B09_Amendment_0002_Attach_03_Hazardous_Material_Survey.pdf

LIMITED HAZARDOUS MATERIALS INSPECTION

REHABILITATION PHASE II

MAMMOTH HOTEL

MAMMOTH HOT SPRINGS

YELLOWSTONE NATIONAL PARK, WYOMING

Prepared for:

Xanterra Parks & Resorts

P.O. Box 587 Yellowstone National Park, WY 82190

Prepared by:

Tetra Tech, Inc.

618 South 25th Street Billings, MT 59501

Tetra Tech Project No. 114-552057

January 9, 2017

Limited Hazardous Materials Inspection Report Rehabilitation Phase II Mammoth Hotel Mammoth Hot Springs, Yellowstone National Park, Wyoming Xanterra Parks & Resorts

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

2.2 Lead-Based Paint

2.3 Mercury-Containing Components

2.4 Polychlorinated Biphenyls-Containing Components

2.5 Chlorofluorocarbons-Containing Components

3.0 INSPECTION METHODOLOGY

3.1 Asbestos-Containing Material

3.1.1 Previous Inspection Results

3.1.2 Asbestos Inspection

3.1.3 Assessment

3.2 Lead-Based Paint

3.3 Mercury-Containing Components

3.4 PCB-Containing Components

3.5 Chlorofluorocarbons-Containing Components

4.0 FINDINGS

4.1 Asbestos-Containing Material Findings

4.1.1 Suspected Asbestos-Containing Materials

4.2 Lead-Based Paint Findings

4.2.1 Suspected Lead-Based Paint Materials

4.3 Mercury-Containing Component Findings

4.4 PCB-Containing Component Findings

4.5 Chlorofluorocarbons-Containing Component Findings

5.0 QUALITY ASSURANCE/QUALITY CONTROL

5.1 Field Quality Assurance/Quality Control

5.2 Laboratory Quality Assurance/Quality Control

6.0 RECOMMENDATIONS

6.1 Asbestos-Containing Building Materials

6.2 Lead-Based Paint

6.3 Mercury-Containing Components

6.4 PCB-Containing Components

6.5 Chlorofluorocarbons-Containing Components

7.0 LIMITATIONS

8.0 REFERENCES

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LIST OF TABLES

Table 1 Summary of Asbestos Definitions Table 2 Summary of Asbestos-Containing Materials Table 3 Summary of Lead-Based Paint Containing Materials Table 4 Summary of Mercury-Containing Components Table 5 Summary of PCB-Containing Components Table 6 Summary of Chlorofluorocarbons-Containing Components

FIGURES

Figure 1 Suspect Asbestos Sample Collection Locations – First Floor Figure 2 Suspect Asbestos Sample Collection Locations – Second Floor Figure 3 Suspect Asbestos Sample Collection Locations – Third Floor Figure 4 Suspect Asbestos Sample Collection Locations – Fourth Floor Figure 5 Suspect Asbestos Sample Collection Locations – Roof Figure 6 Suspect Asbestos Sample Collection Locations – Attic Figure 7 Suspect Asbestos Sample Collection Locations – Basement Figure 8 ACM Locations – First Floor Figure 9 ACM Locations – Second Floor Figure 10 ACM Locations – Third Floor Figure 11 ACM Locations – Fourth Floor Figure 12 ACM Locations – Roof Figure 13 Mercury-Containing Component Locations – First Floor Figure 14 Mercury-Containing Component Locations – Second Floor Figure 15 Mercury-Containing Component Locations – Third Floor Figure 16 Mercury-Containing Component Locations – Fourth Floor Figure 17 PCB-Containing Component Locations – First Floor Figure 18 PCB-Containing Component Locations – Second Floor Figure 19 PCB-Containing Component Locations – Third Floor Figure 20 PCB-Containing Component Locations – Fourth Floor Figure 21 CFC-Containing Component Locations – Second Floor Figure 22 CFC-Containing Component Locations – Third Floor Figure 23 CFC-Containing Component Locations – Fourth Floor

LIST OF APPENDICES

Appendix A Asbestos Materials and Sampling Protocol Appendix B Tetra Tech Personnel Certifications Appendix C Asbestos Bulk Sample Laboratory Reports Appendix D XRF Performance Characteristic Sheet Appendix E Summary of XRF Results

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LIST OF ACRONYMS

ACBM Asbestos-containing building material ACM Asbestos-containing material AIHA American Industrial Hygiene Association CFC Chlorofluorocarbons CFR Code of Federal Regulations DOT Department of Transportation EPA United States Environmental Protection Agency HUD United States Department of Housing and Urban Development LBP Lead-based paint mg/cm2 Milligrams per square centimeter NESHAP National Emission Standards for Hazardous Air Pollutants OSHA Occupational Safety and Health Administration PCB Polychlorinated biphenyls PLM Polarized light microscopy PPE Personal Protective Equipment QA/QC Quality Assurance/Quality Control RACM Regulated Asbestos-Containing Materials RCRA Resource Conservation and Recovery Act REI Reservoirs Environmental, Inc.

TCLP Toxicity Characteristic Leaching Procedure TSI Thermal System Insulation WDEQ Wyoming Department of Environmental Quality XRF X-Ray Fluorescence

Hazardous Materials Inspection Report Former Rimrock Elementary School Rocky Mountain College

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1.0 INTRODUCTION

This report presents results of Tetra Tech’s hazardous materials inspection of the Rehabilitation Phase II project at the Mammoth Hotel located in Mammoth Hot Springs, Yellowstone National Park, Wyoming. The purpose of the inspection was to identify the potential presence of asbestos-containing materials (ACM), lead-based paint (LBP), mercury-containing components, polychlorinated biphenyls (PCB) containing components, and chlorofluorocarbons (CFC) containing components for future renovations. This report consists of the following sections:

• Tetra Tech’s scope of services;

• Applicable regulations pertaining to the inspection;

• Inspection methodology;

• Inspection findings; and,

• Recommendations.

The inspection, conducted by Mr. Daniel Lawrence and Mr. Conner McHugh, was conducted November 28 through November 30, 2016. The asbestos materials and sampling protocol used in the inspection is provided in Appendix A. Tetra Tech personnel certifications, pertinent to the inspection services conducted, are provided in Appendix B. The laboratory analytical reports for bulk ACM samples is provided in Appendix C. The Performance Characteristic Sheet for the LBP testing instrument is presented in Appendix D, results of the LBP inspection are contained in Appendix E.

The scope of services for this inspection included:

• Visual examination of accessible areas of the building for suspect ACM and LBP;

• Review of previous inspection reports;

• Visual examination of accessible areas of the building for components considered to be mercury-containing;

• Visual examination of accessible areas of the building for components considered to be

PCB-containing;

• Visual examination of accessible areas of the building for components considered to be

CFC-containing;

• Collection of samples of suspected ACM for laboratory analyses;

• Field testing of suspected LBP building materials;

• Evaluation of analytical data; and,

• Preparation of this final report which outlines the hazardous substances identified within the building.

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2.0 REGULATORY CRITERIA

2.1 Asbestos-Containing Material

Worker exposure to asbestos during construction operations including ACM removal is regulated under 29 Code of Federal Regulations (CFR) 1926.1101. The Occupational Safety and Health Administration (OSHA) has established worker protection measures during the removal of asbestos from the facilities including, but not limited to: training and medical monitoring requirements for personnel engaging in the oversight and removal of ACM, exposure limits, respiratory protection, personal protective equipment (PPE), work practices and engineering controls, and storage of wastes.

The removal and disposal of ACM is regulated under the asbestos National Emission Standard for Hazardous Air Pollutants (NESHAP), 40 CFR Part 61, Subpart M. Table 1 presents a summary of pertinent United States Environmental Protection Agency (EPA) definitions under 40 CFR 763.83, as administered NESHAP.

Table 1 Summary of Asbestos Definitions

Asbestos-Containing Materials (ACM) Materials containing more than one percent (1%) asbestos.

Asbestos-Containing Building Materials (ACBM)

Surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other parts of a public or commercial building.

Assumed Asbestos- Containing Material

ACM that remains un-sampled, but is considered suspect for asbestos content, and must be treated as ACM until proven negative for asbestos content by laboratory analysis or by documentation (e.g., product Safety Data Sheet).

Friable ACM Ability of material to be crumbled, pulverized or reduced to powder when dry with hand pressure as determined by physical touching by asbestos building inspector.

2.2 Lead-Based Paint

LBP is defined as surface coatings with a lead concentration greater than or equal to 1.0-milligrams per square centimeter (mg/cm2) or 0.5 percent (%) by weight (40 CFR Part 745). Deteriorated LBP can cause elevated lead levels in dust and exposure risks to building occupants.

Worker exposure to lead hazards in construction is regulated under 29 CFR 1926.62. OSHA has established provisions for worker protection including, but not limited to: training and medical monitoring requirements for personnel engaging in the oversight and removal of LBP, exposure limits, respiratory protection, PPE, work practices and engineering controls, and storage of wastes.

The handling storage, transport, and disposal of lead or lead-contaminated waste must be conducted in accordance with 40 CFR 260, 40 CFR 261, 40 CFR 262, 40 CFR 263, 40 CFR 264, and 40 CFR 265. Building owners must comply with land disposal restriction notification requirements as required by 40 CFR 268.

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2.3 Mercury-Containing Components

Free (liquid) mercury or mercury vapor in components can be a source of mercury leaching into the environment, and is identified as a characteristic hazardous waste (D009) under 40 CFR.261.24. Based on the identification as a hazardous waste, mercury-containing fixtures and equipment must be disposed of at a registered hazardous waste facility.

Management and disposal by businesses of fluorescent light bulbs and other mercury-containing bulbs are regulated under the RCRA and the Universal Waste Rule. WDEQ has provided regulatory guidance for the disposal of fluorescent bulbs and ballasts.

2.4 Polychlorinated Biphenyls-Containing Components

PCBs in ballasts and electrical components can be a dermal hazard and a source of PCBs leaching into the soil. Transport and disposal of PCBs must comply with 40 CFR 761.62, and must comply with applicable Department of Transportation (DOT) requirements.

2.5 Chlorofluorocarbons-Containing Components

Freon gas includes a number of gaseous, colorless CFCs that are commonly used as refrigerants.

The EPA regulates the emission of Freon gas into the atmosphere due to its ozone depleting capabilities. Through Title VI, Stratospheric Ozone Protection, of the Clean Air Act Amendments of 1990, the EPA regulates Freon gas and requires mandatory recycling and a ban on the intentional venting or releasing of refrigerants.

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3.0 INSPECTION METHODOLOGY

The limited hazardous materials inspection attempted to identify concealed building materials such as: heating systems, roofing systems, double layer drywall, flooring under existing flooring, or mechanical systems located behind walls. While the inspection endeavored to identify all potentially hazardous substances, users of this report should be aware that the sampling program has some limitations as Tetra Tech did not dismantle or disassemble some equipment due to other potential site safety hazards.

The assessments focused on the following designated substances.

3.1 Asbestos-Containing Material

3.1.1 Previous Inspection Results

There were no records of previous inspection provided by Xanterra Parks & Resorts personnel to Tetra Tech. Therefore, previous inspection findings were not evaluated as a facet of this inspection.

3.1.2 Asbestos Inspection

Suspected ACMs were grouped as homogeneous areas if the material was uniform in appearance and texture. However, if the inspector decided that a material (for example, pipe insulation) was not similar in appearance and texture to other materials in the building, the inspector distinguished the material as unique and collected samples of each unique material.

Bulk samples collected were placed in plastic bags, labeled, and sealed immediately upon collection. The sampling instruments were wiped clean with cleaning wipes after the collection of each sample to prevent cross-contamination between samples. A unique sample identification number was assigned to each sample in general accordance with the following format:

• MH2-F1.1A

Where “MH2” would reference the structure ID number; “F1” would reference the material type, in this case, a flooring material; “1” would reference that this was the first type of flooring identified, and “A” would reference the first of three (to seven) samples associated with the homogeneous material.

Upon completion of sampling activities, the bulk samples were delivered, along with completed chain-of-custody documentation, to the Reservoirs Environmental, Inc., (REI) laboratory located in Denver, Colorado. REI is accredited by the American Industrial Hygiene Association (AIHA) for bulk asbestos sample analysis, which was performed using polarized light microscopy (PLM) in accordance with the EPA Interim Method 600/R-93/116, for identification of mineral forms of asbestos.

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3.1.3 Assessment

Homogeneous ACBM were identified following receipt of the laboratory analyses. The materials were then categorized using the following NESHAP criteria under 40 CFR Part 61, Subpart M:

1) Category I are non-friable asbestos-containing packings, gaskets, resilient floor covering, and asphalt roofing products.

2) Category II are non-friable ACBM excluding Category I non-friable ACBM.

3) Regulated Asbestos-Containing Materials (RACM) are friable materials; Category I non-friable ACM that has become friable; Category I non-friable materials that will or may be subjected to sanding, grinding, cutting, or abrading; or Category II non-friable materials that have a high probability of becoming or have become crumbled, pulverized, or reduced to powder by forces expected to act on the material in the course of demolition or renovation operations.

3.2 Lead-Based Paint

The LBP inspection included documenting types of painted building components and substrate materials. Typical building components tested included walls, door units, window units, ceilings and structural members. Substrate materials typically consisted of metal, plaster, wood, drywall, and concrete. The building components tested were cataloged based on location, specific component type, and substrate material.

The EPA and the United States Department of Housing and Urban Development (HUD) define a lead inspection as a surface-by-surface investigation to determine the presence of LBP. Tetra Tech generally followed the HUD LBP inspection guidelines (HUD, 1995, revised 1997 and 2000).

Tetra Tech used field X-Ray Fluorescence (XRF) methodology to determine the presence or absence of LBP. XRF is identified as the recommended method to determine lead in paint (HUD, 1995, revised 1997 and 2000). For these inspections, Tetra Tech personnel utilized the Niton XLP, Spectrum Analyzer XRF, which automatically calculates measurable amounts of lead in paint by correcting for substrate conditions. The XRF Performance Characteristic Sheet (Appendix D) for the XRF used by Tetra Tech specifies the ranges where XRF results are positive, negative, or inconclusive.

3.3 Mercury-Containing Components

The assessment included the visual inspection of mercury-containing equipment including compact fluorescent lamps, fluorescent U-tubes, fluorescent lamps, linear fluorescent lamps, mercury vapor lamps, metal halide lamps, sodium vapor lamps, thermostats, temperature probes, batteries, and flow meters, as well as miscellaneous components (if present) identified during the course of the inspection. The final portion of the inspection consisted of Tetra Tech personnel opening and disassembling the component to observe whether or not the component had labels indicating mercury content. Where applicable, the components’ manufacturing information was compared against a listing of mercury-containing components provided by the EPA. Any components that were suspected of containing mercury and were either not labeled or did not have labels not identified as “Mercury-Free,” were assumed to be mercury-containing and were documented accordingly.

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3.4 PCB-Containing Components

The assessment included the visual inspection of miscellaneous components identified during the course of the inspection historically identified as PCB-containing, including but not limited to air conditioners, capacitors, equipment with electrical motors, freezers, furnace blower motors, hydraulic equipment, light ballasts, switches, and transformers. The final part of the inspection consisted of Tetra Tech personnel opening the fluorescent lights to observe whether or not the ballasts had labels stating their PCB content. When applicable, the components’ manufacturing information was compared against a listing of PCB-containing components provided by the EPA. Any components that were suspected of containing-PCBs and were either not labeled or did not have labels identifying them as “PCB-Free” were assumed to be PCB-containing and were documented accordingly.

3.5 Chlorofluorocarbons-Containing Components

The assessment included the visual inspection of miscellaneous components identified during the course of the inspection historically identified as CFC-containing, including but not limited to air conditioners, compressor tanks, coolers, and freezers. When applicable, the components’ manufacturing information was compared against a listing of CFC-containing components provided by the EPA. Any components that were suspected of containing-chlorofluorocarbons and were either not labeled or did not have labels identifying them as “Chlorofluorocarbons-Free” were assumed to be chlorofluorocarbons-containing and were documented accordingly.

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4.0 FINDINGS

The limited hazardous materials inspection of the 44,000-square-foot work area was conducted on November 28 through November 30, 2016. The work area consisted of a wood framed structure with interior finishing including wood, vinyl floor tile, vinyl sheet, and carpeted floors, plaster, and drywall, resting on concrete foundation with crawlspace and walkway tunnels, and covered by a vinyl membrane roof system. The findings and results of the inspection are described in the following section.

4.1 Asbestos-Containing Material Findings

Asbestos inspection services were conducted by AHERA Accredited Asbestos inspectors Mr.

Daniel Lawrence and Mr. Conner McHugh on November 28 through November 30, 2016. The site assessment entailed a visual and physical examination of the structure.

Tetra Tech collected and submitted bulk samples to the laboratory for asbestos analyses. A copy of the laboratory analytical report is provided in Appendix C. Approximate sample collection locations are presented on Figures 1 through 7 and approximate asbestos-containing material locations are presented on Figures 8 through 12. Based on the analyses, six materials were identified as ACM. A summary of the asbestos-containing materials, descriptions, conditions, quantity, and estimated abatement cost is contained in Table 2 below.

Table 2 Summary of Asbestos-Containing Materials

Mammoth Hotel Rehabilitation Phase II Mammoth Hot Springs, Yellowstone National Park, Wyoming

HA

Number Material Description Percent

Asbestos Material

Type

NESHAP

Category Condition Estimated

Quantity

Greater than 1% Asbestos-Containing Materials

MH2-F1.3 Tan mosaic pattern vinyl sheet flooring 20% Chrysotile Miscellaneous RACM Good 275 SF

MH2-M1.1 Built-up roofing material under rubber membrane 45% Chrysotile TSI RACM Good 11,000 LF

MH2-M9.1 Metal fire door Assumed Miscellaneous Category II Non-Friable Good 32 Each

MH2-T1.2 Aircell straight pipe insulation and associated fittings inside wall cavities Assumed TSI RACM Good 1,200 LF

Less than 1% Asbestos-Containing Material

MH2-M3.1 Smooth wallboard system

Joint Compound:

3% Chrysotile Composite:

0.66% Chrysotile

NA NA Good 13,800 SF

MH2-S3.1 Orange-peel pattern texture associated with wallboard system 0.5% Chrysotile NA NA Good 4,150 SF

HA Number: Homogeneous Area Number NESHAP: National Emission Standard for Hazardous Air Pollutants TSI: Thermal System Insulation RACM: Regulated Asbestos-Containing Material SF: Square Feet LF: Linear Feet NA: Not Applicable

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4.1.1 Suspected Asbestos-Containing Materials

The following materials sampled from the structure were suspected to contain asbestos but were confirmed by laboratory analyses not to contain asbestos:

• Tan swirl pattern vinyl sheet flooring and associated mastic in Rooms 112, 112a, 112b, 114, 114a, 117a, 120a, 128a, 131a, 132, 212, 2121a, 214, 214a, 217a, 232, 305a, 312, 312a, 314, 314a, 320a, 328a, 331a, 332, 332a, 412, 412a, 414, 414a, 429a, 432, and 432a (MH2-F1.1A, B, C)

• Light blue vinyl sheet flooring and associate mastic in rooms 103a, 1405a, 111a, 113a, 119a, 122a, 123a, 124a, 125a, 127a, 129a, 130a, 203a, 211a, 219a, 220a, 222a, 223a, 225a, 227a, 228a, 229a, 230a, 231a, 303a, 304a, 305a, 306a, 311a, 313a, 317a, 319a, 322a, 323a, 324a, 325a, 327a, 329a, 330a, 403a, 404a, 405a, 406a, 411a, 413a, 417a, 419a, 422a, 423a, 424a, 425a, 427a, 428a, 430a, and 431a (MH2-F1.2A, B, C)

• Yellow/tan mastic associated with Tan mosaic pattern vinyl sheet flooring in Rooms 104a, 132a, 212b, 312b, 412b (MH2-F1.3A, B, C)

• Tan vinyl sheet flooring and associated mastic in Rooms 108, 110, and under MH2-F1.2 in Room 327 (MH2-F1.4A, B, C)

• White with blue streak pattern vinyl sheet flooring and associated mastic in Rooms 206a and under MH2-F1.2 in Rooms 124a, 228a, and 327a (MH2-F1.5A, B, C)

• Tan with white 12-inch by 12-inch vinyl floor tile and associated mastic in Room 112 (MH2- F2.1A, B, C)

• Yellow mastic associated with carpet located through the work area (MH2-F6.1A, B, C)

• Gray leveling compound located under carpet in Room 117 (MH2-F8.1A, B, C)

• Smooth wallboard system located in Rooms B01, B02, B03, and B04 and Attic (MH2- M3.2A, B, C)

• White rubber cove base and associated mastic in Rooms 104a, 108, and 110 (MH2- M12.1A, B, C)

• Weave pattern wallpaper and associated colorless mastic in Rooms 202, 203, 204, 206, 208, and 210 (MH2-M30.1A, B, C)

• Crushed cork with black mastic located in wooden troughs in Rooms B01, B02, B03, and

B04 (MH2-M31.1A, B, C)

• Fiberglass batt insulation and associated backing mastic located in the Attic (MH2- M32.1A, B, C)

• Smooth textured plaster walls and ceilings in Rooms 103, 104, 104a, 105, 106, 107, 108, 109, 110, 111, 112, 112a, 112b, 113, 114, 114a, 115, 116, 117, 117a, 118, 119, 120, 120b, 131, 131b, 132, 134, 135, 136, 206, 207, 209, 212, 212b, 213, 214, 214a, 215, 216, 217, 218, 219, 220, 221, 222, 224, 226, 230, 232, 233, 234, 235, 236, 303, 312, 312a, 312b, 314, 314a, 318, 320, 322, 329, 332, 333, 334, 335, 336, 412, 412b, 414, 432, 433, 434, 435, and 436 (MH2-S1.1A, B, C, D, E, F, G)

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• Rough textured plaster walls and ceilings in Rooms 124, 126, 127, 211, 221, 223, 225, 227, 228, 229, 231, 302, 304, 305, 306, 307, 308, 309, 310, 311, 313, 315, 316, 317, 318, 319, 321, 323, 324, 325, 326, 327, 328, 330, 331, 402, 403, 404, 405, 406, 407, 408, 409, 410, 411, 413, 415, 416, 417, 418, 419, 420, 421, 422, 423, 424, 425, 426, 427, 428, 429, 430, and 431 (MH2-S1.2A, B, C, D, E, F, G)

• Orange peel texture associated with ceilings in Rooms 134, 135, 136, 434, 435, and 436

(MH2-S3.2A, B, C, D, E)

• Heavy knockdown texture associated with ceilings in Rooms 214a and 412a (MH2-S.3A, B, C)

• Black pipe wrap associated with straight pipe insulation located in wooden troughs in Rooms B01, B02, B03, and B04 (MH2-T1.1A, B, C)

4.2 Lead-Based Paint Findings

The lead inspection was conducted by Mr. Daniel Lawrence and Mr. Conner McHugh on November 28 and 29, 2016, and reviewed by EPA Accredited Lead Inspector/Risk Assessor Mr.

Roger W. Herman, Jr. XRF testing indicated that lead-containing paint, as defined by OSHA (any detectable amount) is present on interior and exterior components located throughout the structure.

LBP, as defined by the EPA (greater than 1 milligram per square centimeter), was identified on building components, and is summarized in Table 3 below. A complete listing of XRF readings collected during this inspection is provided in Attachment E.

Table 3 Summary of EPA Defined Lead Based Paint Containing Materials

Mammoth Hotel Rehabilitation Phase II Mammoth Hot Springs, Yellowstone National Park, Wyoming

XRF Reading Number(s) Location Material Description Condition

Highest Lead Concentration

(mg/cm2) 5, 7, 10, 12, 84, 86, 113-115 Exterior walls Tan paint on walls Intact 18.5

21-23, 25-27, 94-95, 123-125 Exterior walls Yellow paint on exterior window trim Intact 20.7

28-29, 31-32, 34-35, 96-97, 129-130 Exterior walls White paint on exterior window frame Intact 17.1

41-42 Exterior door to Room 110 White paint on door Intact 18.1

43-44 Exterior door to Room 110 Yellow paint on door trim Intact 4.5

59-61, 63 Deck Soffit Tan paint on soffit Intact 6.7

65-67 Deck roof fascia Yellow paint on fascia Intact 29.2

131, 146, 164, 276, 280-282, 331, 338, 355, Interior plaster walls throughout White paint on interior walls Intact 15.8 mg/cm2 milligrams per square centimeter

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Table 3 Summary of EPA Defined Lead Based Paint Containing Materials

Mammoth Hotel Rehabilitation Phase II Mammoth Hot Springs, Yellowstone National Park, Wyoming

XRF Reading Number(s) Location Material Description Condition

Highest Lead Concentration

(mg/cm2) 136-138, 151- 153, 167-168, 178-179, 194, 236, 255, 267, 285, 309, 320, 332, 343, 361, 375, 390

Interior windows and window trim throughout

Yellow paint on interior window components Intact 28.2

140-141, 158- 159, 172, 185, 198, 239, 247- 248, 256, 269, 288-289, 312, 322, 335, 345, 348, 363-364, 377, 392, 397

Interior door trim throughout

White paint on interior door trim Intact 19.6

142, 157, 196- 197, 249, 286-

287, 347

Interior door to restrooms in Guest Rooms throughout White paint on interior door Intact 21.6

143, 154, 170, 180, 195, 237, 311, 321, 334, 344, 353, 362, 369, 376, 391, Wall base trim throughout White paint on wall base trim Intact 20.6

208-210, 216, 294-295

Interior door trim in Rooms 134, 135, and 235 Green paint on door trim Intact 23.0

328 Interior plaster walls in Room 310 Tan paint on interior walls Intact 12.8 mg/cm2 milligrams per square centimeter

4.2.1 Suspected Lead-Based Paint Materials

The following painted components tested from the structure were suspected to contain lead but were confirmed by XRF analyses not to contain lead as defined by EPA:

• Tan paint on exterior wood siding (XRF Reading Numbers 9, 11, 24, 85, 87, 112)

• Tan paint on concrete foundation (XRF Reading Numbers 13-15, 18-20, 88-93, 116-119, 122)

• White paint on replacement exterior window frame (XRF Reading Numbers 33, 126)

• White paint on exterior metal doors (XRF Reading Numbers 36-38, 98-101)

• White paint on exterior wood door (XRF Reading Numbers 39-40)

• Yellow paint on exterior door trim (XRF Reading Numbers 45-48, 102-106)

• Tan paint on wood side deck (XRF Reading Numbers 49-53)

• Tan paint on wood side deck column (XRF Reading Numbers 54-58)

• Tan paint on metal conduit (XRF Reading Numbers 68-73)

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• Green paint on electrical box (XRF Reading Numbers 74-83)

• Brown paint on electrical box (XRF Reading Numbers 107-111)

• White paint on plaster walls and ceiling throughout building (XRF Reading Numbers 132- 135, 144, 240, 279, 290-291, 394-395)

• Tan paint on plaster walls and ceilings throughout the building (XRF Reading Numbers 145, 147, 149-150, 156, 162, 163, 166, 173-174, 176-177, 187, 189, 191-193, 203-204, 211-212, 217-218, 232-235, 258, 260, 263, 265, 270, 272-274, 304-305, 307-308, 316- 319, 324, 326-327, 337, 341-342, 354, 358-359, 370-373, 384-386, )

• White paint on interior office and guest room entry doors (XRF Reading Numbers 139, 160, 171, 238, 246, 257, 268, 314, 323, 336, 346, 378, 393)

• Tan paint on interior office and guest room entry doors (XRF Reading Numbers 183, 187)

• Tan paint on metal radiator (XRF Reading Numbers 155, 169, 181, 310, 333)

• White paint on metal radiator (XRF Reading Numbers 207, 221, 293)

• White paint on fire sprinkler pipe throughout building (XRF Reading Numbers 161, 205- 206, 219-220, 292)

• Tan paint on drywall walls and ceilings in guest restrooms (XRF Reading Numbers 182, 199-202, 266, 365-368, 374, 379, 381-383, )

• Tan paint on replacement interior door trim in Room 123 (XRF Reading Number 184)

• White paint on interior metal door and door trim in Rooms 134-136, 234-236, 334-336, and 434-436 (XRF Reading Numbers 213-214, 222,

• Brown paint on interior door in Rooms 135 and 435 (XRF Reading Numbers 215, 398)

• Tan paint on metal stairs and stair railings in Rooms 133 and 137 (XRF Reading Numbers 223-225)

• White paint on drywall walls and ceilings in Room 133 (XRF Reading Numbers 226-229)

• White paint on replacement interior windows and window trim in Rooms 133, 210 and 322 (XRF Reading Numbers 230-231, 245, 360)

• White paint on wood walls in Room 210 (XRF Reading Numbers 241-244)

• Blue paint on plaster walls and ceiling in Room 216 (XRF Reading Numbers 250-254)

• White paint on drywall walls and ceiling in guest room restrooms (XRF Reading Numbers 349-352)

• White paint in wood columns and ceilings in Rooms B01, B02, B03, and B04 (XRF Reading Numbers 399-402)

• White paint on wooded troughs in Rooms B01, B02, B03, and B04 (XRF Reading Numbers 403-404)

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4.3 Mercury-Containing Component Findings

The building was visually inspected for potential mercury-containing equipment on November 30, 2016. The approximate locations of mercury-containing equipment are presented on Figures 13 through 16. A summary of the mercury-containing components, component locations, descriptions, and quantity is summarized in Table 4 below.

Table 4 Summary Mercury-Containing Components

Mammoth Hotel Rehabilitation Phase II Mammoth Hot Springs, Yellowstone National Park, Wyoming

Component ID Number Location Component Description Manufacturer Estimated Quantity

MH2-Hg1

Rooms 108, 110, 202, 203, 204, 205, 206, 207, 208, 209, 210, 216, and

Fluorescent light bulbs 4’ Foot Long 1” Dimeter Phillips 64 Each

MH2-Hg2 Rooms 133 and 137 Compact Fluorescent light bulbs Phillips 15 Each

4.4 PCB-Containing Component Findings

The building was visually inspected for potential PCB-containing equipment on November 30, 2016. The approximate locations of PCB-containing equipment are presented on Figures 17 through 20. A summary of the PCB-containing components, component locations, descriptions, and quantity is summarized in Table 5 below.

Table 5 Summary PCB-Containing Components Mammoth Hotel Rehabilitation Phase II

Mammoth Hot Springs, Yellowstone National Park, Wyoming Component ID Number Location Component Description Manufacturer Estimated Quantity

MH2-PCB1

Rooms 108, 110, 202, 203, 204, 205, 206, 207, 208, 209, 210, 216, and

Fluorescent light ballast General Electric 16 Each

MH2-PCB2

Rooms 134, 135, 136, 234, 235, 236, 334, 335, 336, 434, 435, and 436

Emergency exit light ballast Unknown 21 Each

Tetra Tech, Inc. January 9, 2017 13

4.5 Chlorofluorocarbons-Containing Component Findings

The building was visually inspected for potential CFC-containing equipment on November 30, 2016. The approximate locations of CFC-containing equipment are presented on Figures 21through 23. A summary of the CFC-containing components, component locations, descriptions, and quantity is summarized in Table 6 below.

Table 6 Summary Chlorofluorocarbons-Containing Components

Mammoth Hotel Rehabilitation Phase II Mammoth Hot Springs, Yellowstone National Park, Wyoming

Component ID Number Location Component Description Manufacturer Estimated Quantity

MH2-CFC1 Rooms 235, 335, and 435 Ice machine Mantiwok 3 Each

Tetra Tech, Inc. January 9, 2017 14

5.0 QUALITY ASSURANCE/QUALITY CONTROL

5.1 Field Quality Assurance/Quality Control

Field Quality Assurance/Quality Control (QA/QC) procedures undertaken by Tetra Tech field staff included the cleaning of sampling equipment, sample collection, and handling and management procedures, as summarized below:

• New, clean, disposable nitrile gloves were worn when handling samples or sampling equipment. New gloves were worn for every Homogeneous Area sampled.

• Sampling equipment was cleaned before and between samples by wiping the equipment with an alcohol-based wipe.

• Samples submitted for laboratory analyses were identified on the outside of the laboratory-supplied sample bags.

• XRF analyzer was field calibrated prior to testing for each structure.

5.2 Laboratory Quality Assurance/Quality Control

Each laboratory report provided by REI Lab undergoes a Quality Assurance procedure. The REI Lab Quality Assurance personnel signature can be found on the analytical reports. Asbestos Laboratory reports can be found in Appendix D.

Tetra Tech, Inc. January 9, 2017 15

6.0 RECOMMENDATIONS

Tetra Tech’s recommendations concerning the various types of hazardous materials associated with the Mammoth Hotel Rehabilitation Phase II Work Area are presented below.

6.1 Asbestos-Containing Building Materials

In accordance with state and federal regulations pertaining to asbestos, the ACMs identified in Table 2 of this report are required to be abated prior to disturbance. The ACMs are required to be removed by a licensed asbestos abatement contractor using appropriate asbestos abatement methods and procedures in accordance with applicable state and federal regulations. Following the completion of asbestos abatement, a visual inspection and asbestos air clearance should be conducted. Any contractor preparing to bid or perform work in the building should be informed of the potential presence of ACMs in the building. Contractors should also be informed of compliance requirements under current state and federal regulations.

Tetra Tech also recommends that the materials that were found to contain greater that 0% asbestos, but less than 1% asbestos be abated from the Mammoth Hotel prior to disturbance if Xanterra parks & Resorts chooses to renovate the building.

Based on the asbestos concentration associated with the analysis of those materials, it is not regulated by the EPA or MDEQ. However, Occupational Safety and Health Administration (OSHA) regulations for training and worker protection would apply for any disturbance activities associated with those materials. Accordingly, Tetra Tech recommends that individuals engaging in the disturbance or removal of those materials utilize asbestos safe work practices as specified within 29 CFR 1926.1101. As stipulated under 29 CFR 1926.1101, work practice requirements and prohibitions that must be observed regardless of the exposure levels and of the percentage of asbestos in the installed construction materials include, but are not necessarily limited to:

29 CFR 1926.1101(g)(1)(ii), which requires: wet methods, or wetting agents, to control employee exposures during asbestos handling, mixing, removal, cutting, application, and cleanup, except where employers demonstrate that the use of wet methods is infeasible due to, for example, the creation of electrical hazards, equipment malfunction, and, in roofing, except as provided in paragraph (g)(8)(ii) of this section;

29 CFR 1926.1101(g)(1)(iii), which requires: prompt clean-up and disposal of wastes and debris contaminated with asbestos in leak-tight containers except in roofing operations, where the procedures specified in paragraph (g)(8)(ii)3 of this section apply;

29 CFR 1926.1101(g)(3)(i), which prohibits: high-speed abrasive disc saws that are not equipped with point-of-cut ventilator or enclosures with HEPA filtered exhaust air;

29 CFR 1926.1101(g)(3)(ii), which prohibits: compressed air used to remove asbestos, or materials containing asbestos, unless the compressed air is used in conjunction with an enclosed ventilation system designed to capture the dust cloud created by the compressed air; and

29 CFR 1926.1101(g)(3)(iv), which prohibits: employee rotation as a means of reducing employee exposure to asbestos.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24748#footnote3

Tetra Tech, Inc. January 9, 2017 16

6.2 Lead-Based Paint

This building does not meet criteria established by the EPA that would require compliance with The Residential Lead-Based Paint Hazard Reduction Act (Title X), as the building is not continuously occupied by children.

However, OSHA has regulations pertaining to the disturbance of paint with any concentration of lead (29 CFR 1926.62). OSHA requires that safe work practices be utilized to reduce exposure to harmful levels of lead, regardless of the work being performed. Safe work practices may include use of PPE (respiratory protector, disposable coveralls, and eye protection), initial exposure assessment, and use of wet methods. Tetra Tech recommends that renovation or removal involving any painted surfaces in this building be conducted by a contractor who has received a minimum of OSHA Lead in the Construction Training (commonly referred to as “OSHA Lead Awareness Training”).

In addition, prior to disposal, lead-containing or coated materials require a hazardous waste determination pursuant to 40 CFR 262.11, and 40 CFR 261.24. It is a standard industry approach that demolition waste characterization should be performed on structures containing LBP. This procedure is the Toxicity Characteristic Leaching Process (TCLP), where a sample composite representative of all building components to be demolished (i.e. all lead-based paint coated and non-lead-based paint coated materials from the structure) is submitted to the laboratory for analysis. The TCLP limit for lead is 5 milligrams per liter (mg/l) in the leachate. Materials that exceed this limit must be disposed of as hazardous waste. Materials that do not exceed this limit may be disposed of as solid waste.

• Materials that are recycled, such as metal components are not subject to waste characterization provisions under EPA. However, proper disclosure of lead containing materials should be provided to the recycling facility for hazard communication purposes.

• The types and locations of lead-based paint and regulatory requirements should be disclosed to the demolition contractor and/or salvage contractor to avoid accidental disturbance, and for contractor compliance with applicable regulations (to ensure proper worker protection).

6.3 Mercury-Containing Components

Tetra Tech recommends that the mercury-containing components identified in Table 4 of this report be removed from the facility prior to the commencement of renovation activities. Mercury-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with mercury and the contents of the device. Containers should be clearly labeled as “Universal Waste – Mercury Containing Equipment,” and specify the type and amount of individual component.

Wastes are to be transported to an approved disposal facility in accordance with Universal Waste Transporter Regulations specified in 40 CFR Part 273, Subpart D, and must comply with applicable DOT requirements.

Tetra Tech, Inc. January 9, 2017 17

6.4 PCB-Containing Components

Tetra Tech recommends that the PCB-containing components identified in Table 5 of this report be removed from the facility prior to the commencement of demolition activities. PCB-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with PCBs and the contents of the device.

Storage of the materials must comply with 40 CFR 761.65, and containers are required to be labeled, transported, and manifested for disposal in accordance with 40 CFR 761.62, and must comply with applicable DOT requirements.

6.5 Chlorofluorocarbons-Containing Components

Tetra Tech recommends that the CFC-containing components identified in Table 6 of this report be removed from the facility prior to the commencement of demolition activities. CFC-containing components should be managed in a way that prevents leakage, spillage, or damage in a closed container that is structurally sound and compatible with CFCs and the contents of the device.

Storage of the materials must comply with 40 CFR 82, and containers are required to be labeled, transported, and manifested for disposal in accordance with 40 CFR 82, and must comply with applicable DOT requirements.

Tetra Tech, Inc. January 9, 2017 18

7.0 LIMITATIONS

The scope of this report is limited to the materials expressly covered and is intended solely for the client to whom it is addressed. The assessment was conducted using standard engineering and scientific judgment, principles and practices, within a practical scope and budget. Generally, the findings, conclusions, and recommendations are based on a limited amount of data (e.g., the number of sample points, and the number of samples submitted for laboratory analyses) interpolated between sampling points, and the actual conditions (e.g., the type, level, and extent of impacted media) on the property may vary from that described above. Any findings regarding site conditions different from those described above upon which this report is based may consequently change Tetra Tech’s conclusions and recommendations.

This report has been prepared to provide information concerning the various types of hazardous materials which may be present in the structure at this site. It includes only those materials that were visible and accessible at the time of our inspection, found in the structure inspected as specified in this report. Our opinions are intended exclusively for use by the Xanterra Parks & Resorts. The scope of services performed by Tetra Tech may not be appropriate to satisfy the needs of other users, and any use or re-use of this document, or the findings presented herein is at the sole risk of the user.

The opinions presented herein apply to the site conditions existing at the time of our investigation.

Therefore, our opinions and recommendations may not apply to future conditions that may exist at the site which we have not had the opportunity to evaluate.

Tetra Tech, Inc. January 9, 2017 19

8.0 REFERENCES

Asbestos References Code of Federal Regulations (CFR), Title 29, Part 1910.1001, Asbestos; General Industry Standard; Final Rule, August 24, 2006.

Code of Federal Regulations (CFR), Title 29, Part 1926.1101, Asbestos; Construction Industry Standard; Final Rule, August 24, 2006.

Code of Federal Regulations (CFR), Title 40, Part 763, Asbestos; Asbestos-Containing Materials in Schools; Final Rule, November 12, 1987.

Code of Federal Regulations (CFR), Title 40, Part 61, Subpart M – National Emission Standard for Asbestos; Final Rule, November 20, 1990, revised June 19, 1995.

Lead References

Code of Federal Regulations (CFR), Title 40, Part 745, Lead; Requirements for Lead-Based Paint Activities in Target Housing and Child Occupied Facilities; Final Rule, August 29, 1996, revised January 5, 2001.

Code of Federal Regulations (CFR), Title 24 Part 35 and Title 40, Part 745, Lead; Requirements for Disclosure of Know Lead-Based Paint and/or Lead-Based Paint Hazards in Housing; Final Rule, March 6, 1996.

Code of Federal Regulations (CFR), Title 40, Part 260, Hazardous Waste management System; General; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 261, Identification and Listing of Hazardous Waste; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 262, Standards Applicable to Generators of Hazardous Waste; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 263, Standards Applicable to Transporters of Hazardous Waste; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 264, Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 265, Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 268, Land Disposal Restrictions; Final Rule, July 1, 2012.

Code of Federal Regulations (CFR), Title 29, Part 1926.62, Occupational Health and Environmental Controls, Final Rule May 4, 1993, revised March 26, 2012

Housing and Community Development Act, Residential Lead-Based Paint Hazard Reduction Act, Title X, 1992.

Tetra Tech, Inc. January 9, 2017 20

Housing and Urban Development (HUD), Guidelines for the Control of Lead-Based Paint Hazards in Housing, June 1995, revised 1997 and 2000.

Mercury Reference

Code of Federal Regulations (CFR), Title 40, Part 273, Subpart D, Standards for Universal Waste Management, Volume 28, July 1, 2012.

Code of Federal Regulations (CFR), Title 40, Part 261, Section 24, Toxicity Characteristic;

Final Rule, July 1, 2011.

PCB References

Code of Federal Regulations (CFR), Title 40, Subpart D, Section 761.62, Disposal of PCB Bulk Product Waste. July 1, 2014.

Code of Federal Regulations (CFR), Title 40, Subpart D, Section 761.65, Storage for Disposal.

July 1, 2011.

Agency for Toxic Substances and Disease Registry (ATSDR). “ToxFAQs: Polychlorinated Biphenyls.” Internet: http://atsdr1.atsdr.cdc.gov:8080/tfacts17.html, Atlanta, Georgia, USA, 1997.

Chlorofluorocarbons Reference

Code of Federal Regulations (CFR), Title 40, Part 82, Protection of Stratospheric Ozone, Volume 57, No. 147, July 30, 1992.

http://atsdr1.atsdr.cdc.gov:8080/tfacts17.html, FIGURES

MH2-M12.1B

MH2-S1.1C

MH2-F1.4A

MH2-M12.1A

MH2-S1.1A

MH2-F1.4B

MH2-M12.1C

MH2-S1.1B

MH2-F1.3B

MH2-F2.1A

MH2-F2.1C

MH2-F2.1B

MH2-S3.2D

MH2-S3.2C

MH2-S3.2E

MH2-S1.1D, E

MH2-M3.1A

MH2-F6.1A

MH2-F1.1A

MH2-F1.2A

MH2-F1.5A

MH2-F6.1B

MH2-S1.2A

MH2-M3.1B

MH2-F8.1A, B, C

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

1114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - First Floor

Mammoth, Wyoming

Suspect Asbestos Sample Collection Locations

MH2-M30.1B

MH2-F1.5C

MH2-M30.1A

MH2-M30.1C

MH2-S1.1F

MH2-F1.3C

MH2-S3.3B

MH2-S3.3A

MH2-S1.2B

MH2-M3.1C

MH2-S1.2C

MH2-F1.2B

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

2114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Second Floor

MH2-S1.2D

MH2-S3.1B

MH2-S1.1G

MH2-F1.3A

MH2-S3.1A

MH2-S1.2E

MH2-S3.1C

MH2-M3.1D

MH2-F1.2C

MH2-F1.4C

MH2-F1.5B

MH2-F1.1C

MH2-F6.1C

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

3114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Third Floor

MH2-S1.2F

MH2-S3.3C

MH2-S3.2A

MH2-S3.2B

MH2-S3.1E

MH2-M3.1E

MH2-S1.2G

MH2-S3.1D

MH2-F1.1B

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

4114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Fourth Floor

MH2-M1.1A, B, C

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

5114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Roof

MH2-M32.1A

MH2-M32.1B

MH2-M32.1C

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

6114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Attic

MH2-M3.2C

MH2-M3.2A

MH2-M3.2B

MH2-T1.1C

MH2-M31.1C

MH2-T1.1A

MH2-M31.1A

MH2-T1.1B

MH2-M31.1B

DATE: DRAWN BY:

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

7114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Basement

REVIEWED: APPROX. SCALE:

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

8114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - First Floor

ACM Locations

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

9114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Second Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

10114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Third Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

11114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Fourth Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

12114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Roof

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

13114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - First Floor

Mercury-Containing Component Locations

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

14114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Second Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

15114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Third Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

16114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - Fourth Floor

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

17114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth Hotel - Phase II Work Area - First Floor

PCB-Containing Component Locations

PROJ. NO. FIGURE NO.

12/27/2016 DLL

1" = 20'

18114-552057

RH

Limited Hazardous Materials Inspection

Xanterra Parks & Resorts

Mammoth…