B08_Attachment_2_-_YOSE_Assessment_Report_10-05-2023_final.pdf

HAZARDOUS MATERIALS ASSESSMENT

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

October 5, 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

2.2 Dust Wipe Sample Results

2.3 Ductwork Cleaning

2.4 Hazardous Fluids

2.4.1 Diesel Exhaust Fluid

2.4.2 Leaking Oil

2.5 Lead-Based Paint

2.6 Polychlorinated Biphenyls

2.7 Chemicals

2.8 Vehicle Wash Rack

3.0 REMEDIATION REQUIREMENTS

3.1 Asbestos Containing Materials Remediation

3.1.1 Asbestos Insulated Wiring

3.1.2 Asbestos Insulated Waterpipes

3.2 Dust Cleaning

3.3 Ductwork Cleaning

3.4 Hazardous Fluid Remediation

3.4.1 Diesel Exhaust Fluid10

3.4.2 Leaking Oil

3.5 Lead-Based Paint Remediation

3.6 Polychlorinated Biphenyls Remediation

3.7 Chemical Disposal

3.8 Vehicle Wash Rack Permitting

4.0 FEDERAL AND STATE REGULATIONS

4.1 Asbestos Remediation

4.1.1 Federal Regulations

4.1.2 California Regulations For Asbestos Remediation

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 Lead Remediation

4.4.1 Federal Regulations for Lead Remediation

4.4.2 California Regulations for Lead Remediation

4.5 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

TABLES

Table 1 – Materials positive for Asbestos Table 2 – Asbestos Dust Wipes

APPENDICES

Appendix A - Photographs Appendix B – Maps Appendix C – Hazardous Materials Sample and Testing Data

1. C57-22 Air Test Report, May 17, 2022: Asbestos Air Samples – Background and Work in Progress Results.

2. C57-22 Air Test Report, July 1, 2022: Asbestos Air Samples – Final Air Clearances Results for work directly below the roof work.

3. C57-22 Job Report, July 8, 2023: Air Clearance Samples - Roofing Project Results.

Collect air samples during containment set up for roof replacement.

4. C73-22 Job Report Final, July 8, 2022: Air Clearance Samples – Fire Engine Decon Results

5. C97-23 Air Test Baseline, June 28, 2023: Air Clearance Samples - Results After Roofing and Fire Engine Decon

6. C131-21 Asbestos Dust Wipe Final Report, November 4, 2021: Dust Samples with Asbestos Bulk Results

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 Assessment (HMA) Report (Report). This Report documents the existing hazardous materials and conditions onsite and provides recommendations to allow the NPS to remediate these materials at Yosemite Valley Maintenance Building 527 (“The Fort”), in accordance with federal, state, and local regulations.

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. The exposed ACM insulation will be removed during the first phase of remediation tasks, to allow for a rapid and safe return to operations at The Fort. The remaining concealed insulated waterpipes located throughout the building within wall cavities and crawl spaces are in varying degrees of damage and decay. Lead-based paint was reported on exposed steel beams in the garage maintenance area and storm gutters throughout the facility. Polychlorinated biphenyls (PCBs) are anticipated to exist in the electrical transformer room and in light ballasts, however, no PCBs samples were collected.

Departments displaced from The Fort include Fire Management (FM), Law Enforcement (LE), Investigative Services Branch (ISB), Roads, Trails and Forestry (RTF), Valley Utilities (VE) and Buildings & Grounds (BG).

Since The Fort's closure, these departments have been working out of small office trailers with insufficient workspace and lack of restrooms or temperature-controlled break rooms. The Fort closure has negatively impacted response times across departments due to inadequate vehicle and equipment support.

In September 2023, Soar Environmental developed a Hazardous Materials Abatement Requirements Report (HMARR) describing the ‘Phase I’ remediation work necessary for departments to return to previously occupied spaces, without making building renovations. The HMARR identifies asbestos insulated water pipes, dust with asbestos structures on horizontal surfaces, and spilled chemicals and oil To allow safe return to operations, the initial Phase I remediation phase describes the removal of all exposed asbestos insulated waterpipes, cleaning of spilled chemicals, and wet wiping of horizontal surfaces throughout The Fort. Additionally, the HMARR identifies ductwork cleaning and air clearance testing requirements for a comprehensive approach to Phase I cleaning and mitigation.

This Hazardous Materials Assessment (HMA) includes observations and data relating to Phase I scopes, and additionally includes observations and data relevant for a future ‘Phase II’ task order. Phase II scopes include hazardous materials that would require abatement if NPS were to proceed with a major building renovation project, or if the building were to be demolished and replaced with a new structure, as either approach would disturb the associated hazardous materials; many of which are concealed within walls and floor assemblies. Phase II hazardous materials observed do not present health or safety risks to departments returning to The Fort, so long as they remain undisturbed.

1.3 Facility Description

Constructed of reinforced concrete cast-in-place walls, columns, and decks with a steel frame, the original roof with asbestos containing materials (ACMs) was replaced with roofing materials in accordance with modern building codes. 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

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, 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’ *Removed

02 Roof Tar Paper 30% No 39,000’ *Removed

05 Roof Roof Mastic 10% No 100’ *Removed

Electrical Room

01 Roof Asphalt Rolled Roofing Material

30% No 400’ *Removed

02 Roof Tar Paper 30% No 400’ *Removed

Miscellaneous Areas Throughout the Building

Not Sampled

Throughout Water Pipe Insulation Assumed >1%

Yes 800 ln ft 2”-8” O.D.

Boiler Room 13

Electrical Wire Insulation 30% No TBD

*In June 2023, the NPS removed and replaced all roofing materials.

2.0 HAZARDOUS MATERIALS FINDINGS

2.1 Asbestos Containing Materials

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.

The waterpipe Insulation located throughout the building is assumed positive for asbestos at >1% and is marked “Asbestos Containing Material”. 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. In total, there are approximately 711 linear feet of exposed, two-inch outside diameter (O.D.) to eight-inch O.D., asbestos-insulated pipes throughout The Fort. It is anticipated that approximately 90 linear feet of concealed waterpipe insulation will remain in wall cavities, floor assemblies, and crawl spaces after Phase I activities are complete; however, the lengths of concealed waterpipes are unknown and it may not be possible to quantify without disturbing structural building components. Photographs of asbestos wrapped waterpipes entering wall cavities are included in Appendix A, photo numbers 1 through 8.

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. Photographs of horizontal structures with dust are included in Appendix A, photo numbers 9 through 33. Analytical reports are presented in Appendix C, Hazardous Materials Sample and Testing Data.

The majority of dust sample analytical results show a normal background range for asbestos in dust.

California has the most naturally occurring asbestos of any state in the country. One sample was reported with high concentrations; however, the location of the sample was near ACM insulation (Utility Shop 236A). 13 samples also below or near ACM insulation were reported at or above background concentrations. Other factors contributing asbestos structures in dust may include the length of time elapsed since The Fort was closed, that regular cleaning may not have been performed historically, and the dust sampled is from an accumulation of many years and not an isolated incident.

Table 2.0 DUST WIPE SAMPLE RESULTS

2.3 Ductwork Cleaning

Approximately 185 linear feet of various sized HVAC ductwork is present above and within the Law Enforcement and Jail areas. The majority of ductwork is present in the attic above the Law Enforcement offices with returns located on the eastern wall of the Road & Trails garage and is fed by an evaporative cooler located on the roof of The Fort. Approximately 90 feet of the attic ductwork measures approximately 1.5ft x 2ft. The remaining attic ductwork measures approximately 1.5 ft x 0.5 ft.

Approximately 35 linear feet of ductwork is present along the northern side (rear) of The Fort and conveys fresh air to the Law Enforcement conference room, above the gun and ammo safe. Ductwork conveying fresh air from the rear of the building appears to be 10-inches in diameter. Photographs of ductwork requiring cleaning are included in Appendix A, photo numbers 34 through 36.

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).

2.4 Hazardous Fluids

2.4.1 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. Photographs of the leaking tote are included in Appendix A, Photo number 37, and the locations of photos are keyed into maps in Appendix B.

2.4.2 Leaking Oil

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. Photographs of the leaking boiler room compressor are included in Appendix A, photo number 38, and the location is keyed into the map in Appendix B. .

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 numbers 39 & 40, and the locations are keyed into the maps in Appendix B.

2.5 Lead-Based Paint

Lead-based paint is present on exposed steel trusses in the Roads and Trails garage, in the attic, and on exterior rain gutters. Some of the gutters were replaced during roof replacement tasks. Photographs of the steel trusses are included in Appendix A, photo numbers 41 & 42, and the locations are keyed into the maps in Appendix B.

2.6 Polychlorinated Biphenyls

PCBs are anticipated to be present in electrical equipment and potentially in original fluorescent light ballasts. Photographs of light ballasts and the electrical transformer are included in Appendix A, photo numbers 43 through 46, and the locations are keyed into the maps in Appendix B.

2.7 Chemicals

There are numerous cabinets with various chemicals inside and outside The Fort. Flammable chemicals (gasoline, paint thinner, etc.) are stored in cabinets with automatically closing doors, as required. Other cabinets hold paint and other chemicals. The chemicals may be expired, or out of spec, which requires removal and disposal as a waste at appropriate facilities. Photographs of typical chemical cabinets are included in Appendix A, photo numbers 47 through 49, and the locations are keyed into the maps in Appendix B.

2.8 Vehicle Wash Rack

The vehicle wash rack on the west side of The Fort may be draining directly to the MS4 system, which may require a separate permit. . Direct discharge to the stormwater system may require a separate discharge permit from the Regional Water Quality Control Board. Photographs of the vehicle wash rack are included in Appendix A, photo number 50, and the location is keyed into the maps in Appendix B.

3.0 REMEDIATION REQUIREMENTS

3.1 Asbestos Containing Materials Remediation

3.1.1 Asbestos Insulated Wiring

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 embedded in structural wall cavities and are not possible to quantify without disturbing asbestos insulation and/or structural walls. 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, the material will be classified as friable asbestos containing material. If the NPS elects to replace the electrical wiring during future Phase II scope of work remediation tasks, an abatement contractor must perform the removal and disposal of asbestos containing materials.

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 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.

3.1.2 Asbestos Insulated Waterpipes

There are approximately 800 linear feet of two-inch outside diameter (O.D.) to eight-inch O.D. asbestos-insulated waterpipes conveying hot water throughout The Fort. During Phase I remediation tasks, the asbestos insulation on exposed waterpipes will be removed. After Phase I remediation tasks are complete, approximately 90 linear feet of concealed insulated waterpipes are anticipated to be left behind, encapsulated in structural wall cavities, the attic floor assembly, and/or crawl spaces. However, because there are no construction drawings showing the hot waterpipe configuration in concealed spaces, this estimate may not accurately quantify the entire lengths of concealed waterpipes. The NPS may elect to remove the encapsulated ACM insulation from waterpipes concealed within wall cavities, the attic, and crawl spaces during Phase II remediation tasks. Photographs of concealed, wrapped, waterpipes are included in Appendix A, photo numbers 1 through 8, and the locations are keyed into the maps in Appendix B.

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 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.

3.2 Dust Cleaning

Asbestos structures found in dust are a concern for the NPS. Phase I tasks include the wet wipe and cleaning of all horizontal surfaces from the height of asbestos insulated waterpipes to the floor, in all areas of The Fort. The NPS will retain a licensed asbestos abatement contractor to wet wipe and clean all horizontal surfaces prior to The Fort reopening During Phase I tasks, the abatement contractor shall clean floors throughout The Fort with a vacuum fitted with HEPA filters to ensure all asbestos containing dust is removed prior to resuming operations. Photographs of horizontal structures with dust are included in Appendix A, photo numbers 9 through 33, and the locations are keyed into the maps in Appendix B.

3.3 Ductwork Cleaning

Ductwork located in the attic and feeding the Law Enforcement areas of The Fort is required to be cleaned prior to reopening The Fort. After the interior of ductwork is cleaned, clearance tests are required to be performed while the HVAC system is operating to ensure a safe return to operations for all staff.

Approximately 185 linear feet of various sized HVAC ductwork is present above and within the Law Enforcement and Jail areas. The majority of ductwork is present in the attic above the Law Enforcement offices with returns located on the eastern wall of the Road & Trails garage and is fed by an evaporative cooler located on the roof of The Fort. Approximately 90 feet of the attic ductwork measures approximately 1.5ft x 2ft. The remaining attic ductwork measures approximately 1.5 ft x 0.5 ft.

Approximately 35 linear feet of ductwork is present along the northern side (rear) of The Fort and conveys fresh air to the Law Enforcement conference room, above the gun and ammo safe. Ductwork conveying fresh air from the rear of the building appears to be 10-inches in diameter. Photographs of ductwork requiring cleaning are included in Appendix A, photo numbers 34 through 36.

3.4 Hazardous Fluid Remediation

3.4.1 Diesel Exhaust Fluid

The spilled DEF must be disposed of as waste and the spill cleaned from the floor, prior to Phase I wet wiping of horizontal surfaces and floor vacuuming tasks commencing. This task shall be included in the Phase I abatement services. Photographs of the leaking DEF tote are included in Appendix A, photo number Photographs of the leaking tote are included in Appendix A, Photo number 37.

3.4.2 Leaking Oil

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. Photographs of the leaking boiler room compressor are included in Appendix A, photo numbers 38 & 39. .

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 40.

3.5 Lead-Based Paint Remediation

During the Phase II scope of work tasks, Soar Environmental recommends that a state-certified and licensed lead abatement contractor evaluate the condition of the lead paint throughout the facility to determine appropriate remediation methodologies, and if necessary, remove the damaged paint in accordance with local, state, and federal regulations for lead-based paint. The NPS may elect to repaint or replace the lead painted structures during future remediation phases. Photographs of lead-based painted surfaces and their locations are included in Appendix A, photo numbers 41 & 42.

3.6 Polychlorinated Biphenyls Remediation

The original electrical system and associated equipment are present at The Fort. Aged electrical devices are known to contain PCBs. Before building disturbance activities commence, we recommend the transformer and light ballasts be evaluated for PCBs. If PCBs are found to be present in the transformer and light standards throughout The Fort and the NPS elects to have PCBs removed during Phase II remediation tasks, a qualified environmental abatement contractor must remove PCBs and dispose of them at an appropriate facility, in accordance with local, state, and federal requirements. Photographs of the light ballasts and electrical transformer are included in Appendix A, photo numbers 43 through 46, and the locations are keyed into the maps in Appendix B.

3.7 Chemical Disposal

Soar Environmental recommends that the chemical cabinets and other chemical storage areas, be evaluated for expired, and/or, out-of-spec products. It is recommended that qualified staff investigate the expired products and potentially dispose of them at an accredited facility accepting such types of wastes. Used oil is required to be recycled in California, in lieu of a disincentive fee. Used, dried paint cans may be disposed of in regular household trash. Photographs of chemical cabinets are included in Appendix A, photo numbers 47 through 49, and the locations are keyed into the maps in Appendix B.

3.8 Vehicle Wash Rack Permitting

Direct discharge to the MS4 stormwater system may require a separate discharge permit from the Regional Water Quality Control Board. Soar Environmental recommends that a qualified environmental representative investigate the discharge of stormwater into the drain, contact the Agency to determine if additional permit(s) are necessary, and prepare and submit the permit application(s), as required.

Photographs of the vehicle wash rack are included in Appendix A, photo number 50, and the location is keyed into the maps in Appendix B.

4.0 FEDERAL AND STATE REGULATIONS

4.1 Asbestos Remediation

4.1.1 Federal Regulations

Both the US EPA NESHAP 40 CFR Part 61 and The AHERA 40 CFR Part 763 do not have a clearance level for asbestos in dust. In the AHERA regulation section 763.91(f) deals with a “Minor Fiber Release Episode” (please see below).

US EPA NESHAP 40 CFR Part 61 Based on previous surveys, sampling, and subsequent laboratory analyses and regulatory guidelines affecting The Fort, the types of ACM identified at The Fort require removal (in most cases) prior to demolition and/or renovation procedures to comply with local, state and federal agencies. The US EPA NESHAP (40 CFR Part 61 – November 20, 1990) describes requirements for handling asbestos materials during renovation or demolition. If those materials are friable or likely to become friable due to the forces expected to act upon them during renovation or demolition, they become a regulated asbestos containing material (RACM) and require a 10-day notification and a Tier 2 notification fee to the San Joaquin Valley Air Pollution Control District (District) prior to abatement. The applicant completes the top portion of the notification submission form and the District returns the signed release form upon satisfaction of the NESHAP requirements.

The NESHAP defines a regulated asbestos renovation project as one which will disturb 260 linear feet of pipe or pipe wrap, 160 feet of flat surface building materials, and/or 25 cubic feet of piled materials, such as those resulting from a ceiling collapse. If any load-bearing members of a structure or large component will be removed in the scope of a project, the NESHAP requirements for demolition would apply. Before demolition may commence, 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 of 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 demolition or renovation, 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 any demolition and to renovations 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 special 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 For Asbestos Remediation

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 demolition, a California Licensed Contractor who is registered with Cal/OSHA for asbestos is required. The regulations regarding asbestos are found in Title 8 CCR Section 1529, and also include formal notification requirements to Cal/OSHA at least 24 hours prior to removal. It is required that removal be conducted with the material kept in a wetted state to contain dust and hazardous emissions.

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 abatement 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 demolition or renovation. (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 renovation or demolition, they become a regulated asbestos containing material (RACM

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.

Refer to the Hazardous Materials Abatement Requirements Report (HMARR) for applicable Phase I Dust Cleaning Regulations.

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.

Refer to the Hazardous Materials Abatement Requirements Report (HMARR) for applicable Phase I Hazardous Fluid Regulations.

4.4 Lead Remediation

4.4.1 Federal Regulations for Lead Remediation

The United States Congress enacted Title X - Residential Lead-Based Paint Hazard Reduction Act of 1992, 42 United States Code (U.S.C.) § 4851 (enacted as Title X of the Housing and Community Development Act of 1992). Section 1021 of Title X amended the Toxic Substances Control Act to add Title IV, entitled “Lead Exposure Reduction.”

Pursuant to Section 406(b) of TSCA, EPA promulgated regulations at 40 C.F.R. Part 745, Subpart E, residential property renovations, requiring, among other things, persons who perform for compensation a renovation of pre-1978 housing (“target housing”) to provide a lead hazard information pamphlet to the owner and occupant prior to commencing the renovation.

Pursuant to Section 402(a) of TSCA, EPA promulgated regulations at 40 C.F.R. Part 745, Subpart L, Lead- Based Paint Activities, prescribing procedures and requirements for the accreditation of training programs and renovations, procedures and requirements for the certification of individuals and firms engaged in lead-based paint activities, work practice standards for performing such activities, and delegation of programs.

Pursuant to Section 402(c)(3) of TSCA, EPA promulgated regulations amending at 40 C.F.R. Part 745, Subparts E and L, residential property renovations, prescribing procedures and requirements for the accreditation of training programs, certification of individuals and firms, work practice standards for renovation, repair and painting activities in target housing and child occupied facilities, and delegation of programs (Subpart Q) under Section 404.

Pursuant to Section 408 of TSCA, each department, agency, and instrumentality of the executive, legislative, and judicial branches of the federal government is subject to all federal, state, interstate, and local requirements, both substantive and procedural, regarding lead-based paint, lead-based paint activities, and lead-based paint hazards.

OSHA 1910, Subpart 1 – Personal Protective Equipment OSHA 1910, Subpart Z – Toxic and Hazardous Substances 29 CFR 1926.62, Subpart D - Occupational Health and Environmental Controls

4.4.2 California Regulations for Lead Remediation

Title 8 CCR, Chapter 4, Subchapter 4, Article 4, §1532.1 Lead This applies to all construction work where an employee may be occupationally exposed to lead.

Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. It includes but is not limited to the following:

(1) Demolition or salvage of structures where lead or materials containing lead are present;

(2) Removal or encapsulation of materials containing lead;

(3) New construction, alteration, repair, or renovation of structures, substrates, or portions thereof, that contain lead, or materials containing lead;

(4) Installation of products containing lead;

(5) Lead contamination/emergency cleanup;

(6) Transportation, disposal, storage, or containment of lead or materials containing lead on the site or location at which construction activities are performed, and,

(7) Maintenance operations associated with the construction activities described in this subsection.

There are 29 OSHA-approved State Plans operating state-wide occupational safety and health programs.

State Plans are required to have standards and enforcement programs that are at least as effective as OSHA’s and may have different or more stringent requirements.

4.5 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. Lead-based paint removed from The Fort must be sampled for lead concentrations and submitted to an accredited analytical laboratory. Upon receiving results, waste manifests may be filled out, the material loaded onto trucks, and disposed of at an appropriate landfill that accepts lead contaminated materials.

5. 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.

6. 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.

7. 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 will provide 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.

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

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