Attach_13_Supplemental_Hazardous_Material_Inspection_Report,_May_17,_2016.pdf

Paradise Inn Annex

Mount Rainier National Park

Mount Rainier, Washington

Supplemental Hazardous Material Inspection Report

Prepared for:

RIM Architects

645 G Street, Suite 400

Anchorage, Alaska 99501

Prepared by:

White Environmental Consultants, Inc.

383 Industrial Way, Suite 300

Anchorage, AK 99501

May 23, 2016

Contents

Scope of Work

Inspection Findings

Paradise Inn Annex - Asbestos Containing Materials (ACM)

Compliance Recommendations – Asbestos

Paradise Inn Annex - Lead Containing Paint (LCP)

Compliance Recommendations – Lead

Limitations

Appendices

Appendix A: Bulk Asbestos Analytical Report / Field Collection Forms

Appendix B: Lead Sample Results / Field Collection Forms

Appendix C: Inspectors’ Certifications

Scope of Work

On May 3rd , 2016 White Environmental Consultants Inc. (WEC) performed a supplemental hazardous material inspection of the Paradise Inn Annex located at Mount Rainer National Park, Washington.

The purpose of this survey is to provide our client, RIM Architects with professional guidance from which they may fulfill all relevant environmental and worker health and safety obligations through compliance with applicable Environmental Protection Agency (EPA) and the Federal Occupational Safety and Health Administration (OSHA) regulations during renovation activities conducted at the aforementioned property.

The inspection was supplemental in nature as the Paradise Inn and Annex was previously inspected by Clayton Group Services in April, 1995 and representatives of Federal Occupational Health Services in July of 2004. The interior of the Paradise Inn Annex was inspected and/or sampled for asbestos containing materials (ACM) and suspected lead-containing paint (LCP) to determine specific renovation and disposal activities required if these materials are present. The inspection was limited in scope as non-destructive testing was performed.

WEC collected thirty six samples consisting of forty five layers of suspected asbestos containing materials (ACM). Suspect materials identified and sampled include:

a. Joint Compound

b. Drywall

c. Cement Board

d. Foundation Mortar

e. Vapor Barrier - Floor

f. Vapor Barrier - Roof

g. Sheet Vinyl / Mastic

The materials listed above are not an inventory of all suspect ACM found throughout the Paradise Inn Annex. The materials listed above were sampled to provide supplemental information to assist in the process of asbestos project design for planned renovations scheduled for August, 2017. Reference the April 1995 Investigative Report by Clayton Group Services and the December 2004 Final Report by Federal Occupational Health Services for additional information which showed asbestos containing sheet vinyl, cement board, wall panel adhesive, window glazing and pipe thread sealant to be present in the Paradise Inn Annex.

WEC collected seven samples of suspect lead containing paints from various locations throughout the Paradise Inn Annex. The purpose of the paint sampling was to characterize suspect paints to determine the need, if any, of lead compliance measures during the renovation process. Analysis was performed by flame atomic absorption spectroscopy EPA Method SW846-7420.

Inspection Findings

Paradise Inn Annex - Asbestos Containing Materials (ACM)

WEC personnel collected thirty six samples for a total of forty five discrete layers of suspected asbestos containing building materials from the Paradise Inn Annex located at Mount Rainer National Park, Washington. Of the forty five sample layers collected, three samples were found to contain asbestos. A summary of the materials containing asbestos is shown below and is described as positive along with the percentage of asbestos contained in the product.

SAMPLE

ID# MATERIAL LOCATION

ASBESTOS

CONTENT

636-01 Cement Board Basement, Northeast Corner 25%

636-27b Floor Tile Residue Room 312-314 Bath, Beneath Negative Sheet Vinyl 5%

636-31b Sheet Vinyl Room 419, Beneath Negative Sheet Vinyl 20%

Compliance Recommendations – Asbestos

Sheet Vinyl / Floor Tile:

Asbestos containing floor tile residue was found to be present beneath non-asbestos containing sheet vinyl in Room 312-314 bathroom. Asbestos containing sheet vinyl was found to be present in Room 419 beneath non-asbestos containing sheet vinyl. Sheet Vinyl / Floor tile is considered to be a non-friable Category I asbestos containing material by the Environmental Protection Agency. The presence of asbestos containing floor tile residue and sheet vinyl beneath non-asbestos containing sheet vinyl shows that previous layers of suspect asbestos containing flooring was either not completely removed or covered with non-asbestos flooring products. Any disturbance of the asbestos-containing sheet vinyl and floor tile should only be performed by state certified asbestos abatement personnel.

Cement Board:

Asbestos containing cement board was found to be present at the northeast side of the basement above an abandoned water tank. Approximately fifteen square feet of cement board is located directly above the water tank and remnants remain on wood framing immediately next to the water tank. Cementitious asbestos products are typically considered to be non-friable Category II asbestos containing material by the Environmental Protection Agency. The cement board should be removed from the basement prior to renovation. Any disturbance of the asbestos-containing cement board should only be performed by state certified asbestos abatement personnel.

Vermiculite Attic Insulation (Presumed Asbestos Containing Material (PACM))

Vermiculite insulation was observed to be present in the attic and plumbing chases throughout the Paradise Inn Annex. The presence of the vermiculite insulation was random throughout the attic and plumbing chases, it appeared that a previous attempt had been made to remove the material. No significant quantities were found in any one location, the attic space had the most prevalent amount of vermiculite. The EPA recommends that vermiculite insulation be assumed to contain asbestos and to not disturb the material. Vermiculite insulation may be present in wall and ceiling cavities and other spaces not accessible during the course of the inspection. Any disturbance of the vermiculite insulation should only be performed by state certified asbestos abatement personnel.

Window Glazing (Presumed ACM or Sampled by Others):

Asbestos containing window glazing was found to be present or presumed to be present at the Paradise Inn and Annex during previous inspections performed by others. Window glazing is considered to be a non-friable Category II asbestos containing material by the Environmental Protection Agency. Any disturbance of the asbestos-containing window glazing should only be performed by state certified asbestos abatement personnel.

Wall Panel Adhesive (Presumed ACM or Sampled by Others):

Asbestos containing wall panel adhesive was found to be present or presumed to be present at the Paradise Inn and Annex during previous inspections performed by others. Wall panel adhesive is considered a non-friable Category II asbestos containing material by the Environmental Protection Agency. The asbestos containing wall panel adhesive should be removed from the building prior to renovation activities that could disturb the material. Any disturbance of the asbestos-containing wall panel adhesive should only be performed by state certified asbestos abatement personnel.

Pipe Thread Sealant (Presumed ACM or Sampled by Others):

Asbestos containing pipe thread sealant was found to be present in the Annex basement during previous inspections by others. Pipe thread sealant is considered to be a non-friable Category II asbestos containing material by the Environmental Protection Agency. Any disturbance of the asbestos-containing pipe thread sealant should only be performed by state certified asbestos abatement personnel. Based on the age of installation asbestos should not impact sprinkler piping systems.

Asbestos Comments

Based on sample results and data from previous inspections of the Paradise Inn Annex, WEC recommends the following:

1. All vinyl flooring removal be performed as an asbestos abatement activity.

2. Wall system demolition, consisting of gypsum wallboard, joint compound, paint, panel mastics and wood paneling should all be considered an abatement activity.

3. Small amounts of vermiculite were found in the attic and pipe chases. This material will be cleaned-up in the normal course of the scheduled asbestos work and should not incur any additional costs. There is the potential for vermiculite to be located within wall cavities if used as a sound insulation between guest rooms. In order to manage change orders from unknown vermiculite a unit rate for abatement should be included in the bid documents. Unit could be cubic feet of wall cavity or a unit rate per standard disposal bag of additional work.

4. During execution of work if any materials not identified in the original reports, this report or listed in the construction documents additional sampling may be required to protect workers or to manage the project waste stream.

5. Pipe insulation may exist within walls or above finished ceiling that were not accessible during the previous inspection efforts. In order to manage change orders from unknown pipe insulation a unit rate for abatement should be included in the bid documents. Unit could be lineal feet of insulated pipe or a unit rate per standard glovebag of additional work.

Regulatory Authority

Code of Federal Regulations EPA 40 CFR Part 61 Subpart M (NESHAP), §61.145 Standard for demolition and renovation requires the removal of all Regulated asbestos-containing materials (RACM) from a building being demolished or renovated before any activity begins that would break up, dislodge, or similarly disturb the material or preclude access to the material for subsequent removal. Regulated asbestos containing material (RACM) is defined as (a) friable asbestos material, (b) Category 1 non-friable ACM that has become friable, (c) Category I non-friable ACM that will or has been subjected to sanding, grinding, cutting, or abrading, or (d) Category II non-friable ACM that has a high probability of becoming or has become crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of demolition or renovation operations.

EPA 40 CFR 61 Subpart M National Emission Standard for Asbestos requires the removal of regulated asbestos containing materials prior to the renovation or demolition of a building.

OSHA 29 CFR 1926.1101 requires specific worker training and removal methods for all asbestos disturbances in renovation and demolition procedures.

Paradise Inn Annex - Lead Containing Paint (LCP) WEC personnel collected seven samples of suspected lead containing paints from the interior of the Paradise Inn Annex located at Mount Rainer National Park. Samples were analyzed by EPA Method SW846 – 7420. A summary of the materials paint analyses is shown below.

Sample ID # Sampling Location Result (PPM) Reporting Limit (PPM)

636P-01 Basement, Water Tank 1,800 85

636P-02 Basement, North Wall at Small Man Door <86 86

636P-03 Basement, Sprinkler Room Wall <78 78

636P-04 Room 110, Ceiling 920 99

636P-05 First Floor, Hallway Wall, South End <93 93

636P-06 2nd Floor, Janitors Closet, South 4,500 93

636P-07 3rd Floor, Janitors Closet, South 17,000 91

In addition to lead containing paints, suspect lead caulking in cast iron drain lines was observed in the basement. Lead caulking should be assumed to be present in all bell and spigot pipe joints. Based on the age of installation there should be no lead impacts to the sprinkler piping system.

Compliance Recommendations – Lead

The HUD/EPA term “lead-based paint” addresses the layers of paint on an applicable surface having lead equal to or greater than 1.0 mg/cm2 or 5,000 parts per million. The EPA does not indicate any safe levels of lead on painted components of a waste stream and requires a Toxicity Characteristic Leachate Procedure (TCLP) test to be performed on the waste stream to determine disposal requirements.

The OSHA Lead-in-Construction standard (29 CFR 1926.62) applies to all construction work where an employee may be occupationally exposed to any detectable level of lead, including demolition or salvage of structures where lead or materials containing lead are present. Based on these results OSHA lead compliance measures need to be implemented for any renovation activities that will disturb painted surfaces. Given the age and previous sampling results of painted surfaces at the Paradise Inn Annex all painted surfaces should be assumed to contain lead. Toxic Characteristic Leaching Procedure (TCLP) is required to assess the project waste stream for disposal.

OSHA (29 CFR 1926.62) “Lead in Construction” has specific requirements when working in the presence of lead and where there is a potential for employee exposure to airborne lead.

1. Employee training.

2. Employee exposure assessments

3. Lead compliance plan

Limitations WEC performed a limited supplemental hazardous material inspection of the interior of the Paradise Inn Annex located at Mount Rainer National Park. Asbestos-containing and Lead-containing materials or other hazardous materials may exist in areas not accessible at the time of inspection. Non-destructive testing methods were utilized, any other suspect materials discovered during demolition not covered in this survey should be assumed to contain asbestos and treated as such until further sampling shows materials do not contain asbestos.

appedices - Supplemental Hazarodus Material Inspection Report