Att_05_Hazardous_Materials_Report.pdf

Pre-Renovation Asbestos and Hazardous Building Materials Survey

Laurel Dormitory Old Faithful

Yellowstone National Park, Wyoming July 23, 2021

Terracon Project No. 26217001

Prepared for:

DJ&A, P.C.

Missoula, Montana

Prepared by:

Terracon Consultants, Inc.

Billings, Montana

Terracon Consultants, Inc. 2110 Overland Ave, Ste 124 Bil l ings, Montana 59102 P [406] 656-3072 F [406] 656-3578 terracon.com

July 23, 2021

DJ&A, P.C.

2000 Maple Street Missoula, Montana 59808

Attn: Mr. Jonathan Pederson P: (406) 721-4320 E: jonathan@djanda.com

Re: Pre-Renovation Asbestos and Hazardous Building Materials Survey Laurel Dormitory Old Faithful Yellowstone National Park, Wyoming Terracon Project No. 26217001

Dear Mr. Pederson:

Terracon Consultants, Inc. (Terracon) is pleased to submit the attached Pre-Renovation Asbestos and Hazardous Building Materials Survey report for the Laurel Dormitory at Old Faithful in Yellowstone National Park, Wyoming. The purpose of this report is to present the results of the survey performed June 26 to 28, 2021. This survey was conducted in general accordance with the DJ&A, P.C. Professional Services Agreement dated May 18th, 2021, to complete the work under Task Order Number 140P2021F0140 Contract Number 140P1220D0002, for ‘YELL 313116, Rehabilitate and Reconfigure the Laurel Dormitory at Old Faithful Yellowstone National Park. We understand that this survey was requested in preparation for the planned renovation of the building.

Terracon appreciates the opportunity to provide this service to DJ&A, P.C. If you have any questions regarding this report please contact the undersigned at (406) 656-3072.

Sincerely, Terracon Consultants, Inc.

Prepared by: Reviewed by:

Garett T. Masin Rush Bowers, CIH, CSP Field Environmental Scientist Senior Industrial Hygiene Consultant Montana-Accredited Asbestos Inspector #MTA-5626 Expires 10-16-2021

Pre-Renovation Asbestos and HBM Survey Laurel Dormitory ■ Old Faithful, Yellowstone National Park July 23, 2021 ■ Terracon Project No. 26217001

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This survey was conducted by the following personnel.

For Cameron D. Sapp Staff Scientist Montana-Accredited Asbestos Inspector #MTA-4870 Expires 02-15-2022

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TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

1.1 Project Objective

1.2 Asbestos Survey

1.3 Lead Paint Screen

1.4 Hazardous Building Materials Inventory

1.5 Reliance

BUILDING INFORMATION

ASBESTOS

3.1 Visual Assessment

3.2 Physical Assessment

3.3 Sample Collection

3.4 Sample Analysis

3.5 Regulatory Overview

3.6 Findings and Recommendations

LEAD PAINT SCREEN

4.1 Visual Assessment

4.2 Lead Paint Sampling and Laboratory Analysis

4.3 Lead Regulatory Overview

4.4 Lead Findings and Recommendations

HAZARDOUS BUILDING MATERIALS INVENTORY

5.1 HBM Regulatory Overview

5.2 HBM Findings and Recommendations

Batteries Mercury Stored Paints, Solvents, Chemicals, Pesticides, and Herbicides PCB-Containing Equipment Chlorofluorocarbons (CFCs/HCFCs) Tritium Exit Signs Smoke Detectors Compressed Gases

LIMITATIONS/GENERAL COMMENTS

APPENDIX A IDENTIFED ASBESTOS-CONTAINING MATERIAL BY HOMOGENEOUS AREA (HA)

APPENDIX B ASBESTOS SURVEY SAMPLE LOCATION SUMMARY

APPENDIX C LEAD PAINT SAMPLE LOCATION SUMMARY

APPENDIX D LABORATORY ANALYTICAL DATA

APPENDIX E ASBESTOS AND LEAD PAINT SAMPLE LOCATION DRAWINGS

APPENDIX F PHOTOGRAPHS

APPENDIX G ACCREDITTATIONS

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EXECUTIVE SUMMARY

This Pre-Renovation Asbestos and Hazardous Building Materials (HBM) survey was conducted in accordance with the DJ&A, P.C. Professional Services Agreement dated May 18, 2021, to complete the work under Task Order Number 140P2021F0140 Contract Number 140P1220D0002, for ‘YELL 313116, Rehabilitate and Reconfigure the Laurel Dormitory at Old Faithful Yellowstone National Park. The asbestos survey was conducted in general accordance with 40 CFR 763.86- Sampling. The lead paint screen was conducted to provide information for compliance with OSHA 29 CFR 1926.62 Lead. The HBM inventory was conducted to provide information for compliance with EPA RCRA and TSCA regulations. The survey was conducted June 26 to 28, 2021 by Mr.

Cameron Sapp, an EPA-accredited asbestos inspector.

Findings and Recommendations

Asbestos Asbestos was identified in the following materials as a result of the laboratory analyses, or the material could not be sampled and was assumed ACM as indicated.

n Orange Gasket (Assumed) n Black Gasket (Assumed) n Vermiculite (Assumed) n 06-RF6: Black Membrane Built-up Roofing n 08-RF8: Black Flashing and Associated Black Roofing Tar

The vermiculite identified in the fire suppression housing was assumed as Regulated Asbestos-containing Material (RACM) in good condition. The RACM must be removed prior to any disruptive activity such as renovation or demolition activities.

The orange and black gaskets associated with the fire suppression system were assumed ACM and were identified as Category I Non-friable materials under NESHAP, in good condition. If any of the materials would be disturbed, the work would be considered Class II asbestos work by OSHA. Per NESHAP and MDEQ, Category I Non-friable ACMs that have been or will become friable are RACM and must be removed prior to renovation or demolition operations that may render them friable.

The black membrane built-up roofing and black flashing and associated black roofing tar were identified throughout the site as Category I Non-friable materials under NESHAP, in good condition. All of the identified Category I Non-friable materials will likely not be rendered friable during demolition. Therefore, based on their condition on the date of the assessment, these materials are exempt from the requirement for removal prior to demolition. Terracon recommends the removal of these ACMs prior to demolition activities, as disturbance of the built-up roofing and

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If additional, but un-sampled suspect ACMs are revealed during renovation or demolition activities, the materials must be assumed to contain asbestos and treated as such unless sampled by an accredited inspector and laboratory analysis determines otherwise.

Lead Based Paint Lead was identified in the following paints as a result of laboratory analysis.

n LBP-08: White Paint on Wooden Door Frame n LBP-12: White Paint on Wooden Baseboard n LBP-14: Grayish Blue Paint on Floor n LBP-19: Tan Paint on Wooden Floor

Compliance with OSHA 29 CFR 1926.62 Lead is required for employees that may be occupationally exposed to lead, and waste determination for disposal of lead waste must comply with USEPA’s regulations under the Resource Conservation and Recovery Act (RCRA). See Section 4.4 (Lead Findings and Recommendations) of this report for additional information.

Hazardous Building Materials

Hazardous building materials observed during inventory included the following:

Hazardous Building Materials PCB-containing Light

Ballasts PCB-containing Transformers

PCB-containing Caulking CFC/HCFC units Aerosol/Chemicals

11 (Assumed) 0 N/A 0 0

PCB = polychlorinated biphenyl CFC = chlorofluorocarbon HCFC = Hydrochlorofluorocarbons

Other Concerns

Compressed Gasses Fire Extinguishers

Compressed Gasses Fire Suppression

System(s)

Radioactive Source Tritium Exit Signs

Radioactive Source Smoke Detectors* Stored Paint

6 0 0 0 0

*Smoke alarm component

Universal Wastes Batteries

Emergency Lamps Batteries Other

Liquid Mercury- Containing Equipment

Mercury-Vapor Containing Lamps Pesticides

15 80 0 150 0

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Hazardous materials and Universal wastes should be recycled or properly disposed of under EPA RCRA and certain HBMs must be properly disposed of under EPA TSCA. Other waste concerns identified in the inventory (e.g., fire extinguishers) should be recycled or properly disposed of as prescribed by law or industry standard.

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PRE-RENOVATION ASBESTOS AND HAZARDOUS BUILDING

MATERIALS SURVEY

LAUREL DORMITORY

OLD FAITHFUL

YELLOWSTONE NATIONAL PARK, WYOMING

Terracon Project No. 26217001 July 23, 2021

INTRODUCTION

Terracon Consultants, Inc. (Terracon) conducted a pre-renovation asbestos and hazardous building materials (HBM) survey of the Laurel Dormitory located at Old Faithful, Yellowstone National Park, Wyoming, which included the pre-renovation asbestos survey, a lead paint screen, and an inventory of HBM. The survey was conducted on June 8 and 9, 2021, by an EPA-certified asbestos inspector in general accordance with the DJ&A, P.C. Professional Services Agreement dated May 18, 2021, to complete the work under Task Order Number 140P2021F0140 Contract Number 140P1220D0002, for ‘YELL 313116, Rehabilitate and Reconfigure the Laurel Dormitory at Old Faithful Yellowstone National Park.

1.1 Project Objective

Terracon understands the asbestos survey, lead paint screen and HBM inventory were requested by DJ&A, P.C. to meet the informational needs prior to the planned renovation of the Laurel Dormitory.

1.2 Asbestos Survey

The scope of services included a survey for asbestos-containing materials (ACM) to comply with requirements set forth in the USEPA NESHAP regulation, which prohibits the release of asbestos fibers to the atmosphere during renovation or demolition activities. The asbestos NESHAP requires a thorough inspection of a facility for the presence of asbestos in building materials, including categorization and quantification of building materials, prior to planned demolition or renovation activities. Suspect ACM samples were collected in general accordance with the sampling protocols outlined in USEPA 40 CFR Part 763, Subpart E, known as the Asbestos Hazard Emergency Response Act (AHERA).

This asbestos survey was limited to materials not identified by the Tetra Tech January 10, 2017 Asbestos and Lead-Based Paint Inspection Report and associated with the interior and exterior of the Laurel Dormitory. The Laurel Laundry building was not evaluated. Should renovation work require disturbance of any other building material not identified in this survey report, or other valid

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1.3 Lead Paint Screen

The lead paint (LP) screen was performed to satisfy the requirements of OSHA’s construction standard for lead (29 CFR 1926.62), which defines lead-containing paint as paint containing any detectable lead. The sampling conducted for this project was not intended to meet the requirements of the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP) Hazards in Housing or the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination.

This lead paint screen was limited to coatings identified as negative via X-Ray Fluorescence (XRF) methods in the Tetra Tech January 10, 2017 Asbestos and Lead-Based Paint Inspection Report and associated with the interior and exterior of the Laurel Dormitory. The Laurel Laundry building was not evaluated.

1.4 Hazardous Building Materials Inventory

The hazardous building materials (HBM) inventory included universal wastes and other hazardous building materials, such as polychlorinated biphenyls (PCB) in light ballasts and transformers; chlorofluorocarbons/hydrochlorofluorocarbons (CFCs/HCFCs); smoke detectors containing radioactive material; paints, solvents, chemicals, herbicides, and compressed gas.

HBMs in the building are required to be properly disposed of or recycled prior to demolition in accordance with USEPA Resource Conservation and Recovery Act (RCRA) and USEPA Toxic Substances Control Act (TSCA).

1.5 Reliance

This report is for the exclusive use of DJ&A, P.C. for the project being discussed. Reliance by any other party on this report is prohibited without written authorization of Terracon and DJ&A, P.C.

Reliance on this report by DJ&A, P.C. and all authorized parties will be subject to the terms, conditions, and limitations stated in the DJ&A, P.C. May 18, 2021 Professional Services Agreement.

BUILDING INFORMATION

The following table provides a summary of pertinent building information and construction information such as structure and finishes used within the building.

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Building Description and Information Building Use Dormitory Owned/Leased Owned

Building Square Footage ~17,250 square feet Number of Floors 2 Construction Date 1925 Renovation Date(s) 1980s Basement: No Crawl Space: Yes Tunnels: No Attic: Yes

Building Construction Main Structure Wood frame Building Insulation Rolled fiberglass

Flooring Structure Wooden joist Flooring Finishes Carpet and tile

Exterior Walls Wooden framing Interior Wall Finishes Drywall & plaster Roof Type Flat Roof Finishes Membrane

Ceilings Lower: Plaster Upper: Wood

HVAC1 Equipment Heating: Radiator distribution Cooling: None

ASBESTOS

The survey was conducted by Mr. Cameron D. Sapp, EPA-accredited asbestos inspector. A copy of Mr. Sapp’s asbestos inspector accreditation can be found in Appendix G. A summary of survey activities is provided below. The survey included in the interior or exterior of the building.

3.1 Visual Assessment

Survey activities included visual observations of the interior of the structure to identify homogeneous areas of suspect ACMs. A homogeneous area (HA) consists of building materials that appear similar throughout in terms of color, texture, and date of application. Building materials identified as glass, wood, metal or rubber are not considered suspect ACM and, therefore, were not sampled. Reasonable efforts were made to access suspect materials within known areas of restricted access (e.g., attics) provided these areas were not determined to be permit-required confined spaces, or to pose a health or safety risk to Terracon personnel. While Terracon made efforts to thoroughly inspect the structure for suspect materials, it should be noted that additional suspect but unsampled materials could be located in walls, voids or other concealed areas.

1 HVAC – Heating, ventilating, and air conditioning

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Building materials that may be present in such spaces that are not glass, metal, or wood must be assumed to be ACM or must be proven to be non-ACM through sampling conducted by a Montana-accredited asbestos inspector and analysis by an accredited laboratory.

3.2 Physical Assessment

A physical assessment of each HA of suspect ACM was conducted to assess the friability and condition of the materials. A friable material is defined by the USEPA as a material that can be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friability was assessed by physically touching suspect materials.

3.3 Sample Collection

Based on results of the visual observation, bulk samples of suspect ACM were collected in accordance with the sampling protocols outlined in 40 CFR 763.86-Sampling. Samples of suspect materials were collected from randomly selected locations in each HA. Bulk samples were collected using wet methods, as applicable, to reduce the potential for fiber release. Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker.

The selection of sample locations and frequency of sampling were based on Terracon’s observations and the assumption that like materials in the same area are homogeneous in content. Terracon collected 24 bulk samples from 8 HAs of suspect ACM. A summary of suspect ACM samples collected during the survey is included as Appendix A.

3.4 Sample Analysis

Bulk samples were submitted under chain of custody (COC) to Eurofins EMLab P&K (Eurofins) of Phoenix, Arizona for analysis by polarized light microscopy (PLM) with dispersion staining techniques in accordance with USEPA’s Method for the Determination of Asbestos in Bulk Building Materials (600/R-93/116). The asbestos content, if present, was determined by microscopic visual estimation. Eurofins is accredited under the National Voluntary Laboratory Accreditation Program (NVLAP), Accreditation No. 500031-0. The laboratory analytical report and COC are provided in Appendix D.

3.5 Regulatory Overview

The asbestos NESHAP (40 CFR Part 61, Subpart M) regulates asbestos fiber emissions and asbestos waste disposal practices. The asbestos NESHAP regulation also requires the identification and classification of existing ACM according to friability prior to demolition or renovation activity. Friable ACM is a material containing more than 1% asbestos that, when dry, July 23, 2021 ■ Terracon Project No. 26217001

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The asbestos NESHAP regulation classifies ACM as RACM, Category I nonfriable ACM or Category II nonfriable ACM. RACM includes all friable ACMs, along with Category I and Category II nonfriable ACMs that have become friable; will be or have been subjected to sanding, grinding, cutting or abrading; or have a high probability of becoming or have become crumbled, pulverized, or reduced to powder in the course of renovation or demolition activity. Category I nonfriable ACM are exclusively asbestos-containing packings, gaskets, resilient floor coverings, resilient floor covering mastics and asphalt roofing products that contain more than 1% asbestos. Category II nonfriable ACM are all other nonfriable materials other than Category I nonfriable ACM that contain more than 1% asbestos. Category II nonfriable ACM generally includes but is not limited to cementitious material such as: cement pipes, cement siding, cement panels, glazing, mortar and grouts.

The Wyoming Department of Environmental Quality (WDEQ), enforces the Asbestos NESHAP as adopted by reference under authority of Sections 35-11-110, 112, 114, and 202 through 212 of the Wyoming Environmental Quality Act, 1993 and in accordance with provisions of Sections 16-3-101 through 16-3-115 of the Wyoming Administrative Procedures Act. The owner or operator must provide WDEQ with written notification at least 10 working days prior to the commencement of asbestos abatement activities that will disturb RACM in amounts greater than or equal to 160 square feet, 260 linear feet or 35 cubic feet.

The OSHA asbestos standard for construction (29 CFR 1926.1101) regulates workplace exposure to asbestos. The OSHA standard requires that employee exposure to airborne asbestos fibers be maintained below the permissible exposure limits (PELs) of 0.1 asbestos fiber per cubic centimeter of air (0.1 f/cc) as an 8-hour time-weighted average (TWA) or 1.0 f/cc as a 30-minute excursion limit. The OSHA standard classifies construction and maintenance activities that could disturb ACM and specifies work practices and precautions that employers must follow when engaging in each class of regulated work. The standard also specifies requirements for handling or disturbing materials containing asbestos in concentrations less than or equal to one percent.

3.6 Findings and Recommendations

Asbestos was identified in the following materials as a result of the laboratory analyses, or the material could not be sampled and was assumed ACM. Laboratory analytical reports are included in Appendix D.

n Orange Gasket (Assumed) n Black Gasket (Assumed) n Vermiculite (Assumed) n 06-RF6: Black Membrane Built-up Roofing

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The state of Wyoming requires that an individual trained in the provisions of EPA regulation 40 CFR 61, National Emission Standards for Hazardous Air Pollutants (NESHAP), Subpart M, National Emission Standard for Asbestos will be on-site during the demolition; that evidence of the required training accomplished by this person will be available for inspection during the demolition work hours; that all work will be performed in accordance with 40 CFR part 61, subpart M, Mont. Code Ann. §§ 75-2-501--519, ARM 17.74.301 - 17.74.406; that there are no asbestos-containing waste materials or the materials were previously removed under an approved project permit and transported properly and disposed of in a State-approved Class II landfill or similar approved asbestos disposal facility; and that a copy of the asbestos inspection report will be posted on site during demolition activities.

A summary of the sample locations is presented in Appendix B. Laboratory analytical reports are included in Appendix D.

LEAD PAINT SCREEN

The lead paint screen (LP) was conducted June 9, 2021, by Mr. Cameron Sapp. The LP screen sampling was performed in general accordance with the procedures prescribed in the USEPA’s work practice standards for conducting lead paint testing (40 CFR 745.227). The sampling conducted for this project was not intended to meet the requirements of the U.S. Department of Housing and Urban Development (HUD) Guidelines for the Evaluation and Control of Lead-Based Paint (LBP) Hazards in Housing and the USEPA Resource Conservation and Recovery Act (RCRA) for waste determination.

4.1 Visual Assessment

Sampling activities began with visual observation of areas the building to identify unique combinations of paint most prevalent in or on the building. A unique combination of paint consists of paint that is applied to a building material and has similar color, substrate and component. The observation was conducted throughout the visually accessible interior and exterior areas of the building. Additional paint combinations may be in concealed areas or other spaces not accessed.

A visual assessment of each unique combination of paint was conducted to assess the condition of the paint. Paint was visually assessed and assigned a condition of intact, top layer failure, multi-layer failure and substrate failure.

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4.2 Lead Paint Sampling and Laboratory Analysis

Based on Terracon’s visual observations, chip samples were collected from painted metal and wooden door frames, painted wood stairs, painted window screens, drywall walls, plaster ceilings, painted wooden baseboards, painted wooden floors, painted pipes, and painted attic beams. Paint chip samples included all layers of paint with care taken to minimize collection of substrate.

Samples were placed in sealable containers and labeled with unique sample numbers using an indelible marker. This number (along with other information such as sample location, color, substrate, and condition) was recorded in the Sample Log.

Terracon collected 20 paint chip samples from the above-referenced areas of the building.

The inspector shipped the samples along with a completed chain-of-custody document to the laboratory. The laboratory then arranged the samples in numerical order. If a discrepancy between the samples exists, this is noted and initialed on the log sheet. The laboratory signed a copy of the chain-of-custody to acknowledge receipt. The inspector retained the signed copy for evidentiary purposes. Further, the laboratory assigned a laboratory number to each sample received. The laboratory labeled both the analytical report and the sample container with this laboratory number for cross-reference purposes.

The paint chip samples were received under chain of custody by EMSL Analytical, Inc. (EMSL) of Cinnaminson, New Jersey. EMSL is accredited by the AIHA® Laboratory Accreditation Programs, LLC under the Industrial Hygiene Laboratory Accreditation Program (IHLAP; Accreditation No.

100194).

Paint chip samples were analyzed using USEPA SW-846 Methods 3050B/7000B Acid Digestion of Sediments, Sludges, and Soils / Flame Atomic Absorption Spectrophotometry. The paint chip sample results are reported as percent lead by weight.

4.3 Lead Regulatory Overview

The OSHA lead standard for construction (29 CFR 1926.62) regulates workplace exposure to lead. OSHA regulates construction activities that disturb lead-containing material regardless of the concentration. Personnel performing renovation or demolition activities that may disturb painted components with concentrations of lead above the designated analytical detection limit should comply with all current OSHA regulations in order to minimize employee exposure.

Construction work covered by OSHA standards includes any repair or renovation activities or other activities that disturb in-place lead-containing materials, but does not include routine cleaning and repainting where there is insignificant damage, wear, or corrosion of existing lead-containing coatings or substrates. Employers must assure that no employee will be exposed to lead at concentrations greater than the PEL of 50 micrograms per cubic meter (mg/m3) averaged over an

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The Resource Conservation and Recovery Act (RCRA) gave the USEPA authority to regulate the waste status of demolition and renovation debris, including lead-containing materials. Specific notification and testing requirements must be addressed prior to transporting, treating, storing, or disposing of hazardous wastes. Lead-containing wastes are considered hazardous waste under RCRA if Toxicity Characteristic Leaching Procedure (TCLP) results exceed 5 milligrams per liter (mg/L). USEPA exempts from most RCRA requirements for those generators whose combined hazardous waste generation is less than 100 kilograms (kg) per month.

4.4 Lead Findings and Recommendations

Lead was identified in the following paints as a result of laboratory analysis.

n LBP-08: White Paint on Wooden Door Frame n LBP-12: White Paint on Wooden Baseboard n LBP-14: Grayish Blue Paint on Floor n LBP-19: Tan Paint on Wooden Floor

Compliance with OSHA 29 CFR 1926.62 Lead is required for employees that may be occupationally exposed to lead and waste determination for disposal of lead waste must comply with USEPA’s regulations under the Resource Conservation and Recovery Act (RCRA).

Disturbance of paints containing detectable lead concentrations are regulated by OSHA’s construction lead standard (29 CFR 1926.62). Disposal of lead-contaminated waste is regulated by USEPA RCRA.

A summary of the lead paint sample locations and analysis is presented in Appendix C. Laboratory analytical reports are included in Appendix D.

HAZARDOUS BUILDING MATERIALS INVENTORY

The hazardous building materials (HBM) inventory was conducted June 25-27, 2019 by Mr.

Cameron Sapp. The HBM inventory was performed to provide information for hazardous materials covered under the USEPA Resource Conservation and Recovery Act (RCRA) and Toxic Substances Control Act (TSCA).

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5.1 HBM Regulatory Overview

Universal Waste

USEPA’s universal waste regulations are found in 40 CFR 273 Universal Wastes. The State of Wyoming has adopted 40 CFR 273 and does not recognize universal wastes other than those set forth by the USEPA. The universal waste regulation streamlines the hazardous waste management standards for certain categories of hazardous waste that are commonly generated by a wide variety of establishments. The universal waste regulations apply to four types of universal waste:

n Batteries (40 CFR 273.2) n Pesticides (40 CFR 273.3) n Mercury-containing equipment (40 CFR 273.4) n Mercury lamps (40 CFR 273.5)

The standard helps the promote the collection and recycling of universal waste, ease the regulatory burden on retail stores and other generators that wish to collect these wastes, ease the regulatory burden on transporters of these wastes, and encourage the development of municipal and commercial programs to reduce the quantity of these wastes going to municipal solid waste landfills or combustors.

Four types of regulated participants are defined in the universal waste system: small quantity handlers, large quantity handlers, universal waste transporters and universal waste destination facilities.

In general, materials managed as universal waste can be stored for a year and are not required to be shipped with a manifest. In addition, universal waste does not need to be counted for the purpose of determining whether the generator is conditionally-exempt small quantity, small quantity, or large quantity. The universal waste regulations do require that the materials be managed in a way to prevent releases to the environment and tailors those requirements to each type of universal waste (for small quantity handlers and for large quantity handlers). Finally, the standards also include labeling, a requirement to respond to releases, and transport to a facility that is permitted or otherwise designated for receiving hazardous waste, like a recycler.

Polychlorinated Biphenyls

USEPA regulation 40 CFR 761, Subpart R regulates disposal of PCB bulk product waste under section 761.62. Small ballasts containing less than 50 parts per million (ppm) PCBs may be disposed of at a solid waste landfill. However, the effort to determine the PCB content in ballasts is burdensome, and the USEPA recommends that all PCB ballasts be disposed of at a TSCA-approved incinerator facility. It should be noted that ballasts manufactured between July 1, 1979 and July 1, July 23, 2021 ■ Terracon Project No. 26217001

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1998 do not typically contain PCBs and “No PCBs” should be stated on labels affixed to these ballasts. If no indication is made on the ballast label, these ballasts should be assumed to contain PCBs unless it is known to be manufactured after 1979. Ballasts manufactured after 1998 are not required to be labeled.

The PCB inspection consisted of locating suspect PCB-containing equipment, such as electrical transformers, large electrical capacitors and electrical light ballasts, and PCB-containing caulk.

Chlorofluorocarbons/Hydrochlorofluorocarbons (CFCs/HCFCs)

USEPA regulations 40 CFR 82, Subpart F under Section 608 of the Clean Air Act include requirements for the safe disposal of refrigeration and air-conditioning equipment. These requirements are designed to minimize refrigerant emissions when these appliances are disposed. CFCs/HCFCs are not considered a hazardous waste if reclaimed.

Air conditioning units and other refrigeration devices will not be accepted at a solid waste landfill unless regulated refrigerants have been properly evacuated and recovered from the equipment.

Smoke Detectors

Smoke detectors can be one of two kinds: photoelectric or ionizing. The ionizing variety contains a small amount of radioactive material (americium-241).

Specific requirements do not exist for the disposal of smoke detection devices. USEPA’s Household Hazardous Waste program encourages waste reduction and minimization, but does not exert any special disposal requirements. Many manufacturers encourage return of the devices to their facilities for salvage and recycling of components. The battery or batteries should be removed from the unit(s) prior to disposal.

Tritium Exit Signs

Exit signs that glow in the dark (without need of an external energy source such as electricity) often contain a radioactive gas called tritium. Tritium exit signs pose little or no threat to public health and safety and do not constitute a security risk. Tritium is regulated by the United States Nuclear Regulatory Commission (USNRC) 10 CFR 31.5.

USNRC requires proper accounting and disposal of all radioactive materials. Proper handling and accounting are important, because a damaged or broken sign could cause mild radioactive contamination of the immediate vicinity, requiring a potentially expensive clean up.

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5.2 HBM Findings and Recommendations

Hazardous building materials observed during inventory included the following:

Hazardous Building Materials

PCB-containing Light Ballasts

PCB-containing Transformers

PCB-containing Caulking CFC/HCFC units Aerosol/Chemicals

11 (Assumed) 0 N/A 0 0

Other Concerns

Compressed Gasses Fire Extinguishers

Compressed Gasses Fire Suppression

System(s)

Radioactive Source Tritium Exit Signs

Radioactive Source Smoke Detectors Stored Paint

6 0 0 0 0

Universal Waste

Batteries Emergency Lamps

Batteries Other

Liquid Mercury- Containing Equipment

Mercury-Vapor Containing Lamps

Pesticides

15 80 0 150 0

The HBM inventory was limited to visual observations of readily accessible areas and providing an inventory of recognizable and identified hazardous materials documenting the presence, location, and condition of suspect PCB-containing equipment, mercury liquid-containing equipment, mercury vapor-containing equipment, and CFC/HCFC-containing equipment. The stored materials inventory included identifying the presence, location, and quantity of paints, solvents, chemicals, pesticides, herbicides, and compressed gasses. Sampling of HBMs was not performed.

Batteries

The following equipment was observed to be battery-backed:

n 15 Battery-backed emergency lights n 10 Battery-backed exit signs n 70 Battery-backed smoke detectors

Terracon recommends that batteries be managed in compliance with the 40 CFR 273.2 of the universal waste regulation.

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Mercury

Mercury is a toxic heavy metal and in its vapor form or liquid metal form, may be present in switches and light bulbs. When a mercury device breaks, it releases mercury into the air, which is toxic to the human nervous system and can poison wildlife.

Mercury Liquid-Containing Equipment

Mercury liquid-containing equipment was not observed.

Mercury Vapor-Containing Lamps

A cursory inspection was conducted and the following lighting equipment was assumed to contain mercury:

n 150 Fluorescent light tubes

Terracon recommends that mercury vapor-containing light tubes or lamps be managed in compliance with the 40 CFR 273.5 of the universal waste regulation.

Stored Paints, Solvents, Chemicals, Pesticides, and Herbicides

Stored paints, solvents, chemicals, pesticides or herbicides were not observed in the building.

PCB-Containing Equipment

Polychlorinated biphenyls, or PCBs, are a class of synthetic chemicals, once widely used by industry. Their physical properties made them ideal as insulating and cooling fluids in electrical equipment such as transformers, light ballasts, and capacitors and were added to window caulking for protection from ultraviolet (UV) light degradation. PCBs are known carcinogens and the manufacturing of PCBs was banned in 1977.

PCB-Containing Light Ballasts

A cursory inspection was conducted for differing types of light fixtures following observations were made:

n Single-line LED strip light fixture: The ballast (General Electric 74463 - GE432MAX-G-N GE UltraMax® General Series T8 High performance electronic ballast) observed in this type of fixture did not have “No PCBs” printed on the label however based on information from GE’s product data sheet, this type of ballast

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n All other light fixture ballasts observed had “No PCBs” printed on the label.

Terracon recommends checking all light ballast labeling and properly disposing any ballast that does not have “no PCBs” on labeling or do not have a verified manufacture date in compliance with TSCA 40 CFR 671.

PCB-Containing Equipment

Transformers or capacitors that might contain PCBs were not observed in the building.

Transformers observed on-site were air-cooled type transformers.

Chlorofluorocarbons (CFCs/HCFCs)

Equipment was not observed or assumed to contain CFCs/HCFCs.

Tritium Exit Signs

Suspect tritium exit signs were not observed in the building.

Smoke Detectors

Suspect photoelectric or ionizing variety smoke detectors were not observed in the building.

Compressed Gases

The following items were observed.

n 6 ABC fire extinguishers

Terracon recommends recycling fire extinguishers.

LIMITATIONS/GENERAL COMMENTS

Terracon made reasonable efforts to access and sample suspect materials within known areas of restricted access which required demolition or destructive activities such as opening walls, dismantling of equipment and removal of protective coverings. Those entities and persons involved with the inspection and generation of this report do not imply or guarantee that all potential asbestos-containing materials on or in the building have been identified or sampled.

Areas which posed a health or safety risk to Terracon personnel were not sampled.

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The asbestos survey, lead screen, and hazardous building materials inventory were conducted in a manner consistent with the level of care and skill ordinarily exercised by members of the profession currently practicing under similar conditions in the same locale. The results, findings, conclusions and recommendations expressed in this report are based on conditions observed during our survey of the building. The information contained in this report is relevant to the dates on which this survey was performed, and should not be relied upon to represent conditions at a later date. This report has been prepared on behalf of and exclusively for use by DJ&A, P.C. for specific application to their project as discussed. This report is not a bidding document; Terracon can, upon request, provide pricing for generation of an abatement scope of work document.

Contractors or consultants reviewing this report must draw their own conclusions regarding further investigation or remediation deemed necessary. Terracon does not warrant the work of regulatory agencies, laboratories or other third parties supplying information which may have been used in the preparation of this report. No warranty, express or implied is made.

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APPENDIX A

LAUREL DORMITORY, OLD FAITHFUL, YELLOWSTONE NATIONAL PARK, WYOMING

Terracon Project No. 26217001

July 23, 2021

Identified Asbestos-Containing Material by Homogeneous Area (HA)

The materials listed in this table have been sampled or assumed to contain concentrations of asbestos. When disturbed, various federal, state, and local regulations may apply. See Appendix B for a summary of samples collected. See Appendix C for detailed analytical results.

Bin X

HA No. Material Description Material Location % and Type Asbestos1 NESHAP Classification2 Condition

Estimated Quantity3

- Orange Gasket Fire suppression system Assumed CAT I Non-friable Good 1 Piece

- Black Gasket Fire suppression system Assumed CAT I Non-friable Good 1 Piece

- Vermiculite Fire suppression system Assumed RACM Good 6 Cubic Ft

06 Black Membrane Built-up Roof Roof 35% Chrysotile CAT II Non-friable Good ̴ 9,700 SF

Black Flashing and Associated Black

Roofing Tar Roof 8% Chrysotile CAT I Non-friable Good ̴ 565 SF

1 % & Type Asbestos = this column contains both the analytical result of the sample with the highest concentration of asbestos detected in the samples that make up the HA and the types of asbestos identified.

2 CAT I = Category I Non-friable; CAT II = Category II Non-friable 3 Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if ACMs are present in hidden and/or inaccessible areas not evaluated as part of this survey. SF = square feet

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APPENDIX B

LAUREL DORMITORY, OLD FAITHFUL, YELLOWSTONE NATIONAL PARK, WYOMING

Terracon Project No. 26217001

July 23, 2021

ASBESTOS SURVEY SAMPLE LOCATION SUMMARY

HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

01 01-MG5-01

Room 142, 4.5’ from South wall, 3.5 from East wall, 6’ up

Blue adhesive L1 – Transparent Adhesive L2 – White Compound

L1 – None detected L2 – None detected Non-ACM Good

Various Rooms in Showers

Not Quantified01 01-MG5-02

Room 136, 3’ from North wall, 3’ from East wall, 6’ up

Blue adhesive L1 – Blue Adhesive L2 – White Compound

L1 – None detected L2 – None detected Non-ACM Good

01 01-MG5-03

Room 240, 3’ from North wall, 3’ from East wall, 6’ up

Blue adhesive L1 – Blue Adhesive L2 – White Compound

L1 – None detected L2 – None detected Non-ACM Good

02 02-MG8-04

Room 136A, Northeast corner, 4’ up

Yellow FRP adhesive L1 – Yellow Adhesive L2 – White Compound with White Paint

L1 – None detected L2 – None detected Non-ACM Good

Not Quantified02 02-MG8-05

Room 242, North wall, 4’ from West wall

Yellow FRP adhesive L1 – Yellow Adhesive L2 – White Compound with White Paint

L1 – None detected L2 – None detected Non-ACM Good

02 02-MG8-06

Room 240A, Northeast corner, 4’ up

Yellow FRP adhesive L1 – Yellow Adhesive L2 – White Compound with White Paint

L1 – None detected L2 – None detected Non-ACM Good

4 G = good; D = damaged; SD = severely damaged 5 Estimated quantities are based on a cursory field evaluation, and actual quantities may vary significantly, especially if asbestos containing materials are present in hidden and/or inaccessible areas not evaluated as part of this survey. ~ = approximately; SF = square feet; LF = linear feet.

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HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

03 03-SC7-07 Crawlspace Gray duct sealant L1 – Gray Sealant L1 – None detected Non-ACM Good On duct work present in crawlspace

Not Quantified03 03-SC7-08 Crawlspace Gray duct sealant L1 – Gray Sealant L1 – None detected Non-ACM Good

03 03-SC7-09 Crawlspace Gray duct sealant L1 – Gray Sealant L1 – None detected Non-ACM Good

04 04-PI4-10 Crawlspace

Aluminum/paper-backed yellow fiberglass pipe insulation with white sealant

L1 – Yellow Insulation L2 – White Wrap L3 – White Sealant

L1 – None detected L2 – None detected L3 – None detected

Non-ACM Good

Crawlspace Not Quantified04 04-PI4-11 Crawlspace

Aluminum/paper-backed yellow fiberglass pipe insulation with white sealant

L1 – Yellow Insulation L2 – White Wrap L3 – White Sealant

L1 – None detected L2 – None detected L3 – None detected

Non-ACM Good

04 04-PI4-12

Attic over, Room 245, 9’ from North wall, 26’ from East wall, 10’ up

Aluminum/paper-backed yellow fiberglass pipe insulation with white sealant

L1 – Yellow Insulation L2 – White Wrap L3 – White Sealant

L1 – None detected L2 – None detected L3 – None detected

Non-ACM Good

05 05-PM5-13

Exterior, North wall, 20’ from East wall, 3’ up

White air barrier L1 – White Fibrous Material (Air Barrier) L1 – None detected Non-ACM Good

Exterior of building.

Not Quantified05 05-PM5-14

Exterior, North wall, 20’ from East wall, 3’ up

White air barrier L1 – White Fibrous Material (Air Barrier) L1 – None detected Non-ACM Good

05 05-PM5-15 Exterior, Southwest corner, 3’ up White air barrier L1 – White Fibrous

Material (Air Barrier) L1 – None detected Non-ACM Good

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HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

06 06-RF6-16 Roof, Northeast corner

Black-membrane built up roofing

L1 – Black Roofing Material L2 – Black Semi- Fibrous Material (Membrane) L3 – Black Semi- Fibrous Material (Membrane) L4 – White Fibrous Material L5 – White Powdery Material L6 – Black Roofing Material L7 – Black/Brown Roofing Felt L8 – Black Roofing Tar L9 – Brown/Black Roofing Felt L10 – Brown/Black Roofing Felt L11 – Brown/Black Roofing Felt L12 – Brown Fibrous Material

L1 – None detected L2 – None detected L3 – None detected L4 – None detected L5 – None detected L6 – None detected L7 – 35% Chrysotile L8 – None detected L9 – 35% Chrysotile L10 – 35% Chrysotile L11 – 35% Chrysotile L12 – None detected

Category II Non-friable Good Roof ̴̴̴̴̴̴ 9,700 SF

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HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

06 06-RF6-17 Roof, Northwest corner

Black-membrane built up roofing

L1 – Black Roofing Material L2 – Black Semi- Fibrous Material (Membrane) L3 – White Fibrous Material L4 – White Powdery Material L5 – Black Roofing Material L6 – Black/Brown Roofing Felt L7 – Black Roofing Tar L8 – Brown/Black Roofing Felt L9 – Brown/Black Roofing Felt L10 – Brown Fibrous Material

L1 – None detected L2 – None detected L3 – None detected L4 – None detected L5 – None detected L6 – 35% Chrysotile L7 – None detected L8 – 35% Chrysotile L9 – 35% Chrysotile L10 – None detected

Category II Non-friable Good Roof ̴̴̴̴̴̴ 9,700 SF

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HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

06 06-RF6-18 Roof, Southwest corner

Black-membrane built up roofing

L1 – Black Roofing Material L2 – Black Semi- Fibrous Material (Membrane) L3 – Black Semi- Fibrous Material (Membrane) L4 – White Fibrous Material L5 – White Powdery Material L6 – Black Roofing Material L7 – Brown/Black Roofing Felt L8 – Brown/Black Roofing Felt L9 – Brown/Black Roofing Felt L10 – Brown Fibrous Material

L1 – None detected L2 – None detected L3 – None detected L4 – None detected L5 – None detected L6 – None detected L7 – 35% Chrysotile L8 – 35% Chrysotile L9 – 35% Chrysotile L10 – None detected

Category II Non-friable Good Roof ̴̴̴̴̴̴ 9,700 SF

07 07-CP5-19

Exterior, East wing, Southeast corner, 1’ up

Gray concrete L1 – Gray Concrete L1 – None detected Non-ACM Good

Foundation Not Quantified07 07-CP5-20 Exterior, Northeast corner, 1’ up Gray concrete L1 – Gray Concrete L1 – None detected Non-ACM Good

07 07-CP5-21 Exterior, Northwest corner, 1’ up Gray concrete L1 – Gray Concrete L1 – None detected Non-ACM Good

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HA

No.

Sample Number Sample Location Material Description Layer Lab Results NESHAP

Category Condition4 HA Locations Estimated Quantity5

08 08-RF4-22

Roof, soffit cut out between 225 and

Black flashing and associated black roofing tar

L1 – Gray/Black Roofing Mastic L2 – Black Roofing Tar

L1 – 8% Chrysotile L2 – None detected

Category I Non-friable Good

Flashing along roof edge ̴ 565 SF08 08-RF4-23 Roof soffit

Black flashing and associated black roofing tar

L1 – Gray/Black Roofing Mastic L2 – Black Roofing Tar

L1 – 8% Chrysotile L2 – None detected

Category I Non-friable Good

08 08-RF4-24 Roof soffit Black flashing and associated black roofing tar

L1 – Gray/Black Roofing Mastic L2 – Black Roofing Tar

L1 – 8% Chrysotile L2 – None detected

Category I Non-friable Good

June 15, 2021 ■ Terracon Project No. 26217001

APPENDIX C

LAUREL DORMITORY, OLD FAITHFUL, YELLOWSTONE NATIONAL

PARK, WYOMING

Terracon Project No. 26217001 June 15, 2021

LEAD PAINT SAMPLE LOCATION SUMMARY

SAMPLE

NUMBER SAMPLE LOCATION COMPONENT SUBSTRATE COLOR CONDITION RESULT

(% by wt.)

LBP-01 Exterior, East wing, South entrance, 0.5’ up Door Frame Metal Light Brown Intact <0.033%7

LBP-02 Exterior, East wing, South entrance, 0.5’ up Door Metal Light Brown Intact <0.013%

LBP-03

Exterior, East wing, West side of stairs, 2’ up

Stairs Wood Brown Intact <0.015%

LBP-04

Exterior, East wing, East entrance, 3’ West, 2’ up

Siding Wood Brown Intact <0.013%

LBP-05

Exterior, East wing, 4’ East of South entrance, 4’ up

Window Screen Wood Light Brown Intact <0.0080%

LBP-06 Room 140, Northwest corner, 0.5’ up Wall Drywall White Intact <0.0080%

LBP-07 Room 245, Southwest corner, ceiling Ceiling Plaster White Intact <0.0080%

LBP-08 Room 110, door frame, 0.5’ up Door Frame Wood White Intact 6.5%

LBP-09 Room 116, door, 0.5’ up Door Wood White Intact <0.0080%

LBP-10

Door frame between Rooms 137 / 145, 0.5’ up

Door Frame Metal White Intact <0.030%

LBP-11 Door between Rooms 241 / 242, 0.5’ up Door Metal White Intact <0.014%

LBP-12 Room 110B, Northeast corner, 0.5’ up Baseboard Wood White Intact 8.5%

7 < = below detection limits

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SAMPLE

NUMBER SAMPLE LOCATION COMPONENT SUBSTRATE COLOR CONDITION RESULT

(% by wt.)

LBP-13 Room 218, Northeast corner, ceiling Pipe Metal White Intact <0.013%

LBP-14 Room 113, Northeast corner, floor Floor Wood Grayish Blue Intact 0.49%

LBP-15

Beam next to attic opening on 2nd floor, South side

Attic Beam Wood White Intact <0.0080%

LBP-16 Room 142, North wall, 4’ from East wall, 4’ up Wall/Celling Drywall Tan Intact <0.0080%

LBP-17 Room 136, door, 5’ up Door Wood Tan Intact <0.013%

LBP-18 Room 136, door frame, 5’ up Door Frame Wood Tan Intact <0.011%

LBP-19 Room 100, Northwest corner, floor Floor Wood Tan Intact 0.58%

LBP-20 Pipe outside East wing crawlspace entrance Pipe Metal Brown Intact <0.0080%

APPENDIX D

LABORATORY ANALYTICAL DATA

Approved by:

Approved Signatory Renee Luna-Trepczynski

Report for:

Garett Masin,…