. For detailed regulatory requirements in specific situations, FACS should be consulted, or the applicable regulations should be examined.

Lead Paint:

Lead is present in several materials onsite. Washington State Department of Labor & Industries regulates construction work where an employee may be occupationally exposed to lead.

Any detectable amount of lead triggers the requirements of the OSHA Lead in Construction Standard, 29 CFR 1926.62 (as adopted by Washington Labor & Industries (L&I) under WAC Chapter 365-230). The Washington L&I standard for lead in construction applies to all construction work where an employee may be occupationally exposed to lead. Even when lead content in a sampled material is below the EPA lead-based paint definitions, it is possible that these activities could still generate airborne lead dust. This includes any activities that may disturb surfaces that contain any amount of lead, e.g. demolition, removal, repair, alteration, etc.

www.forensicanalytical.com Forensic Analytical Consulting Services

Therefore, controls are required when removing ‘lead-containing’ paint to ensure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 µg/m3) averaged over an 8-hour period.

Applicable Washington L&I requirements include, but may not be limited to:

• Hazard determination, including exposure assessment [An initial determination of whether employees are exposed to lead at or above the action level (30 µg/m3) is required] o Until the employer performs an exposure assessment and documents that employees are not exposed above the PEL, Washington L&I requires some interim protection for employees involved in manual demolition of building materials where lead containing coatings or paints are present.

• engineering and work practice controls

• respiratory protection (if engineering or other controls cannot provide sufficient protection)

• personal protective equipment (if engineering or other controls cannot provide sufficient protection)

• housekeeping,

• recordkeeping, and

• other provisions as defined by law.

Limitations

This investigation is limited to the conditions and practices observed and information made available to FACS. The methods, conclusions and recommendations provided are based on FACS’ judgment, expertise and the standard of practice for professional service. They are subject to the limitations and variability inherent in the methodology employed. As with all environmental investigations, this investigation is limited to the defined scope and does not purport to set forth all hazards, nor indicate that other hazards do not exist.

The building materials and conditions presented in this report represent those observed on the dates FACS conducted the sampling. This sampling is intended for the exclusive use of the National Park Service for specific application to the referenced property. This assessment does not replace, nor can be used as, professionally developed construction or demolition plans, specifications, or bidding documents.

This report is not a legal opinion.

Please contact our offices at 503-595-1001 with any questions or concerns. Thank you for the opportunity to assist the National Park Service in promoting a more healthful environment.

Respectfully, Respectfully, FORENSIC ANALYTICAL FORENSIC ANALYTICAL

Senior Environmental Health Specialist AHERA Asbestos Inspector #IR-23-9492B

Jonathan Curtis Principal Scientist AHERA Asbestos Inspector #FACSBIR1405 Washington Lead Risk Assessor #23-0012 www.FACS.com Forensic Analytical Consulting Services

Appendix A

Appendix A Asbestos Sample Inventory Table

Asbestos Survey Summary (Lab Report # B355144)

Survey Date: December 20, 2023

HA Sample Number Material Description Location(s) of Material

Asbestos Content

(percent) and type

Friable or Non-friable

Approximate Quantity

Material Condition

1 79970-01 79970-02

Pink Insulation with paper foil and backing

• Women’s restroom ceiling

• Men’s restroom ceiling ND N/A 300 SF Good

2 79970-03 79970-09

4” brown vinyl cove base and brown adhesive

• Women’s restroom

• Men’s restroom ND N/A 40 SF Fair

3 79970-06 79970-07

6” black vinyl cove base and brown adhesive • Service sink room

2% Anthophyllite in brown adhesive

Non-friable 6 SF Poor

4 79970-05* 79770-11

1”x1” ceramic floor tile tan and brown with gray mortar and brown grout

• Women’s restroom floor

• Men’s restroom floor

< 1% Chrysotile Friable 252 SF Good

5 79970-08 Tan fiberglass reinforced plastic

• Service sink room

• Men’s restroom walls

• Women’s restroom walls

ND N/A 588 SF Good

6 79970-04 79904-10 White caulk • Men’s restroom

• Service sink ND N/A 55 LF Good

7 79770-12 Black woven wire sheathing, painted • Electrical closet ND N/A -- Good

* Analyzed by Point Count 400 Method and found to contain less than 1% asbestos by weight N/A = Not Applicable; ND = None Detected; RACM = Regulated Asbestos Containing Material; Cat. 1 = Category I (nonfriable packings, gaskets, resilient floor coverings (not including backing), and asphaltic roofing; Cat. 2 = Category II (nonfriable materials other than Category I); Chry. = Chrysotile; Am. = Amosite; Trem. = Tremolite; SF = Square Feet; LF = Lineal Feet;

NOTE: This summary table must not be used alone. Important explanations and limitations are contained in the accompanying survey report text.

Percent asbestos content is based upon visual area estimation unless noted otherwise (point count analysis was not performed).

www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix B

Appendix B Lead Paint Sample Inventory Table

Lead Survey Summary (Lab Report # M256487)

Survey Date: December 20, 2023

Sample Number Location Component Substrate Color Lead Content

(% by Weight)

79970-Pb01 Men’s restroom Exterior door Wood Yellow with light yellow & green <0.006

79770-Pb02 Men’s restroom Plywood wall covering Wood White 0.017

79770-Pb03 Exterior north wall Exterior wall Wood Gray 0.91

79770-Pb04 Women’s restroom Restroom stall frame Metal Peach 0.009

79770-Pb05 Service Sink Room Window frame Metal Gray <0.006

79770-Pb06 Service Sink Room Door mechanism Metal and Plastic Brown <0.008

Notes:

< = less than the laboratory reporting limit based on sample size.

Samples with detectable levels of lead are in bold www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix C

Appendix C Sample Location Diagrams

P: 503.595.1001 Portland, OR 97224 17700 SW Upper Boones Ferry Rd., Suite 130

JOB NUMBER:

PJ79770

DRAWN BY:

CLIENT:

National Park Service

Heart O' the Hills Campground Restroom - Loop B

LOCATION:

2823 S Oak Street Port Angeles, WA 98362

Sample Location Diagram This is a design drawing and is the propery of Forensic Analytical Consulting Services, Inc.

It is not inteded to replace required architectural or engineering plans. This drawing is not to be reused or reproduced without written permission from FACS.

Men's Restroom

Women's Restroom

Electrical Room

Service Sink Room

Pb-01

Pb02 Pb03

Pb04

Pb05, Pb06 01, 02

03, 05

10 11 www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix D

Sample Photograph Narrative - Asbestos

Photo #1 (9399): Pink insulation with paper and foil backing (79770-01, 79770-02) Photo #2 (9401): 4” Brown vinyl cove base with brown adhesive (79770-03, 79770-09))

Photo #3 (9413): 6” black vinyl cove base with brown adhesive (79770-06, 79770-07)

Photo #4 (9406): 1”x1” ceramic floor tile, tan and brown with gray mortar and brown grout (79770-05, 79770-11) www.forensicanalytical.com Forensic Analytical Consulting Services

Photo #5 (9418): Tan fiberglass reinforced plastic with adhesive (79770-08)) Photo #6 (9403): White caulk (79770-04, 79770-

10)).

Photo #7 (9439): Black woven wire sheathing, painted (79770-12) www.forensicanalytical.com Forensic Analytical Consulting Services

Sample Photograph Narrative – Lead Paint

Photo #1 (9408): Exterior door (Metal, Yellow, Light

Yellow, Green) (79770-Pb01) Photo #2 (9412): Interior, men’s restroom-plywood covered wall (Wood, White) (79770-Pb02)

Photo #3 (9419): Exterior wall (Wood, Gray)

(79770-Pb03) Photo #4 (9428): Women’s restroom, stall frame

(Metal, Peach) (79770-Pb04) www.forensicanalytical.com Forensic Analytical Consulting Services

Photo #5 (9435): Service Sink Room, window frame

(Metal, Gray) (79770-Pb05) Photo #6 (9436): Service Sink Room, exterior door mechanism (Metal/Plastic, Brown) (79770-Pb06)

Appendix www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix E

Appendix E Laboratory Reports and Chain of Custody Forms

Final Report

(EPA Method 40CFR, Part 763, Appendix E to Subpart E and EPA 600/R-93-116, Visual Area Estimation)

Bulk Asbestos Analysis NVLAP Lab Code: 101459-0

PE21Client ID:Forensic Analytical Consulting Svcs B355144Report Number:Emily Ricker

Date Received:17700 SW Upper Boones Ferry Rd 01/02/24Date Analyzed:Suite 130 01/02/24Date Printed:Portland, OR 97224

First Reported:

PE21PJ79970; National Park Service 21228 Cabot Blvd., Hayward, CA 94545 SGSFL Job ID:Job ID/Site:

Date(s) Collected: 12/20/2023

12Total Samples Submitted:

Total Samples Analyzed: 12

12/22/23

01/02/24

Sample ID Lab Number Asbestos

Type Percent in

Layer Asbestos AsbestosPercent in Percent in

Type TypeLayer Layer

79970-01 12717999

Layer: Pink Fibrous Material ND

Layer: Brown Fibrous Backing ND

Layer: Black Coating ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace) Fibrous Glass (85 %)

79970-02 12718000

Layer: Pink Fibrous Material ND

Layer: Brown Fibrous Backing ND

Layer: Black Coating ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace) Fibrous Glass (85 %)

79970-03 12718001

Layer: Brown Non-Fibrous Material ND

Layer: Black Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-04 12718002

Layer: Off-White Non-Fibrous Material ND

Layer: Paint ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-05 12718003

Layer: Multicolored Ceramic Tile ND

Layer: Grey Mortar Chrysotile Trace

Layer: Tan Fibrous Backing ND

Asbestos (Trace)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-06 12718004

Layer: Black Non-Fibrous Material ND

Layer: Tan Mastic Anthophyllite 2 %

Asbestos (Trace)Total Composite Values of Fibrous Components:

Cellulose (Trace)

3777 Depot Road, Suite 409, Hayward, CA 94545 | Phone: 510.887.8828 / 800.827.3274 Fax: 510.887.4218 | https://falaboratories.sgs.com

Report Number: B355144

Date Printed: 01/02/24Client Name: Forensic Analytical Consulting Svcs

Sample ID Lab Number Asbestos

Type Percent in

Layer Asbestos AsbestosPercent in Percent in

Type TypeLayer Layer

79970-07 12718005

Layer: Black Non-Fibrous Material ND

Layer: Tan Mastic Anthophyllite 2 %

Asbestos (Trace)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-08 12718006

Layer: Wood ND

Layer: Multicolored Coating ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (95 %)

79970-09 12718007

Layer: Brown Non-Fibrous Material ND

Layer: Yellow Mastic ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-10 12718008

Layer: Off-White Non-Fibrous Material ND

Layer: Paint ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-11 12718009

Layer: Multicolored Ceramic Tile ND

Layer: Brown Mortar ND

Layer: Grey Grout ND

Layer: Off-White Fibrous Backing ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (Trace)

79970-12 12718010

Layer: Silver Paint ND

Layer: Black Tar ND

Layer: Brown Fibrous Material ND

Layer: Clear Fibrous Material ND

Layer: Wires ND

Asbestos (ND)Total Composite Values of Fibrous Components:

Cellulose (10 %) Fibrous Glass (7 %)

Analytical results and reports are generated by SGS Forensic Laboratories (SGSFL) at the request of and for the exclusive use of the person or entity (client) named on such report.

Results, reports or copies of same will not be released by SGSFL to any third party without prior written request from client. This report applies only to the sample(s) tested.

Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGSFL. The client is solely responsible for the use and interpretation of test results and reports requested from SGSFL. This report must not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. Government. SGSFL is not able to assess the degree of hazard resulting from materials analyzed. SGS Forensic Laboratories reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified. All samples were received in acceptable condition unless otherwise noted.

Note: Limit of Quantification ('LOQ') = 1%. 'Trace' denotes the presence of asbestos below the LOQ. 'ND' = 'None Detected'.

Maria Cosper, Laboratory Supervisor, Hayward Laboratory

3777 Depot Road, Suite 409, Hayward, CA 94545 | Phone: 510.887.8828 / 800.827.3274 Fax: 510.887.4218 | https://falaboratories.sgs.com

|JJ

(J i

N

J+

Final Report

Bulk Asbestos Point Count Analysis (NESHAP Final Rule, 40 CFR, Part 61)

Forensic Analytical Consulting Svcs

17700 SW Upper Boones Ferry Rd

Suite 130

Emily Ricker

Portland, OR 97224

Client ID:

Report Number:

Date Received:

Date Printed:

Date Analyzed:

N015974

PE21

01/30/24

01/30/24

Job ID/Site: SGSFL Job ID:PJ79970; National Park Service 21228 Cabot Blvd., Hayward, CA 94545 PE21

01/23/24

Total Samples Submitted:

Total Samples Analyzed:

1PLM Report Number: B355144

Sample Preparation and Analysis:

The NESHAP Final Rule does not define the preparation method for multi-layered samples. In order to determine the composite quantity of asbestos, the volume percent of each layer is determined, the asbestos containing layers are analyzed by point counting and the composite quantity of asbestos is calculated. The NESHAP Final Rule can not be applied to matrices that dissolve in refractive index liquid. This includes tar, mastic or adhesive typically found on the back of floor tiles. According to the NESHAP Final Rule, point count data is only necessary when the visual estimate of asbestos is below 10%.

Lab NumberSample ID Layer Description

79970-05 12718003 Grey Mortar

Asbestos type(s) detected: Chrysotile

< 1

Number of asbestos points counted:

Number of non-empty points: 400

Percent asbestos in layer:

Layer percentage of entire sample:

Point Count Results:

Comment: Asbestos was detected but no points were counted due to counting criteria. Therefore quantitation deemed to be < 1%.

Sample volume is less than that advised by method, this result may not be repeatable.

Note: Point count results are reported to the nearest percent per EPA method.

Maria Cosper, Laboratory Supervisor, Hayward Laboratory

Note: Limit of Quantification (LOQ) = 1%. Trace denotes the presence of asbestos below the LOQ. ND = None Detected.

Analytical results and reports are generated by SGS Forensic Laboratories (SGSFL) at the request of and for the exclusive use of the person or entity (client) named on such report.

Results, reports or copies of same will not be released by SGSFL to any third party without prior written request from client. This report applies only to the sample(s) tested.

Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGSFL. The client is solely responsible for the use and interpretation of test results and reports requested from SGSFL. This report must not be used by the client to claim product endorsement by NVLAP or any other agency of the U.S. Government. SGSFL is not able to assess the degree of hazard resulting from materials analyzed. SGS Forensic Laboratories reserves the right to dispose of all samples after a period of thirty (30) days, according to all state and federal guidelines, unless otherwise specified. All samples were received in acceptable condition unless otherwise noted.

3777 Depot Road, Suite 409, Hayward, CA 94545 | Phone: 510.887.8828 / 800.827.3274 Fax: 510.887.4218 | https://falaboratories.sgs.com

|JJ

(J i

N

J+

Metals Analysis of Paints Client ID:

Report Number:

Date Received:

M256487

Job ID / Site: PJ79970; National Park Service 21228 Cabot Blvd., Hayward, CA 94545

Forensic Analytical Consulting Svcs

Suite 130

PE21

SGSFL Job ID:

Date Analyzed:

PE21

Emily Ricker

Portland, OR 97224

17700 SW Upper Boones Ferry Rd

Date Printed: 01/02/24

12/29/23

First Reported: 01/02/24

12/22/23

Final Report

(AIHA-LAP, LLC Accreditation, Lab ID #101762)

Date(s) Collected: 12/20/2023 Total Samples Submitted:

Total Samples Analyzed:

Sample Number Lab Number Result Result Reporting Method

Analyte Units Limit* Reference

EPA 3050B/7000B< 0.006Pb79970-PB-01 30932253 wt% 0.006

EPA 3050B/7000B0.017Pb79970-PB-02 30932254 wt% 0.007

EPA 3050B/7000B0.91Pb79970-PB-03 30932255 wt% 0.07

EPA 3050B/7000B0.009Pb79970-PB-04 30932256 wt% 0.007

EPA 3050B/7000B< 0.006Pb79970-PB-05 30932257 wt% 0.006

EPA 3050B/7000B< 0.008Pb79970-PB-06 30932258 wt% 0.008

Analytical results and reports are generated by SGS Forensic Laboratories at the request of and for the exclusive use of the person or entity (client) named on such report.

Results, reports or copies of same will not be released by SGS Forensic Laboratories to any third party without prior written request from client. This report applies only to the sample(s) tested. Supporting laboratory documentation is available upon request. This report must not be reproduced except in full, unless approved by SGS Forensic

Laboratories. The client is solely responsible for the use and interpretation of test results and reports requested from SGS Forensic Laboratories. SGS Forensic Laboratories is not able to assess the degree of hazard resulting from materials analyzed. SGS Forensic Laboratories reserves the right to dispose of all samples after a period of thirty

(30) days, according to all state and federal guidelines, unless otherwise specified. Any modifications that have been made to referenced test methods are documented in

SGS Forensic Laboratories' Standard Operating Procedures Manual. Sample results have not been blank corrected. Quality control and sample receipt condition were acceptable unless otherwise noted.

Note* Sampling data used in this report was provided by the client as noted on the associated chain of custody form.

* The Reporting Limit represents the lowest amount of analyte that the laboratory can confidently detect in the sample, and is not a regulatory level. The Units for the Reporting Limit are the same as the Units for the Final Results.

Kevin Poon, Laboratory Supervisor, Hayward Laboratory

3777 Depot road, Suite 409, Hayward, CA 94545 | Phone: 510.887.8828 / 800.827.3274 Fax: 510.887.4218 | https://falaboratories.sgs.com www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix F

Appendix F Glossary of Terms

ACM: Asbestos containing material.

AHERA: Asbestos Hazard Emergency Response Act of 1986.

AHERA Building Inspector: A person who has successfully completed the training requirements for a building inspector established by EPA Asbestos Model Accreditation Plan; Interim Final Rule (40 CFR Part 763, Appendix C to Subpart E, I.B.3) and whose certification is current.

AHERA Project Designer: A person who has successfully completed the training requirements for an asbestos abatement project designer established by EPA regulations (40 CFR 763.90(g)) and whose certification is current.

Asbestos: Chrysotile, amosite, crocidolite, tremolite, anthophyllite, actinolite and any of these minerals that have been chemically treated and/or altered. This includes suspect and/or presumed ACM.

Asbestos Containing Material (ACM): Any material containing more than one percent asbestos.

Asbestos Inspection: A written report describing an inspection using the procedures contained in EPA regulations (40 CFR 763,86) to determine whether materials or structures to be worked on, renovated, removed, or demolished (including materials on the outside of structures) contain asbestos.

Authorized Person: Any person authorized by the employer and required by work duties to be present in regulated areas.

Chain of Custody: Legal documentation that follows samples from collection to the laboratory indicating who has been in possession of the samples.

Competent Person: A person capable of identifying asbestos hazards, selecting appropriate control strategies and having the authority to take prompt corrective measures. Additionally, for Class I and Class II work, one who is specially trained in a training course meeting the criteria of EPA’s Model Accreditation Plan (40 CFR 763) for project designer or supervisor, or its equivalent and, for Class II work, who is trained in an operations and Maintenance O & M Course developed by EPA (40 CFR 76392 (a) (2)).

Contractor: The asbestos abatement contractor.

EPA: United States Environmental Protection Agency

Friable Asbestos Containing Material: Asbestos containing material that can be crumbled, pulverized or reduced to powder when dry, by hand pressure.

High-Efficiency Particulate Air (HEPA) Filter: A filter capable of trapping and retaining at least 99.97 percent of all mono-dispersed particles of 0.3 micrometers in diameter.

Intact: ACM that has not crumbled, been pulverized, or otherwise deteriorated so that it’s no longer likely to be bound within its matrix.

LF: Linear feet

NESHAPs: National Emission Standard for Hazardous Air Pollutants, 40 CFR part 61.

NVLAP: National Voluntary Laboratory Accreditation Program www.forensicanalytical.com Forensic Analytical Consulting Services

Appendix F

WASHINGTON L&I: United States Department of Labor and Industries

Owner: The legal entity, including a lessee, which exercises control over management and record keeping functions relating to a building and/or facility in which the abatement activities described in this document take place.

Owners Representative: A person authorized by the Owner to act on the Owners behalf.

PLM: Polarized Light Microscopy

Presumed Asbestos Containing Material (PACM): Thermal system insulation and surfacing material found in buildings constructed no later than 1980. The designation of a material as PACM may be rebutted through PLM analysis of samples obtained by certified inspectors.

Removal: All operations where ACM and/or PACM are taken out or stripped from structures or substrate and include demolition operations.

Sq. Ft.: Square feet

Surfacing Material: Material that is sprayed, troweled-on or otherwise applied to surfaces.

Suspect ACBM: Material that is suspected of containing asbestos that has not been sampled and analyzed for asbestos content.

Thermal System Insulation: ACM applied to pipes, fittings, boilers, breaching, tanks, ducts or other structural components to prevent heat loss or gain.

Appendix G

Accreditation

STATE OF WASHINGTON

Department of Commerce

Lead-Based Paint Activities Program

Has fulfilled the certification requirements of

WAC 365-230

and has been certified to conduct lead based paint activities as a

Risk Assessor.

Certification # Issuance Date Expiration Date 23-0012 12/21/2023 08/10/2026

Jonathan Scott Curtis

Forensic Analytical Consulting Services, Inc.

This is to confirm that

Jonathan S Curtis Has attended the four-hour

AHERA Refresher Course for Asbestos Inspectors

And has completed the requisite training for asbestos accreditation under TSCA Title II

January 19, 2023 Certificate Number: FACSBIR1405

Valid Until: January 19, 2024

Cal/OSHA Approval Number: CA-025-06

David B. McGrath, Corporate Training Director Forensic Analytical Consulting Services,Inc.

21228 Cabot Blvd, Hayward, CA 94545

(800) 677-1483

01/05/2025

01/05/2024

ONLINE AHERA ASBESTOS INSPECTOR REFRESHER

Course Date:

Expiration Date:Certificate: IRO-24-1051C for

Course Location:

For verification of the authenticity of this certificate contact:

PBS Engineering and Environmental Inc.

Andy Fridley, Instructor

In accordance with TSCA Title II, Part 763, Subpart E, Appendix C of 40 CFR

4-Hour Online AHERA Inspector Refresher Training; AHERA is the Asbestos Hazard Emergency Response Act enacting Title II of Toxic Substance Control Act (TSCA)

HAS SUCCESSFULLY COMPLETED THE TRAINING COURSE

ALLISON KREIN

THIS IS TO CERTIFY THAT

CCB #SRA0615 4-Hr Training

__________________________Online

4412 S Corbett Avenue

Portland, OR 97239

503.248.1939

Right People

Right Perspective

Right Now www.forensicanalytical.com