1. Introduction

The Sitka Maritime Heritage Society, Incorporated, was organized in 1999 in Sitka, Alaska. The Society has determined that the Japonski Island Boathouse, unused for approximately the last twenty years, should be preserved as an important structure symbolizing Sitka’s maritime past, present, and future. The Society intends to use the rehabilitated boathouse as a maritime museum, and an interpretive center for the Japonski Island National Historical Landmark, which was created out of the World War II military sites on Japonski Island.

The Society prepared an application on behalf of the City and Borough of Sitka to the Alaska Historic Preservation Office for a federal Historic Preservation Fund grant, also known in Alaska as a Certified Local Government grant, for a hazardous materials survey on the boathouse. This federal grant was matched with in-kind services by the City (administration of the grant) and donated services, materials and cash from the Sitka Maritime Heritage Society.

The Society contracted with D.G.Jones/Associates to complete the hazardous materials survey of the Boathouse, as a prerequisite to cleanup and rehabilitation of the structure. The proposed scope of the survey was to “…determine what types and quantities of contaminants exist at the Boathouse…to allow the Society to contract for subsequent cleanup, as needed.” The proposal excluded the historical and regulatory research included in an ASTM 1527-00 Phase 1 Environmental Assessment, but included physical sampling and testing for any suspected Hazardous materials found at the site. Based on an exterior reconnaissance of the Boathouse, the proposal assumed the existence of Asbestos Containing Materials (ACM), Lead in paint, PCBs/Mercury, and hydrocarbons in soils. Additional time and lab expense was included in the proposal for “…other materials, should they present themselves during the survey.”

Sampling began in late July 2003, with follow-up sampling done in September and October 2003.

2. Sampling

Sampling was done 18 and 20 July, 13 September, and 19 October 2003. All samples to be analyzed were sent to North Creek Analytical, Inc. (NCA), in Bothell, Washington. Analysis of asbestos samples was subcontracted by NCA to Prezant Associates, Inc. (Prezant), of Seattle, Washington.

Under the scope of work for sampling and testing of “…other materials, should they present themselves during the survey”, soil samples were collected from the boat repair bay to be tested for hazardous materials as constituents of bottom paint

Figure 1, at the rear of this report, indicates the location of samples taken for this survey.

2.1 18 July 2003 Sampling

On 18 July, paint chips were collected from exterior and interior painted surfaces. All three of the samples taken were sent for analysis for Cadmium and Lead Total Metals, by the EPA 6020 method. Sampling information is provided in Table 2-1, below.

Date	Field No.	Lab ID No.	Report No.	Material	Location

18-Jul-03	071803-1	B3G045-01	02094-101	Paint chips	N/A
18-Jul-03	071803-2	B3G045-02	02094-102	Paint chips	N/A
18-Jul-03	071803-3	B3G045-03	02094-103	Paint chips	N/A

Table 2-1

The field notes for this sampling event were lost prior to preparation of this report, so the locations of the samples are not included on Figure 1, and they are listed in table 2-1 as unknown. Nonetheless, the lab results are presented here and in Section 3. Results, as they are useful in determining the amount and type of cleanup required.

The following photo of the interior of the rooms south of the boat repair bay indicates the general condition of the interior paints throughout the building.

Also during this sampling event, an inventory was made of potentially hazardous waste materials that can be handled by Society members or other non-certified personnel. These materials, located in the rooms south of the boat repair bay, included:

Paint (various, including aluminum paint)
Resorcinol (adhesive) resin
Various other adhesives
Varnish and shellac
Pentachlorophenol
Turpentine
Kerosene
Asbestos-filled roof patch
Various greases
Fluorescent light fixtures with ballasts and tubes
Additional fluorescent tubes
Lead/acid batteries

2.2 20 July 2003 Sampling

Additional paint samples, and bulk samples of materials suspected of being asbestos containing materials (ACM), were taken on 20 July. The paint samples were taken in the rooms north and west of the boat repair bay. One suspected ACM sample was taken in the furnace room at the east end of the rooms south of the boat repair bay. This sample was a strip of painted wallboard tape and taping mud. The other suspected ACM sample was a stray piece of insulation found outside of the building.

The paint samples were sent for analysis for Cadmium and Lead Total Metals, by the EPA 6020 method. The suspected ACM samples were sent for analysis for asbestos by polarized light microscopy per EPA method 600/R-93/166. Sampling information is provided in Table 2-2, below.

Date	Field No.	Lab ID No.	Report No.	Material	Location

18-Jul-03	071803-1	B3G045-01	02094-101	paint chips	N/A
18-Jul-03	071803-2	B3G045-02	02094-102	paint chips	N/A
18-Jul-03	071803-3	B3G045-03	02094-103	paint chips	N/A

20-Jul-03	072003-1	B3G0619-01	02094-201	Paint chips	Interior wall, additional building
20-Jul-03	072003-2	B3G0619-02	02094-202	Paint chips	Interior wall, north room
20-Jul-03	072003-3	B3G0619-03	02094-203	Paint chips	Interior wall, north room
20-Jul-03	072003-4	B3G0619-04	02094-204	Light green painted wallboard tape	Furnace room
20-Jul-03	072003-5	B3G0619-05	02094-205	Insulation scrap	Exterior ground

Table 2-2

Additional hazardous materials that can be collected and disposed of by non-certified personnel were found in the rooms north and west of the boat repair bay. These materials included:

Paint (zinc primer, other unidentified types)
Canvas treatment (varnish)
Caulking compound
Gear oil (or some other petroleum-based fluid in a gear oil can)
Unknown fluid with solvent smell (in 55 gallon drum labeled “Lard”)
Fluorescent light fixtures with ballasts and tubes

Additional fluorescent tubes and screw-base bulbs
Lead/acid batteries

2.3 13 September 2003 Sampling

On 13 September, soil samples were collected in the boat repair bay, and at the foot of the south exterior wall. The samples from the work bay were collected to be tested for hazardous materials from bottom paint, but were not sent to the lab at that time. The soil sample from below the exterior wall was sent for analysis for the eight RCRA metals by TCLP (Leaching of metals), by EPA method 1311/6000/7000.

One additional sample of wallboard from the furnace room was taken, excluding wallboard tape and taping mud, and sent for analysis for asbestos by polarized light microscopy per EPA method 600/R-93/166. Three additional paint samples, two of exterior wall paint and one of paint from the marine railway cradle in the boat repair bay, were taken and sent for analysis for Cadmium and Lead Total Metals, by the EPA 6020 method.

Sampling information is provided in Table 2-3, below.

Date	Field No.	Lab ID No.	Report No.	Material	Location

18-Jul-03	071803-1	B3G045-01	02094-101	paint chips	N/A
18-Jul-03	071803-2	B3G045-02	02094-102	paint chips	N/A
18-Jul-03	071803-3	B3G045-03	02094-103	paint chips	N/A

20-Jul-03	072003-1	B3G0619-01	02094-201	paint chips	interior wall, additional building
20-Jul-03	072003-2	B3G0619-02	02094-202	paint chips	interior wall, north room
20-Jul-03	072003-3	B3G0619-03	02094-203	paint chips	interior wall, north room
20-Jul-03	072003-4	B3G0619-04	02094-204	light green painted wallboard tape	furnace room
20-Jul-03	072003-5	B3G0619-05	02094-205	insulation scrap	exterior ground

13-Sep-03	02094-401		02094-301	Soil	Work bay
13-Sep-03	02094-402		02094-302	Soil	Work bay
13-Sep-03	02094-403	B2I0441-01	02094-303	Soil	Below exterior wall
13-Sep-03	02094-404	B2I0441-02	02094-304	Light green painted wallboard, no tape or mud	Furnace room
13-Sep-03	02094-405	B2I0441-03	02094-305	White paint chips	Exterior wall
13-Sep-03	02094-406	B2I0441-04	02094-306	Red paint chips	Boat cradle
13-Sep-03	02094-407	B2I0441-05	02094-307	Blue paint chips	Exterior wall

Table 2-3

The photo below indicates the degree of deterioration of the exterior white paint at the southeast corner of the building.

2.4 19 October 2003 Sampling

During the 13 September 2003 sampling event the copper feed tubing to the boathouse furnaces was traced under the structure, but no fuel tank could be located. Additional exploration revealed the fill and vent pipes for the tank (an underground storage tank, UST) in October, and the 19 October sampling event included excavation for soil samples around the tank. Two of the five samples taken were sent for analysis for diesel range organic (DRO) and residual range organics (RRO), by Alaska protocol AK102/103.

The soil samples from the boat work bay taken on 13 September had not been sent for analysis, on the assumption that tidal flushing of most of the boat work bay would have removed any hazardous waste materials. At the request of the Society, one additional soil sample from the work bay was taken during this sampling event, and sent to the lab along with one of the samples from 13 September for analysis for all RCRA 8 metals (which includes arsenic), plus Copper, by EPA 6010A/7471A.

Sampling information is provided in Table 2-4, below.

Date	Field No.	Lab ID No.	Report No.	Material	Location

19-Oct-03	02094-401		02094-401	soil	UST
19-Oct-03	02094-402	B3J0571-02	02094-402	Soil	UST
19-Oct-03	02094-403		02094-403	soil	UST
19-Oct-03	02094-404	B3J0571-03	02094-404	Soil	UST
19-Oct-03	02094-405		02094-405	soil	UST
19-Oct-03	02094-406	B3J0571-04	02094-406	Soil	Work bay @ S.end

The following photo is of the west side of the UST, excavated and re-buried during this sampling event.

3. Laboratory Results

The full texts of the NCA lab results are attached to this report as the Appendix. Those results have been summarized by type of material in the following tables.

Table 3-1, below, contains all paint samples with lab results for Cadmium and Lead.

Lab ID No.	Report No.	Material	Total Metals, Cadmium, mg/kg (ppm)	Total Metals, Lead, mg/kg (ppm)

B3G045-01	02094-101	Paint chips	10.4ppm	3880ppm
B3G045-02	02094-102	Paint chips	6.80ppm	7890ppm
B3G045-03	02094-103	Paint chips	ND	27900ppm
B3G0619-01	02094-201	Paint chips	28.9ppm	2380ppm
B3G0619-02	02094-202	Paint chips	644ppm	3680ppm
B3G0619-03	02094-203	Paint chips	79.7ppm	1680ppm
B2I0441-03	02094-305	White paint chips	41.8ppm	32500ppm
B2I0441-04	02094-306	Red paint chips	ND	93500ppm
B2I0441-05	02094-307	Blue paint chips	ND	4790ppm

Table 3-1

The result ND means that the amount of the constituent of interest present, if any, is lower than the detection capability of the testing equipment. In all cases, the detection capability of the testing equipment allows detection below any regulatory limit.

Although the Cadmium levels in samples -103 and -305 are significantly different, the Lead levels are close enough to make the assumption that sample –103 is the exterior white paint sample taken during the 18 July sampling event.

Table 3-2 portrays all suspected ACM samples with lab results for Asbestos fiber.

Lab ID No.	Report No.	Material	Asbestos Fibrous Components, %

B3G0619-04	02094-204	Light green painted wallboard tape	2% Chrysotile in one of three layers
B3G0619-05	02094-205	Insulation scrap	ND
B2I0441-02	02094-304	Light green painted wallboard, no tape or mud	ND

Table 3-2

Table 3-3, on the following page, contains the one soil sample with lab results for leachable metals.

Lab ID No.	Report No.	Material	Total Leachable Metals (TCLP), mg/L (ppm)

B2I0441-01	02094-303	Soil	3.21ppm

Table 3-3

Table 3-4 contains the soil samples from the work bay with lab results for RCRA 8 metals plus Copper. Note that Selenium, one of the RCRA 8 metals, was deleted from the table to make it easier to display, because the results for both samples was ND.

			Total Metals, mg/kg
Lab ID No.	Report No.	Material	Silver	Arsenic	Barium	Cadmium	Chrome	Copper	Mercury	Lead

B3J0571-01	02094-301	Soil	2.68	33.4	221	5.07	80	1510	9.35	1040
B3J0571-04	02094-406	Soil	ND	12.8	13.4	ND	29.3	61.5	ND	40.4

Table 3-4

The results of testing two of the soil samples from the underground storage tank onsite are displayed in Table 3-5.

Lab ID No.	Report No.	Material	Diesel Range Hydrocarbons, mg/kg	Residual Range Hydrocarbons, mg/kg

B3J0571-02	02094-402	Soil	5230	733
B3J0571-03	02094-404	Soil	124	72.3

Table 3-5

4. Regulatory Cleanup Requirements

4.1 Lead-based paint

Sections 402, 403, and 404 of the federal Toxic Substances Control Act (TSCA) establish standards for lead-based paint hazards and cleanup, specifically with respect to “…pre-1978 housing and child-occupied facilities.” These standards seek to protect young children from the seriously detrimental effects of high levels of lead in the blood. Although plans for the Boathouse include use neither as “housing” nor “child-occupied facilities”, the TSCA regulatory requirements appear to be a reasonable standard by which to judge its condition.

TSCA defines paint with 0.5% by weight (5000ppm) as lead-based paint. Any deteriorated lead-based paint is defined as a paint-lead hazard. TSCA defines a soil-lead hazard as bare soil that contains 400ppm in a play area, or an average of 1200ppm in the remainder of a yard.

The Resource Conservation and recovery Act (RCRA) governs disposal of non-household wastes including construction debris. Under the standard, materials which can leach Lead under controlled conditions at concentrations in excess of 5 ppm must be considered as hazardous waste and disposed of in licensed facilities. No Toxic Characteristic Leaching Procedure tests were run on the samples of paint chips, but a rule of thumb exists for hazardous waste determinations which states that if metals concentrations in the sample exceed 20 times the TCLP Regulatory Level, the sample would fail the test with a high degree of probability. Any paint chip sample exceeding 100 ppm would therefore be considered as requiring disposal as hazardous waste. As all samples tested exceeded this value by many times, it is safe to conclude that paint chips should be disposed of as hazardous waste.

Occupational Safety and Health (OSHA) standards exist for worker safety. The OSHA general standards contained in 29CFR 1910 and the OSHA construction standards in 20 CFR 1926 govern worker safety with regard to exposure to Lead in the work place. The major provision of these standards is the requirement for use of appropriate Personal Protection Equipment (PPE) while handling materials known or suspected of containing Lead.

4.2 Cadmium

Cadmium is one of the metals of concern with regard to waste disposal under RCRA. As it has been found in many older paint products, the paint chips were tested for cadmium as well as lead. The TCLP Regulatory Level for cadmium is 1 ppm (one fifth that of lead), therefore, if the paint chips had levels above 20 ppm they should be considered as requiring disposal as hazardous waste for cadmium. This was the case for four of the samples. However, as lead was present in all of the samples in sufficient concentration to require disposal as hazardous waste, lead is the metal of concern.

4.3 Asbestos Containing Materials

Asbestos Containing Materials containing more than 1% asbestos are regulated under 40 CFR 61.141. Undisturbed ACM is considered safe, and is generally removed only during renovation or demolition of the structure or portion of the structure that contains it.

4.4 Hydrocarbons in Soil

Hydrocarbon contamination of soils is regulated by the State of Alaska under 18 AAC 75. Using Method 1 of 18 AAC 75.340 for determining cleanup levels, most areas of Sitka fall under Category B. The cleanup levels for Category B are 200ppm for Diesel Range Organics (DRO), and 2000ppm for Residual Range Organics (RRO). It was assumed that no gasoline was used on the site, and no testing for Gasoline Range Organics (GRO) was done.

Previous work field screening with the Rae Systems MiniRae 2000 Photo Ionization Detector (PID) used in this project indicates that a PID reading of 5ppm in the field correlates roughly to 200ppm DRO in the lab. PID readings were used to select samples for lab testing.

4.5 RCRA Metals and Copper in Boat Work Bay

The provisions of RCRA, as discussed in section 4.1 above, also apply to this issue. Copper is not considered a hazardous waste material under RCRA, but was also considered

4.6 Potentially Hazardous Waste Materials, Universal Wastes

The lists of waste materials found during the 18 and 20 July sampling events include potentially hazardous wastes, universal wastes, and undoubtedly some non-hazardous wastes. The potentially hazardous wastes are subject to regulation under RCRA, although in small quantities and non-commercial use RCRA typically is not applied. Universal wastes, as defined by the EPA under 40 CFR 273, include such things as batteries, pesticides, and mercury and PCB bearing items such as light bulbs and electrical ballasts.

As a service to households and small businesses in Sitka, the City and Borough of Sitka, in conjunction with the Southeast Conference and the Alaska Department of Environmental Conservation, accepts universal wastes and other potentially hazardous wastes at quarterly collection events. Responsibility for final disposal of the wastes collected is transferred to the event sponsors.

5. Hazardous Materials Cleanup

Cleanup costs were estimated for each of the following topics. Estimates were based on a combination of R.S. Means 2000 Building Construction Cost Data adjusted for use in Sitka in 2004, and proprietary local cost information.

5.1 Lead-based paint.

Although the samples indicate that not all of the paint would be classified as lead-based, all of the paint contains lead in sufficient amounts to fail the TCLP leaching test if tested as chips or sanding dust. Therefore, any removal of paint must be done in a way to minimize the chips or dust produced, and allow disposal of them as hazardous waste.

Based on paint condition it would be reasonable to scrape locally deteriorated (flaking) areas of the interior painted surfaces and then encapsulate the remaining well adhered paint with non-lead based paint. The exterior paints are in very poor condition and scraping will remove the majority of the paint that remains. Localized patches of well adhered paint can be left in place, to be encapsulated by the non- lead-based paint used to repaint.

Any mechanical removal of lead-based paint has potentially hazardous health effects on those performing the work. Workers removing paint during rehabilitation of the boathouse should wear the appropriate Personal Protective Equipment. Hand scraping can be performed with HEPA filtered respirators; Tyvek suits with some head covering, safety glasses and disposable gloves. The filters, suits and gloves should be disposed of with the paint chips as hazardous waste. If sanding or grinding is done, the OSHA Lead in Construction Code requires additional respiratory protection for employees, possibly including provision of supplied air.

Hand scraping all interior and exterior painted surfaces over a drop cloth, then encapsulating the remaining paint with fresh coats of non-lead based paint is suggested. HEPA vacuuming the area both before and after scrapping and before painting would be beneficial to control lead contamination of the area.

Soil samples immediately under the deteriorated exterior paint had TCLP lead contents of 3.21 ppm, which is below the RCRA regulatory limit of 5 ppm of leachable lead in soil for consideration as hazardous waste. It will be important to prevent further contamination of the soil during renovation, as additional paint waste would add to the lead burden of the soil, potentially pushing it over the limit and thus requiring remediation. Use of a drop cloth during removal of deteriorated exterior paint, as suggested with the interior paints, is imperative.

For the purposes of this report, it was assumed that the poor condition of the boat repair carriage means that it will be disposed of, rather than repaired and painted. If disposed of without removal of the lead-based paint, the mass of the steel vs. the lead in the paint should provide a classification of general waste. However, the receiving landfill or scrap buyer should be made aware of the existence of the lead based paint.

Only the costs beyond working with non-hazardous paint were estimated. Costs of PPE for workers, HEPA vacuum equipment, packaging materials, and hazardous waste material disposal service for Lead-based paint work is estimated to be:

Lead-based paint scraping and waste disposal $7,210

5.2 Asbestos Containing Materials

The initial sample taken from the wall in the furnace room indicated the presence of Asbestos, apparently in the taping mud. The second sample was taken of wallboard without tape and mud, and was negative for Asbestos. If the furnace room is to be removed or remodeled, any wallboard removal which includes disturbance of taping mud should be done by a certified asbestos worker and disposed of in accordance with state and federal regulations. If the wallboard is to remain in place, repair or painting done with non-ACM materials will ensure that the existing ACM taping mud remains encapsulated.

Assuming removal and disposal by Certified asbestos worker(s), cost for ACM cleanup is estimated to be:

ACM removal and disposal $2,120

5.3 Hydrocarbons in Soil

Excavation and sampling indicated some amount of hydrocarbon contaminated soil to be removed and disposed of. The UST will also have to be properly cleaned and disposed of by the excavation contractor used to remove the soil. Soil removal requires reporting to the State including submittal of a plan prior to beginning work, and completion of a site assessment and site closure document. This work must be done by a State qualified contaminated soil site assessment firm. Removal of the tank includes use of a State certified UST removal worker.

Because of the lack of local soil treatment facilities, the best option for contaminated soil disposal is shipment to the Rabanco solid waste facility in Washington State.

Assuming a single Rabanco shipping container will be adequate to contain all of the contaminated soil removed, cost of the cleanup and tank removal is estimated to be:

UST removal and contaminated soil disposal $11,160

5.4 RCRA Metals and Copper in Boat Work Bay

The levels of RCRA metals and copper in the boat work bay appear to be lower than would require cleanup, but high enough that any materials removed from this area should be considered to be hazardous waste materials. Assuming that the debris in the area will be swept up during the initial cleanup of the facility, cleanup workers should wear Personal Protective Equipment, and the materials collected disposed of as hazardous waste materials. Society members or other non-certified workers should be able to do this work. Disposal should be coordinated with disposal of Lead-based paint waste.

A reasonable allowance for the cost of PPE, packaging materials, and hazardous waste material disposal service for boat work bay cleanup is estimated to be:

Boat work bay debris cleanup and waste disposal $550

5.5 Potentially Hazardous Waste Materials, Universal Wastes

As with the boat repair bay cleanup, Society members or other non-certified workers should be able to do this work. The work should be timed to coincide with a hazardous materials collection event at the City and Borough of Sitka Wastewater Treatment plant.

The costs of PPE for a work party of 8 to 10 persons, packaging materials, and HEPA vacuum rental is estimated to be:

Potentially hazardous materials and universal waste disposal $1,250

Japonski Island Boathouse

Hazardous Materials Survey

5. Hazardous Materials Cleanup