B08_Attach_1a_C99-21_Asb_and_Lead_Rpt_Bug.pdf

Leon Environmental Services 4545 N. Brawley Ave., Suite 104, Fresno, CA 93722

Phone: 559.274.9200 Fax: 559.274.9240 Email: LeonEnviro@comcast.net

June 03, 2022

Kelly White Yosemite National Park Facilities Management Design & Engineering

Re: Asbestos and Lead Limited Survey Bug Camp

Tuolumne Meadows

Yosemite National Park, CA Job No. C99-21

Dear Kelly:

Attached is the Asbestos and Lead Limited Survey Report for the above referenced site. The report includes inspection observations; a list of all samples taken, bulk sample analysis results, and recommendations concerning Asbestos and Lead identified at this site.

If you have any questions or need additional information, please do not hesitate to call. Thank you for using Leon Environmental Services. We look forward to working with you in the future.

Respectfully yours, Tommy Leon Certified Asbestos Consultant Certification No. 05-3882

ATTACHMENT 1a

Asbestos and Lead Limited Survey: Bug Camp, Tuolumne Meadows, C99-21

ASBESTOS ANALYSIS RESULTS

A limited Asbestos and Lead survey was performed at Tuolumne Meadows Bug Camp, Yosemite National Park, CA. The sample collection areas were determined by the information given to the inspector by Kelly White.

The following Buildings were included in the limited inspections:

Building 3049 Limited lead XRF samples Building 3055 Limited lead XRF samples Building 3065 Limited lead and asbestos samples Building 3083 Limited lead and asbestos samples Building 3085 Limited lead XRF samples Building 3086 Limited lead XRF samples

A total of 03 samples of suspect materials were collected by a state certified asbestos inspector at Tuolumne Meadows, Yosemite National Park, CA. The sample collection areas were determined by the information given to the inspector by Kelly White about the impending remodel/renovation that is planned for this site. McCall and Spero Environmental, Inc., a NVLAP accredited laboratory performed a total of 08 analyses from 03 samples collected. The chain of custody from Leon Environmental Services and the report from McCall and Spero contains a full list of all samples taken from this site.

Sample Location Material % Of

ACM

Friable

01 Cabin 3065 Floor Light Brown

12x12 Floor Tile

ND

Cabin 3065 Floor Adhesive ND

02 Cabin 3083 Floor Linoleum ND

Cabin 3083 Floor Adhesive ND

03 Cabin 3083 Floor Blue

12x12 Floor Tile

ND

Cabin 3083 Floor Adhesive ND

ASBESTOS COMMENTS AND RECOMMENDATIONS

All samples of suspect materials from the selected areas were negative for asbestos.

ASBESTOS CONCLUSIONS AND REGULATIONS

US EPA NESHAP (40 CFR Part 61)

Based on our survey, sampling and subsequent laboratory analysis and regulatory guidelines affecting this site, the types of ACM identified on the previous page require removal (in most cases) prior to demolition and/or renovation procedures to comply with local, state and federal agencies. The US EPA NESHAP (40 CFR Part 61 – November 20, 1990) requires materials containing greater than one percent asbestos be removed prior to renovation or demolition. If those materials are friable or likely to become friable due to the forces expected to act upon them during renovation or demolition, they become a regulated asbestos containing material (RACM) and require a 10-day notification to the local Air Pollution Control District prior to abatement.

Non-friable and non-regulated ACM, in most cases, may be disposed of as a Non- Hazardous waste in a landfill that accepts Asbestos Containing Materials. All friable waste containing more than 1% asbestos (RACM) should be manifested as hazardous waste for disposal purposes.

CAL OSHA--------Construction Industry--------8CCR, 1529

Cal/OSHA worker health and safety regulations apply during any disturbance of ACM by a person while in the employ of another. This is true regardless of friability or quantity disturbed. If there is greater than 100 square feet of ACM which will be affected by the demolition, a California Licensed Contractor who is registered with Cal/OSHA for asbestos is required. The regulations regarding asbestos are found in Title 8 CCR Section 1529, and also include formal notification requirements to Cal/OSHA at least 24 hours prior to removal. It is required that removal be conducted with the material kept in a wetted state to contain dust and hazardous emissions.

The construction industry standard covers employees engaged in demolition and construction, and the following related activities likely to involve asbestos exposure:

removal, encapsulation, alteration, repair, maintenance, insulation, spill emergency cleanup, transportation, disposal and storage of ACM.

Demolition contractors typically require that a building owner/operator accept responsibility for removal of all ACM found during the building inspection prior to start of demolition activities.

LEAD BASED PAINT ANALYSIS RESULTS

The sample collection areas were determined by the information given to the inspector by Kelly White about the impending remodel/renovation that is planned for this site. All paint samples were analyzed HUD Guidelines by XRF. The samples listed below are positive for Lead Based Paint (LBP). Please see table 1 for a full list of XRF samples.

Sample Sample Location Bldg Substrate Color XRF Result (mg/cm²) LBP

Kitchen North Window Still

3083 Wood Brown 11.60 Yes

Front Room East

Window Sill 3083 Wood Brown 12.90 Yes

Front Room South

Window Trim 3083 Wood White 18.20 Yes

LBP COMMENTS AND RECOMMENDATIONS

The Brown Paint on the interior window sills in the kitchen and front room of cabin 3083 is positive for Lead at > 1.0 mg/cm² level by XRF.

The White Paint on the interior window trim in the front room of cabin 3083 is positive for Lead at > 1.0 mg/cm² level by XRF.

Paint samples tested for this survey that were above the 1.0 mg/cm² level by XRF level established by HUD are considered Lead Based Paint (LBP). All homes built prior to 1978 are assumed to contain Lead Based Paint. Lead safe work practices should be in place during all any construction or demolition that would affect these areas.

All loose and flaky LBP should be removed prior to demolition or renovation, collected and handled as one waste stream. Based on the levels of LBP identified in the building survey, Leon Environmental recommends that only qualified Lead Abatement Company with properly trained and equipped individuals be used on this project. Procedures and engineering controls must be designed to follow CALOSHA and Department of Health Services (State of California) requirements.

The federal and CALOSHA regulations for lead in construction do not specify a level of a lead in paint that classifies it as LBP. However, federal and state OSHA regulations specify airborne lead levels that should not be exceeded during construction without appropriate protection and training.

The action level for lead is 30 micrograms per cubic meter of air (µg/m³) and the permissible exposure limit (PEL) is 50µg/m³. These airborne lead levels can be exceeded during construction or demolition activities such as scraping, sanding, grinding, blasting, and torching LBP surfaces, even when levels of lead in paint are far below the HUD definition of LBP of 1.0 mg/cm² or 0.5 percent lead by weight.

OSHA Lead in Construction Standard Cal/OSHA 8 CCR 1532.1 shall apply whenever construction work is conducted where employees may be exposed to lead.

Beginning April 2010, new federal law (EPA RRP rule) will require that contractors performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities and schools built before 1978 that a child under age six visits regularly to be certified and follow specific work practices to prevent lead contamination.

Also, beginning April 2010, federal law will require contractors that disturb lead-based paint in homes, child care facilities and schools, built before 1978 to be certified and follow specific work practices to prevent lead contamination.

LBP CONCLUSIONS AND REGULATIONS

The Department of Housing and Urban Development (HUD) considers a paint to be a lead-based paint hazard when the content of the paint exceeds 0.5% or 5000 ppm.

California Occupational Safety and Health (OSHA) regulations require employee personnel monitoring at any detectable levels until statistically reliable results indicate that exposure will remain consistently below the OSHA Action Level of 30 micrograms/m3 and the Permissible Exposure Level of 50 micrograms/m3 for an 8 hour day. The employer must then produce a “Negative Exposure Assessment” to indicate that it is not possible with the specific lead-based paint product to create excessive lead exposure levels.

LIMITATIONS OF LIABILITY

Conclusions and recommendations presented in this report are qualitative judgments based on the prevailing regulations and accepted industry standards at the time of the report issuance. Leon Environmental Services provides no other guarantees, either expressed or implied. All quantities of materials listed herein are estimates for sampling purposes only, and should be verified by Owner representative or an abatement / demolition contractor prior to asbestos abatement or demolition.

The nature of demolition is such that materials can be uncovered which previously were unknown to exist. Therefore, Leon Environmental Services cannot be responsible for materials not previously detected due to lack of accessibility or concealment, although every effort was made during the inspection to detect all suspect materials. If any suspect materials other than those included herein are discovered during renovation or demolition, it must be assumed that the materials are asbestos containing, and should be treated accordingly until further testing and analysis is performed.

The data interpretations and recommendations are based solely on information available to Leon Environmental Services at the time of our inspection. The customer recognizes that site conditions or accessibility may vary, from those encountered at the time of our inspection and sample collection. Varying conditions or access could result in additional information that would lead us to revise conclusions and recommendations. Leon Environmental Services will not be responsible for the interpretation or use by others of information contained within this report.

Thomas Leon Date Certified Asbestos Consultant Certification No. 05-3882 State of California Department of Public Health Lead Inspector Assessor # LRC-00002505

*Abbreviation Key:

Asbestos Containing Material — ACM (equal to or greater than 0.1% by weight) Vinyl Asbestos Tile – VAT No Asbestos Detected--N.A.D or N.D.

Homogeneous—H Not Sampled—NS

Richard “Danny” Leon CAC Certification No. 04-3708

Tommy Leon CAC Certification No. 05-3882

4545 N. Brawley Ave., Suite 104, Fresno, CA 93722

Phone: 559.274.9200 Fax: 559.274.9240 Email: LeonEnviro@comcast.net

Job C99-21 Sample Location Diagram

Bugg Camp / Tuolumne Meadows, Yosemite National Park, CA

Kelly White / National Park Service

Drawing not to Scale

= Lead + Asbestos

= Lead Only

N

X

X X

Bug Camp

Tuolumne Meadows, Yosemite National Park

May 26, 2022

XRF Table 1

Reading No Type Units Building Room Side Component Substrate Color Results PbC

55 PAINT mg / cm ^2 3049 FRONT ROOM C WALL WOOD BROWN Negative 0.00

56 PAINT mg / cm ^2 3049 B WALL WOOD BROWN Negative 0.00

57 PAINT mg / cm ^2 3049 A WALL WOOD WHITE Negative 0.10

58 PAINT mg / cm ^2 3049 B WALL WOOD WHITE Negative 0.00

59 PAINT mg / cm ^2 3065 B WALL WOOD BROWN Negative 0.00

60 PAINT mg / cm ^2 3065 A WALL WOOD BROWN Negative 0.00

61 PAINT mg / cm ^2 3065 KITCHEN C WALL WOOD WHITE Negative 0.00

62 PAINT mg / cm ^2 3065 KITCHEN A WALL WOOD WHITE Negative 0.00

63 PAINT mg / cm ^2 3083 A WALL WOOD BROWN Negative 0.00

64 PAINT mg / cm ^2 3083 C WALL WOOD BROWN Negative 0.10

65 PAINT mg / cm ^2 3083 KITCHEN A WINDOW FRAME WOOD BROWN Negative 0.10

66 PAINT mg / cm ^2 3083 KITCHEN A WINDOW SASH WOOD BROWN Negative 0.00

67 PAINT mg / cm ^2 3083 KITCHEN A WINDOW SILL WOOD BROWN Positive 11.60

68 PAINT mg / cm ^2 3083 FRONT ROOM B WINDOW SILL WOOD BROWN Positive 12.90

69 PAINT mg / cm ^2 3083 FRONT ROOM B WINDOW SASH WOOD BROWN Negative 0.00

70 PAINT mg / cm ^2 3083 FRONT ROOM B WINDOW TRIM WOOD BROWN Negative 0.00

71 PAINT mg / cm ^2 3083 FRONT ROOM C WINDOW TRIM WOOD WHITE Positive 18.20

72 PAINT mg / cm ^2 3083 FRONT ROOM C WINDOW FRAME WOOD WHITE Negative 0.00

73 PAINT mg / cm ^2 3083 C DOOR WOOD WHITE Negative 0.00

74 PAINT mg / cm ^2 3055 C WALL WOOD BROWN Negative 0.20

75 PAINT mg / cm ^2 3055 D WALL WOOD BROWN Negative 0.10

76 PAINT mg / cm ^2 3055 FRONT ROOM D WALL WOOD BROWN Negative 0.00

77 PAINT mg / cm ^2 3055 FRONT ROOM A WALL WOOD BROWN Negative 0.20

78 PAINT mg / cm ^2 3085 A WALL WOOD BROWN Negative 0.10

79 PAINT mg / cm ^2 3085 D WALL WOOD BROWN Negative 0.00

80 PAINT mg / cm ^2 3086 A WALL WOOD BROWN Negative 0.00

81 PAINT mg / cm ^2 3086 D WALL WOOD BROWN Negative 0.00