Attach_5_Asbestos,_Lead-Based_Paint,_and_PCB_Surveys_at_Paradise_Inn_and_Annex_Dec_8,_2004.pdf

ASBESTOS, LEAD-BASED PAINT, AND PCB SURVEYS

at

PARADISE INN and ANNEX

MOUNT RAINER NATIONAL PARK - WASHINGTON

for

NATIONAL PARK SERVICE

by

U.S. PUBLIC HEALTH SERVICE

FEDERAL OCCUPATIONAL HEALTH

2201 SIXTH AVENUE, M/S RX-21

SEATTLE, WASHINGTON 98121-2500

206/615-2510

FINAL REPORT

December 8, 2004

Asbestos, Lead-Based Paint, and PCB Surveys Paradise Inn – Mount Rainier National Park Mt. Rainier, Washington A-6450.32 Page i

Table of Contents

A. EXECUTIVE SUMMARY

B. INTRODUCTION

C. BACKGROUND AND BUILDING DESCRIPTIONS

D. METHODS

E. APPLICABLE STANDARDS AND CRITERIA

F. FINDINGS

G. RECOMMENDATIONS

Tables

Table 1 Summary of Asbestos-Containing Materials Table 2 Materials Sampled For Asbestos Table 3 Summary of XRF Results

Appendices

Appendix A Asbestos Hazard Emergency Response Act Building Inspector Certificates Appendix B EPA Certified Lead-Based Paint Inspector Certificate Appendix C Analytical Results – Asbestos Appendix D XRF Results Appendix E Table 2, Materials Sampled for Asbestos Appendix F Abatement Cost Estimate Appendix G Asbestos Abatement Specification Section Appendix H Lead-Based Paint Abatement Specification Section Appendix I Polychlorinated Biphenyls Abatement Specification Section Appendix J Sample Location and Materials Drawings Appendix K Previous Surveys – Summary Documents Appendix L National Voluntary Laboratory Accreditation Program Appendix M Photos

Mt. Rainier, Washington A-6450.32 Page ii

Acronyms

AAS atomic absorption spectroscopy ACM asbestos-containing materials AHERA Asbestos Hazard Emergency Response Act ASHARA Asbestos Schools Hazard Abatement Reauthorization Act CAB Cement Asbestos Board CHMM Certified Hazardous Materials Manager CIH Certified Industrial Hygienist CFR Code of Federal Regulation CMU Cement Masonry Unit DOE Department of Ecology EPA U.S. Environmental Protection Agency FOHS Federal Occupational Health Services HVAC Heating Ventilation and Air Conditioning mg/kg milligram per kilogram mg/l milligram per liter mg/cm2 milligram per centimeter squared NESHAP National Emissions Standards for Hazardous Air Pollutants NVLAP National Voluntary Laboratory Accreditation Program OSHA Occupational Safety and Health Administration PCB Polychlorinated Biphenyls PLM polarized light microscopy PACM presumed asbestos-containing material ppm parts per million RCRA Resource Conservation and Recovery Act TCLP Toxic Characterization Leaching Procedure TSI thermal system insulation VAT vinyl asbestos tile XRF X-ray Fluorescence

Mt. Rainier, Washington A-6450.32

A. EXECUTIVE SUMMARY

Ms. Ingrid Holznagel and Ms. Michelle Riche-Huppe, representatives of Federal Occupational Health Services (FOHS), Seattle, Washington, conducted renovation specific hazardous materials surveys for asbestos, lead-based paint, and Polychlorinated Biphenyls (PCB) containing light ballasts at Paradise Inn, Mount Rainier National Park, Mount Rainier, Washington. Both inspectors are Asbestos Hazard Emergency Response Act (AHERA) accredited building inspectors as required by 40 Code of Federal Regulation (CFR) 763, and Environmental Protection Agency (EPA) certified lead-based paint inspectors, as required by 40 CFR 745. The survey was performed July 7 through July 21, 2004.

The asbestos survey consisted of an on-site inspection of each room which will be affected by renovations, and the exterior of the building, along with the identification of suspect asbestos-containing materials, and sample collection. The lead survey included a comprehensive inspection of painted components and systems performed by x-ray fluorescence (XRF) sampling (bulk sampling was not necessary). PCB-containing light ballasts were assumed to contain PCB’s and were counted throughout the building. In addition, survey documentation from the previous report by Clayton Environmental Services in 1996 (Annex information only), historical records, and conferences with the Steve Wilson of General Services Inc Maintenance, (GSI) were reviewed for pertinent information. Also, pertinent information was incorporated from previous materials sampled for asbestos or lead-based paints.

Asbestos A total of one hundred seventy-four (174) samples were collected and analyzed for asbestos content representing seventy-five (75) homogeneous building materials throughout the building. Samples were collected randomly (in inconspicuous areas), documented, and placed in labeled sample bags. All samples were stored in a second sealed bag then sent to the analytical laboratory using proper chain of custody methods. Of the samples analyzed, nine were found to contain asbestos, representing nine different homogeneous materials.

Please see Table 1 for a summary of asbestos-containing materials (ACM).

The following materials were sampled and found to be asbestos-containing during this survey:

• Red Speckled vinyl floor sheeting and mastic

• Yellowing vinyl floor sheeting and mastic

• Brown window putty on interior lobby/gift shop windows

• Gray window putty on interior and exterior windows

• Gray cement asbestos board

• Joint compound on fiberboard ceiling

• Skim coat on fiberboard ceiling

• Aircell pipe insulation

In addition, some materials where it would either be too destructive to sample or because they were inaccessible were assumed to contain asbestos based on discussions with GSI. These include the following:

Mt. Rainier, Washington

• Pipe fittings

• Mastic for 12” white ceiling tile

• Wall laminate mastic

• Fire doors

• Electrical panels (insulation behind them)

• Pipe thread mud

In this survey was Thermal system insulation (TSI) identified through visual observation on the second floor of the east wing. TSI is also assumed to be located on the first floor of the east wing and above the dining room ceiling, based on discussions with the maintenance supervisor. There may still be hidden TSI that was inaccessible to the inspectors, therefore, quantities were estimated. Quantities for pipe thread mud, window putty, and yellowing vinyl floor sheeting were also estimated, due to the inspectors’ limited accessibility to visually observe all locations for these materials. A list of unit prices should be requested for each material to minimize change order impacts caused by quantities of materials being more than what was accounted for, due to limited accessibility.

Lead-Based Paint In accordance with EPA protocol 40 CFR 745, XRF spectrum analyses were collected throughout the building. The survey included inspection of the entire interior and exterior paints with the use of XRF. The purpose of the survey was to identify painted surfaces regulated by the Occupational Safety and Health Administration (OSHA) lead construction standard, 29 CFR 1926.62 and the EPA regulations 40 CFR Part 745.

OSHA has not defined a minimum level for regulating lead, and has determined that lead at any detectable level shall be considered regulated. The specific OSHA regulation pertaining to lead exposure in construction is 29 CFR 1926.62 Lead. The presence of lead in paint at any level triggers the worker protection requirements of the regulation. The building contains lead-based painted surfaces greater than 1.0 milligram per centimeter squared (mg/cm2) or 5000 parts per million (ppm) as defined by 40 CFR Part 745.

There were 85 readings above the EPA regulated levels throughout the building. A total of 401 samples (shots) were obtained from various painted building materials throughout the Paradise Inn and Annex. Several painted interior materials were found to contain lead above the EPA limit, including:

• Cream paint on wood and gypsum walls, baseboards, doors, door frames, ceilings, window sills, window frames,

• White paint on wood walls, baseboards, window sills, window sashes,

• Light pink paint on wood walls (behind wood paneling)

• Dark pink paint on wood walls (behind wood paneling)

• Dark brown paint on wood walls, door frames, window sills, window frames, window sashes, beams

Mt. Rainier, Washington

• Green/blue/orange/red paint on wood columns

• Gray exterior paint on walls/siding, beams, interior window sills*

• Green exterior paint on doors, door frames, window sills, window frames*

* Colors listed are to be used as identifiers. Materials painted with these colors have lead-based paint in earlier painting schemes. Colors indicated here are newer latex based paints.

Lead-based paint still exists, it just is not in the top coat of paint.

See Table 3 for all XRF results. Although a majority of the samples found lead concentrations below the EPA limits, lead was detected at some concentration in a majority of the samples, requiring compliance with the OSHA regulations for worker protection.

Mt. Rainier, Washington

B. INTRODUCTION

The Federal Occupational Health Services (FOHS) division of the Department of Health and Human Services was requested by National Park Service to conduct a renovation specific hazardous materials survey of the Paradise Inn located at Mount Rainier, Washington. The inspection was to include sampling building materials for asbestos, lead-based paint, and PCB light ballasts.

FOH representatives, Ingrid Holznagel and Michelle Riche-Huppe performed the site survey.

Both representatives are Asbestos Hazard Emergency Response Act (AHERA) accredited building inspectors and EPA certified lead-based paint inspectors. Copies of certificates are attached in Appendix A and B respectively. The fieldwork was conducted under the supervision of Mr. Anthony Fullerton, Project Manager. Fieldwork was performed July 7 through July 21, 2004. Sample and material location drawings are attached in Appendix J.

C. BACKGROUND AND BUILDING DESCRIPTIONS

Paradise Inn – Main Building The Paradise Inn is a four-story building with a wood and heavy timber frame, concrete and stone rubble foundation, wood shingle siding, and wood shingle/metal roofing. Large wood support beams brace the front of the building. The main building is 41,872 square feet. The original building was constructed in 1916 to provide lodging and dining facilities for park visitors. Structural upgrades were made in 1979 to allow the structure to withstand lateral snow loads.

The sub-basement floor is located below the basement in the east wing of the building and consists of an electrical room, storage room, fire sprinkler room, and generator room. Boiler insulation, pipe insulation and lagging are present in the sub-basement, although they should not be affected by renovation activities. There is access to the crawlspace, where non-insulated pipes are visible.

The basement floor in the east wing consists of employee rooms, an infirmary, and a maintenance shop. There is a snow bridge connecting to the first floor of the Annex. The basement of the kitchen wing contains storage rooms and a boiler labeled “asbestos-free”.

Another crawlspace access is located here and reveals bare pipes.

The main floor of the building has a connecting kitchen/employee dining area, dining hall, lobby area (which includes an information desk area, gift shop, and snack bar), lounge, public restrooms, a few visitor rooms and offices. The walls are primarily gypsum wallboard throughout the main building. There are three large masonry chimneys located in the north area of the dining room, the north end of the lobby, and at the south end of the lobby. Tall wood columns run throughout the lobby and dining areas. The kitchen has a hood exhaust located centrally in the room. Steam pipes running along the front gift shop wall are un-

Mt. Rainier, Washington A-6450.32 insulated and very close to the thin wallboard and wood paneling on the walls. There is a snow bridge connecting to the second floor of the Annex.

The second floor consists of cook’s quarters in the kitchen wing, visitor rooms in the dining wing and east wing, public restrooms in the east wing, and the mezzanine area above the lobby. Known asbestos-containing TSI is located on the pipe run above the hallway ceiling tiles and is labeled as such.

Paradise Inn – Annex The Annex was constructed in 1921 for more visitor rooms. The Annex has wood framing, concrete and stone rubble foundation, wood shingle siding, and wood shingle/metal roofing.

There is a stone wall located on the north side of the structure. Remains of an old firebrick furnace are found against the rock wall, and an old metal furnace is located on the north wall of the basement. The Annex is 23,384 square feet.

There are four visitor room floors, as well as a basement and attic. The basement floor consists of an old boiler room, sprinkler room, and open area with bare pipes. All four main floors of the Annex are primarily visitor rooms with private bathrooms. Walls in the rooms are gypsum wallboard covered with wood paneling, and the ceilings are suspended 2’ x 4’ ceiling tiles. Housekeeping rooms are also found on each floor. Wall cavities were opened in the hallways to reveal bare pipes. The attic area is all wood framing and houses the heating, ventilation, and air conditioning (HVAC) system. Bare pipes are visible in the attic. According to GSI, all carpeting in the Annex hallways and rooms is tacked down.

D. METHODS

Asbestos Bulk asbestos samples of suspect materials were collected and then submitted to NVL Laboratories, 4805 Aurora Avenue North, Seattle, Washington for analyses. Analysis was performed using the EPA method EPA/600/R-93-116. The laboratory has is accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) accreditation number 102063.

A copy of this accreditation is located in Appendix L.

Lead-Based Paint Nondestructive sampling was performed using the MAP 4 XRF spectrometer with a 12.15 millicurie Cobalt 57 source. XRF sampling was performed using the testing procedures as outlined in the EPA Research and Development Document, “Standard Operating Procedures for Measurement of Lead in Paint using the Scitec Map-3 X-Ray Fluorescence Spectrometer,” September 1991. XRF results are attached in Appendix D; refer to the column showing K-shell readings for lead results in milligrams per square centimeter (mg/cm2).

Each space was designated with a homogeneous number and treated as such. Shot combinations in the spaces consisted of each color, substrate, and component represented.

Each shot from the XRF was also coded with the current condition of the paint. Paint conditions were determined to be good, satisfactory (fair), or poor by appearance, function, Mt. Rainier, Washington A-6450.32 and amount of damage. Calibration shots were taken at the beginning, middle, and end of the day, to ensure that the XRF was giving results accurately, and to comply with EPA regulations.

Test shots were displayed with positive, negative or inconclusive readings.

The readings are shown with the “K-shell” (high energy) and “L-shell (low energy) lead. The K-shell lead reading reflects the amount of lead present in the subsurface layers of paint, and the L-shell reading reflects the amount of lead present in the surface layers of paint. The only exception to this form of analysis is encountered when working with metal substrates. In these circumstances the K-shell reading provides the overall lead content for all paint layers and detectable levels of lead contained within the metal substrate. As a result the device cannot determine the L-shell value due to it being absorbed into the K-shell high-energy reading.

E. APPLICABLE STANDARDS AND CRITERIA

Asbestos The AHERA regulation, 40 CFR 763, is the primary governing regulation when performing asbestos surveys. This regulation was originally enacted for school buildings, but has since been applied to public and commercial buildings by the Asbestos School Hazard Abatement Reauthorization Act (ASHARA) in 1994. In addition, in 1995 OSHA revised their worker protection regulations dealing with asbestos exposure and included language requiring asbestos inspections to comply with AHERA. These regulations include 29 CFR 1926.1101 for construction related activities, which will apply if the asbestos materials are removed or if the building is renovated. AHERA and 29 CFR 1926.1101 define asbestos-containing material (ACM) as greater than 1% asbestos by volume when defining an asbestos project. OSHA however, regulates worker exposure to materials with less than 1% content through training, exposure assessments, and engineering controls.

Lead-Based Paint Lead was commonly used in most paint products until 1978, when it was banned from residential paints at levels greater than 600 ppm, (commercial applications with lead are still available). Lead is poisonous to the human body and presents a potential health hazard during any kind of disturbance (renovation, demolition, and even new construction) and also if improperly disposed where lead contaminants can enter drinking water wells.

EPA defines lead-based paint as a concentration of 1.0 mg/cm2 or greater by XRF or 0.5% by weight or greater by total lead analysis (which is equivalent to 5,000 ppm). This EPA action level triggers certain requirements for protection of the environment and building occupants in target housing and also specifies training and certification requirements for inspectors, project designers, contractors, supervisors, and workers in accordance with 40 CFR 745. Although it does not apply at this time, this is considered best management practice. OSHA has not defined a minimum level for regulating lead, and has clarified that lead at any detectable level shall be considered regulated. The specific OSHA regulation that pertains to lead exposure in construction is 29 CFR 1926.62 Lead. The presence of lead in paint at any level triggers these worker protection requirements.

Mt. Rainier, Washington A-6450.32

F. FINDINGS

Asbestos A total of one-hundred seventy-four (174) samples were collected and analyzed for asbestos content representing seventy-five (75) different homogeneous materials throughout the Paradise Inn. Of the samples analyzed, nine contained asbestos, representing nine different homogeneous materials.

The materials in Table 1 below are asbestos-containing based on analytical laboratory results.

The table presents a summary of the asbestos containing materials encountered during this survey, those reported in the survey conducted by Clayton Environmental Services (annex only), and materials known to exist as noted from current GSI personnel. Laboratory results from previous surveys are also presented in the appendix for reference. Table 2 in Appendix E details each suspect homogeneous material including sample numbers and location along with the result. Sample and material location drawings are attached in Appendix J. Quantities reported in the table have been increased by approximately 15% for contingency purposes.

Mt. Rainier, Washington

Table 1 Summary of Asbestos-Containing Materials

Paradise Inn – Mt. Rainier National Park Material Location Friable Quantity

Red speckled vinyl floor sheeting and mastic

1st floor, lounge Y 48 sf

Yellowing vinyl floor sheeting and mastic (under white/tan square-pattern vinyl floor sheeting and mastic)

Annex, 4th floor bathrooms (may not be in every bathroom)

Y Estimate 284 sf

Brown window putty Lobby, outside gift shop entrance between wood columns and windows

N 110 lf

Gray cement asbestos board Annex, basement, old boiler room

N 300 sf

Skim coat on fiberboard ceiling Lobby, information area Y 60 sf Joint compound on fiberboard ceiling

Lobby, information area Y 60 sf

Aircell pipe insulation Above dining room ceiling; 1st and 2nd floors of east wing, above suspended ceiling

Y Estimate 945 lf

Pipe thread mud Throughout the buildings N Unknown

Gray window putty Interior and exterior windows N Estimate 11,050 lf

Assumed Asbestos-Containing Materials Pipe fittings Throughout the buildings Unknown Estimate

2,540 ea Mastic for 12” ceiling tiles Cook’s quarter’s rooms, bathrooms and shower; 1st floor east wing restrooms; 3rd floor annex room 311

Unknown Estimate 1,378 sf

Wall laminate mastic Kitchen, employees dining area, annex bathrooms, cook’s quarter’s shower

Unknown Estimate 7,816 sf

Fire Doors Throughout the building Unknown Estimate 90 ea

Electrical panels (insulation behind them)

Throughout the building Unknown Estimate 30 ea

Summary of Materials from Clayton Environmental Services in 1996 (Annex only*) Cream colored sheet vinyl Room 424** N/A N/A White/gray floor tile Room 319 bathroom** N/A N/A Purple sheet vinyl Room 224 bathroom** N/A N/A

Mt. Rainier, Washington

Table 1 Summary of Asbestos-Containing Materials

Paradise Inn – Mt. Rainier National Park Material Location Friable Quantity

Brown mosaic sheet vinyl Room 112** N/A N/A Panel adhesive Room 420** N/A N/A Sheet vinyl mastic Room 319** N/A N/A Cove base mastic Room 319** N/A N/A

*Many materials found in this survey have since been replaced with new materials during the course of remodeling, according to GSI.

**Report does not specify if materials were located in other rooms.

lf = linear feet sf = square feet fittings = elbows, valves, “Tee’s”

When interpreting the data in this table, all other sections of the report must be referenced.

To be used for bidding purposes, contractors must take into account all information pertaining to location, material, and accessibility. The table alone should not be used for bidding purposes. Determination of friability is for abatement processes only and does not consider demolition forces, which may render non-friable materials friable. Additional material assessments are recommended for maintenance and renovation activities.

Non Asbestos-Containing Materials Of the seventy-five (75) homogenous materials sampled during this survey, sixty-six (66) were determined to be non-asbestos containing. These include the following:

• Green terrazzo vinyl floor sheeting and mastic

• Black with green and white flecks rubber flooring and mastic

• 4” brown cove base and brown mastic

• 4” black cove base and brown mastic

• Residual brown cove base and mastic

• White gypsum wallboard and joint compound

• Dark gray vapor barrier paper

• Cream-colored carpet mastic under blue carpet

• Light gray firebrick mortar

• Dark gray firebrick mortar

• Black tar material under 8” x 8” wood floor tiles

• Gray firebrick mortar with firebrick

• Gray rock mortar

• Gray slate grout and mastic

• Off-white sealant on fireplace

• Brown stair tread

• Textured gypsum wallboard and joint compound

• White 2’ x 4’ suspended ceiling tile with pinholes and small fissures

• White 2’ x 4’ suspended ceiling tiles with pinholes

• Brown stair tread and mastic

Mt. Rainier, Washington

• Tan carpet mastic under green carpet

• White wall caulking

• White textured wallpaper

• Silver paint – exterior roof

• White shower caulking

• Off-white textured wallpaper

• White with tan 4” square pattern vinyl floor sheeting and mastic

• White pipe penetration sealant

• White 2’ x 4’ suspended ceiling tile with pinholes and large fissures

• Gray rock mortar – exterior

• Gray brick mortar – exterior

• White hard window putty – exterior

• White soft window putty – exterior

• White tub caulking

• Tan/white 2” square pattern vinyl floor sheeting and mastic

• Tan vapor barrier paper

• Yellow mastic for 12” gray carpet tiles

• Black rubber floor mat and mastic

• Firebrick on old furnace – exterior

• Black vapor barrier paper under wood shingles - exterior

• Brown gypsum wallboard and joint compound

• White wood beam sealant

• 1” tan ceramic tile and grout

• 12” white glued-on ceiling tiles with pinholes and fissures

• Thin white gypsum wallboard

• Yellow mastic under red, blue, and brown carpet

• Painted mortar on concrete column

• White/blue square pattern vinyl floor sheeting and mastic

• White vibration isolator

• Black paper on posts – exterior roof

• Metal roof sealant – exterior roof

• Gray paper

• Concrete pipe penetration patch

• Gray concrete coating

• Gray floor sealant along 6” brown ceramic tile

• 6” brown ceramic tile

• Silver paint on brick mortar

• Black tar foundation sealant under gray paint

• Cream colored textured ceiling

• Green speckled vinyl floor sheeting and mastic

• 2” tan cove base and mastic

• White square pattern vinyl floor sheeting and mastic

• Paper under wood shingles –gift shop entry

Mt. Rainier, Washington

• Brown caulking – wood columns

• Gray mortar on heat shield opening

For a complete listing on non-asbestos containing materials please refer to the laboratory analytical data in Appendix C and Appendix E, and Table 2 for specific locations of materials tested. Also, according to GSI, Room 406 was found to have a new white floor sheeting that recently replaced old flooring in the bathroom, therefore, no samples were taken of this new material.

Lead-Based Paint A total of 401 readings were obtained from various surfaces throughout the building for determination of lead content. Lead was detected in nearly all surfaces at varying concentrations. A majority of the samples obtained found lead at concentrations below the EPA limit of 1.0 mg/cm2. Several interior materials were found to contain lead above the EPA limit, primarily painted wood walls, ceilings, doors, door frames, window sills, window frames, window sashes, baseboards, and wood columns/beams. Several exterior materials were found to contain lead above the EPA limit; primarily wood siding/walls, doors, door frames, window sills, window frames, and beams. For a complete list of XRF readings refer to Appendix D.

Fluorescent Light Tubes and PCB-Containing Ballasts Older fluorescent light ballasts have small capacitors that may contain high concentrations of PCBs. Nearly all ballasts manufactured before 1979 contain PCBs. All ballasts manufactured after July 1, 1978 that do not contain PCBs are required to be clearly marked "No PCBs."

Unmarked ballasts or ballasts without a date code should be assumed to be PCB ballasts.

PCBs are toxic chemicals according to EPA. While there is only a small amount, about one ounce, of PCBs in each light ballast capacitor, there are a large number of ballasts in the United States. About half of the estimated one billion ballasts, currently installed, were manufactured before 1979, and usually contain PCBs. Ballasts manufactured after 1978 may contain a PCB replacement called DEHP, a probable human carcinogen. In any case, ballasts should not be disassembled for disposal. Several fluorescent light ballasts were inspected for possible PCBs and no labels were observed indicating that the ballasts did not contain PCB’s.

Based on this, all light ballasts are assumed to be PCB-containing and must be handled accordingly. Light fixtures of several types were found, counted, and assumed to contain PCBs.

There are approximately 622 fluorescent light tubes and 155 ballasts throughout the building.

Some of the fixtures are newer, particularly those in the cafeteria area, but these ballasts were not inspected to determine if they are PCB containing.

Mercury in Fluorescent Lamps Fluorescent light bulbs are usually more energy efficient and have a longer use life than incandescent light bulbs. However, there are some environmental issues to consider in use and disposal of light bulbs.

Mt. Rainier, Washington A-6450.32

The EPA has tested fluorescent light bulbs based on the new Toxicity Characteristic Leaching Procedure (TCLP). In this testing, about 50 percent of the fluorescent light bulbs tested, were considered hazardous waste. The mercury used in the light bulbs represents a small part of the total mercury potentially entering the environment. According to the National Electrical Manufacturers Association, the fluorescent light bulbs account for about 0.2 % (or about 34 tons) of the total mercury releases. About 700 million mercury-containing lamps are purchased each year (1994). New procedures for handling fluorescent light bulbs are being developed, and interest in recycling has increased.

Additionally, a count was undertaken to determine how many fluorescent light tubes may be impacted by renovation or demolition activities. The EPA’s Green Light Policy encourages that, for activities that generate fluorescent light tubes as a potential waste stream, these tubes be recycled at an authorized facility. Requirements for recycling fluorescent light tubes included removing them from the fixture, packaging them into cardboard boxes, and transporting them to the recycler. Approximately 622 fluorescent light tubes were inventoried throughout the building.

G. RECOMMENDATIONS

FOH recommends that professional project management, including project oversight and monitoring for compliance to law, can minimize abatement costs. An abatement cost estimate is attached in Appendix F.

Asbestos The asbestos materials identified in this report are scheduled for removal prior to renovation of the structure; an abatement specification is attached in Appendix G. The ACM were determined to be in good condition and if removal does not occur in the near future, maintenance staff should perform a visual inspection every 6-months to verify that conditions do not change.

The results of this survey should be communicated to all employees, contract labor, and vendors who work in the building. In addition, this information should be included in the initial and annual asbestos awareness training performed for maintenance and custodial staff.

OSHA and EPA require copies of this survey to be maintained on the jobsite during any construction, maintenance, or abatement activities. Disturbance or removal of these asbestos materials can only be performed by trained and adequately supervised workers following regulatory requirements specified in 29 CFR 1926.1101 and EPA or local requirements.

This building was surveyed for suspect ACM based on renovation specific areas that will be affected by construction activities. Suspect materials may exist in non-typical locations and/or hidden areas that have not been surveyed (i.e. pipe chases, wall cavities, under carpet, etc.).

During any demolition or renovation project, care should be taken to visually ascertain that additional suspect asbestos materials are not disturbed without following the appropriate regulatory requirements. An AHERA building inspector should also perform a final visual

Mt. Rainier, Washington A-6450.32 inspection after demolition or renovation activities to ensure no additional suspect materials remain.

A list of unit prices per material should be requested to minimize change order impacts if quantities of materials are more than what was accounted for, due to limited accessibility.

Lead-Based Paint The EPA regulates the spaces that have lead levels greater than 1.0 mg/cm2 or more than 0.5% by weight. Although not regulated by the EPA, work in these areas and removal methods such as open flame burning, machine sanding or grinding without high-efficiency particulate air (HEPA) vacuum exhaust tool, uncontained high pressure washing, sandblasting without a HEPA vacuum exhaust tool, and heat guns operating above 1,100 degrees Fahrenheit would not be approved. If dry hand sanding or dry scraping is to occur, wet methods must be conducted or a HEPA vacuum must be used while sanding or scraping. For more information or clarification, see the U.S. Department of Housing and Urban Development, Guidelines for the Evaluation and Control of Lead Based Paint Hazards in Housing.

For areas with trace levels of lead-based paint, compliance with 29 CFR 1926.62 must be adhered to during renovation or construction activities. An abatement specification is attached in Appendix G.

Appendix A

Asbestos Hazard Emergency Response Act Building Inspector Certificates

Appendix B

EPA Certified Lead-Based Paint Inspector Certificates

Appendix C

Analytical Results- Asbestos

Appendix D

XRF Results

Appendix E

Table 2, Materials Sample for Asbestos

Table 2

Materials Sampled for Asbestos Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0712PI001 Green terrazzo vinyl floor sheeting with paper backing and mastic Lobby, snack bar 01 ND

0712PI002 Green terrazzo vinyl floor sheeting with paper backing and mastic

Lobby, snack bar 01 ND

0712PI003 Green terrazzo vinyl floor sheeting with paper backing and mastic

Lobby, snack bar 01 ND

0712PI004 Black with green and white flecks rubber flooring and mastic over HM# 01

Lobby, snack bar 02 ND

0712PI005 Black with green and white flecks rubber flooring and mastic over HM# 01

Lobby, snack bar 02 ND

0712PI006 Black with green and white flecks rubber flooring and mastic over HM# 01

Lobby, snack bar 02 ND

0712PI007 4” brown cove base and brown mastic Lobby, snack bar 03 ND 0712PI008 4” black cove base and brown mastic Lobby, snack bar 04 ND 0712PI009 Residual 4” black cove base and brown mastic Lobby, snack bar 05 ND 0712PI010 White gypsum wallboard and joint compound Lobby, snack bar 06 ND 0712PI011 White gypsum wallboard and joint compound Lobby, snack bar 06 ND 0712PI012 White gypsum wallboard and joint compound Lobby, snack bar 06 ND 0712PI013 Dark gray vapor barrier paper Basement, below snack bar 07 ND 0712PI014 Brown window putty Lobby, between wood columns and windows of gift shop 08 2% Chrysotile

0712PI015 Brown window putty Lobby, between wood columns and windows of gift shop

08 2% Chrysotile

0712PI016 Brown window putty Lobby, between wood columns and windows of gift shop

08 2% Chrysotile

0712PI017 Gray window putty Exterior, east side of gift shop 09 5% Chrysotile 0712PI018 Cream-colored carpet mastic under blue carpet Lobby, gift shop 10 ND 0712PI019 Cream-colored carpet mastic under blue carpet Gift shop 10 ND 0712PI020 Light gray firebrick mortar Lobby, behind north fireplace 11 ND 0712PI021 Dark gray firebrick mortar Lobby, behind north fireplace 12 ND 0712PI022 Black tar material under 8” x 8” wood floor tiles Lobby, south end 13 ND 0712PI023 Black tar material under 8” x 8” wood floor tiles Lobby, south end 13 ND 0712PI024 Black tar material under 8” x 8” wood floor tiles Lobby, south end 13 ND 0712PI025 Gray firebrick mortar with firebrick Lobby, south fireplace 14 ND 0712PI026 Gray rock mortar Lobby, south fireplace 15 ND 0712PI027 Gray slate grout and mastic Lobby, south fireplace 16 ND 0712PI028 Gray slate grout and mastic Lobby, south fireplace 16 ND

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0712PI029 Off-white sealant on fireplace Lobby, south fireplace 17 ND 0712PI030 4” brown cove base and brown mastic Lobby, wood columns 03 ND 0712PI031 4” brown cove base and brown mastic Lobby, wood columns 03 ND 0712PI032 Brown stair tread Dining room entry 18 ND 0712PI033 Textured gypsum wallboard and joint compound Dining room, south wall 19 ND 0712PI034 Textured gypsum wallboard and joint compound Dining room, south wall 19 ND 0712PI035 Textured gypsum wallboard and joint compound Dining room, south wall 19 ND 0712PI036 Black tar material under 8” x 8” wood floor tiles Dining room 13 ND 0712PI037 Gray window putty Exterior, east side of dining room

09 ND

0712PI038 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures

East wing, 2nd floor hallway 20 ND

0712PI039 Air cell insulation on pipes East wing, 2nd floor hallway, above suspended ceiling tiles

21 55% Chrysotile

0712PI040 White 2’ x 4’ suspended ceiling tile with pinholes East wing, 2nd floor hallway 22 ND 0712PI041 Brown stair tread and mastic East wing stairway, between 1st and 2nd floors

23 ND

0712PI042 Tan carpet mastic under green carpet East wing, 2nd floor hallway 24 ND 0712PI043 White gypsum wallboard and joint compound East wing, 2nd floor hallway 06 ND 0712PI044 White caulking East wing, 2nd floor women’s restroom wall

25 ND

0712PI045 White textured wallpaper East wing, 2nd floor women’s restroom

26 ND

0712PI046 Gray window putty Exterior, end of 2nd floor hallway 09 ND 0712PI047 Silver paint Exterior, end of 2nd floor hallway 27 ND 0714PI048 White shower caulking East wing, 2nd floor, north shower

28 ND

0714PI049 Off-white textured wallpaper East wing, 2nd floor women’s restroom

29 ND

0714PI050 White with tan 4” square pattern vinyl floor sheeting and mastic

East wing, 2nd floor north shower

30 ND

0714PI051 White 2’ x 4’ suspended ceiling tile with pinholes Lobby, snack bar 22 ND 0714PI052 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures Lobby, snack bar 20 ND

0714PI053 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures

East wing, 1st floor hallway 20 ND

0714PI054 White pipe penetration sealant East wing, 1st floor hallway 31 ND 0714PI055 White gypsum wallboard and joint compound East wing, basement, northwest corner of maintenance shop

06 ND

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0714PI056 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures East wing, basement hallway 20 ND

0714PI057 White 2’ x 4’ suspended ceiling tile with pinholes East wing, basement hallway 22 ND 0714PI058 White 2’ x 4’ suspended ceiling tile with pinholes and large random fissures East wing, basement hallway 32 ND

0714PI059 White 2’ x 4’ suspended ceiling tile with pinholes and large random fissures

East wing, 1st floor hallway 32 ND

0714PI060 White pipe penetration sealant East wing, basement, room

BHV2

31 ND

0714PI061 Gray rock mortar Annex exterior, north rock wall 33 ND 0714PI062 Gray brick mortar Annex exterior, north rock wall 34 ND 0714PI063 Gray rock mortar Annex exterior, north rock wall 33 ND 0714PI064 White hard window putty Annex exterior, north basement window

35 ND

0714PI065 White soft window putty Annex exterior, north basement window

36 ND

0714PI066 White hard window putty Annex exterior, east basement window

35 ND

0714PI067 Gray rock mortar Annex exterior, north rock wall 33 ND 0716PI068 White 2’ x 4’ suspended ceiling tile with pinholes Annex, 4th floor, room 405 22 ND 0716PI069 White 2’ x 4’ suspended ceiling tile with pinholes and large random fissures Annex, 4th floor, room 405 32 ND

0716PI070 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures

Annex, 4th floor, room 405 20 ND

0716PI071 White tub caulk Annex, 4th floor, room 405 37 ND 0716PI072 White with tan 4” square pattern vinyl floor sheeting and mastic Annex, 4th floor, room 405 30 ND

0716PI073 White with tan 4” square pattern vinyl floor sheeting and mastic over yellowing vinyl floor sheeting and mastic

Annex, 4th floor, room 415 30

Lyr 1: ND Lyr 2: ND Lyr 3: ND Lyr 4: 50% Chrysotile

0716PI074 White gypsum wallboard and joint compound Annex, 4th floor, hallway 06 ND 0716PI075 White gypsum wallboard and joint compound Annex, 3rd floor, hallway 06 ND 0716PI076 Tan/white 2” square pattern vinyl floor sheeting and mastic Annex, 3rd floor, room 307 38 ND

0716PI077 White 2’ x 4’ suspended ceiling tile with pinholes and small fissures

Annex, 3rd floor, room 307 20 ND

0716PI078 White 2’ x 4’ suspended ceiling tile with pinholes Annex, 3rd floor, room 307 22 ND

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0716PI079 White with tan 4” square pattern vinyl floor sheeting and mastic Annex, 3rd floor, room 315 30 ND

0716PI080 Tan vapor barrier paper under wood floor Annex, 2nd floor, hallway wall cavity

39 ND

0716PI081 White gypsum wallboard and joint compound Annex, 1st floor, hallway 06 ND 0716PI082 Yellow mastic for 12” gray carpet tiles Annex, 1st floor, hall entry 40 ND 0716PI083 Gray rock mortar Annex, 1st floor, hall entry 33 ND 0716PI084 White gypsum wallboard and joint compound Annex, 1st floor, hallway 06 ND 0716PI085 Black rubber floor mat and mastic Annex, 1st floor, housekeeping 41 ND 0716PI086 White gypsum wallboard and joint compound Annex, 1st floor, housekeeping 06 ND 0716PI087 Cement asbestos board Annex, basement, old boiler room 42 30% Chrysotile

0716PI088 4” brown cove base and brown mastic Annex, basement, fire sprinkler room

03 ND

0716PI089 White gypsum wallboard and joint compound Annex, basement, fire sprinkler room

06 ND

0716PI090 Pipe thread mud Annex, basement 44 ND 0716PI091 Pipe thread mud Annex, basement 44 4% Chrysotile 0716PI092 Pipe thread mud Annex, basement 44 ND 0716PI093 Firebrick on old furnace Annex exterior, north rock wall 45 ND 0716PI094 Black vapor barrier paper under wood shingles Annex exterior, north wall 46 ND 0716PI095 Black vapor barrier paper under wood shingles Annex exterior, north wall 46 ND 0716PI096 Black vapor barrier paper under wood shingles East wing exterior, north wall 46 ND 0716PI097 Black vapor barrier paper under wood shingles East wing exterior, north wall 46 ND 0716PI098 Brown gypsum wallboard and joint compound East wing, 2nd floor, room 465 47 ND 0716PI099 White wood beam sealant Mezzanine, 2nd floor 48 ND 0716PI100 Brown gypsum wallboard and joint compound East wing, 2nd floor, room 461 47 ND 0716PI101 White wood beam sealant East wing, 2nd floor, room 461 48 ND 0716PI102 Brown gypsum wallboard and joint compound East wing, 2nd floor, room 460 47 ND 0716PI103 White wood beam sealant East wing, 2nd floor, room 460 48 ND 0716PI104 1” tan ceramic tile and grout East wing, 2nd floor, room 460 49 ND 0716PI105 Brown gypsum wallboard and joint compound East wing, 1st floor, women’s restroom

47 ND

0716PI106 12” white glued-on ceiling tiles with pinholes and fissures

East wing, 1st floor, women’s restroom

50 ND

0716PI107 4” black cove base and brown mastic Lobby, snack bar 04 ND 0716PI108 White with tan 4” square pattern vinyl floor sheeting and mastic East wing, 1st floor, room 10 30 ND

0716PI109 White gypsum wallboard and joint compound East wing, 1st floor, room 10 06 ND

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0716PI110 Thin white gypsum wallboard East wing, 1st floor room 10 closet

51 ND

0716PI111 White gypsum wallboard and joint compound East wing, 1st floor, office 2 06 ND 0716PI112 Yellow mastic under red, blue, and brown carpet East wing, 1st floor, office 2 52 ND 0716PI113 Yellow mastic under red carpet East wing, 1st floor, office 1 52 ND 0716PI114 White 2’ x 4’ suspended ceiling tile with pinholes East wing, 1st floor, office 2 22 ND 0716PI115 Painted mortar on concrete column East wing, 1st floor, office 1 53 ND 0716PI116 White gypsum wallboard and joint compound East wing, basement, room

BHV2

06 ND

0716PI117 White/blue square pattern vinyl floor sheeting and mastic (2 layers)

East wing, basement, room

BHV2

54 ND

0716PI118 Yellow mastic under carpet East wing, sub-basement, top of stairs

52 ND

0716PI119 Brown stair tread East wing, sub-basement, stairs 18 ND 0716PI120 White gypsum wallboard and joint compound East wing, sub-basement, hallway

06 ND

0716PI121 White gypsum wallboard and joint compound East wing, sub-basement, fire sprinkler room

06 ND

0716PI122 4” brown cove base and brown mastic East wing, sub-basement, fire sprinkler room

03 ND

0716PI123 White vibration isolator East wing, sub-basement, generator room

55 ND

0716PI124 White 2’ x 4’ suspended ceiling tile with pinholes and large random fissures

East wing, basement, hallway 32 ND

0716PI125 White gypsum wallboard and joint compound Mezzanine, 2nd floor 06 ND 0716PI126 White gypsum wallboard and joint compound Mezzanine, 2nd floor 06 ND 0716PI127 Black paper on posts East wing, exterior of 2nd floor, end of hallway

56 ND

0716PI128 Metal roof sealant East wing, exterior of 2nd floor, end of hallway

57 ND

0716PI129 Black paper on posts East wing, exterior of 2nd floor, end of hallway

56 ND

0716PI130 Gray paper Mezzanine, south stairs 58 ND 0716PI131 Concrete pipe penetration patch Kitchen wing, basement, battery/storage room

59 ND

0716PI132 White gypsum wallboard and joint compound Kitchen wing, basement, battery/storage room

06 ND

0716PI133 White gypsum wallboard and joint compound Kitchen wing, basement, back storage room

06 ND

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0716PI134 Gray concrete coating Kitchen wing, basement, back storage room

60 ND

0716PI135 Gray concrete coating Kitchen wing, basement, back storage room

60 ND

0716PI136 Gray floor sealant along 6” brown ceramic tile Kitchen wing, 1st floor, employee dining area

61 ND

0716PI137 6” brown ceramic tile and grout Kitchen wing, 1st floor, employee dining area

62 ND

0716PI138 Silver paint on brick mortar Kitchen wing, 1st floor, kitchen 63 ND 0716PI139 Black tar foundation sealant under gray paint Kitchen wing, exterior, north foundation wall

64 ND

0716PI140 Black tar foundation sealant under gray paint Kitchen wing, exterior, north foundation wall

64 ND

0716PI141 Cream colored textured ceiling Dining room, ceiling 65 ND 0716PI142 Cream colored textured ceiling Dining room, ceiling 65 ND 0716PI143 Cream colored textured ceiling Dining room, ceiling 65 ND 0716PI144 Gray rock mortar Dining room, north fireplace 15 ND 0716PI145 Gray rock mortar Dining room, north fireplace 15 ND 0716PI146 Green speckled vinyl floor sheeting and mastic East wing, lounge 66 ND 0716PI147 4” brown cove base and brown mastic East wing, lounge 03 ND 0716PI148 2” tan cove base and mastic East wing, lounge 67 ND 0716PI149 Red speckled vinyl floor sheeting and mastic East wing, lounge, bar floor 68 55% Chrysotile 0716PI150 White square pattern vinyl floor sheeting and mastic East wing, basement, infirmary 69 ND

0716PI151 Black vapor barrier paper under wood shingles Kitchen wing, exterior, north roof edge

46 ND

0716PI152 Thin white gypsum wallboard Lobby, front wall of gift shop 51 ND 0716PI153 Thin white gypsum wallboard Lobby, front wall of gift shop 51 ND 0716PI154 Paper under wood shingles Lobby, front roof of gift shop 70 ND 0716PI155 Paper under wood shingles Lobby, front roof of gift shop 70 ND 0716PI156 Brown caulking Lobby, wood columns 71 ND 0716PI157 Brown caulking Lobby, wood columns 71 ND 0716PI158 Gray mortar material on heat shield opening Lobby, closet behind north fireplace

72 ND

0716PI159 Gray mortar material on heat shield opening Lobby, closet behind north fireplace

72 ND

0716PI160 Joint compound along fiberboard seams on ceiling Lobby, information area 73 2% Chrysotile 0716PI161 Joint compound along fiberboard seams on ceiling Lobby, information area 73 2% Chrysotile 0716PI162 Skim coat on fiberboard ceiling Lobby, information area 74 2% Chrysotile 0716PI163 Skim coat on fiberboard ceiling Lobby, information area 74 2% Chrysotile

Paradise Inn – Mt. Rainier National Park

Sample Material Location HM Results 0716PI164 Silver paint on brick Kitchen wing, kitchen 63 ND 0716PI165 Gray window putty Kitchen wing, employee dining area, east windows 09 2% Chrysotile

0716PI166 Gray window putty Kitchen wing, employee dining area, east windows

09 2% Chrysotile

0716PI167 12” white glued-on ceiling tiles with pinholes and fissures

Kitchen wing, 2nd floor, cook’s quarters, room 9

50 ND

0716PI168 12” white glued-on ceiling tiles with pinholes and fissures

Kitchen wing, 2nd floor, cook’s quarters, west restroom

50 ND

0716PI169 White gypsum wallboard and joint compound Kitchen wing, 2nd floor, cook’s quarters, hallway

06 ND

0716PI170 12” white glued-on ceiling tiles with pinholes and fissures

Annex, 3rd floor, room 311 bathroom

50 ND

0716PI171 White with gray border vinyl floor sheeting and mastic

Annex, 3rd floor, room 316 43 ND

0716PI172 White hard window putty Annex exterior, north wall 35 ND 0716PI173 White soft window putty Annex exterior, north wall 36 ND 0716PI174 White soft window putty Annex exterior, north wall 36 ND

Appendix F Abatement Cost Estimate

COST ESTIMATE

Date Prepared

11/23/2004 Sheet 1 of 1 Activity and Location Estimate by: Med-Tox NW Job No.

Paradise Inn, Mt. Rainier National Park Anthony Fullerton A.6450.32 Client Project Title Status of Design Delivery Order Number Asbestos, Lead-based Paint and PCB Demolition Survey 15% 90% Final Other SE. 04-11

Item Description Quantity Equipment/Material Cost Labor Cost Engineering Estimate

Number Unit Unit Cost Total Unit Cost Total Total Mobilization/demobilization 1 EA $5,000.00 $5,000.00 $0.00 $5,000.00 $5,000.00 Asbestos Abatement Paradise Inn

Sheet vinyl flooring 48 SF $0.40 $19.20 $2.00 $96.00 $2.40 $115.20 Sheet vinyl flooring- two layers 284 EA $0.40 $113.60 $2.35 $667.40 $2.75 $781.00 Brown window putty 110 LF $0.53 $58.30 $1.56 $171.60 $2.09 $229.90 Gray cement asbestos board 300 SF $0.40 $120.00 $1.12 $336.00 $1.52 $456.00 Skim coat and joint compound on fiberboard 60 SF $0.75 $45.00 $2.35 $141.00 $3.10 $186.00 Aircell pipe insulation 945 LF $4.65 $4,394.25 $10.00 $9,450.00 $14.65 $13,844.25 Gray window putty 11,050 LF $0.53 $5,856.50 $1.56 $17,238.00 $2.09 $23,094.50

Presumed Asbestos Containing Materials Magnesite Pipe Fittings 550 EA $0.90 $495.00 $14.57 $8,013.50 $15.47 $8,508.50 12-inch ceiling tile mastic 1,378 SF $0.55 $757.90 $0.90 $1,240.20 $1.45 $1,998.10 Wall laminate mastic 7,816 SF $0.55 $4,298.80 $0.90 $7,034.40 $1.45 $11,333.20 Electrical panel insulation 30 EA $1.50 $45.00 $9.00 $270.00 $10.50 $315.00 Fire doors 90 EA $81.75 $7,357.50 $81.75 $7,357.50 $163.50 $14,715.00

Lead-Based Paint Controls/ Removal Training and workplan components 1 EA $600.00 $600.00 $3,814.50 $3,814.50 $4,414.50 $4,414.50 Exposure assessments1 10 EA $140.00 $1,400.00 $340.00 $3,400.00 $480.00 $4,800.00 Waste stream characterization 8 EA $425.00 $3,400.00 $800.00 $6,400.00 $1,225.00 $9,800.00

PCB Light Ballasts and Fluorescent light tubes Remove and recycle light tubes 622 EA $0.59 $366.98 $1.35 $839.70 $1.94 $1,206.68 Remove and dispose PCB light ballasts 155 EA $1.56 $241.80 $7.60 $1,178.00 $9.16 $1,419.80

Subtotal $34,569.83 $67,647.80 $102,217.63 Contingency (10%) $3,456.98 $6,764.78 $10,221.76

Total $38,026.81 $74,412.58 $112,439.39

Note 1: Exposure assessments for lead are one per removal process. More exposure assessments may be needed depending on the type of work being performed.

Note 2: Overhead of 10% and profit of 15% are figured into each unit cost Note 3 : Unit prices are figured for year 2006 dollars. Numbers were figured using a 3% increase per year. Prices are based on on the 3% increase alone and do not factor in regulation changes. Figures were determined using 2004 Means Guide and does not include location factors for Mount Rainier National Park.

Appendix G

Asbestos Abatement Specification Section

National Park Service Mount Rainier National Park Paradise Inn

08/16/04 Page 1 Asbestos Abatement Performance Specifications 02113

SECTION 02113 – REMOVAL AND HANDLING OF…