B08_Attachment_1_-_YOSE_Abatement_Requirements_Report_Rev_10-31-23_Final.pdf

HAZARDOUS MATERIALS ABATEMENT

REQUIREMENTS REPORT

Yosemite Valley Maintenance Building 527

(The Fort) 9000 Lost Arrow Drive

Yosemite Valley, California

Prepared for

The National Park Service

Yosemite National Park

Prepared by:

Soar Environmental Consulting, Inc.

1322 E. Shaw Avenue, Suite 400

Fresno, California 93710 September 6, 2023

Revised October 31, 2023

Page Left Blank

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Project Objective

1.2 Project Background Information

1.3 Facility Description

2.0 HAZARDOUS MATERIALS FINDINGS

2.1 Asbestos Containing Materials

2.1.1 ACM Present

2.1.2 ACM Replaced

2.2 DUST WIPE SAMPLE RESULTS

2.3 Hazardous Fluids

2.3.1 Diesel Exhaust Fluid

2.3.2 Leaking Oil

3.0 REMEDIATION REQUIREMENTS

3.1 Asbestos Containing Materials Remediation

3.2 Dust Cleaning

Roads & Trails Offices Roads & Trails Breakroom Roads & Trails Garage Road & Trails Restroom Road & Trails Parts Room:

Law Enforcement Offices Law Enforcement Jail Law Enforcement Restroom Building & Grounds Offices Building & Grounds Garage Building & Grounds Breakroom:

Building & Grounds Restroom Building & Grounds Breakroom Boiler Room:

Fire Department Offices Fire Department Garage Mezzanine Attic Attic Restroom

3.2.1 Ductwork Cleaning

3.3 Hazardous Fluid Remediation

3.3.1 Diesel Exhaust Fluid

3.3.2 Leaking Oil

4.0 FEDERAL AND STATE REGULATIONS

4.1 Asbestos Remediation

4.1.1 Federal Regulations

4.1.2 California Regulations

4.2 Dust Cleaning Regulations

4.2.1 Federal Regulations

4.2.2 California Regulations

4.3 Hazardous Fluids Regulations

4.3.1 Federal Regulations

4.3.2 California Regulations

4.4 Waste Disposal Regulations

5.0 CONTRACTOR REQUIREMENTS

5.1 Third Party Abatement Oversight

5.2 Personnel Training and Experience

5.3 Contractor’s Use of the Premises

5.4 Special Construction Requirements

5.5 Submittals and Documentation

5.6 Certifications

5.7 Quality Assurance

5.8 Personal Protective Equipment, Abatement Equipment, and Products

5.9 Work Area Preparation

5.10 Re-Establishment of Work Area

5.11 Air Monitoring

5.12 Safety

APPENDIX A

APPENDIX B 87

TABLES

Table 1 – Materials Positive for Asbestos Table 2 – Asbestos Dust Wipes Table 3 – The Fort Exposed Asbestos Insulated Water Pipes

1.0 INTRODUCTION

1.1 Project Objective

Soar Environmental Consulting (Soar Environmental) was retained by Hennebery Eddy Architects (Client) on behalf of the National Park Service (NPS) to prepare this Hazardous Materials Abatement Requirements Report (Report). This Report documents the existing hazardous materials and conditions onsite and provides recommendations for remediation tasks to allow the NPS to safely resume operations, in accordance with federal, state, and local regulations, at the Yosemite Valley Maintenance Building 527 (“The Fort”) as soon as possible.

1.2 Project Background Information

Completed in 1935, The Fort was originally constructed as a roads and large vehicle maintenance facility, fire station, trail maintenance and equipment shop, custodial and utility shop, and parts storage. Through the years, the building has been modified to accommodate additional uses for additional departments. Most of the ad-hoc modifications were made without professional consultation or a building permit review process. No plans were provided to indicate that building codes were considered during modifications. Due to the age and condition of The Fort, many of the building’s systems are out of date and do not comply with modern building codes.

On October 20, 2021, The Fort was evacuated at the recommendation of a team of safety professionals due to the presence of asbestos containing materials (ACM). The ACM is associated with pipe insulation (thermal systems insulation), which may contain friable, hazardous, asbestos. These materials are located throughout the building and are in varying degrees of damage and decay. The closure is required due to asbestos hazards and other identified safety and health issues. Dust samples collected from locations throughout The Fort indicate the presence of asbestos structures in dust.

The Fort closure has negatively impacted response times across departments due to inadequate vehicle and equipment support. As such, it is imperative that departments return operations to The Fort as soon as possible. The NPS will determine whether to rehabilitate The Fort. As a means for streamlining a safe return to The Fort, the NPS elects to address remediation work in a phased approach. This report will focus on the remediation work necessary for departments to return to previously occupied spaces, without making building renovations (Phase I). In the future, the NPS will determine whether to rehabilitate The Fort or to demolish and rebuild the facility and will address any additional concealed hazardous materials conditions as a Phase II task order and scope of work.

1.3 Facility Description

The Fort is constructed of reinforced concrete cast-in-place walls, columns, and decks with a steel frame.

The original roof with asbestos containing materials (ACM) was replaced with modern building materials.

Interior walls consist of cast-in-place concrete, unreinforced terracotta block, unreinforced brick, and wood and sash partitions.

BUILDING & SYSTEMS DESCRIPTION

Structure Reinforced Concrete and Steel Frame painted with lead-based paint

Exterior Cladding Cast in place Concrete

HVAC Original Internal Ducting/Self-Contained Wall A/C Units

Roof Built-up roofing, Shingles (Replaced)

Flooring Tile, Concrete, Wood, Carpet

Rain Gutters Steel, painted with lead-based paint (Partially replaced)

Interior Walls Wood and sash partitions, unreinforced terra cotta block, unreinforced brick, and cast in place Concrete

Ceilings Drywall, Wood, Drop Ceilings, and Cast in place Concrete

TABLE 1.0 - MATERIALS POSITIVE FOR ASBESTOS

The following table lists materials either known, or assumed to contain, asbestos at >1%.

Sample Location Material % Of

ACM

Friable Sq. Ft.

Main Roof

01 Roof Transite Shingle 15% No 39,000’ (Replaced)

02 Roof Tar Paper 30% No 39,000’ (Replaced)

05 Roof Roof Mastic 10% No 100’ (Replaced)

Electrical Room

01 Roof Asphalt Rolled Roofing Material

30% No 400’ (Replaced)

02 Roof Tar Paper 30% No 400’ (Replaced)

Miscellaneous Areas Throughout the Building

Not Sample d

Throughout Water Pipe Insulation Assumed >1%

Yes 800 ln ft 2” – 8” *Phase I

62 Boiler Room 13 Electrical Wire Insulation 30% No TBD

*Phase I recommendations are to remove all exposed asbestos water pipe insulation (~711 ln ft).

2.0 HAZARDOUS MATERIALS FINDINGS

2.1 Asbestos Containing Materials

2.1.1 ACM Present

Asbestos insulated wiring located on the boiler in the B&G room 13 is positive for asbestos at 30% (The Wire Insulation Materials are in conduits and not possible to quantify without disturbing asbestos insulation). This material is considered a non-hazardous, non-friable, ACM. It is required that a licensed asbestos abatement contractor remove these materials. If the material is to be removed by mechanical means, then the material will be classified as friable asbestos containing material. The asbestos-insulated wiring is contained within conduit and portions are embedded in structural walls. For these reasons, the undisturbed wiring may be left in place without posing a health risk during future operations.

The Water Pipe Insulation located throughout the building is assumed positive for asbestos at >1% and is marked “Asbestos Containing Material”. Due to the condition and age of the material, the exposed ACM pipe insulation throughout the building must be removed prior to reopening The Fort. This material is considered friable, hazardous, ACM. A licensed asbestos abatement contractor must be retained to remove asbestos in accordance with local, state, and/or federal regulations.

Photographs and captions of asbestos insulated water pipes are presented in Appendix A, Photographs.

Photograph numbers are populated in Appendix B, Maps, to provide photo locations.

By OSHA regulation, air testing is required to be performed to determine asbestos exposure to the breathing zone of working personnel in the building. The Permissible Exposure Limit (PEL) set by OHSA is

0.1 fibers/cc over an 8hr Time Weighted Average (TWA). We recommend that area air monitoring and or personal air monitoring be performed during all Phase I interior asbestos remediation work to determine if the PEL is being exceeded. If the PEL is being exceeded, work must be stopped until the PEL is below action levels.

2.1.2 ACM Replaced

The Transite Shingles on the main roof tested positive for asbestos at 15%. The Asphalt Rolled Roofing Material on the Electrical Room roof tested positive for asbestos at 30%. The Tar Paper under the Transite shingles on the main roof and under the asphalt rolled roofing material on the Electrical Room roof, tested positive for asbestos at 30%. The Roof Mastic on the roof jacks, vents, and the flashing at the wall/roof junctions tested positive for asbestos at 10%.

In June 2023, the NPS removed roof shingles, tar paper, and mastic and replaced with modern, non-asbestos roofing materials.

2.2 DUST WIPE SAMPLE RESULTS

After the closure of The Fort, the NPS retained Leon Environmental Services to collect indoor dust samples and submit them to an accredited analytical laboratory for analysis of asbestos structures. Numerous dust sample results indicate the presence of asbestos structures throughout The Fort.

Asbestos structures found in dust are a concern for the NPS.

2.3 Hazardous Fluids

2.3.1 Diesel Exhaust Fluid

Diesel exhaust fluid (DEF) is a liquid used to reduce the amount of air pollution created by operating a diesel engine. DEF is non-toxic and safe to handle but may be corrosive on metals like aluminum. There is a partially full, 330 gallon tote leaking DEF in the garage area. The spilled DEF must be disposed of as waste and the spill cleaned from the floor, prior to Phase I wet wipe of horizontal surfaces and floor vacuuming tasks commencing. This task shall be included in the quote for abatement services and performed by the abatement contractor.

2.3.2 Leaking Oil

2.3.2.1 Boiler Room Compressor

A compressor in the boiler room is leaking oil onto the concrete floor. The oily stain is being spread around the room. This is a maintenance issue that must be addressed, and the spill cleaned up, before Phase I wet wipe and floor vacuuming remediation activities commence. This task shall be included in the quote for abatement services and performed by the abatement contractor.

2.3.2.2 Roads & Trails Office

There is a box of oil leaking in the R&T Office, closest to the R&T garage. The oil is pooled on the floor and must be cleaned up prior to wet wipe or floor vacuuming remediation activities. This task shall be included in the Phase I abatement services. Photographs of the leaking box of oil are included in Appendix A, photo number .

3.0 REMEDIATION REQUIREMENTS

ASBESTOS IN DUST

LOCATION

No Structures Detected 33 samples

B&G Shops, Offices, Breakroom, Storage (west); Custodial Breakroom, Offices, Storage; LE office #’s 208, 230, 302, Evidence Room, Conference Room; Electrical Panels and Valley Switch Gear; R&T Garage, Parts Room; Utility Office 237;

Below Background Levels (<10,000 s/cm2 )

39 samples

Custodial Storage; R&T Vehicle Bay, Garage, office; Fire House Garage, Offices; Boiler Room; LE Office (228, 229) jail cells (215, 210A, B, &C), Booking Room (213);

B&G Storage (east), Shop.

At or Above Background Levels (10,000 to 100,000 s/cm2 )

13 samples

B&G Wood Shop, Storage; Vending; Mezzanine (M1); R&T Mezzanine Storage (M2); Utility Offices (# 237), Shop and Parts Racks; Unisex Restroom 238.

Considered High Levels ( >100,000 s/cm2 )

1 sample Utility Shop (236A).

3.1 Asbestos Containing Materials Remediation

(Asbestos wrapped pipes are located approximately 20 feet above the floor throughout The Fort).

Retain a competent (AHERA- certified worker) person trained, knowledgeable, and qualified, in the techniques of abatement, handling, and disposal of asbestos-containing and asbestos-contaminated materials, and the subsequent cleaning of asbestos contaminated areas to remove all exposed asbestos-insulated water pipes.

Remove approximately 711 linear feet of all accessible and exposed asbestos insulation from water supply pipes throughout The Fort (Appendix A, Photo #’s 4-9, 11-17, 38, 41, 43-46, 49, 56;

Appendix B, Maps, A1, A2, & A3). Asbestos insulated pipe that is encapsulated in wall, floor, or attic cavities, or otherwise inaccessible areas within The Fort, can safely remain in place during operations.

Table 3 below details the exposed lengths of asbestos insulation on water supply pipes at The Fort recommended for removal during Phase I remediation tasks:

TABLE 3 – THE FORT ASBESTOS INSULATED WATERPIPES

AREA

WATERPIPE LENGTH

(ft)

Roads & Trails Offices, Garage, Breakroom, and Restrooms 196

Fire Department Garage, Offices, Breakroom, and Restrooms 110

Boiler Room 40

Entrance to Law Enforcement (Downstairs) 60

Jail 70

Buildings & Grounds Offices, Garage, Breakroom, Woodworking area, and restrooms

TOTAL EXPOSED ASBESTOS INSULATION TO BE REMOVED 711

3.2 Dust Cleaning

(*An abatement contractor may require a lift to reach horizontal surfaces as ceilings are up to 24 feet high) Asbestos structures found in dust are a concern for the NPS. Wet wipe and clean all horizontal surfaces from the height of asbestos insulated waterpipes to the floor, in all areas of The Fort, including in the:

• Roads & Trails Garage, Offices, and Restroom (Appendix A, Photo #’s 3, 12, 14, 15, 25-27, 29, 34, 36, 55, 56; Appendix B, Maps, Page A1);

• Law Enforcement Offices, ISB, Jail, and Restroom (Appendix A, Photo #’s 1, 23, 47, 48, 50-53; Appendix B, Maps, Page A3),

• Buildings & Grounds Garage, Offices, and Restroom (Appendix A, Photo #’s 5, 19-22, 28, 37; Appendix B, Maps, Page A2),

• Valley Utilities (Appendix A Photo #’s 63, 64; Appendix B, Maps, Page A4)

• Fire Department Garage, Offices, and Restroom (Appendix A Photo #’s 9, 42-46; Appendix B, Maps, Page A1),

• Boiler Room (Appendix A Photo #’s 65-67; Appendix B, Maps, Page A1)

• Mezzanine (Appendix A, Photo # 11; Appendix B, Maps, Page A1), and,

• Attic (Appendix A, Photo #’s 2, 13, 30-33, Appendix B, Page A4).

The following locations in The Fort require wet wipe of all horizontal surfaces, including, but not limited to:

Roads & Trails Offices: (Photo #’s 25-27, 29) Windows (sills, sashes, and glass).

Doors, door jams.

Shelving and items on the shelves that will remain after reopening.

Bookcases, books, and binders that will remain after reopening.

Desks, chairs, & tables.

Paperwork that will remain after reopening.

Radiators.

Window and/or wall air conditioning units.

Telephones.

Computers, monitors, keyboards, printers.

Tools, equipment, radios.

Photos, awards, trophies.

File cabinets.

Electrical wall outlets and associated exposed conduit.

Other miscellaneous horizontal surfaces.

Fire extinguisher(s) Vacuum floors with HEPA filter equipped vacuum (Spilled oil in office .

Roads & Trails Breakroom:

Refrigerator exterior, Clean out/wipe interior.

Range and oven interior and exterior.

Countertops and sinks.

Tables, chairs.

Shelves.

Dishes, glasses, and utensils.

Doors and door jams.

Fans, air conditioning units and associated conduits.

Heaters and associated vertical conduit.

Electrical wall switches.

Lockers.

Fire extinguisher(s) Vacuum floors with HEPA filter equipped vacuum.

Roads & Trails Garage: (Photo #’s 3, 12, 14, 15, 36, 55, 56) Parts and materials storage (shelves and parts).

Desks, chairs, tables, filing cabinets.

Roll Up doors.

Windows, sills, sashes.

Doors and jams.

Exposed steel trusses below ACM insulated waterpipes (With lead-based paint in good condition).

Wall/Window air conditioning units and exposed conduit below ACM piping.

Exposed A/C ductwork on eastern wall (exterior).

Work benches.

Washer & dryer.

Light fixtures (if below ACM piping).

Lockers.

Vehicle exhaust removal piping.

Fire Extinguishers.

Vacuum fitted with HEPA filter to vacuum floors (Spilled DEF must be removed prior to vacuum).

Road & Trails Restroom:

Doors and jams.

Faucet, sink, countertops, mirrors, soap dispenser.

Toilets.

Electrical outlet boxes.

All horizontal surfaces below ACM piping.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Road & Trails Parts Room: (Photo # 34)

Parts bins.

Lockers.

Conduit.

Light fixtures.

Power cords.

All other horizontal surfaces from ceiling to floor.

Fire extinguisher(s) Vacuum floors with HEPA filter equipped vacuum.

Law Enforcement Offices & Investigative Services Branch: (Photo #’s 1, 23, 47-49, 53) Doors and jams.

Windows, sills, and sashes.

Shelving, books remaining, awards, mementos, pictures, trophies, etc… Radiators, heaters, wall/window air conditioning units, fans.

Evaporative air inlet and exhaust registers (should be cleaned by duct cleaners).

Desks, tables, chairs.

Computers, monitors, keyboards, printers.

Paperwork anticipated to remain.

File room and files to remain.

Filing cabinets.

Electrical outlet boxes.

Gun safe (exterior and interior).

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Law Enforcement Jail: (Photo #’s 50-52) Sleeping berths.

Wire cages.

Electrical light switches.

Desks, chairs, tables, filing cabinets.

Computers, monitors, keyboards, printers.

Miscellaneous horizontal surfaces.

Evaporative air inlet and exhaust registers (should be cleaned by duct cleaners).

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Law Enforcement Restroom:

Doors and jams.

Fixtures, sink, countertops, mirrors, soap dispenser.

Toilets.

Evaporative air inlet and exhaust registers (should be cleaned by duct cleaners).

Electrical outlet boxes.

All horizontal surfaces below ACM piping.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Building & Grounds Offices: (Photo #’s 19-21, 28) Doors and jams.

Windows, sills, and sashes.

Heaters and associated piping/conduits below ACM waterpipes.

Washer & dryer exterior.

Desks, tables, chairs.

Bookshelves, books, and binders remaining.

Vending machines (exterior).

Remove unnecessary paperwork and boxes.

Electrical wall switches and exposed conduit.

Miscellaneous horizontal surfaces below ACM piping.

Dust removal equipment (wood shop).

Vending machines.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Building & Grounds Garage: (Photo #’s 5, 37) (*Tall ceilings may require a man lift to reach) Roll Up doors.

Windows, sills, and sashes.

Heaters and associated conduits below height of ACM piping.

Cabinets (exterior only).

Tables, work benches, desks, chairs.

Bookshelves and books to remain after opening.

Stored wood, steel, tools, equipment, and materials to remain after opening.

Electrical wall boxes.

Exposed steel trusses below ACM insulated waterpipes (Trusses painted with lead-based paint in good condition).

Building & Grounds Breakroom: (Photo #22) Countertops.

Sinks.

Stovetop and range.

Refrigerator.

Shelves.

Tables.

Chairs.

Silverware.

Glassware.

Plates.

Small appliances.

Fire Extinguishers.

All horizontal surfaces below ACM piping.

Building & Grounds Restroom:

Fixtures, sink, countertops, mirrors, soap dispenser.

Toilets.

Electrical outlet boxes.

All horizontal surfaces below ACM piping.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Building & Grounds Breakroom: (Photo # 22) Refrigerator exterior, Clean out/wipe interior.

Range and oven interior and exterior.

Countertops and sinks.

Tables, chairs.

Shelves.

Dishes, glasses, and utensils.

Doors and door jams.

Fans, air conditioning units and associated conduits.

Heaters and associated vertical conduit.

Electrical wall switches.

Lockers.

Fire extinguisher(s) Vacuum floors with HEPA filter equipped vacuum.

Shop & Parts Racks: (Photo #’s 63, 64) Doors and jams.

Windows, sills, and sashes.

Heaters and associated piping/conduits below ACM waterpipes.

Shelving and storage bins.

Parts, fittings, and supplies, electrical fittings and supplies.

Ladders, tools, equipment, supplies (remove non necessary items, wet wipe remaining).

Desks, tables, chairs.

Bookshelves, books, and binders remaining.

Remove unnecessary paperwork and boxes.

Electrical wall switches and exposed conduit.

Miscellaneous horizontal surfaces below ACM piping.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Valley Utilities Offices:

Doors and jams.

Windows, sills, and sashes.

Heaters and associated piping/conduits below ACM waterpipes.

Washer & dryer exterior.

Desks, tables, chairs.

Bookshelves, books, and binders remaining.

Vending machines (exterior).

Dust removal equipment (wood shop).

Remove unnecessary paperwork and boxes.

Electrical wall switches and exposed conduit.

Miscellaneous horizontal surfaces below ACM piping.

Vending machines.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Mezzanine: (Photo #11) Shelves.

Tools, equipment, chains, cones, signs, ladders, drums, steel bars, tow straps, fluorescent bulbs (boxed).

Cages.

Heaters and conduit.

Compressor.

Exposed steel trusses below the height of ACM piping.

Miscellaneous horizontal surfaces below existing piping.

Fire Extinguishers.

Vacuum floors and stairs with HEPA filter equipped vacuum.

Remove unnecessary tools, equipment, and materials from the Mezzanine prior to reopening.

Attic: (Photo #’s 2, 13, 30-33) (*Accessible areas only. Do not disturb blown insulation. Tall ceilings may require a lift)

Shelving and storage bins.

Plumbing fittings and supplies, electrical fittings and supplies, HVAC supplies, pipe insulation.

Exposed steel trusses with lead-based paint (Paint in good condition).

Ladders, tools, equipment, supplies (remove non necessary items, wet wipe remaining).

Attic Restroom: (Photo #31)

Fixtures, sink, countertops, mirrors, soap dispenser.

Toilets.

Electrical outlet boxes and conduit.

Cot.

All horizontal surfaces.

Fire Extinguishers.

Vacuum floors with HEPA filter equipped vacuum.

Fire Department Offices: (Photo #’s 42, 46) (*Fire Dept. wet wiped in 2022. Recommend additional cleaning due to accumulated dust).

Doors and jams.

Windows, sills, and sashes.

Radiators, window/wall air conditioning units, fans.

Desks, tables, chairs.

Computers, monitors, keyboards, printers.

Bookshelves and books remaining during opening.

Shelves and paperwork (remove unnecessary paperwork).

File cabinets.

Tools, equipment, materials, supplies.

Photos, personal mementos, awards, artwork (remove unnecessary items prior to cleaning).

Electrical wall outlets.

Miscellaneous horizontal surfaces.

Fire Department Garage: (Photo #’s 9, 43-45) (*Wet wiped in 2022. Tall ceilings may require the use of a lift.)

Tools and materials storage (shelves and parts).

Desks, chairs, tables, filing cabinets.

Roll Up doors.

Windows, sills, sashes.

Doors and jams.

Exposed steel trusses below ACM insulated waterpipes (Trusses painted with lead-based paint in good condition).

Wall/Window air conditioning units and exposed conduit below ACM piping.

Work benches.

Light fixtures.

Lockers.

Vacuum fitted with HEPA filter to vacuum floors.

Boiler Room: (Photo #’s 10, 35, 65-67) (*All asbestos pipe insulation previously removed)(*Tall ceilings may require a lift) Windows, sills, and sashes.

Doors and jams.

Boiler tanks, transformer, compressor, all electrical equipment, and associated electrical conduits.

Desks, tables, chairs, shelves, and equipment remaining.

Piping below height of former ACM insulated waterpipes.

Exhaust fans and ducts (exterior).

Miscellaneous horizontal surfaces below existing piping.

3.2.1 Ductwork Cleaning

Abatement contractors shall include the cost for cleaning ductwork interior in the quote for abatement services. If ductwork cannot be internally cleaned, the abatement contractor shall be required to perform air sampling at all duct outlets with the HVAC system running to confirm no asbestos fibers will be transported through ductwork upon recommencing operations at The Fort.

3.3 Hazardous Fluid Remediation

3.3.1 Diesel Exhaust Fluid

The spilled DEF in the R&T Garage must be disposed of as waste and the spill cleaned from the floor, prior to Phase I wet wipe and floor vacuuming remediation tasks. This task shall be included in the quote for abatement services and performed by the abatement contractor. (Appendix A, Photo #36, Appendix B, Maps, A1)

3.3.2 Leaking Oil

3.3.2.1 Boiler Room Compressor

A compressor in the boiler room is leaking oil onto the concrete floor. The oily stain is being spread around the room. This is a maintenance issue that must be addressed, and the spill cleaned up, before Phase I floor vacuuming remediation activities commence. This task shall be included in the quote for abatement services and performed by the abatement contractor. (Appendix A, Photo #35; Appendix B, Maps, Page A1),

3.3.2.2 Road & Trails Office

The Roads & Trails office has a leaking oil container inside. The container is leaking oil to the concrete floor. This is a maintenance issue that must be addressed before Phase I floor vacuuming remediation activities commence. This task shall be included in the quote for abatement services and performed by the abatement contractor. (Appendix A, Photo #36;

Appendix B, Maps, Page A1)

4.0 FEDERAL AND STATE REGULATIONS

4.1 Asbestos Remediation

4.1.1 Federal Regulations

US EPA NESHAP 40 CFR Part 61 The US EPA NESHAP (40 CFR Part 61 – November 20, 1990) describes requirements for handling asbestos materials. If those materials are friable or likely to become friable due to the forces expected to act upon them, they become a regulated asbestos containing material (RACM) and require a 10-day notification and a Tier 2 notification fee to the San Joaquin Valley Air Pollution Control District (District) prior to abatement.

The NESHAP defines a regulated asbestos project as one which will disturb 260 linear feet of pipe or pipe wrap. All of the regulated asbestos abatement must be completed by a state-certified asbestos abatement contractor.

Air toxics regulations under the Clean Air Act specify work practices for asbestos to be followed during abatement procedures at all buildings. The regulations require a thorough inspection where the project activities will occur. The regulations require the owner or the operator of the contractor operation to notify the appropriate delegated entity (often a state agency) before removal of a certain threshold amount of regulated asbestos-containing material. The rule requires work practice standards that control asbestos emissions. Work practices often involve removing all asbestos-containing materials, adequately wetting all regulated asbestos-containing materials, sealing the material in leak tight containers and disposing of the asbestos-containing waste material as expediently as practicable, as the regulation explains in greater detail.

These work practice standards are designed to minimize the release of asbestos fibers during building disturbance activities, waste packaging, transportation, and disposal.

Institutional, Commercial and Industrial Buildings

Any abatement operation at an institutional, commercial or industrial building is regulated by the

Asbestos NESHAP. At a minimum, the thorough inspection requirement applies. The notification requirements apply to abatements over a certain threshold amount of regulated asbestos-containing material.

Asbestos Control Method

The Asbestos NESHAP requires specific work practices to control the release of asbestos fibers.

To help ensure that the work practice standards of the asbestos NESHAP are followed during an abatement operation, the asbestos NESHAP requires at least one onsite representative trained in the regulatory provisions and the means of compliance. This trained individual needs to receive refresher training every two years, including: applicability of the rule; notifications;

material identification; control procedures for removal; adequate wetting; local exhaust ventilation; negative pressure enclosures; glove-bag procedures; High Efficiency Particulate Air (HEPA) filters; waste disposal work practices; reporting and recordkeeping; and asbestos hazards and worker protection.

Waste Disposal and Transportation

The rule generally requires that asbestos-containing waste material be sealed in a leak-tight container while wet, labeled, and disposed of properly in a landfill qualified to receive asbestos waste. Landfills have specific requirements for handling and securing the asbestos containing waste to prevent releases of asbestos into the air. Transportation vehicles that move the waste from the point of generation to the asbestos landfill have special labeling requirements and waste shipment recordkeeping requirements.

AHERA 40 CFR Part 763.91(f)(1) Minor Fiber Release Episode The local education agency shall ensure that the procedures described below are followed in the event of a minor fiber release episode (i.e., the falling or dislodging of 3 square or linear feet or less of friable ACBM): 5 (i) Thoroughly saturate the debris using wet methods. (ii)Clean the area, as described in paragraph (e) of this section.(iii) Place the asbestos debris in a sealed, leak-tight container. (iv) Repair the area of damaged ACM with materials such as asbestos-free spackling, plaster, cement, or insulation, or seal with latex paint or an encapsulant, or immediately have the appropriate response action implemented as required by § 763.90.

4.1.2 California Regulations

CAL OSHA-Construction Industry-8CCR, §1529 - General Asbestos Regulations 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 activities 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.

1. The construction industry standard covers employees engaged in abatement 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.

2. Abatement 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.

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

San Joaquin Valley Air Pollution Control District - Regulated Asbestos Containing Material (RACM) Per the NESHAP, Regulated Asbestos Containing Material (RACM) is subject to the notification and abatement requirements prior to the commencement of regulated abatement projects.

This includes:

▪ Friable asbestos-containing material (ACM), which is any material containing more than 1 percent asbestos, as determined by Polarized Light Microscopy (PLM) testing, which, when dry, can be crumbled, pulverized, or reduced to powder by hand pressure.

▪ Category I Nonfriable ACM that is in poor condition and "has become friable" or "that has, or will be subjected to sanding, grinding, cutting, or abrading." (Category I Nonfriable ACM means "asbestos-containing packings, gaskets, resilient floor coverings, and asphalt roofing products containing more than 1 percent asbestos as determined by PLM testing that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.")

▪ Category II Nonfriable ACM that has a high probability of becoming, or has become, crumbled, pulverized, or reduced to powder by the forces expected to act on the material in the course of abatement. (Category II Nonfriable ACM is "any asbestos-containing material, excluding Category I ACM, containing more than 1 percent asbestos as determined by PLM testing, that, when dry, cannot be crumbled, pulverized or reduced to powder by hand pressure.")

If ACMs are friable or likely to become friable due to the forces expected to act upon them during abatement, they become a regulated asbestos containing material (RACM) and require a 10-day notification and a Tier 2 notification fee to the San Joaquin Valley Air Pollution Control District (District) prior to abatement.

4.2 Dust Cleaning Regulations

4.2.1 Federal Regulations

40 CFR §61.145 Standard for Demolition and Renovation In a facility being abated of asbestos, the requirements of this section apply if the combined amount of RACM to be stripped, removed, dislodged, cut, drilled, or similarly disturbed is at least 260 linear feet on pipes.

Title 40, Chapter I, Subchapter R, §763.91 The mandatory transmission electron microscopy (TEM) method which all laboratories must follow; it is the minimum requirement for analysis of air samples for asbestos by TEM.

4.2.2 California Regulations

Title 22, Division 4.5, Chapter 13, Article 2, §66263.23 If a discharge or spill of hazardous waste occurs during transportation, the transporter shall take appropriate immediate action to protect human health and the environment, and shall be responsible for the discharge/cleanup.

Title 22, Subchapter 4, Article 4, §1529 This section regulates asbestos exposure in all construction work, including, but not limited to:

Removal or encapsulation of materials containing asbestos.

4.3 Hazardous Fluids Regulations

4.3.1 Federal Regulations

4.3.1.1 Contaminated Used Motor Oil

40 CFR, Parts 260-273 Establishes regulations for the safe transport and disposal of federal hazardous waste.

4.3.2 California Regulations

4.3.2.1 Contaminated Used Motor Oil

CalRecycle encourages the recycling of used motor oil by certifying used oil recycling collection centers throughout the state.

HSC, Division 20, Chapter 6.5, Article 7, Section 25174.6 Establishes fees to go directly to disposal facilities who then pay fees to the DTSC.

HSC, Division 20, Chapter 6.5, Article 13, Section 25250.11 Management of used oil.

4.4 Waste Disposal Regulations

1. Friable Asbestos containing debris must be properly disposed of and manifested in accordance with all federal, state and local regulations.

2. Disposal of non-friable asbestos materials shall be documented with a non-friable waste shipment manifest. The manifest must clearly state that the landfill is aware that they are accepting non-friable asbestos containing materials.

3. Transportation of asbestos debris must comply with DOSH and DOT regulations.

4. In the event PCBs ae discovered onsite, a sample of the material(s) must be submitted to an accredited analytical laboratory for chemical analysis. Analytical results will point toward an appropriate disposal facility who may accept the PCB material.

5. All wastes requiring disposal shall be packaged, labelled, transported, disposed of at appropriate facilities, and manifested, in accordance with all federal, state, and local regulations for hazardous materials in California.

Wastes shall be collected and disposed of in sealed, labeled, impermeable bags or other containers, and should be removed as soon as practicable. All wastes shall be documented on waste manifests prior to loading, transport, and disposal at an appropriate facility accepting the specific hazardous materials.

5.0 CONTRACTOR REQUIREMENTS

5.1 Third Party Abatement Oversight

The National Park Service requires oversight during all Asbestos abatement activity in accordance with AHERA Regulations 763, Subpt. E, App. C. Oversight will be performed by a State Certified Asbestos Consultant who will function as the owner’s representative and have the authority to stop work if necessary.

The Abatement Contractor selected to remediate asbestos at The Fort shall retain a third-party State Certified Asbestos Consultant to provide oversight of the remediation work during Phase I remediation tasks.

5.2 Personnel Training and Experience

Personnel must be certified prior to gaining entry to the facility during remediation activities. Training must include all info related to asbestos hazards, PPE, and respirator requirements. Certification training consists of a 16-hour course (40 CFR 763.92(a)) and must include all info related to asbestos hazards and respirator requirements.

5.3 Contractor’s Use of the Premises

The Contractor shall confine its apparatus; the storage of materials and the operations of its work staff to limits indicated by law, ordinances, permits or directions of the National Park Service representative and shall not exceed those established limits in their operations. The Contractor shall not load or permit any part of the structure to be loaded with a weight that will endanger its safety. The Contractor shall enforce the National Park Service representative’s instructions regarding signs, advertisements, fires, and smoking.

5.4 Special Construction Requirements

The contractor shall follow all federal, state, and local, guidelines and regulations for asbestos removal, asbestos dust cleaning, ductwork cleaning, and waste disposal. The contractor shall gain permission to enter the premises from the national Park Service for the purposes of removing hazardous wastes from The Fort.

5.5 Submittals and Documentation

Contractors shall submit proof of training to the NPS representative for all personnel performing tasks associated with hazardous materials within, or immediately surrounding, The Fort. The contractor shall provide daily work reports documenting personnel and equipment onsite, tasks completed, and a description and location of containers with any remediated hazardous materials inside. The contractor shall ensure all staged hazardous materials containers are properly labeled, and are staged in an appropriate area, confirmed by the NPS representative. Subsequent to the remediation of hazardous materials, the contractors shall provide a summary report describing volumes of regulated ACM removed, transported, and disposed, a summary of dust wet wiping results throughout, and a report describing the duct cleaning process. Subsequent to the completion of remediation tasks, the abatement contractor shall provide results from air monitoring with the HVAC system running to achieve clearance to return operations to The Fort.

5.6 Certifications

Certification is required by Title 8, California Code of Regulations, Article 2.6, Section 341.15 for individuals who contract to provide health and safety services for asbestos-related work (projects involving more than 100 square feet of asbestos-containing construction material). A certified asbestos consultant shall possess a valid and appropriate federal Asbestos Hazard Emergency Response Act [Subchapter II (commencing with Section 2641) of Chapter 53 of Title 15 of the United States Code] certificate, or its equivalent, as determined by the Division.

5.7 Quality Assurance

Quality assurance is a firm’s process for improving the quality of its services or products. The abatement contractor(s) shall follow their company-specific quality assurance plan to ensure they are meeting their desired quality goals. Quality assurance is a proactive process. Attention to quality allows companies to reduce errors by investigating the root cause of potential errors and developing a solution to prevent/reduce the same errors from recurring.

5.8 Personal Protective Equipment, Abatement Equipment, and Products Personal Protective Equipment (PPE) for Class I-III asbestos work requires a half-mask air purifying respirator fitted with HEPA filters, coveralls with head covering, gloves, and foot coverings. Disposable coveralls, gloves, and foot coverings are preferred. Ceilings are over 20 feet in garage and workshop spaces. Contractors may use a lift, or other means, to reach tall surfaces requiring ACM removal or wet wipe.

Abatement:

1. A full 3-stage decontamination facility to include an operational shower with hot and cold running water is required for all CLASS I work.

2. All penetrations into the work area(s) shall be sealed with critical barriers consisting of two (2) layers of 6-mil poly and duct tape for all CLASS I work.

3. Containment shall consist of two (2) layers of 6-mil polyethylene sheeting and duct tape for all

CLASS I work.

4. The removal areas shall be kept wet before and during removal activities.

5. Should visible emissions occur, removal efforts will be immediately ceased, and the situation corrected to the satisfaction of the Consultant.

6. Work will not start again until approved by the Consultant.

7. Removal shall be accomplished with minimal cutting, tearing, or breaking of the materials.

8. The use of compressed air, dry sweeping is prohibited.

5.9 Work Area Preparation

Decontamination areas must include an equipment room with impermeable labeled bags and containers for removed PPE, shower area with hot and cold running water, and a clean room for changing into street clothes, in series.

The decontamination entry procedure is as follows:

1. Enter the clean room. Remove personal clothing, place into a locker, and don new, disposable coveralls, gloves, foot coverings, and respirator.

2. Walk through the shower room to the equipment room.

3. Enter the facility fully protected with PPE.

The decontamination exit procedure is as follows:

1. Remove gross contamination from PPE.

2. Enter the equipment room and remove all PPE except the respirator, and place discarded disposable PPE into impermeable labeled bags/containers.

3. Enter the shower room. Wash yourself, rinse your respirator, dry off.

4. Enter the clean room, don personal clothing, and leave the premises.

5. Always enter and exit through the clean room to prevent cross-contamination.

5.10 Re-Establishment of Work Area

The contractor shall ensure they restore the work area to a safe condition at the end of each day and prior to returning to operations. The contractor shall be required to identify and segregate waste materials for disposal and identify and segregate materials suitable for recycling, if applicable. The contractor shall follow safe working practices and shall maintain environmental compliance at all times. Reinstate the work area after performing a tailboard safety meeting to document the hazards present.

5.11 Air Monitoring

By OSHA regulation, air testing is required to be performed to determine asbestos exposure to the breathing zone of working personnel in the building. The Permissible Exposure Limit (PEL) set by OHSA is

0.1 fibers/cc over an 8hr Time Weighted Average (TWA). We recommend that area air monitoring and/or personal air monitoring be performed during all Phase I interior asbestos remediation work 9dust cleaning, asbestos removal, ductwork cleaning) to determine if the PEL is being exceeded. If the PEL is being exceeded, work must be stopped until the PEL is below action levels.

The containment shall be kept under negative air pressures at all times until containment passes TEM clearances. No visible emissions are permitted at any time during the course of this project, regardless of the results of any air monitoring. The work area shall be HEPA vacuumed and misted with water prior to the end of each day’s shift. The contractor is required to maintain a competent person on-site at all times.

TEM Final Air Clearance shall be performed upon passing visual inspection conducted by the State-certified Consultant. All personal air monitoring results shall be submitted to the Consultant within 48 hours of collection.

Requirement documents state that ventilation/heating ductwork cleaning during Phase I abatement activities must occur prior to reopening The Fort. Transmission electron microscopy (TEM) air sampling clearance tests shall occur after ducts are cleaned and with the HVAC system running to ensure appropriate clearance for a safe return to operations at The Fort.

The Abatement contractor shall ensure that air sampling clearance tests are spaced appropriately in each area to ensure indoor air quality is accurately quantified. The following areas require air sampling clearance tests prior to recommencing operations at The Fort:

1. Building & Grounds Offices & Garage – Five (5) Air Clearance Samples.

2. Fire Department Offices & Garage – Five (5) Air Clearance Samples.

3. Roads & Trails Offices, Garage, & Mezzanine – Five (5) Air Clearance Samples.

4. Law Enforcement Offices, Jail, & Conference Room – Five (5) Air Clearance Samples.

5. Utility Offices & Storage – Five (5) Air Clearance Samples.

6. Attic – Five (5) Air Clearance Samples.

We recommend a total of 30 Air Clearance Samples to be collected with the HVAC system running to ensure appropriate clearance for a safe return to operations at The Fort.

5.12 Safety

The contractor shall be knowledgeable of federal. state, and local regulations for handling, storing, transporting, and disposing of California hazardous wastes. The contractor shall perform daily safety tailboard meetings to remind personnel of the hazards they may encounter during remediation tasks.

Personnel shall ensure they follow all laws, Yosemite National Park rules and regulations, and safety procedures as outlined in the daily safety tailboard meetings.

Prior to commencing remediation activities, contractor(s) shall submit a Site-Specific Health and Safety Plan (SSHASP) to the NPS to document each potential hazard that exists onsite. The SSHASP shall contain specific measures for safety during the course of work.

APPENDIX A

PHOTOGRAPHS

Photo 1: Ductwork entering the LE storage room from the rear of the building supplies fresh air to the Law Enforcement offices. Note gun and ammo safe at lower rear and wall mounted Air conditioning unit. All horizontal surfaces must be wet wiped. The floor must be cleaned with HEPA filter vacuums. Approximately 10 feet of 2” O.D. asbestos insulation must be removed from the water supply pipes to the heater.

Photo 2: Large (1.5’ x 2’) ductwork in attic above Law Enforcement offices feeds smaller ducts supplying conditioned air to offices.

Photo 3: Ductwork daylights from attic into west side of B&G garage before conveying forced air from evaporative cooler on roof to Law Enforcement offices.

Photo 4: Asbestos-insulated water pipes with asbestos label.

Photo 5: View of damaged, protected asbestos insulation on water pipe in B&G storage. All exposed asbestos insulating water pipes must be removed prior to reopening The Fort. All horizontal surface below asbestos pipes must be wet wiped, including stored parts and supplies, tools, and equipment, doors, and windows. Floors must be cleaned with a HEPA filter vacuum.

Photo 6: Three different diameter asbestos insulated waterpipes exposed in B&G wood shop.

Note typical heater and water pipe connection. There are 235 linear feet of asbestos insulation requiring removal in the B&G areas. All horizontal surfaces in the wood shop must be wet wiped, including windows, doors, tools, equipment, parts and supplies, and cabinet exteriors. Floors must be cleaned with HEPA filter vacuums.

Photo 7: Almost all asbestos insulation has been removed from water supply pipes in the B&G garage. Horizontal surfaces must be wet wiped and the floors cleaned with HEPA filter vacuums prior to reopening.

Photo 8: Minor remaining asbestos insulation on water pipes in the B&G garage must be removed.

Photo 9: Various diameters of piping are conveyed through walls and ceilings in B&G/Fire Dept.

Asbestos insulation encapsulated within walls may remain in place. 110 linear feet of insulation in the Fire Dept. and 235 linear feet in B&G areas require removal. Pipe sizes range from 2”-8” O.D.

Photo 10: Asbestos insulation has been removed from the boiler room and replaced by fiberglass insulation. Replace fiberglass insulation with new, if necessary.

Photo 11: Exposed asbestos insulation is damaged in the mezzanine. All horizontal surfaces below exposed asbestos wrapped pipes must be wet wiped and floors cleaned with HEPA filter vacuums.

Photo 12: Approximately 196 linear feet of asbestos insulated water pipes are exposed in the R&T garage. The majority (~100 ft) is 8” O.D, approximately 60 feet is 4” O.D., and the remaining is ~2” O.D.

Photo 13: Asbestos insulated water supply to heater in the attic. Approximately 196 linear feet of asbestos insulation is exposed in the R&T garage and mezzanine.

Photo 14: Typical sized ACM insulated pipes in R&T garage. All horizontal surfaces below the ACM piping must be wet wiped during Phase I remediation tasks, including beams and trusses, and floors cleaned with HEPA filter vacuums. Ceilings are approximately 25 feet tall.

Photo 15: R&T garage with asbestos piping. Roll up doors, windows, heaters, & workbenches.

tools, equipment, and other horizontal surfaces below piping requiring wet wipe and floors cleaned with HEPA filter vacuums.

Photo 16: 2” O.D. asbestos wrapped pipe in B&G custodial shops requiring removal. All horizontal surfaces below piping must be wet wiped and floors cleaned with HEPA filter vacuums.

Photo 17:

Photo 18: B&G custodial office requiring wet wipe of all horizontal surfaces. Note paperwork, binders, personal items that must be removed or cleaned prior to reopening The Fort.

Photo 19: B&G Office displays dusty conditions. All horizontal surfaces must be wet wiped, including windows, sills, and sashes during Phase I remediation activities. Floors must be cleaned with HEPA filter vacuums.

Photo 20: B&G office. Clean all desks, computers, monitors, keyboards, printers, binders, and personal items that will remain after reopening. Remove all non-necessary items, including paperwork. Clean floors with HEPA filter vacuums.

Photo 21: B&G office. Clean all computers, monitors, keyboards, printers, tables, desks, chairs, radios, power cords, and vacuum floors with vacuum fitted with HEPA filters. Remove artwork from walls, wipe all horizontal surfaces in each room throughout.

Photo 22: B&G and custodial kitchen/breakroom requires countertops, stovetop and range, and refrigerator exterior wet wiped.