DRAFT Analysis of Brownfields Cleanup Alternatives City of Olympia Isthmus Properties 505/529 4 th Avenue West

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1 DRAFT Analysis of Brownfields Cleanup Alternatives City of Olympia Isthmus Properties 505/529 4 th Avenue West December 2013 Prepared by: Kip Summers, P.E. City of Olympia

2 Table of Contents Introduction... 3 Scope... 3 Background... 3 Site Location... 3 Previous Site Uses and Previous Cleanup Activity... 3 Site Assessment Findings... 4 Project Goal... 4 Applicable Regulations... 5 Cleanup Oversight Responsibility... 5 Cleanup Regulations... 5 Evaluation of Cleanup Alternatives... 5 Cleanup Objective... 5 Cleanup Alternatives Considered... 5 Evaluation of Alternatives... 5 Effectiveness... 5 Implementability... 6 Costs... 6 Recommended Cleanup Alternative

3 Introduction This document presents an Analysis of Brownfields Cleanup Alternatives (ABCA) for the Isthmus buildings, formerly Thurston County Health Building and Thurston County Housing Building. This document was prepared by the City of Olympia as part of the EPA Brownfield Cleanup Grant Application. Notice of this document has been published and made available for comment, in accordance with the community relations plan of the EPA Brownfields Grant. Scope The scope of work for this ABCA is to identify, evaluate and select an appropriate cleanup plan to address the asbestos contamination in the former Thurston County Health Building and former Thurston County Housing Building. The ABCA uses information provided in the Phase I Environmental Site Assessment 1 and Phase II Environmental Site Assessment 2 for the properties and Asbestos Hazard Emergency Response Act (AHERA) Asbestos Surveys 3 for each of the buildings. Background Site Location The Site consists of two tax parcels, and , with corresponding addresses of 529 and 505 4th Avenue West, respectively. The building at 529 4th Avenue W was the former Thurston County Health Building and the building at 505 4th Avenue W was the former Thurston County Housing Building. Previous Site Uses and Previous Cleanup Activity The earliest use of the Site was as a wharf and eventually the Site was used as a lumber yard and mill. An auto shop, boat building and oyster packing plant were on the north portion of the Site. In the 1950s, Thurston County purchased the parcels and developed them for use by the County. The Memorial Clinic was built in 1955 on the 529 address. This two story, 14,000 square foot building was then continuously used by Thurston County Health Department until the 1980s. It had several remodels over the years. The building has not been used since the County moved all its personnel to their new facilities in the 1980s. It has been unused since that time. In about 2007, the building was illegally taken over by Occupy Olympia, for a short period of time. The County built a 5,000 sq. ft. single story building on the 505 address in 1968 for Thurston County Housing. This building was added to over the years and expanded to about 7,000 sq. ft. The County moved out of the building in the 1980s and the building has been mostly vacant since then. 1 ESA I, Pioneer Technologies, Inc., October ESA II, Pioneer Technologies, Inc., August Asbestos Surveys for 505 and th Ave W, Krazan & Associates, Inc., October

4 There has been no previous cleanup or remediation of the asbestos material in either of the buildings. Site Assessment Findings During the purchase process, the City of Olympia hired Pioneer Technologies, a local environmental engineering firm, to prepare an ASTM Phase I Report for the Site. That report is dated October Pioneer was unable to gain access to the buildings but did report previously identified regional environmental conditions (RECs). Those RECs were asbestos containing materials, mercury containing light bulbs and fixtures, and potentially lead based paint. A Phase II Environmental Site Assessment (ESA) was conducted by Pioneer Technologies in August of That Phase II ESA evaluated RECs and other potentially environmental concerns that were identified in the Phase I ESA for the Site. The three RECs, asbestos, mercury and lead, were all associated with the building and were addressed by a later Asbestos and Lead 4 study. The Phase II therefore developed a Conceptual Site Model (CSM) and focused on the other potential environmental concerns. Samples were taken from ten unique sample locations. Soil and groundwater concentrations were evaluated for compliance with Model Toxic Control Act (MTCA) Method B for unrestricted land use. There were isolated exceedances in soil for arsenic and Polycyclic Aromatic Hydrocarbons (PAHs) and in groundwater for arsenic and lead. Additional investigation was recommended to investigate the extent of contamination. Asbestos and lead surveys were done by Krazan and Associates in October of These surveys were to identify and quantify the presence of any Asbestos-Containing Materials (ACM) and lead containing materials on and within the structures. The survey of the 529 building noted extensive interior damage to the structure that had been done by trespassers to steal 'scrap' copper tubing and wiring. Numerous areas had used syringes lying on the carpets. Several rooms were used as secondary latrines, after the existing restrooms were filled. The results of the room-by-room asbestos investigation found 31 of the 53 bulk samples contained more than one-percent asbestos content. The lead testing identified a total of 6 components that tested positive for the presence of lead. The asbestos survey for the 505 building tested 39 bulk samples and identified 10 samples as containing more than one-percent asbestos content. The asbestos-containing materials were vinyl floor tile and black mastic. The survey stated all tile flooring and black mastic within the building must be abated. The lead survey for the 505 building tested 123 painted components and found a total of 3 components that tested positive for the presence of lead. Project Goal The planned reuse of the Site is as a recreational park. The City has not yet developed a master plan for the park. This grant application is to assist the City in the abatement of asbestos- 4 Lead Surveys for 505 and th Ave W, Krazan & Associates, Inc., October

5 containing materials in the two buildings. This is considered a first phase for creating the park. The City will be working to secure additional funding sources to develop a complete financial package for the park. Applicable Regulations Cleanup Oversight Responsibility Asbestos cleanup oversight will be overseen by Olympic Region Clean Air Agency (ORCAA). Licensing and working standards are regulated by Washington State Labor and Industries per Chapter RCW. Cleanup Regulations CFR title 40 Subpart is the Federal regulation for National Emission Standards for Hazardous Air Pollutants (NESHAP) under the Clean Air Act and specifies work practices for asbestos to be followed during demolitions and renovations of all structures, installations, and buildings. Chapter RCW identifies required preconstruction inspections, notifications to LNI, and asbestos contractor licensing for construction projects. Evaluation of Cleanup Alternatives Cleanup Objective The objective of the asbestos cleanup at the Isthmus site is to reduce or eliminate the potential risk of airborne asbestos fibers to workers and the public both prior to and during demolition of the buildings. The cleanup shall meet United States Environmental Protection Agency (USEPA), Occupational Safety and Health Administration (OSHA), Washington State Labor and Industries, and Olympic Region Clean Air Agency requirements. Cleanup Alternatives Considered To address asbestos contamination at the Site, two different alternatives were considered; Alternative #1: No Action and Alternative #2: Removal. Evaluation of Alternatives To satisfy USEPA requirements, the effectiveness, implementability and cost of each alternative must be considered prior to selecting a recommended cleanup alternative. Effectiveness Alternative #1: No Action This alternative is not effective and would result in the potential release of friable asbestos. ACM have been identified in both buildings. Since demolition of the buildings is the ultimate goal, no action would most likely release friable asbestos and thereby expose the demolition workers and potentially the public in the area to hazardous materials as the asbestos becomes airborne and uncontained. 5

6 Alternative #2: Removal Removal, in accordance with regulations, will reduce the human health risk. This alternative requires all contractors exposed to the ACM to be licensed Asbestos Abatement firms as regulated by Washington State Labor and Industries (L&I). Physical removal of the ACM will eliminate the potential for human exposure at the subsequent project stage, which will be demolition of the building. It also effectively removes the hazard for the long term through proper offsite disposal. Implementability Alternative #1: No Action is easy to implement since no activity will be conducted. Alternative #2: Removal is more difficult. It will require permitting with ORCAA and L&I. Removal will require the contracting of licensed abatement contractors, proper documentation of the removal and certified inspection of the completed removal. All of these functions are readily available in the area but require additional project management and time. One complicating factor for removal of ACM in the 525 building is the presence of biohazards within the building. It is recommended that ACM cleanup for this building begin with the removal of the biohazards. It is assumed that biohazard removal would be rolled into the same construction contract as the ACM removal since any work within the building will have to comply with asbestos cleanup regulations, until the ACM is abated or removed. Costs Alternative #1: No Action is a no cost alternative as funds would not be expended to clean-up the ACM. Alternative #2: Removal is estimated to cost roughly $515, Recommended Cleanup Alternative The recommended cleanup alternative is Alternative #2: Removal. Alternative #1 does not address the site risks. Without cleanup or removal of the ACM, the Site will always contain asbestos contaminated material; and therefore, will have a continued risk to human health through exposure to airborne asbestos fibers. The long term solution of removal and proper disposal of ACM from the Site is the only alternative that allows the City to move forward with the continued evaluation, cleanup and development of the Site, as proposed. 5 Revised Cost Estimates for Abatement and Demolition Letter Report, Krazan & Associates, Inc., October

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