B08-ATTACH_9-Asbestos_Project_Design_-_Final.pdf

ZION NATIONAL PARK

APPENDIX A

ASBESTOS ABATEMENT PROJECT

DESIGN

PMIS 317454, 240254, 319664, & 325305

MAY 2023

BLANK PAGE

ASBESTOS ABATEMENT PROJECT DESIGN

ZION NATIONAL PARK – SOUTH CAMPGROUND

SPRINGDALE, UT 84767

Prepared for DHM Design by Smith Environmental & Engineering

March 3, 2023

W W W. S M I T H D E L I V E R S. C O M 250 Perry Lane Dacono, CO 80514 phone: 720.887.4928 fax: 720.887.4680

Smith Environmental and Engineering Delivering Sustainable Environmental Solutions

ASBESTOS ABATEMENT PROJECT DESIGN

SPRINGDALE, UT 84767

Prepared for:

DHM Design 900 S Broadway, Suite #300

Denver, CO 80209

Prepared by:

Smith Environmental and Engineering 250 Perry Lane

Dacono, CO 80514

SMITH Project No. 2020-1702

March 3, 2022

SMITH ENVIRONMENTAL & ENGINEERING

i

TABLE OF CONTENTS

INTRODUCTION AND PROJECT OVERVIEW

1.1 ‘PROJECT OVERVIEW

1.2 SITE CONDITIONS - ASBESTOS

1.3 PURPOSE

SPECIAL CONDITIONS

2.1 REGULATORY NOTIFICATION AND VARIANCES

2.2 FACILITY OCCUPANCY STATUS

2.3 SITE SECURITY

2.4 FIELD CHANGES

PROJECT DESIGN SPECIFICS

3.1 STANDARDS AND PRIMACY OF RULES

3.2 WORK INCLUDED

3.3 SITE ACCESS

3.4 EQUIPMENT STAGING AREAS

3.5 CONTAINMENT

3.6 NEGATIVE PRESSURE VENTILATION

3.7 VIEW PORTS

3.8 DECONTAMINATION

3.9 WASTE LOAD-OUT

3.10 WASTE REMOVAL

3.11 PERSONAL AIR MONITORING

3.12 ELECTRICAL HAZARDS CONTROL

3.13 EMERGENCY EGRESS AND FIRE PROTECTION

3.13.1 Egress Points

3.13.2 Fire Protection Plan

3.14 RESPIRATORY PROTECTION

3.15 DOCUMENT SUBMITTAL

REFERENCES

LIST OF FIGURES

FIGURE 1 PROJECT AREA MAP

FIGURE 2 BUILDING 1 RWA DIAGRAM

FIGURE 3 BUILDING 3 RWA DIAGRAM

FIGURE 4 BUILDING 4 RWA DIAGRAM

LIST OF TABLES

TABLE 1 ACM SAMPLING RESULTS

ii

LIST OF APPENDICES

APPENDIX A ASBESTOS, LEAD-BASED PAINT, AND OTHER REGULATED BUILDING

MATERIALS SURVEY

APPENDIX B CERTIFICATIONS

INTRODUCTION AND PROJECT OVERVIEW

1.1 ‘PROJECT OVERVIEW

The National Park Service (NPS) plans to demolish buildings on the Zion National Park South Campground as part of a wider renovation project. A State of Utah Certified General Asbestos Abatement Contractor (Contractor) will be conducting asbestos abatement activities to remove the following regulated asbestos-containing materials (RACMs) from the three (3) Type – D Mission 66 Comfort Stations within the Zion National Park South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767. This abatement will precede significant planned renovations and demolitions of buildings within Zion National Park Campgrounds.

Approximately 1850 SF of surfaces, on the three comfort stations, are covered by non-friable asbestos cement board roof shingle. Laboratory analysis determined that the roof shingles are 10% Chrysotile Asbestos. These roof shingles were observed covering the roofs for all the Mission 66 Type-D Comfort Stations within the South Campground. These stations are referred to as Buildings 1, 3, and 4 and their exact locations within the campground can be seen on Figure 1.

The roof shingles are in good condition and considered a Category I non-friable Asbestos Containing Material (ACM) with potential to become friable during demolition. As such, they are RACMs and need to be removed prior to demolition of the Comfort Stations.

1.2 SITE CONDITIONS - ASBESTOS

Smith Environmental and Engineering (SMITH), a Utah Certified Asbestos Firm, performed a survey of ACM and lead-based paint (LBP) on 5 buildings at the Zion National Park South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767 from October 21, 2022, to May 26, 2022. This survey of suspect materials included visual inspections and sampling to evaluate the presence/absence of ACM. Results from the survey are summarized in the report dated June 22, 2022. The report identified >1% asbestos in one material that is homogenous on three (3) of the roofs of the buildings. Table 1 summarizes the results of the RACM, The SMITH report titled, Asbestos, Lead-Based Paint, and other Regulated Building Materials Survey (SMITH 2022) can be found in Appendix A.

1.3 PURPOSE

The purpose of this project design is to give clear guidance to the Contractor regarding the abatement of ACM for Building 1, 3, and 4 at the Zion National Park South Campground (See Figure 1). The objective of this project is to abate the ACM on the roofs of buildings 1,3, and 4 within full compliance of federal and state regulations. The Project Design will describe the types, quantities, and locations of ACM affected, and any specific characteristics related to the work site.

TABLE 1

RACM IDENTIFICATION

ACM Material HOMOGENOUS

AREA TYPE LOCATION(S)

ASBESTOS CONTENT CONDITION ASSESSMENT FOR FRIABLE ACM

TYPE OF

ASBESTOS PERCENT ACM

FRIABLE

OR NON-

FRIABLE

APPROX.

AMOUNT

(Sq ft)

CONDITION

POTENTIAL

FOR

DISTURBANCE

AHERA

CATEGORY

REASON

FOR

DAMAGE

Tan/Grey Roof Shingle Mission 66

Comfort Station Roof

Miscellaneous Material

Building 1 (Northeast) Chrysotile 10 NF 650 Good High 5 Demolition

Tan/Grey Roof Shingle Mission 66

Comfort Station Roof

Miscellaneous Material

Building 3 (Central) Chrysotile 10 NF 600 Good High 5 Demolition

Tan/Grey Roof Shingle Mission 66

Comfort Station Roof

Miscellaneous Material

Building 4 (West) Chrysotile 10 NF 600 Good High 5 Demolition

RACM

3/2/2023 Smith Environmental and Engineering Zion National Park South Campground

X:\PROJECTS_2009_format\On Call National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 1 Dacono, CO 80514

Phone (720) 887-4928 Site Location Map Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

*RST-1,2

*RST-3

Pursuant to Utah Department of Environmental Quality – Division of Air Quality (Utah DAQ), Utah Asbestos Rule, Asbestos Abatement, Renovation, and Demolition Projects:

Notifications and Asbestos Removal Requirements (R307-801-11) (Utah DAQ 2021) all RACM must be abated prior to demolition activities scheduled for any buildings where it is present and pursuant to R307-801-13, a certified abatement supervisor must be present during all removal activities. Due to the RACM being a Category I Non-Friable ACM, encapsulant is not required during removal activities, if RACM remains non-friable.

The Utah DAQ Asbestos Rule (R307-801) defines an ACM as a material containing more than 1% asbestos. The intent of this project is to remove the ACM detailed in this Project Design. The scope of work includes the installation of critical barriers and establishing abatement workspaces, pre-cleaning of the entire workspace, removal and disposal of the above-identified ACM and all contaminated debris. OSHA regulations regarding occupational exposure during abatement activities also apply to this project. OSHA 29 CFR

1926.1101 (OSHA 2012) requires that workers performing construction-related activities be protected from asbestos fibers more than the permissible exposure limit (PEL) of 0.1 f/cc of air. Contractors must comply with applicable provisions of OSHA 29 CFR 1926.1101 (OSHA 2012) during abatement, renovation, and demolition activities. These OSHA provisions include, but are not limited to, Personal Protective equipment (PPE) and respirators, personnel training, personal-exposure air monitoring, employee medical surveillance, wet removal methods, signage for regulated areas, etc. The scope of work for this project includes, but is not limited to:

1. Site mobilization

2. Installing critical barriers

3. Establishing work area(s)

4. Building a decontamination unit(s)

5. Pre-cleaning of the entire work area(s)

6. Covering or removing fixed objects

7. Removing and packaging of known or assumed regulated ACM and affected contents

8. Transportation and disposal of all ACM and waste materials

9. Tear-down of containment(s) and demobilization from the site

10. Reporting, documentation, and submittals

All asbestos-containing waste generated during the project shall be disposed of at an asbestos-permitted landfill by Contractor, documented through waste manifests.

Containerizing and transport of wastes shall be in accordance with applicable regulations.

It is the Contractor’s responsibility to arrange for delivery and pickup of waste containers without impeding the flow of pedestrian and vehicular traffic. Containerizing and transport of wastes shall be in accordance with all applicable local, state, and federal regulations.

Profiling, transporting, and disposing of regulated materials other than asbestos (such as, lead, mercury-containing building components, Polychlorinated Biphenyls (PCB) light ballasts, etc.) are not covered in this asbestos project design.

If the abatement contractor feels that it is necessary (based on their work force, availability of equipment, etc.) to alter this project design, it must be amended by SMITH personnel and posted on site prior to the commencement of any abatement activities.

SPECIAL CONDITIONS

2.1 REGULATORY NOTIFICATION AND VARIANCES

The Contractor will make all mandatory notifications to Federal and State entities regulating the work as required by applicable rules, regulations, and standards. This includes, but is not limited, to the National Emission Standards for Hazardous Air Pollutants (NESHAP) notification and Asbestos Renovation/Abatement Notification Form provided to the Utah Department of Environmental Quality (Utah DEQ). At the time of this version of this Project Design, there are no variances associated with this project.

2.2 FACILITY OCCUPANCY STATUS

The Regulated Work Areas will remain unoccupied by the public for the duration of the asbestos abatement project.

2.3 SITE SECURITY

Access to the Regulated Work Areas shall be strictly regulated. Entry into a regulated work area is limited to asbestos-trained personnel and will be granted by the Contractor supervisor’s permission only. The perimeter of the Regulated Work Area shall be always monitored during abatement by a competent person employed by the Contractor. Only asbestos-licensed personnel employed by the Contractor, the Industrial Hygienist, or federal or state regulatory agency personnel shall be granted access to the regulated work areas.

2.4 FIELD CHANGES

Minor modifications to this Project Design may be made only by the Utah DAQ’s employees or a certified Project Designer from SMITH. Minor changes may include, but are not limited to, the relocation of decontamination facility and waste load-out, installation and/or repositioning of negative air machines, changing of view-port locations, addition of make-up air, etc.

PROJECT DESIGN SPECIFICS

3.1 STANDARDS AND PRIMACY OF RULES

The following standards will be adopted as they pertain to asbestos abatement. In any instance where adopted standards conflict with each other, the most stringent shall apply.

a) Utah Department of Environmental Quality’s Regulation Title R307 – Air Quality. Section 801 – Utah Asbestos Rule (Utah DAQ R307-801) (Utah DAQ 2021)

b) 29 Code of Federal Regulations (CFR) 1926.1101, the OSHA Construction Industry Asbestos Standard (OSHA 1995)

c) 40 CFR 61 Subpart M, EPA’s NESHAP Asbestos Standard (EPA 1990)

d) National Institute of Safety and Health(NIOSH)/Occupational Safety and Health Organization (OSHA)/U.S Coast Guard (USCG)/Environmental Protection Agency (EPA) - Occupational; Safety & Health Guidance Manual for Hazardous Waste Site Activities, Sections 8-20; “Heat Stress and Other Physiological Factors” (OSHA 1985)

e) All other applicable laws, rules, and regulations, including but not limited to those relating to:

1. Workers' Compensation Insurance

2. Liability Insurance

3. All contract specifications and bid documents

3.2 WORK INCLUDED

Work completion includes preparation of the work area, non-asbestos debris removal, removal of all listed ACM as well as associated overspray and affected contents (if applicable) and packaging for disposal, final cleaning of the work area, optional encapsulation.

3.3 SITE ACCESS

The Contractor will have access to the campground for the purpose of abatement, the duration detailed on the approved Utah DAQ permit application.

3.4 EQUIPMENT STAGING AREAS

The Contractor shall schedule the pickup and delivery of all equipment, supplies and waste-transportation vehicles (roll-off dumpsters, trucks and trailers, etc.). Equipment may be staged adjacent to the work area, but only for the duration of the project.

The decontamination area must be maintained in a clean and orderly condition throughout the duration of the project. The clean room shall be sized to accommodate the clothes and equipment of the work crew. Clean work clothes, clean disposable clothing, replacement filters for respirators, towels and other necessary items shall be provided in the clean room. No asbestos-contaminated items may enter this room. Workers shall use this area to suit up, store street clothes, and don respiratory protection on their way to the work area, and to dress in clean clothes after showering.

The specific locations of the waste load-out and clean room are detailed in the Regulated Work Area Diagrams shown in Figures 2, 3, and 4.

3.5 CONTAINMENT

The Project Design calls for an abatement of ACM in exceedance of the NESHAP (EPA 1990) limits (160 square feet of RACM), and thus requires an enclosure using the following work practices:

• All openings to the work area shall be covered with at least one layer of six mil or thicker polyethylene sheeting sealed with duct tape or an equivalent barrier to air flow.

• If RACM debris is present in the proposed work area prior to the start of a NESHAP-sized asbestos abatement project, the site shall be prepared by removing the debris using the work practice requirements of R307-801-13 (Utah DAQ 2021) and disposal requirements of R307-801-14 (Utah DAQ 2021).

• A decontamination unit constructed to the specifications of R307-801-13(4)(h) shall be attached to the Regulated Work Area prior to disturbing RACM or commencing a NESHAP-sized asbestos abatement project, and all persons shall enter and leave the negative pressure enclosure or work area only through the decontamination unit except in a life-threatening emergency situation. The decontamination unit and waste load-out has been designed on scaffolding in order for them to be directly adjacent to the Regulated Work Area.

• All persons subject to R307-801 shall shower before entering the clean-room of the decontamination unit when exiting the enclosure and shall follow all procedures required by 29 CFR 1926.1101(j)(1)(ii) (OSHA 2002).

Date:3/2/2022 Project #2020-1702

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FIGURE 2

Building 1 - RWA Diagram Ziion

National Park – South Campground

Smith Environmental and Engineering 250 Perry Lane

Dacono, CO 80514

Phone (720) 887-4928 Fax: (720) 887-4680

X:\PROJECTS_2009_format\On Call National Park Service -Reg 6, 7 and 8\Working Files\zion\Asbestos Project Design\Figures

FIGURE 3

Building 3 - RWA Diagram Ziion

National Park – South Campground

Smith Environmental and Engineering 250 Perry Lane

Dacono, CO 80514

X:\PROJECTS_2009_format\On Call National Park Service -Reg 6, 7 and 8\Working Files\zion\Asbestos Project Design\Figures

FIGURE 4

Building 4 - RWA Diagram Ziion

National Park – South Campground

Smith Environmental and Engineering 250 Perry Lane

Dacono, CO 80514

• No materials may be removed from the Regulated Work Area or brought into the enclosure through any opening other than a waste load-out or a decontamination unit.

The specific location of the enclosures is shown in Figures 2, 3, and 4.

3.6 NEGATIVE PRESSURE VENTILATION

The enclosure must include a negative pressure ventilation system constructed with the following specifications:

• Apply at least two layers of six mil or thicker polyethylene sheeting or its equivalent to the floor extending at least one foot up every wall and seal in place with duct tape or its equivalent; (a drop cloth must be put inside of each structure during abatement to catch any debris that may fall into the structure)

• Apply at least two layers of four mil or thicker polyethylene sheeting or its equivalent to the walls without locating seams in wall or floor corners;

• Seal all seams with duct tape or its equivalent;

• Maintain the integrity of all enclosure barriers.

Specifications for the Negative Air Pressure and Flow within the enclosure are as follows:

• Maintaining at least four air changes per hour in the enclosure;

• Routing the exhaust from HEPA filtered ventilation units to the outside of the regulated facility whenever possible;

• Maintaining a minimum of 0.02 column inches of water pressure differential relative to outside pressure; and

• Maintaining a monitoring device to measure the negative pressure in the enclosure.

The approximate volume of the containment 1 (Building 1 –east building) is <5,000 cubic feet. The approximate volume of the containment 2 (Building 3 – center building) is <5,000 cubic feet. The approximate volume of the containment 3 (Building 4 – west building) is <5,000 cubic feet.

Each containment will require a minimum of (1) one negative-air machines (NAM), rated at a minimum of 500 cubic feet per minute (CFM) under ideal conditions. However, the Contractor shall have a backup negative-air machine onsite, rated at a minimum of 1,000 CFM each, to achieve adequate air movement and ensure four air exchanges/hour, while maintaining a minimum -0.02 inches of water.

3.7 VIEW PORTS

View ports shall be installed in the enclosure or barriers where feasible, and view ports shall be:

• At least one foot square;

• Made of clear material that is impermeable to the passage of air, such as an acrylic sheet;

• Positioned so as to maximize the view of the inside of the enclosure from a position outside the enclosure; and

• Accessible to a person outside of the enclosure.

3.8 DECONTAMINATION

A three-stage decontamination unit, which includes: Stage 1 - dirty room (equipment room), Stage 2 - shower room, and Stage 3 - clean room, shall be constructed for abatement operations and located immediately adjacent to the Regulated Work Area. The decontamination unit shall be constructed and prepared in accordance with the following Utah DEQ R307-801-13 (Utah DAQ 2021) specifications.

The unit shall be attached to the enclosure or work area:

Stage 1 - Dirty Room

• The chamber that opens to the negative pressure Regulated Work Area, shall be no less than three feet wide by three feet long by six feet high, when feasible; and

• The dirty room shall be provided with an accessible waste bag at any time that asbestos abatement project is being performed.

Stage 2 - Shower Room

• The chamber between the clean and dirty rooms, shall have hot and cold or warm running water and be no less than three feet wide by three feet long by six feet high, when feasible;

Stage 3 - Clean Room

• The chamber that opens to the outside, shall be no less than three feet wide by three feet long by six feet high, when feasible;

• No asbestos-contaminated items may enter this room;

• The clean room shall be sized to accommodate the clothes and equipment of the work crew. Clean work clothes, clean disposable clothing, replacement filters for respirators, towels and other necessary items shall be provided in the clean room;

and

• Workers shall use this area to suit up, store street clothes, and don respiratory protection on their way to the work area, and to dress in clean clothes after showering.

Workers must enter and exit the Regulated Work Area through the decontamination unit.

The decontamination unit must be maintained in a clean and orderly condition throughout the duration of the project.

3.9 WASTE LOAD-OUT

Pursuant to Utah DEQ R307-801-13 (Utah DAQ 2021), separate waste load-out following the specifications below will be attached to the enclosure for removal of decontaminated waste containers and decontaminated or wrapped tools from the enclosure.

• The waste load-out shall consist of at least one chamber constructed of six mil or thicker polyethylene walls and six mil or thicker polyethylene flaps or the equivalent on the outside and inside entrances;

• The waste load-out chamber shall be at least three feet long, three feet high, and three feet wide; and

• The waste load-out supplies shall be sufficient to decontaminate bags, and shall include a water supply with a filtered drain, clean rags, disposable rags or wipes, and clean bags.

The specific locations of the waste loadouts are shown in Figures 2, 3, and 4.

Pursuant to Utah DEQ R307-801-13(Utah DAQ 2021), Negative air pressure and flow shall be established and maintained within the enclosure by:

• Maintaining at least four air changes per hour in the enclosure;

• Routing the exhaust from High Efficiency Particulate Air (HEPA) filtered ventilation units to the outside of the regulated facility whenever possible;

• Maintaining a minimum of 0.02 column inches of water pressure differential relative to outside pressure; and

• Maintaining a monitoring device to measure the negative pressure in the enclosure.

The specific locations of the Negative Air Machine(s) are shown in in Figures 2, 3, and 4.

3.10 WASTE REMOVAL

Disposal and handling of asbestos waste shall follow Utah Admin. Code R307-801-14 (Utah DAQ 2021) as follows:

(1) Owners and operators of regulated facilities shall containerize asbestos-containing waste material (ACWM) while adequately wet.

(2) ACWM containers shall be leak-tight and strong enough to hold contents securely and be labeled with an OSHA warning label found in 29 CFR 1926.1101(k)(8) (OSHA 2002).

(3) Containers shall be labeled with the waste generator's and contractor's names, addresses, and telephone numbers before they are removed from the asbestos renovation or abatement work area.

(4) Containerized RACM shall be disposed of at a landfill which complies with 40 CFR

61.150 (OSHA 2003).

(5) The waste shipment record shall include a list of items and the amount of ACWM being shipped. The waste generator originates and signs this document.

(6) Owners and operators of regulated facilities where an asbestos abatement or renovation project has been performed shall report in writing to the director if a copy of the waste shipment record, signed by the owner or operator of the designated waste disposal site, is not received by the waste generator within 45 working days from the date the waste was accepted by the initial transporter. Include in the report the following information:

(a) A copy of the waste shipment record for which a confirmation of delivery was not received; and

(b) A cover letter signed by the waste generator explaining the efforts taken to locate the asbestos waste shipment and the results of those efforts.

3.11 PERSONAL AIR MONITORING

The Contractor shall be responsible for conducting personnel air-monitoring as applicable in accordance with OSHA 29 CFR 1926.1101 Asbestos Construction Standard (OSHA 1994).

Results will be posted at the jobsite or made available to employees with 24-hours.

3.12 ELECTRICAL HAZARDS CONTROL

All electrical power utilized during the project will be on ground fault circuit interrupters (GFCI). All power sources must be located outside of the work area.

3.13 EMERGENCY EGRESS AND FIRE PROTECTION

3.13.1 Egress Points

1. The abatement contractor shall abide by the emergency egress rules and routes for the building. All contractor personnel shall receive emergency-procedure orientation specific to the building prior to initiation of abatement activities.

3.13.2 Fire Protection Plan

1. No items capable of initiating or sustaining combustion (lighters, matches, torches, etc.) will be allowed inside the containment.

2. The use of flammable liquids or gasses is not permitted.

3. Any electricity utilized must be on Ground Fault Circuit Interrupters (GFCI).

4. A minimum of two, 2A:10B:C rated fire extinguishers will be maintained on-site.

There must be available at least one 2A:10B:C rated fire extinguisher within a maximum-travel distance of 50 feet from any point in the work area.

5. Workers will be trained in the use of fire extinguishers, emergency-evacuation plans, fire safety, and emergency reporting procedures prior to beginning work.

6. All emergency exits will be labeled as such with tools available for breaching poly sheeting and keys will remain in door locks where necessary.

7. The Contractor must implement a written emergency action and fire prevention plan in accordance with OSHA 29 CFR 1910.38 – Employee Emergency Plans and Fire Prevention Plans.

8. Work areas shall have or be fitted with temporary emergency egress lighting.

3.14 RESPIRATORY PROTECTION

The Contractor shall provide its personnel with the appropriate NIOSH approved HEPA filters and respirators during all preclean, removal and waste load-out procedures.

Contractor shall provide proof of a medical physical to wear respiratory protection and current respirator fit-testing documentation for all employees.

3.15 DOCUMENT SUBMITTAL

Following de-construction of the Regulated Work Area and de-mobilization, the Contractor will provide the following submittals to the building owner:

• Copies of all regulatory inspections, orders, citations, or other correspondence with Utah DAQ, OSHA, and the EPA related to this project.

• Copies of all asbestos waste shipment manifests.

• Copies of all air and/or bulk sampling results related to the project.

• Copies of all daily logs and containment sign-in sheet

REFERENCES

EPA. 1990. National Emission Standards for Hazardous Air Pollutants (NESHAP).

Washington D.C.

OSHA. 1985. Occupational; Safety & Health Guidance Manual for Hazardous Waste Site Activities. Washington D.C.

OSHA. 1994. Occupation Safety and Health Administration, Safety and Health Regulations for Construction. 29 CFR 1926.62. Washington, DC.

OSHA. 2003. Standard for Waste Disposal for Manufacturing, Fabricating, Demolition, Renovation, and Spraying Operations. 40 CFR 61.150. Washington D.C.

OSHA. 2011. Occupational Safety and Health Administration. Protection of Environment – Asbestos.40 CFR, Part 763. Washington, DC.

OSHA 2012. Safety and Health Regulations for Construction – Asbestos. CFR 1926.1101.

Washington D.C.

SMITH. 2022. Asbestos, Lead-Based Paint, and other Regulated Building Materials Survey.

June 22, 2022. Dacono, CO.

Utah DAQ. 2021.Utah Asbestos Rule 307-801. Utah Department of Environmental Quality – Air Quality. Salt Lake City, UT.

APPENDIX A

ASBESTOS, LEAD-BASED PAINT, AND OTHER REGULATED BUILDING MATERIALS

SURVEY

ASBESTOS, LBP, AND TCLP SURVEY

FIVE RESTROOMS

ZION NATIONAL PARK – SOUTH CAMPGROUND

SPRINGDALE, UT 84767

Prepared for National Park Service by Smith Environmental & Engineering

June 22, 2022

W W W . S M I T H D E L I V E R S . C O M 250 Perry Lane Dacono, CO 80514 phone: 720.887.4928 fax: 720.887.4680

Delivering Sustainable Environmental Solutions

ASBESTOS SURVEY, LBP, AND TCLP SURVEY

FIVE RESTROOMS

SPRINGDALE, UT 84767

Prepared for:

National Park Service 12795 W. Alameda Parkway

Lakewood, CO 80228

Prepared by:

250 Perry Lane

Dacono, CO 80514

SMITH Project No. 2020-1702

June 22, 2022

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 INTRODUCTION

1.1 REGULATION REVIEW

1.1.1 Lead-Based Paint (LBP)

1.2 SURVEY AREA DESCRIPTION

2.0 SURVEY METHODOLOGY

2.1 SUSPECT ACM SAMPLING AND ANALYSIS

2.1.1 Sampling Methodology

2.1.2 ACM Laboratory Analysis

2.2 SUSPECT LBP SAMPLING AND ANALYSIS

2.2.1 LBP Laboratory Analysis

3.0 LABORATORY RESULTS

3.1 ACM TEST RESULTS

3.2 LBP TEST RESULTS

4.0 CONCLUSIONS AND RECOMMENDATIONS

HAZARDOUS WASTE DETERMINATION

5.0 REFERENCES

6.0 LIMITATIONS

LIST OF FIGURES

FIGURE 1 SITE LOCATION

FIGURE 2 SAMPLE LOCATION SITE PLANS

LIST OF TABLES

TABLE 1 SUSPECT ACM RESULTS

TABLE 2 SUSPECT ACM PHYSICAL ASSESSMENT

TABLE 3 SUSPECT LBP SAMPLING RESULTS

TABLE 4 TCLP SAMPLING RESULTS

LIST OF APPENDICES

APPENDIX A BUILDING INSPECTOR CERTIFICATION

APPENDIX B PHOTOGRAPHS OF STRUCTURE AND BULK ACM SAMPLES

APPENDIX C ASBESTOS LABORATORY ANALYTICAL REPORT

APPENDIX D LEAD LABORATORY ANALYTICAL REPORT

LIST OF ACRONYMS

ACBM – Asbestos-Containing Building Material ACM – Asbestos-Containing Material AHERA – Asbestos Hazard Emergency Response Act AMS – Air Monitoring Specialist CABI – Certified Asbestos Building Inspector CAQCC – Colorado Air Quality Control Commission CERCLIS - Comprehensive Environmental Response, Compensation, and Liability Information System CFR – Code of Federal Regulations DAQ – Division of Air Quality EPA – Environmental Protection Agency FID – Flame Ionization Detector HUD – Housing and Urban Development LBP – Lead-Based Paint OSHA – Occupational Safety and Health NIST – National Institute of Standards and Technology NVLAP - National Voluntary Lab Accreditation Program PLM – Polarized Light Microscopy PPM – Parts Per Million QA/QC – Quality Assurance/Quality Control RCRA- Resource Conservation and Recovery Act SMITH – Smith Environmental and Engineering TCLP – Toxicity Characteristic Leaching Procedure TSCA - Toxic Substances Control Act TSI – Thermal System Insulation

EXECUTIVE SUMMARY

On behalf of National Park Service (NPS), SMITH conducted a survey for asbestos-containing material (ACM) and lead-based paint (LBP) on five buildings within the South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767 (Figure 1).

The survey was conducted on October 21, 2021 and May 26, 2022, to support planned demolition and renovations. The survey included:

• Collection and analysis of 40 suspect ACM samples

• Collection and analysis of 4 suspect LBP samples

• Collection and analysis of 1 TCLP sample

SMITH also visually inspected the Subject Buildings for suspected hazardous materials or regulated building materials (RBMs).

Asbestos-Containing Materials

Materials containing more than 1% asbestos are federally regulated in accordance with the Asbestos Hazard Emergency Response Act (AHERA). In total, 40 samples of suspect ACM were collected from and submitted for laboratory analysis of asbestos content. Laboratory analysis detected >1% asbestos in the following materials:

• Roof material (Tan/Grey roof shingles) on three Mission 66 Restrooms

Polarized Light Microscopy (PLM) analysis determined the shingles are 10% Chrysotile.

The cementitious roof shingles are a Category II non-friable ACBM with potential to become friable during demolition. As such, they are a Regulated Asbestos Containing Material (RACM) and need to be removed prior to demolition or renovation activities involving the roof.

The men’s bathroom within the historical restroom (Building 2) was locked during time of inspection. Demolition and/or renovation activities for this area must be postponed until this room is inspected.

During the June 2022 Inspection the men’s bathroom was accessible and all materials found within the room were addressed during the inspection of the Historical Girls Bathroom during the first visit and inspection.

Lead-Based Paint

Paint containing >0.5% lead by weight is regulated as LBP. Four samples of suspect LBP were collected for laboratory analysis. According to laboratory results, one of the sampled paints was determined to be LBP (S – WP). The white paint sample collected inside the storage building from the ceiling was determined to contain a lead concentration of 18.8%.

The second sample, a grey paint found inside the Mission 66 Restroom bathroom wall (4- GP) was determined to contain lead at a concentration less than 0.5%. Demolition debris containing LBP needs to be characterized as hazardous or non-hazardous prior to disposal.

S-WP painted areas were analyzed following Toxicity Characterization Leaching Procedure methods. S-WP was determined to be hazardous and should be disposed of accordingly.

Other Observations:

Light fixtures and ballasts throughout the building are considered universal waste.

1.0 INTRODUCTION

SMITH performed a survey of ACM and LBP on five buildings within the Zion National Park South Campground located at 1 Zion Park Blvd, State Route 9, Springdale, UT 84767 (Figure 1) on October 21, 2021. The survey was performed to support planned demolition activities to the buildings. The survey was performed by Itoro Akpakpan, a Certified Asbestos Building Inspector (CABI). A copy of his CABI certification is attached in Appendix A. The inspection included the inside and exterior surfaces of the buildings.

1.1 REGULATION REVIEW

ACM and LBP are regulated on a state and federal level by the US Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA).

Relevant regulations include:

• Utah Asbestos Rule (Utah DAQ 2020)

• Asbestos Hazard Emergency Response Act (AHERA, EPA 1987)

• Asbestos School Hazard Abatement Reauthorization Act (ASHARA, EPA 1994)

• National Emission Standards for Hazardous Air Pollutants (NESHAP, EPA 2004)

• Asbestos Standard for General Industry (OSHA 2012a)

• Asbestos Standard for the Construction Industry (OSHA 2012b)

• Respiratory Protection Standard (OSHA 2011)

EPA established AHERA in 1986 to identify, evaluate, and control ACM in private and public elementary and secondary schools in the U.S. and its territories. ASHARA extended most of the same requirements to public and commercial buildings. The application, removal, and disposal of ACM is regulated under NESHAP. OSHA regulates worker exposure to asbestos.

State and federal regulation require completion of an asbestos inspection by a CABI prior to disturbance of any material suspected to contain asbestos. The survey identifies ACM that is friable or may become friable during building demolition or renovation activities. EPA identifies three categories of ACM used in buildings:

1. Surfacing materials- surface material sprayed or troweled on surfaces (walls, ceilings, structural members) for acoustical, decorative, or fireproofing purposes

2. Thermal system insulation (TSI) - insulation used to inhibit heat transfer or prevent condensation of pipes, boilers, ducts, or other components of a hot/cold water system, and heating, ventilation, and air condition systems (HVAC)

3. Miscellaneous materials other largely nonfriable products and materials such as floor tile, ceiling tile, roofing felt, concrete pipe, outdoor siding, and fabrics

The Utah DAQ and EPA define ACM as any material containing more than 1% asbestos or any material assumed to contain asbestos. The materials can be either friable or non-friable. Friable ACM is a material containing more than 1% asbestos, which when dry, can be pulverized or reduced to a powder by hand pressure. EPA and Utah DAQ provide two categories of non-friable ACM.

• Category 1 Non-friable ACM- non-friable packing materials, gaskets, resilient floor covering and asphalt roofing products containing more than 1% asbestos

• Category II Non-friable ACM- remaining non-friable materials containing more than 1% asbestos

Regulated asbestos-containing materials (RACMs) include: friable ACM; Category I non-friable ACM that has become friable; Category I non-friable ACM that will be or has been subjected to sanding, grinding, cutting, or abrading; and Category II non-friable ACM that has a high probability of becoming friable due to impact, cutting, grinding, etc. during demolition or renovation. RACMs potentially disturbed by demolition or renovation require abatement.

Certain Category 1 and Category II non-friable ACM can remain in-place during normal building demolition (non-explosive, etc.) and can be disposed as demolition debris, provided these materials remain non-friable during demolition activities. Although category I non-friable ACM (resilient floor covering, asphalt roofing products, window glazing, etc.) are allowed to remain in place during demolition, it is often difficult to demonstrate that the materials will not be rendered friable during demolition activities.

Many considerations go into this determination such as age, location, condition, and demolition process. As a result, recommendations for removal of these materials as a RACM may be made.

The OSHA asbestos standard for the construction industry (29 CFR 1926.1101) regulates worker exposure to asbestos during demolition, salvaging, abatement, construction or repairs, spill clean-up, and transportation. Due to the potential health risk, the OSHA standard applies to all RACM, in addition to materials containing < 1% asbestos, except asbestos-containing roof coatings, cements, and mastics.

1.1.1 Lead-Based Paint (LBP)

Lead is regulated under numerous state and federal programs. Rigorous regulations apply to the inspection and abatement of LBP in homes or child-occupied facilities. The Resource Conservation and Recovery Act (RCRA) and OSHA regulations govern the presence of lead during demolition or renovation of commercial, industrial, or facilities that are not occupied by children.

The OSHA lead standard for the construction industry (29 CFR 1926.62) regulates worker exposure to lead during demolition, salvaging, abatement, construction, installations or repairs, spill clean-up, transportation, and maintenance activities. The OSHA standard applies to all materials containing lead, and establishes maximum limits of lead exposure, including a permissible exposure limit (PEL) and action level (AL). The PEL sets the maximum worker exposure to lead at 50 micrograms per cubic meter of air (50μg/m3) averaged over an eight-hour period. The AL, regardless of respirator use, is an airborne concentration of 30μg/m3, averaged over an eight-hour period. The AL is the level at which an employer must begin specific compliance activities outlined in the standard.

If any painted materials are scheduled for disposal, a waste characterization must be performed to determine the appropriate disposal requirements as regulated by RCRA.

Waste characterization includes sample collection and analysis using the Toxicity Characteristic Leaching Procedure (TCLP) method as outlined by the EPA (1992). If the TCLP results exceed 5 milligrams/liter, the materials must be handled, transported, and disposed as a hazardous waste in accordance with local, state, and federal regulations.

1.2 SURVEY AREA DESCRIPTION

The Survey Area included these five buildings located on the South Campground:

• One historic restroom, known as Building 2, is in the central area of the campground. Building 2 consists of a men’s bathroom (inaccessible during inspection), a women’s bathroom, and a maintenance closet. Building 2 has an approximate area of 350 sq ft. The men’s bathroom door was locked during the time of the inspection.

• Three Mission 66 Restrooms, known as Bathroom 1, Bathroom 3, and Bathroom 4.

These bathrooms were built in the early 1960s. During the survey it was observed that these bathrooms have similar floor layouts and identical building materials.

Given the buildings history and observations, the Mission 66 Restrooms are considered one functional space with identical homogenous areas. Each building consists of a men’s bathroom on the north side, a storage and utility room in the center of the building, and a women’s bathroom on the south side. Building I was observed to have an additional bathroom, a handicap accessible bathroom, located between the men’s bathroom and storage room. This additional bathroom observed during inspection consists of the same building materials observed from the other rooms of Bathroom 1 and in the other Mission 66 Restrooms. Building 1 has an approximate area of 500 sq ft, and Buildings 3 and 4 have an approximate area of 400 sq ft. Buildings 1 is located to the north and Buildings 3 and 4 are located to the south within the South Campground.

• One storage building is located in the east side of the campground. This building is used mainly for storage of tools and equipment required for landscaping activities within the campground. The storage building has an approximate area of 400 sq ft.

At the time of SMITH’s inspection, the Subject Buildings were off-limits to park visitors.

Building utilities remained online (electricity & plumbing) during the inspections, so precautions were taken to limit destruction during sampling to avoid these electrical systems. The men’s bathroom within the historical restroom (Building 2) was locked during time of inspection. Planned demolition and/or renovation activities for this area must be postponed until this room is inspected. SMITH inspected materials inside and on the Subject Buildings. SMITH did not inspect the subsurface or parts of the property beyond the Subject Buildings.

11/18/2021 Smith Environmental and Engineering Zion National Park South Campground

X:\PROJECTS_2009_format\On Call National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 1 Dacono, CO 80514

Phone (720) 887-4928 Site Location Map Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

2.0 SURVEY METHODOLOGY

On October 21, 2021, SMITH completed an ACM survey of the subject buildings, which included survey of suspect materials to evaluate the presence/absence of ACM and LBP.

SMITH also visually inspected the buildings for RBMs and other materials requiring special handling. Sampling procedures and analysis methods are discussed below.

2.1 SUSPECT ACM SAMPLING AND ANALYSIS

Completion of an ACM inspection consists of the following three steps.

• Identifying the homogeneous area and functional spaces within the building or survey area

• Collection and analysis of representative ACM and LBP samples

• Physical assessment and classification of the material

The initial step in the survey is to identify the areas in the building where the suspect ACM (surfacing material, thermal system insulation, or miscellaneous material) is uniform in color and texture (i.e. homogeneous area). Functional spaces are also identified, which can include a room, group of rooms, or homogeneous area. A functional space includes rooms such as classroom(s), cafeteria, hallways, etc. and spaces such as crawl spaces and spaces between a drop ceiling and roof deck.

The suspect material potentially containing asbestos is the same in all regards (color, texture) throughout a homogeneous area. The number of samples needed to represent a suspect ACM in a homogeneous area depends on the material type (surfacing material, thermal system insulation, miscellaneous material) and the quantity of the homogenous material.

2.1.1 Sampling Methodology

Sample locations were selected by dividing sample areas into 9 equal sub-areas in an equally divided grid. These sub-areas are approximated by eye. Sample locations were selected for each sub-area using the random number chart (Table 2) in the EPA’s Simplified Sampling Scheme Guidance Document (EPA 1985). Site-specific circumstances frequently require professional judgment in choosing the sampling location within the randomly selected subarea. Circumstances leading to modification of the random sampling methodology can include, but are not limited to:

• Access limitations

• Safety considerations

• Reduction of building damage or disturbance of occupants

• Areas of existing damage or noticeable repair

• Amount of miscellaneous material does not permit multiple samples

2.1.2 ACM Laboratory Analysis

Bulk samples of suspect ACM were submitted to Reservoirs Environmental, Inc. (REI), a third party independent laboratory. REI is accredited through the National Institute of Standards and Technology (NIST) and participates in the NIST National Voluntary Lab Accreditation Program (NVLAP), Lab Code 101896-0 as required by the EPA. ACM bulk samples were analyzed by Polarized Light Microscopy (PLM) EPA Method 600/R-93/116, in compliance with guidelines established by the EPA (40 CFR Part 763, Subpart E, Appendix A). Asbestos concentrations were visually estimated and/or point counted and reported in percent for each layer of the sample.

2.2 SUSPECT LBP SAMPLING AND ANALYSIS

Suspect LBP samples were collected using a similar process to that described in Section

2.1.1. Homogeneous areas of paint coatings were identified based on the painted material type (drywall, railing, foundation, etc.) and color.

2.2.1 LBP Laboratory Analysis

LBP bulk samples were analyzed by EPA Method SW 846-3050A utilizing a Flame Atomic Absorption technique (Flame AA 7420) with compliance guidelines established by the EPA (1989).

3.0 LABORATORY RESULTS

The survey of the building included collection and analysis of 40 samples of suspect ACM and 4 samples of suspect LBP. Photographs of the site are provided in Appendix B and the laboratory reports are included in Appendices C and D.

3.1 ACM TEST RESULTS

Homogeneous areas were defined by uniform ACM materials. In total, 40 bulk samples were collected from 10 homogeneous areas and submitted for laboratory analysis of asbestos content. Sample results are summarized in Table 1.

TABLE 1

SUSPECT ACM RESULTS

SAMPLE

MATERIAL

DESCRIPTION /

HOMOGENOUS

AREA

TYPE FUNCTIONAL

SPACE MINERAL PERCENT

ACM

4-WC-1 Window Caulking Misc Mission 66 ND 4-WC-2 Window Caulking Misc Mission 66 ND

4-RF-1 Black/Brown Roof Felt Misc Mission 66 ND

4-RF-2 Black/Brown Roof Felt Misc Mission 66 ND

4-RS-1 Tan/Grey Roof Shingle Misc Mission 66 Chrysotile 10

4-RS-2 Tan/Grey Roof Shingle Misc Mission 66 Chrysotile 10

4-YWT-1 Yellow Wall Tile in bathroom Misc Mission 66 ND

4-YWT-2 Yellow Wall Tile in bathroom Misc Mission 66 ND

4-WTG-1 Gray Grout in bathroom Misc Mission 66 ND

4-WTG-2 Gray Grout in bathroom Misc Mission 66 ND

4-BFT-1 Brown Floor Tile in bathroom Misc Mission 66 ND

4-BFT-2 Brown Floor Tile in bathroom Misc Mission 66 ND

4-EM-1 Exterior Masonry SURF Mission 66 ND 4-EM-2 Exterior Masonry SURF Mission 66 ND 4-EM-3 Exterior Masonry SURF Mission 66 ND

4-CP-1 Ceiling Plaster in utility closet SURF Mission 66 ND

4-CP-2 Ceiling Plaster in utility closet SURF Mission 66 ND

4-CP-3 Ceiling Plaster in utility closet SURF Mission 66 ND

SAMPLE

MATERIAL

DESCRIPTION /

HOMOGENOUS

AREA

TYPE FUNCTIONAL

SPACE MINERAL PERCENT

ACM

4-UI-1

Utility Insulation in crawl space

TSI Mission 66 ND

4-UI-2

Utility Insulation in crawl space

TSI Mission 66 ND

4-UI-3

Utility Insulation in crawl space

TSI Mission 66 ND

1-WU-1

Wall Underlayment in bathroom

Misc Mission 66 ND

1-WU-2

Wall Underlayment in bathroom

Misc Mission 66 ND

1-WB-1 Wallboard in bathroom Misc Mission 66 ND

1-WB-2 Wallboard in bathroom Misc Mission 66 ND

1-WWT-1 White Wall Tile in bathroom Misc Mission 66 ND

1-WWT-2 White Wall Tile in bathroom Misc Mission 66 ND

2-TWT-1 Tan Wall Tile in bathroom Misc Historic ND

2-TWT-2 Tan Wall Tile in bathroom Misc Historic ND

2-TA-1 Tile Adhesive in bathroom Misc Historic ND

2-TA-2 Tile Adhesive in bathroom Misc Historic ND

2-WG-1 Wall Grout in bathroom Misc Historic ND

2-WG-2 Wall Grout in bathroom Misc Historic ND

2-BWT-1 Brown Wall Tile in bathroom Misc Historic ND

2-BWT-2 Brown Wall Tile in bathroom Misc Historic ND

2-TP-1 Grey Tile Putty in bathroom Misc Historic ND

2-TP-2 Grey Tile Putty in bathroom Misc Historic ND

2-DS-1 Brown Door Surfacing – Misc Historic ND

SAMPLE

MATERIAL

DESCRIPTION /

HOMOGENOUS

AREA

TYPE FUNCTIONAL

SPACE MINERAL PERCENT

ACM

Women’s bathroom

2-DS-2

Brown Door Surfacing – Women’s bathroom

Misc Historic ND

S-IM-1

Insulating Material around piping

TSI Storage ND

S-IM-2

Insulating Material around piping

TSI Storage ND

S-IM-3

Insulating Material around piping

TSI Storage ND

Notes: ND- Not Detected SURF- Surfacing Material TSI- Thermal System Insulation Misc.- Miscellaneous Material TR-Trace

According to analytical results, the Tan/Grey roof shingles of the Mission 66 Restrooms contain 10% asbestos (Chrysotile). No other ACBM was detected. Homogenous area locations, quantities, and condition assessments for friable ACM, are summarized in Table

2. Areas where suspect LBP & ACM samples were taken are attached in Figures 2a, 2b, 2c and 2d.

National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 2: Sample Location Map Dacono, CO 80514

Phone (720) 887-4928 A: Mission 66 Restroom (B3,B4) Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 2: Sample Location Map Dacono, CO 80514

Phone (720) 887-4928 B: Mission 66 Restroom (B1) Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 2: Sample Location Map Dacono, CO 80514

Phone (720) 887-4928 C: Historic Restroom (B2) Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

National Park Service -Reg 6, 7 and 8\Working Files\zion

250 Perry Lane Figure 2: Sample Location Map Dacono, CO 80514

Phone (720) 887-4928 D: Storage Building (S) Fax: (720) 887-4680

CTGD-1*

CTGD-2*

CT2-2*

*FTW-2

*FTW-1

FTR-2*

FTR-1*

OCT-3*

*CT1-2

CT3-1*

CT3-2*

TABLE 2

SUSPECT ACM PHYSICAL ASSESSMENT

Condition Assessment for Friable ACM

SAMPLE

MATERIAL

DESCRIPTION /

HOMOGENOUS

AREA

TYPE FUNCTIONAL

SPACE MINERAL PERCENT

ACM (%)

FRIABLE

OR NON

FRIABLE

APPROX.

AMOUNT

(Sq ft)

CONDITION

POTENTIAL

FOR

DISTURBANCE

AHERA

CATEGORY

REASON FOR

DAMAGE

4-WC-1 Window Caulking Misc Mission 66 ND 4-WC-2 Window Caulking Misc Mission 66

4-RF-1 Black/Brown Roof Felt Misc Mission 66 ND

4-RF-2 Black/Brown Roof Felt Misc Mission 66 ND

4-RS-1 Tan/Grey Roof Shingle Misc Mission 66 Chrysotile 10 NF 500 (per building) Good High 5 NA

4-RS-2 Tan/Grey Roof Shingle Misc Mission 66 Chrysotile 10 NF 500 (per building) Good High 5 NA

4-YWT-1 Yellow Wall Tile in bathroom Misc Mission 66 ND

4-YWT-2 Yellow Wall Tile in bathroom Misc Mission 66 ND

4-WTG-1

Gray Grout in bathroom Misc Mission 66 ND

4-WTG-2 Gray Grout in

4-BFT-1 Brown Floor Tile in bathroom SURF Mission 66 ND

4-BFT-2 Brown Floor Tile in bathroom SURF Mission 66 ND

4-EM-1 Exterior Masonry SURF Mission 66 ND 4-EM-2 Exterior Masonry SURF Mission 66 ND 4-EM-3 Exterior Masonry SURF Mission 66 ND

4-CP-1 Ceiling Plaster in utility closet SURF Mission 66 ND

4-CP-2 Ceiling Plaster in utility closet TSI Mission 66 ND

4-CP-3 Ceiling Plaster in utility closet TSI Mission 66 ND

4-UI-1

Utility Insulation in crawl space TSI Mission 66 ND

4-UI-2

Utility space Misc Mission 66 ND

4-UI-3

Utility space Misc Mission 66 ND

SAMPLE

MATERIAL

DESCRIPTION /

HOMOGENOUS

AREA

TYPE FUNCTIONAL

SPACE MINERAL PERCENT

ACM (%)

FRIABLE

OR NON

FRIABLE

APPROX.

AMOUNT

(Sq ft)

CONDITION

POTENTIAL

FOR

DISTURBANCE

AHERA

CATEGORY

REASON FOR

DAMAGE

1-WU-1

Wall Underlayment in

1-WU-2

Wall Underlayment in

1-WB-1 Wallboard in bathroom Misc Historic ND

1-WB-2 Wallboard in

1-WWT-1 White Wall Tile in

1-WWT-2 White Wall Tile in

2-TWT-1 Tan Wall…